ML20211K864
| ML20211K864 | |
| Person / Time | |
|---|---|
| Issue date: | 09/01/1999 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-3087, NUDOCS 9909080090 | |
| Download: ML20211K864 (322) | |
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\'U>>sn- _ .am _ __ g-. e OFFICIAL TRANSCRIPT OF PROCEEDINGS NUCLEAR REGULATORY COMMISSION ADVISOllY COAIAIITTEE ON REACTOR SAFEGUARDS
Title:
165TIl ADVISORY COAIAIITTEE ON REACTOR SAFEGUARDS
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M S T ~_E26 ' 4;5 7,3: - t :w:rs : , ) Docket No.: Work Ortier No.: ASil-300-902
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LOCATION: Rocks ille, MD DATE: Wednesday , Septernlier 1,1999 PAGES: 1 - 272 ANN ItiLEY & ASSOCIATES, LTD. 1025 Connecticut Ase.,NW, Suite 1014
. Washington, D.C. 20036
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e-i l 4 1 ( ("' l l l 1 DISCLAIMER l 1 l UNITED STATES NUCLEAR REOCLATORY COMMISSION'S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS l I SEPTEMBER 1, 1999 l 1 l l The contents of this transcript of the proceeding of the United States Nuclear Regulatory Commission Advisory O s ,) I Committee on Reactor Safeguards, taken on September 1, 1999, as reported herein, is a record of the discussions recorded : at the meeting held on the above date. l This transcript had not been reviewed, corrected and edited and it may contain inaccuracies.
\v
l 1 i 1 UNITED STATES OF AMERICA l [ } 2 NUCLEAR REGULATORY COMMISSION
- N~/
l 3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4 *** l l 5 465TH ADVISORY COMMITTEE ON REACTOR SAFEGUARDS l 6 7 U.S. Nuclear Regulatory Commission 8 11545 Rockville Pike l 9 Room T-2B3 10 White Flint Building 2 11 Rockville, Maryland 12 Wednesday, September 1, 1999 13 14 The committee met, pursuant to notice, at 8:30
) 15 a.m.
16 MEMBERS PRESENT: 17 DANA A. POWERS, ACRS, Chairman i 18 GEORGE APOSTOLAKIS, ACRS, Vice-Chairman l 19 THOMAS S. KRESS, ACRS Member 20 MARIO BONACA, ACRS Member 21 JOHN J. BARTON, ACRS Member ; 22 ROBERT E. UHRIG, ACRS Member 23 WILLIAM J. SHACK, ACRS Member 24 JOHN D. SIEBER, ACRS Member 25 ROBERT L. SEALE, ACRS Member
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2 i . 1 PROCEEDINGS 2 [8:30 a.m.] l (R) 3 DR. POWERS: The meeting will now come to order. ! 4 This is the first day of the 465th meeting of the 5 Advisory Committee on Reactor Safeguards. During today's 6 meeting the committee will consider the following: Safety 7 Evaluation Report related to the Oconee nuclear power plant ) 3 license renewal application; proposed resolution of Generic l 9 Safety Issue-145 actions to reduce common cause failures; 10 proposed final source term rule and associated draft ! 11 Regulatory Guide and Standard Review Plan; proposed revision 12 to Regulatory Guide 1.78 evaluating the habitability of a l 13 nuclear power plant control room during a postulated 14 hazardous chemical release; ACRS plans for revising the ( 15 RETRAN-3D Thennal-Hydraulic Transient Analysis Code; i i 16 proposed ACRS reports. 17 The meeting is being conducted in accordance with 18 the provisions of the Federal Advisory Committee Act. Dr. 19 John T. Larkins is the Designated Federal Official for the 20 initial portion of the meeting. 21 We have received no written statements or requests 22 for time to make oral statements from members of the public. 23 A transcript of portions of the meeting is being 24 kept and it is requested that the speakers use one of the 25 microphones, identify themselves, and speak with sufficient h
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i 3 1 clarity and volume so that they can be readily heard. () 2 There are some of us that might think there is no 3 justice in the world but it has turned out that there is at 4 least a little bit. I am pleased to announce that Professor 5 Apostolakis received the American Nuclear Society's Tommy 6 Thompson Award at the PSA '99 Conference on August 24th, 7 1999. I would like all of you to join with me to 8 congratulate Professor Apostolakis for receiving this 9 prestigious award. 10 [ Applause.] 11 DR. POWERS: I also note that Professor 12 Apostolakis is the second member of the ACRS to receive the 13 Tommy Thompson Award, and furthermore Tommy Thompson himself 14 was a former member of the ACRS and the Chairman in 1961, I 15 believe. 16 This is clearly a banner day and shows that the 17 American Nuclear Society is an astute and perspicacious l 18 organization. 19 [ Laughter.] 20 DR. SEALE: That's on good days. j 21 DR. POWERS: I will also note that the members l 22 have before them a draft calendar for meetings in the coming l 23 year. I would hope that you could look at that calendar and 24 compare it to your own obligations so that we can finalize 25 that this evening. l l 1 ANN RILEY & ASSOCIATES, LTD. O- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i l l 1 L J
r ! 4 l 1 Members also have before them an agenda for the () 2 preparation of reports and the priority we attach them. I 1 3 will hope that all the cognizant members can be prepared in ! 4 approximately the order of priority for that process. 5 I will ask now are there any comments that other 6 members would like to make before we begin today's session? l l 7 [No response.] 8 DR. POWERS: Seeing none, I guess we will turn to 1 9 the first item of business, which is the very important 10 process of license renewal. Jack? 11 MR. SIEBER: As far as the Oconee report, I must I 12 recuse myself from this presentation to avoid any possible 13 conflict of interest which might arise from my stock i l 14 ownership in Duke Capital Corporation. 15 DR. POWERS: Okay. We will expect you to remain 16 mum, then. It is, however, perfectly legitimate for you to l 17 pose questions as you go through, but you will otherwise not 18 be involved in that process. 19 The license renewal process -- Mario, I guess you 20 are the cognizant member. 21 DR. BONACA: Yes. ! 22 DR. POWERS: And do you want to lead us through 23 this process? 24 DR. BONACA: Yes. Thank you, Mr. Chairman. On 25 June 31st and July 1st on this year, 1999, we met to review b ANN RILEY & ASSOCIATES, LTD.
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m 5 l' the application by Duke Power for life extension of the l 2 Oconee units. 1 l 3 We heard presentations from Duke Power. We also 4 . heard presentations from Babcock.& Wilcox, which has 5 developed four topical reports supporting the application in 6 the area of the vessel and ability to go to life extension. 7 We also heard from the Staff. There was a 8 significant presentation on the SER. Both the application 9 and the SER were thorough and quite extensive. There are 10 still a number of open issues and confirmatory items to be 11 addressed. However, notwithstanding those items, there t l l 12 seems to be significant progress in this application and j l 13 therefore we have asked the applicant to come and give us an 14 overview of the application itself and then for the NRC to 4 () 15 give us an overview of the SER with special emphasis on the l 16 open issues and confirmatory items. l 17 With that, I will move on to Mr. Grimes -- 18 DR. POWERS: This will include the discussion of j 1 19 fuses and things like that? l 20 DR. BONACA: Yes, we specifically have identified I l 21 the number of issues and communicated them to the Staff so l 22 that they are prepared to answer those questions regarding 1. l 23 issues such as fuses, for example. 24 DR. POWERS: Good. 25 DR. BONACA: So we will have, first of all, a I l ANN RILEY & ASSOCIATES, LTD. ; Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034
I J 6 1 presentation from the licensee, Duke. () 2 3 MR. ROBISON: from Duke Power. Good morning. I am Greg Robison I am the Project Manager for the Oconee 4 License Renewal Project. I want to take just a few minutes 5 this morning to give you an overview of our application. 6 With me assisting this morning is our Lead 7 Structural Engineer, Deb Ramsey and Paul Colaianni is with 8 us also -- he is our Lead Electrical Engineer. 9 Just a smidgeon on Oconee. Many of you are very 10 familiar with Oconee and where it is located. It is in 11 northwestern South Carolina. We have three units on site, a l 12 little over 2500 megawatts. It is the largest nuclear 13 installation we have on the Duke system. Construction 14 obviously finished in the early '70s. We are here for () 15 license renewal since our license is expiring in 2013 and 16 2014 and we have about 1300 people employed on the site -- 17 that might give you a feel for the magnitude of the site 18 itself. 19 We will do two things. We will do a view of the 20 application and then an overview of the application. Here 21 is the view of the application. Through the wonders of 22 getting to play with a digital camera, we took a picture of 23 the application. It made it a whole lot easier to transport 24 than the volumes themselves. 25 (Laughter.] ANN RILEY & ASSOCIATES, LTD. b, \-
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I l 1 MR. ROBISON: ( Some of you have seen the n 2 application. There are four volumes to the application. (} 3 Three of the volumes are technical, involve the technical 4 matters. The fourth volume involves the environmental l 5 report, and I will overview each of those this morning. 6 I thought it would be interesting to give you a 7 little bit of the organizational criteria of the first three 8 volumes, the technical volumes associated with the l 9 application. 10 The thought process that went into making this 11 puzzle piece, this application puzzle piece, fit were we 12 wanted to present the information required by the rule, 13 address generic safety issues, follow our discipline results l i 14 because we designed our answer on a discipline basis --
) 15 mechanical, civil, structural, and electrical. We also l 16 wanted to present the information such that it paralleled i
17 the current FSAR we have for Oconee so that you can see 18 matches between the apolication itself and the current 19 licensing information that we have at the plant, so that was 20 another criteria that we put into developing the 21 application. 22 Finally, we wanted to make sure that commitments 23 were clear in the future, so we created a new chapter to the 1 24 UFSAR, Chapter 18, where we hope to house and we propose to 25 draft a formal for the UFSAR, Chapter 18 to capture the O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l (202) 842-0034 l i
8 1 aging management programs, so those are some f the criteria I () 2 3 that we put into the design of the application itself. I will walk through in a little more detail how we 4 created the thought process that went into creating the I 5 technical information. I won't dwell long on this. There 1 6 are a good many notes in the handouts, and I will just hit 7 the high points of the next few slides. 8 The integrated plan assessment portion of the 9 application, we took the regulatory wordc and really worked 10 to get it down to an engineering equation, if you will, 11 something that we could be mindful of continually as we went 12 through the process of putting together the technical 13 documents that back up the application, as well as the 14 application itself. And that equation is C plus A plus P () 15 plus D equals R.A. 16 DR. WALLIS: What are the units of this equation? 17 [ Laughter.] 18 MR. ROBISON: Time. Lots of time and lots of 19 money. 20 That's a great question. I'll have to think about 21 that. 22 [ Laughter.) 23 It did give us a shorthand on being able to ask -- 24 when you ask a question or when you're in the middle of the 25 t=chnical work, where are you? Where are you in the O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r 9 1 development of this work? Are we describing aging effects 2 and how the aging effects may manifest or describing the 3 screening and scoping process and the derivement of the 4 components that it's important to be looked at? Are we l l 5 talking about the programs, which is the "P portion of the l l 6 equation? 7 The second area I'll speak just a few minutes on ! 8 is the time limited aging analyses. 9 Let's just walk through the equatirn at a high 10 level and show you how it fits into the application. The C l 11 is the structures or components that require aging f 12 management review. Again, I say that we're divided by l l 13 traditional engineering discipline. l 14 There's a special feature of note in our 15 application. We separated reactor building containment and 16 the reactor coolant system out.from the remainder of the 17 structures, the mechanical and electrical items in the i 18 plant. We did that on purpose, for two reasons. 19 Historically they've received additional treatment in our 20 design and our licensing basis. Certainly they are the l 21 focus of safety at our plant. And additionally we were 22 working with the B&W owners' group on primarily the reactor 23 coolant system components, so it allowed us to make a match 24 line between the work that the owners' group was working on 25 and our application and not get it somehow convoluted with ANN RILEY & ASSOCIATES, LTD.
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10 1 the other materials. So we could very clearly see how the () 2 owners' group work marries into the Oconee work. So this 3 worked out well, and the results of that are captured in 4 volume 1, chapter 2 of volume 1 of the application set. 5 Moving on to the applicable aging effects, here 6 again we worked to develop a set of information working with 7 the owners' group so that we could understand the potential 8 aging effects or the range of aging effects that could be 9 possible given certain material, environment, and stress 10 conditions. 11 A little bit of basic material science review. We 12 created that and then used that as a template or a menu, if 13 you will, to look at the actual plant conditions at Oconee, 14 the materials of construction, the environment we had those (O
,/ 15 materials exposed to, to determine the applicable aging 16 effects set that we needed to make sure we were managing.
17 That information is captured in the application in chapter 18 3, which is in volume 2 of the notebook set. 19 The third portion of the equation is the P or the 20 programmatic aspects. Here in our application we defined a 21 series of attributes for a. program so that we could make 22 sure we had a measuring stick for each of the programs, for 23 each of the programmatic actions we were using at the plant 24 or we were going to need to use at the plant to manage 25 aging. We wanted to make sure we had a standard to hold ANN RILEY & ASSOCIATES, LTD. Os Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r , 11 1 that up against and find a way to consistently present that () 2 3 information. We did provide that set of attributes in the application, initially in chapter 4, which is in volume 3, l 4 and then each of the programmatic actions after that, follow 5 that template, follow that format. So again, that's a 6 little organizational process that we use to help us stay on 7 track and to make sure we presented information in a l 8 consistent fashion. 9 DR. WALLIS: So looking at your equation again, 10 and really if any one of these parts that you're talking l 11 about is zero, then the result is zero. So we really ought 12 to multiply these things instead of -- 13 MR. ROBISON: You are absolutely right. It dawned 14 on us a year after we developed the equation that it was O q_j 15 really a multiplication equation. So you're right. 16 DR. WALLIS: You are taking logs. j 17 MR. ROBISON: Yes. 18 DR. APOSTOLAKIS: It's really the Boolean 19 intersection. 20 [ Laughter.] 21 MR. ROBISON: The fourth variable here is 22 demonstration. Here it was important I think through the 23 course of the number of years we developed this thought 24 process in discussing this with the NRC staff that we find a 25 way to work the demonstration or the reality check of our h
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12 1 programmatic actions into the application. It wasn't good () n 3 2 enough, and we agree it's not good enough just to assert that you have a program and look at a notebook on a shelf. 4 You need to pull it off the shelf, look at the historical 5 results of how that programs been run over time, and ask 6 yourself is it a learning program, does it havt features 7 built into it, has it been executed at a certain frequency 8 that makes it justifiable, not just one time 20 years ago, 9 but is it robust enough to be able to do the job that we're 10 asking it to do. The demonstration portion of this equation 11 allowed us to ask those questions, and we presented the 12 results of those findings in volume 3 in chapter 4 with the 13 programs themselves. 14 And then the final variable, which I don't have a
'O
( ,) 15 slide for, is reasonable assurance, which is what we're 16 after here, reasonable assurance that we're managing aging 17 of that important set of hardware. 18 DR. WALLIS: What's the measure of reasonable 19 assurance? 20 MR. ROBISON: We had a sort of an engineering feel 21 when we got through the process of what we believed was a 22 reasonable answer. If it didn't feel right, again, I don't 23 believe there's a prescriptive criteria for that. If it 24 didn't seem right, it didn't have the fullness to it, we 25 went back into the -- O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
E 13 1 DR. WALLIS: Do you mean something like 90 percent () '2 or 50 percent or,_ I mean, what -- 3 MR. ROBISON: We asked ourselves does the 4 ' component set -- is the component set fully described? Is 5 the aging effect characterized in a manner that industry 6 literature can help us understand the rate the phenomena 7 occur so that we can look at our programmatic actions and l 8 -make sure they're happening at a reasonable frequency? Do { 9 we have operating experience at Oconee that may tell us 10 we've not operated a program at a correct frequency or 11 perhaps not focused in detail on the correct set of 12 hardware? 13 DR. WALLIS: So it's all qualitative? 14 MR. ROBISON: Very much so; yes, sir. ( 15 DR. WALLIS: So it depends very much -- our 16 evaluation depends then very much on our assessment of your 17 judgment? 18 MR. ROBISON: Yes. Yes. And many of the programs 19 themselves have industry standards to back them up, a good 20 portion do. So I think there's a collective wisdom that 21 comes back to the table. But in many cases where you don't 22 have rigorous criteria out of a code book to hold up, it 23 does come down to engineering judgment, and I think having 24 multiple sets of eyes in this case, the owners' group 25 developed to where we have a number of utility contract O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 , Washington, D.C. 20036 ! (202) 842-0034 ! 1
14 1 people, then our own folks at Duke, and then the staff l 2 review, it's the combination of all of those things that 3 help us feel that we've reached reasonable closure on each I 4 of these topics. 5 And certainly as this is a first-of-a-kind 6 activity, there will be an opportunity to learn and 7 standardize and perhaps quantify the measuring criteria for 8 when you solve an equation like this. But the good thing is 9 I think we went in with our eyes open, not biased to not go 10 put a program in place or not ask ourselves if there was an 11 important activity we needed to do. We went in looking for 12 opportunities to put programmatic actions to make sure the 13 plant stays safe as we move forward in time. So that was 14 our bias. () 15 DR. BONACA: I have a question regarding this 16 overhead here. The existing programs, activities to be 17 enhanced actually, you showed in many case a that they 18 consist of one-time inspection, okay? For the exieting 19 programs that you list under the number of 28 there, if I 20 understand it, those are actually programs in a broad sense. 21 They involve many procedures. Or are they simply -- I'm 22 trying to understand the extent of the content of those 28 23 programs there. And the reason is very clear. For the 24 application we had for Calvert Cliffs, there were on the 25 order of 400 existing programs, and there were a very small ANN RILEY & ASSOCIATES, LTD. Ox Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i i
1 15 1- fraction of new programs which were similar to what you had, () 2 one-time inspections. So I'm trying to compare the 350-odd 3 number for Calvert Cliffs with your 28 presented here. 4 MR. ROBISON: That's a very good question. The 5 slide we're looking at is a compilation of 50 programs that 6 we found necessary to implement or have implemented at 7 Oconee for license renewal. The difference in the Calvert 8 work and our work is as an engineer I don't think in terms 9 of multiple procedures to accomplish an activity. I try to 10 think in a holistic sense of the programmatic solution or 11 making sure that the system and component set can continue 12 to do its job. 13 An example in the existing program area where 14 there were multiple procedures that we grouped under a () 15 program was fire protection. We have a long list of 16 fire-protection procedures that check the condition of the 17 pumps, the valves, the pipe. I took all of that and grouped 18 it and called it the fire-protection program with a variety 19 of attributes and controlled it at a high level to make sure 20 that I didn't miss something within the framework of that 21 program. I want the whole program that touches the 22 important hardware that we're looking at here to work, the 23 workings of the program. 24 We did look at the procedures, but when we 25 reported the results, we tried to look at a higher level and [\ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r' 16 1 group the information. So that's.the difference in the () 2 Calvert work and our. work. You'll see Calvert very 3 meticulously looked at each of the procedure sets. Nothing 4- wrong with that, but they reported it brick in the 5 application at the procedure-set level. We just simply 6 grouped those, because in many cases that's the way we 7 operate our station. We group that procedure set up into a 8 higher-level program, and then try to -- 9 DR. APOSTOLAKIS: So the corrective action is a 10 program then? 11 MR. ROBISON: The corrective action step is a 12 program itself; yes. 13 DR. APOSTOLAKIS: Which will have preventive 14 maintenance, corrective maintenance, and those things? () 15 MR. ROBISON: Yes, sir. It'll ins.tigate whatever 16 the appropriate -- 17 DR. APOSTOLAKIS: So if we start counting those, 18 the work processes under the program, then the number 28 may 19 become 300 or -- 20 DR. SEALE: This is the log again. 21 MR. ROEISON: Yes. 22 DR. WALLIS: I have a question. It seems to be 23 kind of self-assessment. You're inventing a process and 24 inventing the equation and so on and satisfying yourselves 25 you've done something. But this is a license renewal O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
17 1 application. I.would think you'd start out by saying these () 2- are the NRC requirements listed. Those are the NRC criteria 3 that we have to meet, and this is how we're going to do it. 4 Maybe it's because these don't exist that you've done it 5 yourself your way. Why aren't you doing it in the way of 6 meeting something that's already been laid down by the NRC? 7 MR. ROBISON: I think your point that this is a 8 really early or first of a kind is an appropriate comment. 9 DR. WALLIS: But you start with some objective, to 10 meet some NRC criteria. 11 MR. ROBISON: Yes. 12 DR. WALLIS: Surely they have framework laid out. 13 MR. ROBISON: They very much do. We have both NRC 14 guidance materials in both final and draft form as well as () 15 industry materials in final state as of 1995-1996. But we 16 have to understand that in this initial interpretation we're 17 all going to continue to struggle to get perspectives on the 18 answer. And so what we wanted to do is create a process 19 that used the guidance -- certainly we're based on the 20 materials that are there -- but not limit ourselves to the 21 guidance that's there, so that as new ideas and new thoughts l 22 came along, we were going to be inclusive of those. 23 I thing you'll see I have a slide in just a few ! 24 moments where I relate the application structure back to the 25 license renewal rule and the findings, and you can see very i O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r l 18 1 much our thought _ process on_how we were linking it back to 2 the regulations. What you've seen in the equation here is j 3 really our interpretation of what's below the regulations, 4 how do.you take the words in the regulation and go to your i 5 plant and identify the correct hardware, pull the correct 6 -material science results out and pull all of that together 7 in order to meet that rule requirement. 8 DR. BONACA: But isn't it true that for existing 9 programs -- existing programs essentially compare with what 10 program you have implemented against the requirements of the 11' regulation. 12 MR. ROBISON: Yes, they do. 13 DR. BONACA: So the judgment you're using is that 14 for -- in the extended life certain components will be under 15 those programs, which means that the programs are adequate. 16 I mean, you're still making a judgment of compliance with 17 current regulation, aren't you? So the judgment really is 18 whether or not the current program, which is how you comply 19 with regulation, meets the requirements also during the 20 extended life or if you need a new program. That's the 21 judgment your making. 22 MR. ROBISON: We are making both that judgment, 23 and we tried to be cbjective when we made that judgment. 24 Because some of the programs were put in place based on a 25 knowledge and awareness level that maybe is not as acute as ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i ?
19 1 where we are today with understanding the aging of the () 2 plant. So we really did a -- I say reviewed again for the 3 first time of the existing programs to make sure that, given 4 our material science understanding of how the plant is 5 aging, that those programs really are doing the right job, 6 and even in the area where we say the programs perhaps 7 require enhancement, some of the enhancements here could be 8 due to the fact that the program's not quite focused at the 9 right level or depth. 10 To deal with the aging phenomenon, given the state 11 of the world, the knowledge of the world back in 1978, or 12 '80 or '82 when that program was established, it may not 13 focus exactly where we needed it to focus for the remainder ! 14 of the six year period. () 15 DR. APOSTOLAKIS: Why, I mean just on my own 16 information, why was there a need for programs because of 17 what happened? 18 MR. ROBISON: There are a few components that are 19 receiving the spotlight on them for really the first time. 20 The reactor internals package is a good example of where we 21 are putting a new program in place. We were so focused on 22 the reactor vessel shell for all of these years, and 23 rightfully so, that when we began to look at functional 24 needs to operate the reactor, and we looked at the aging of 25 the metals in the internals, we realized we really didn't O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
20 1 have a real good handle on what was going'on with thermal () 2 3. issues and neutron issues. It just sort of raised itself as an area we need to focus on, it caused the creation of a new 4 program. 5 DR. POWERS: I guess that is really surprising. I 6 mean the-history of the last 10 years has focused on reactor 7 internals. 8 MR ., ROBISON: I think the focus has been, my 9 understanding, and I could stand corrected, would be more on 10 the bolting issues associated with the internals and our 11 understanding of specific aspects. What we were trying to 12 do was take, again, a more holistic view of the entire 13 internals package to make sure if there are plate materials 14 that are somehow having an aging phenomena that we need to f 15 look at out into the extended period, that perhaps have not 16 'been focus of the research of the last 10 years. We didn't 17 want to miss that. So we established a program to make sure 18 we could be inclusive of that. 19 DR. APOSTOLAKIS: So should we go back then to 20 licensees who do not -- were not requesting a license 21 extension and demand that these programs that you call new 22 also be implemented there? 23 MR. ROBISON: I think to the extent that -- you 24 have to qualify you are specifically staying with the 25 reactor internals. One of the real struggles there is the O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
21 1 difficulty characterizing the aging that is actually going
\ 2 on. We recognize, understanding material, environment and
[G 3 stress, something could be going on. There is a little bit 4 of data coming out of the research world that tells us 5 something may be going on and, because we can't quite 6 characterize it, we wanted to put a frame around it and make 7 sure we are consciously looking at that. 8 Ten years from now, if there is a good 9 understanding of what is going on, aging-wiss. and it looks 10 like the right smart thing to do, then, yes, I think we 11 would go back and make sure that folks that be in that 12 condition would make sure that that problem is not occurring 13 or being managed in their plant. 14 Today, I can't say that I would recommend that, 15 because one of the struggles in the new program is to really 16 characterize the aging. And there are a number of steps 17 that we have laid out in program, both the B&W Owners Group 18 Program and the Duke Program to characterize the aging, do 19 some initial inspections, come back and see if we have 20 learned something new, and then determine what additional 21 activities would need to be taken. That is going to happen 22 over maybe a 10 year or more period. 23 DR. POWERS: I get the impression that you would 24 have felt benefited by a more aggressive research program in 25 this area. ANN RILEY & ASSOCIATES, LTD. O- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r- 1 22
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1 MR. ROBISON: I don't think I am qualified to f% \ 2 address that. (} { 3 DR. POWERS: Did you see significant gaps in the 4 existing knowledge? 5 MR. ROBISON: I saw an issue raised for the first 6 time in my awareness, I don't know if that is an initial 7 first step or a large gap. I don't know that I could 8 characterize it. It was just new information to us that we 9 felt like we needed to be able to work with and manage over 10 the course of time. 11 DR. UHRIG: When will these new programs he put 12 into effect? With the issuance of the new license or some 13 other time? 14 MR. ROBISON: Tnat point is under discussion right
) 15 now. From a regulatory perspective, we saw the need to have 16 the program in place at the end of the 40 years, that is my 17 regulatory answer. From a technical standpoint, it may be 18 beneficial to us to go ahead and instigate them now and let 19 them begin to grow up, so that we have them in place at that 20 40 year point. So there is really two answers that are 21 being discussed.
22 One of our new programs that we credited is an 23 old, oil sampling program at our Keowee hydrostation. That 24 program has been in existence for 30 years, and it is now a 25 matter of just simply formalizing what we have already done. I ANN RILEY & ASSOCIATES, LTD.
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1 1 I don't need to wait till 2013 to formalize that. ] .2 For the reactor internals program, as it grows up, 3' you know, the commitments we were trying to make were to 4 have us at a'certain point in that program at a future 5 state'. How'that grows up between here and 2013, we have yet 6 to design. 7 DR. WALLIS: It is interesting to me that there is 8 always an emphasis on programs and activities rather than on 9- results. 10 DR. APOSTOLAKIS: I think it is because of the 11 rule. The rule says you should manage aging, right. 12 DR. WALLIS: : just seems to me that you go 13 through a lot of motions, and I don't really care what the 14 motions are. It would seem to me there are certain results 15 to be achieved. It should be definite and hard. 16 DR. APOSTOLAKIS: The rule says that you should i 17 demonstrate, as I recall, you are managing aging. ! 18 DR. WALLIS: Yes, but demonstrate something i 19 substantial. 20 DR. APOSTOLAKIS: But you are managing aging, and 1 21 that.is what they are trying to do, demonstrate that they 22 ara managing it. 23 DR. BONACA: Either that, or, in effect, it is not 24 . going to have an impact for the extended life, or that a 25 program is in place to detect the impact and to address it O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
24 1 when it is detected. I mean that is my understanding of how I ("% ,.( ; 2 you have covered that. 3 One final question I have, and I don't expect that i 4 you made a direct comparison, but maybe the staff can answer 5 that. Going back to the issue of the metrics here, would 6 you say that the ratio of new programs to existing programs 7 is comparable just as an order to magnitude to the one for 8 Calvert Cliffs. 9 MR. GRIMES: This is Chris Grimes, I am the Chief 10 of the License Renewal and Standardization Branch. And my 11 reaction to that question is that I think they are generally 12 comparable. 13 DR. BONACA: Okay. 14 MR. GRIMES: Obviously, there is a different 15 counting structure 16 DR. BONACA: Sure. 17 MR. GRIMES: And we attempted to explain that in 18 the context of the broader generic issue on credit for 19 existing programs. And we did not see substantial 20 differences, apart from it is a different plant, the utility 21 manages this plant a little bit differently, but I would say < 22 they are comparable. 23 DR. BONACA: Okay. Thank you. 24 MR. ROBISON: And I will close the slide by making 25 one comment. A number of the enhancements, as you pointed ! [ \ ANN RILEY & ASSOCIATES, LTD.
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1 25 1 out, were one time programs that we felt were needed to () 2 characterize aging, if it is there, with a corrective action 3 loop to continue to investigate it or programmatically 4 manage it should it be there. 5 The other is many programs were not learning 6 programs,~they didn't require a documentation step at the 7 end, so that you understood you had done the inspection but 8 found no problems. The procedure said do the inspection, 9 but it never told you what to do if there were no problems, 10 so the next person coming along could not learn from you the 11 fact that you had not seen anything in the past, so there 12 were document enhancements. But we also called up -- 13 DR. WALLIS: That is an emphasis on activity 14 rather than achievement, rather than outcome. () 15 DR. SEALE: In those areas. 16 DR. WALLIS: Yeah, but this is a concern I have 17 with the way the agency does business. The outcome is the 18 only thing that matters. Activities, 10 activities or 100 19 are irrelevant if they don't achieve the outcome. , , _20 _
. MR . ROBISON: The time-limited aging analysis 21 portion was the next step in the technical matters in 22 Volumes 1 through 3. Again, these are boundary conditions 23 on the design. We went through a multi-tiered step to find 24 these particular items. There is a criteria in the '.icense 25 renewal rule, a six part criteria to help you to understand O ANN RILEY & ASSOCIATES, LTD.
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26 1 how to define a time-limited aging analysis. It included a () 2 3 review of exemptions. that were time-based. We did not find any Oconee exemptions j The results are presenteG in 4 Volume 3. 5 The environmental area was the fourth volume of 6 the set. You can see the organization again tried to write 7 it in a style, lacking any better guidance, that told a 8 story so that there were completeness in thoughts and we 9 could provide information. I will note here that the good 10 work the NRC had done with the Generic Environmental Impact 11 Statement meant that the plant-specific work was simply a 12 complement to that and added to that. You take the results 13- that the Staff's already provided us in the Generic 14 Environmental Statement and you supplement it with your 15 information, and the Staff will write the supplemental 16 environmental impact statement. 17 Our environmental report is aimed at providing 18 information to create that supplement and show a match line 19 between the generic work and the plant-specific work, and 20 that is what we have done. 21 DR. WALLIS: Is there anything in the 22 environmental issues which really is important for license 23 renewal, any issue that matters? 24 MR. ROBISON: We have really found none that rose 25 to the level that we had not already been taking care of in O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
27 1 our other environmental work and our commitments to the () 2 community -- in permiting -- we were taking care of for 3 thermal permiting and what-not. Those were already pretty l 4 well being focused on at the plant. 5 These were the conclusions. I think I'll move on I 6 for the sake of time -- I'll let you read it. The 1 7 conclusions of our report were pretty much substantiated in 8 the draft Environmental Impact Statement that I am sure you j i 9 have seen for the plant, and I will move right to the table j 10 slide and get back to a previous question. 11 What you see on this table is a matrix breakdown 12 of the equation itself for the technical areas. You will 13 see the environmental report out in the far right column, 14 but for the particular items in the equation the five focus 15 areas within the report itself and each of the chapters of ; i 16 the application, so you can see how the equation itself maps 17 into the application. 18 In turn, you can see how each of those items maps 19 onto the regulations down along the lower part of the 20 matrix. Exhibit A just happens to be the name of the , l 21 particular tab in the book that captured all the technical ! 22 items. You see the regulatory requirement in the next to 23 the last item for the 54.21 area, so each of the regulatory l 24 required steps we map back onto the application. , 1 DR. APOSTOLAKIS: 25 So what are the numbers in the O 1dRJ RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1 l
1 28 1 matrix there, 2.3? r'N (j 2 MR. ROBISON: I'm sorry -- the 2.3, 2.4 are 3 chapter numbers or section numbers within the application l 4 itself. This was my attempt to show you how each of the 5 five technical focus areas and each of the equation steps 6 map to each other and it makes it fairly easy. 7 You will see a progression of thought, for example 8 on containment, from 2.3 to 3.3 over into Chapter 4. You l 9 wi?.1 see RCS components 2.4, 3.4 -- again we are trying to l l 10 create shorthand patterns that are easy enough to be able to 11 jump section to section, lacking a better way to organize i 12 the application. 13 DR. WALLIS: Well, if you have, say, electrical 14 components here is one line, does the demonstration end up (G,) 15 with some clear evidence that electrical components will 16 satisfy the requirements for the next license period? 17 MR. ROBISON: Yes. The Electrical Component Aging 18 Review is done in Section 3.6. In that area we presented 19 information to show that we were not going to have any 20 electrical components that fall within the scope of renewal. 21 DR. WALLIS: You don't have to renew anything? 22 MR. ROBISON: We did not feel so at the time. ! l 23 Since then we have had an open item on the SE where we have 24 investigated it further with the NRC Staff at Oconee and we 25 are now of the opinion that there are a few limited areas in ANN RILEY & ASSOCIATES, LTD. (' Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
29 1 the plant where cabling could experience -- water's in a () 2 3 trench is one isolated location there and there may be, we haven't finished resolving the issue, there may be one area 4 where cable may be exposed to temperature extremes. 5 The general -- the conclusions we drew in the 6 application based on field survey, work that we had done l 7 through the plant, were there were going to be no areas that 8 had aging effects that were going to cause detrimental 9 effects on the hardware, the electrical hardware, over the 10 60-year period. 11 Finally, I will conclude and address any 12 questions. I put in your package this morning the 13 conclusion and again we put this in the very front end of 14 the application so that you begin reading the application () 15 with the confidence that the complete application is there 16 and the findings can be made from the materials that are 17 presented, so you have seen the view, you have seen the l 1 18 overview, and you get a feel for the conclusion that is 19 there. l 20 This is the materials that the Staff has not taken 21 and driven through their SER process, so that just gives you 22 a feel for what the Staff encountered when they opened the 23 front of the notebooks. With that, I will conclude. Thank 24 you. 25 DR. BONACA: Thank you. Any -- t O ANN RILEY & ASSOCIATES, LTD. (m Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
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1 MS. RAMSEY: I'm sorry -- Debbie Ramsey, Duke 2 Power. I would like to address two points that Mr. Wallis [v) 3 made. 4 The first one is the standards that we used. The 5 equation that Greg put up there is really a simplified 6 equation of the Staff guidance and information that is in 7 the rule and I think it showed very clearly in the previous 8 table he put up the "C" in our equation is equal to the 54.4 9 criteria for defining the scope, so there is a very good 10 correlation between our simplified equation to what was in 11 the rule. 12 The other point I would like to make about i i l 13 programs is that the rule does focus on the programs but you 14 have to remember that in 54.21 we are not required just to 15 identify the programs but to demonstrate that the programs
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1 i 16 are effective. I think that is where we focus on the ) l 17 outcome of the programs that you are concerned about, 18 because we had to demonstrate that we are looking at the
)
l ( 19 correct scope, that we are looking at the aging effects that i 20 are associated with those components, that frequency and all j 21 of that is satisfactory, to identify the aging effect prior 22 to any kind of loss of intended function, so I think that we 23 do -- are required by the rule to address your concern with 24 outcome of the program. 25 DR. WALLIS: Can I ask my colleague, Dr. Bonaca, [}
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F-31 1 something? 2 DR. BONACA: Yec. 3 DR. WALLIS: Are we going to get this simply as a 4 presentation by Duke Power that they have made this 5 submission and then there is going to be NRC come here and 6 say we have evaluated it and we have reached some 7 conclusions, or is there some effort by this committee to l 8 look maybe randomly at pieces of this and say is the quality 9 good enough? 10 DR. BONACA: That is exactly what the subcommittee 11 has done. We as a subcommittee assigned portions of the 12 applications, all relevant portions, to individual members 13 and also portions of the SER. We did that review and so I 14 think we had quite a thorough review. () 15 DR. SHACK: Nobody mentioned whether there is any 16 program -- there are a number of open issues we sort of left 17 in July. Have any of those been resolved? 18 MR. ROBISON: We have not made a formal submittal 19 of responses but what we have done is there have been a 20 number of topics that we felt like we needed further 21 discussion with the Staff on so we provided draft responses 22 to the Staff and we have held public meetings to work 23 through those responses to make sure we were of the sama ; 24 mind and there's probably 60-70 percent of those open items, ) 25 the 43 open items and 6 confirmatory items, that we have ! O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
32 1 already had some type of discussion with the Staff on. 2 We are progressing well to get them all closed. [) w 3 DR. SHACK: Okay, so you don't see any particular i 4 hard spots there? 5 MR. ROBISON: I don't feel that there are any hard 6 spots that we can't resolve. 7 DR. BONACA: And I understand the presentation 8 from the Staff is going to focus on the open' issues. 9 MR. GRIMES: Chris Grimes. I would like to point 10 out from a procedural standpoint that we are going to 11 describe the results of the Staff's evaluation that led to l 12 the initial issuance of the safety evaluation and based on 13 the feedback that we got during the subcommittee meeting we 14 are prepared to talk about the results of our review in () 15 specific areas to illustrate the nature of the Staff's 16 review and particular issues, but Greg is correct that the 17 process will proceed by continuing dialogue between the NRC l 18 Staff and Duke to make sure that they understand the nature 1 19 of the open and confirmatory items so that they can respond 20 by October 15th in a formal way with their position on those l l l 21 topics and then we will use that information to start I i 22 preparing a final Safety Evaluation. ! 23 We would intend to come back to the ACF.S with an 24 explanation of how the open and confirmatory items have been 25 resolved, but today we are going to make a presentation on i
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33 1- particular areas that were of interest to the subcommittee ,( 2 and that we feel illustrate the quality of the Staff's 3 review and provide a technical explanation for how we 4 reached conclusions relative to the programs that Oconee 5 will demonstrably manage aging effects through a period of 6 extended operation. 7 DR. KRESS: Did the Oconee IPE play any role in 8 this evaluation of the license renewal application? 9 MR. ROBISON: We did not directly use the IPE. l 10 Certainly we have talked to the plant engineering staff and 11 we are looking at many programs, not just license renewal 12 activities but maintenance rule and other activities to make I 13 sure that we have an integrated set of programmatic 14 solutions for our plant and as the IPE played in we (f 15 understood how the results fit in, but it doesn't have a 16 direct criteria, if you will, that applied into license 17 renewal. 18 DR. KRESS: Just out of curiosity, what is the CDF 19 and LERF for Oconee? j 20 MR. ROBISON: I knew you'd ask that. I don't 21 know. I didn't bring the staff member. Maybe there is ! 22 someone else here that can help with that. I don't walk l 23 around with that particular number in my head. I apologize. 24 DR. WALLIS: Will the aging of Oconee have any 25 effects on the CDF? 'h v ANN RILEY & ASSOCIATES, LTD. Court Reporters j 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202).842-0034
34 1 MR. ROBISON: At'this point we think not. When we () 2 3 took at look at the items that were there that really are high risk items, we believe that they are not really 4 age-driven type risks, and we couldn't see a correlation 5 there between those two. 6 .Again, it was not a formal criteria that we 7 investigated but we did ask that question in a qualitative 8 sense. 9 DR. BONACA: Irrespective of the CDF, but a 10 complete PRA would likely identify some components which are 11 safety important that are not identified by the 12 deterministic process and it seems to me that the existence 13 of an IPE would offer an opportunity, even if the IPE may 14 not be as complete as-one wishes it to be, you have not 13 looked at all to IPE? 16 DR.~APOSTOLAKIS: I thought it was the opposite, 17 that the deterministic approach they are following includes 18 many more components than the risk-significant ones. In 19 other words, if you used the risk information you would j 20 probably have to do less work. 21 MR. BARTON: That's true. 22 DR. BONACA: That is true, but if you remember, 23 for example, the South Texas application where they 24 identified a lot of components on the deterministic process 25 which are not safety-significant, but then they define only O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
35 a small family of components which are highly 1
.1-() 2 safety-significant but they are not in the deterministic 3 process, so from a perspective of cvtpleteness there may be 4 a number of components which are not merged under the aging 5 program that are safety-significant.
6 DR. KRESS: That was the nature of the question I 7 was trying to ask. 8 DR. POWERS: I think both, you are both correct j 9 that in some integrated view it is true that the PRA could 10 focus you activities and reduce the amount of work time, but 11 it is very likely that the PRA would find a different subset 12 including things that are not found by the deterministic 13 process. I think you are both correct. 14 DR. APOSTOLAKIS: Did the deterministic process () 15 limit itself to safety-related components? 16 MR. ROBISON: No , it did not. 17 DR. APOSTOLAKIS: No -- so we don't know. 18 MR. ROBISON: Right. 19 DR. APOSTOLAKIS: It is true that South Texas 20 . identified I think about 300 nonsafety related components i 21 that deserve to be elevated to some risk significance level, 22 but they may be part of the group that the Oconee people are l 23 looking into because they didn't use any classification as 24 safety-related or non-safety-related in identifying what 25 they have to look at. Right? ANN RILEY & ASSOCIATES, LTD. O- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
1 36 1 DR. BONACA: The issue of scope still is a 7n 2 l ( significant issue that is open and the Staff will discuss. ! s 3 I understand the Staff looked at the IPE, so we should hear 4 from them what the experience is because I think that what 5 is important about it is going forward with the scope issue 6 regarding what falls under the aging programs for plants in 7 life extension. 8 If there is in fact a family that only PRA would l 9 identify, however small that may be, you know, that is an 10 issue. 11 DR. SEALE: Could I ask, one of the programs that 12 was already in existence at Oconee before you started on 13 this particular thing was your implementation of the 14 maintenance rule. O 15 MR. ROBISON: Yes. ( ,/ 16 DR. SEALE: And I assume that the maintenance rule 17 is represented by one of the programs or perhaps a subset of 18 two or three of the so-called programs that went into the 19 list that made up your pie chart? 20 MR. ROBISON: The maintenance rule itself really 21 does not fit into the pie chart, since 'he maintenance rule 22 in most respects was the complementary e ogram to handle the 23 dynamic equipment in the plant and the license renewal 24 efforts were focused on the static equipment, if I can do a 25 gross characterization. [ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l 37 1 DR. SEALE: Okay, t () 2 3 MR. ROBISON: DR. SEALE: You end up having -- Fine. 4 MR. ROBISON: -- having a complementary set. Now 5 the way we did link them is we created an engineering 6 functions set for the plant -- systems and structures -- and 7 it was from that common set that the maintenance rule drew 8 and the license renewal drew -- 9 DR. SEALE: Okay. 10 MR. ROBISON: -- in order to establish the 11 functional criteria, so it has a common foundation that 12 exists side-by-side -- 13 DR. SEALE: But let me ask you this. As you then 14 went through.and looked at this overall array, and I agree () 15 with you it is license renewal but it is a little more 16 besides when you talk about what it takes for the next 17 20-year period, but when you looked at that overall array, 18 did you find yourself coming up with some amendments, 19 extensions, elaborations, whatever, to the things that were 20 covered under the maintenance rule as well as the things you 21 found for your aging management programs? 22 MR. ROBISON: We really did not explicitly find 23 additional items for maintenance rule. Because of some 24 additional maintenance rule scoping criteria that are 25 separate from renewal, many more aspects of the plant for ANN RILEY & ASSOCIATES, LTD. n_- s Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
38 1 the emergency operating procedures were already drawn into () 2 3 the maintenance rule and again it is focused on the dynamic equipment. It had already picked up a good bit of the other 4 equipment, so we really didn't find license renewal driving 5 any changes to the maintenance rule. 6 DR. SEALE: 'Okay. 7 DR. WALLIS: Can I ask you a very general question 8 on public perception. The public perception is an 9 engineering system, as it gets older, is more likely to 10 malfunction. .That is the experience of life, washing 11 machines, you know, no matter what. What is different about 12 reactors where we are told that it doesn't matter as it gets 13 older? 14 MR. ROBISON: Well, I think -- that is a nice b g,j 15 -question. If you look at your washing machine example, we 16 typically don't go into the washing machine and look at the 17 hoses and the pumps and the belts and the windings of things 18 on a periodic basis. We put our clothes in, we turn the i 19 controls and it works. Until it doesn't work, and then we ) l 20 go complain and we fix it. 21 In the case of a nuclear power plant, we do go 22 look at the motors and the pumps and the belts and we -- 23 DR. WALLIS: And we fix them. 24 MR. ROBISON: And we fix them, or we maintain them l 25 at a certain high level. And if you look at our operating O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L
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r 39 1 end maintenance expenses, a significant difference between () 2 3 perhaps our fossil brethren in the nuclear is that additional maintenance, insight and focus that we have to
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4 keep the plant at a high order, so that, if you will, our 5 washing machine is maintained at a high level. 6 DR. WALLIS: So it is more like an airplane. 7 MR. ROBISON: It is more like an airplane. 8 DR. WALLIS: It is maintained much more 9 strenuously than the washing machine. 10 MR. ROBISON: Yes. 11 DR. BONACA: Any other questions for Mr. Robison? 12 [No response.] 13 DR. BONACA: If not, thank you very much for your 14 presentation and we will hear now from Mr. Grimes. () 15 MR. GRIMES: I would like to introduce first Joe 16 Sebrosky, who is the Project Manager for the Oconee license l 17 renewal application, and also Barry Elliot, and John Fair of , 18 the staff, and Chris Groton. The team is still growing. j l 19 And Alan Heiser. 20 We are going to start off, because of the broad
- 21 interest in the reactor vessel, with a discussion of the
( 22 staff's review B&W Topical Report 2251, and we are going to l 23 describe aging management programs relative to the reactor 24 vessel. And then after that presentation, then we will move 25 into the specific area of interest for the Oconee i [~\
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40 1 application. l ( 2 DR. SEALE: Mr. Chairman, I wasn't aware of the 3 fact that ACRS was getting its license renewed. 4 DR. POWERS: You haven't seen some of the SRMs 5 coming down, have you? \ 6 [ Laughter. ] 7 MR. ELLIOT: Good morning, my name is Barry 8 Elliot', I am with the Materials'and Chemical Engineering 9 Branch of NRR. My discussion today is going to be about our 10 view of the BAW Topical Report -- B&W Topical Report, 11 BAW-2251, which has to'do with the reactor vessel and our 12 review of license renewal. Helping in this review was Herb 13 Conrad, Simon Sheng, John Fair and Mohammed Razzaque, 14 Our review is complete, there were no open items 15 and there were no confirmatory items. The' principal aging 16 management programs for the reactor vessel are, first, the 17 ASME Code, Section 11, Inservice Inspection Program, in l 18 which critical components are inspected to determine whether ! 1 19 there is cracking, where or loss of bolting integrity. 20 Another critical program is the Boric Acid Wastage l j 21 Surveillance Program, which is used to manage whether there 22 is any corrosion of the carbon steel reactor pressure vessel 23 on the outside. l 24 A third program is a Technical Specification 25 Leakage Limit Program where leakage is monitored to O
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F l -41 l i 1 determine whether there is loss of bolting integrity. () 2 3 And the fourth program is the B&W Owners Group l Reactor Vessel Integrity Program, and this program is used 4 to manage the aging effect of embrittlement of the reactor 5 vessel, neutron embrittlement. 6 DR. SHACK: Did they have a program for the 7 Alloy-600 vessel penetrations? 8 MR. ELLIOT: Good point. I left that out. ASME 9 Code, Section 11 -- I just changed my glasses, so now I can 10 see what I wrote here. The ASME Code, Section 11 program, i l 11 we found it acceptable except for one particular area, which i 12 was the vessel head penetrations which are Alloy-600. The 13 ASME Code program needed to be augmented with an additional 14 inspection of the Alloy-600 vessel head penetrations. )
"N l 15 Oconee has been participating in an industry-wide program i 16 and has inspected some of their critical vessel head 17 penetrations in the CRDM nozzles. Thank you.
18 DR. SHACK: Barry, just on that, everybody says 19 Alloy-600, I mean that must be Alloy-600 with an 82-182 20 weldment. 21 MR. ELLIOT: I am not sure of how the nozzles are 22 welded to the -- 23 DR. SHACK: To the vessel. 24 MR. ELLIOT: To the vessel. But we are looking at 25 the welds and the adjacent material to see if there is l 0 ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
42 1 primary water stress corrosion cracking. 2 When wefreviewed the safety evaluation -- when we
'3 made our' safety evaluation, this was a Topical Report and we 4 identified 13 plant-specific renewal applicant action items.
5 At the time we discussed this with the subcommittee. All 6 the action items-had been completed except-for one. The
.7 only one that was still open was a flaw evaluation and that 8 has been completed now. So now all the plant-specific 9 action. items for the reactor vessel are complete.
10 There are two -- 11 DR. SHACK: What is the nature of that flaw 12 evaluation? Is that evaluating flaws that they have 13 identified? 14 MR. ELLIOT: Yes, this is a flaw that they have () 15 identified in the reactor vessel during their Section 11 16 inspection program. The flaw is left in the vessel and it 17 was originally evaluated for the 40 year. life, and now it 18 needed to be evaluated for a 60 year life, and the applicant 19 has completed that evaluation. 20 There are two license renewal issues that are 21 generic license renewal issues that affect the vessel. One 22 is vessel surveillance and the other is fatigue of metal 23 components. 24 DR. WALLIS: Can you tell me about the flaws? Are 1 1 25 these flaws sort of seen and you watch how they grow and you ANN RILEY & ASSOCIATES, LTD. O. l Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 , Washington, D.C. 20036 (202) 842-0034 l
43 l 1 decide they are not going to grow significantly during their () 2 ' life, or is that the flaws aren't seen at all? 3 MR. ELLIOT: No , what happens is the flaws are 4 ' observed during inspection and it is part of the Section -- 5 if they see a certain amount, which in this case one of them 6 did, they are required to be evaluated and tc see if it can 7- remain in the ve sel without repair, it was done. Now, 8 after that is done, the applicant or licensee, in this case, 9 is required to go back and monitor the flaw growth. , 10 The original evaluation assumes a certain amount l l 11 of flaw growth. And then over the next 10 years the 12 licensee goes back and looks -- in fact, over the next 40 13 years, the next 60 years, the licensee will go back and look 14 at those flaws to determine whether the actual flaw growth 15 used in the evaluation is actually true. Okay. 16 DR. SHACK: But he does no probabilistic exam of 17 the flaws that he might have missed? 18 MR. ELLIOT: No , we don't -- well, it is not -- 19 DR. SHACK: There is no flaw tolerance kind of 20 argument here? 21 MR. ELLIOT: There is no flaw tolerance argument i 22 that what he missed is the -- we have a requirement that is l 23 being implemented now to qualify inspection procedures and, ! 1 24 as a result, if you pass that qualification procedure, you l 25 are capable of finding, detecting and monitoring flaws with Idni RILEY & ASSOCIATES, LTD. Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034
44 1 some high probability. [G l 2 The vessel surveillance program, I will start off 3 with that. Our goal here for the license renewal is that 4 every vessel should have a vessel surveillance program where 5 the irradiation data is sufficient, is far enough out that 6 it is equivalent to the end of life. At the end of the 7 license extension period, the neutron fluence of the 8 surveillance data is equivalent or greater than what is 9 expected for the vessel at the end of the license renewal 10 term. 11 The second goal is that if -- and this affects 12 Oconee in particular, is if the surveillance capsules are 13 removed prior to end of the license extension period, that 14 the licensee define the critical environmental p) (, 15 characteristics of the reactor vessel, neutron environmental 16 characteristics and that it maintain those based upon the 17 surveillance results, based upon when the capsules were 18 removed, and maintain those, that neutron environment 19 throughout the license extension period. 20 In both these cases, the applicant has complied. 21
- They are participating in an integrated surveillance program 22 in which they will be received at equivalent to end of 23 license, end of life extension neutron fluences.
24 The integrated surveillance program for Oconee, 25 the actual capsules are not irradiated in Oconee, therefore, O \m / ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
45 1 Oconee doesn't have any capsules. So they have established 2 a neutron environment which they must maintain. If they [GT 3 violate that environment, they have to reestablish the 4 program and tell us how they are going to modify their 5 embrittlement estimates. 6 As far as fatigue -- 7 DR. SHACK: On that one again, all their materials 8 are in a surveillance program similar or are they relying on 9 the Reg. Guide for some evaluations? 10 MR. ELLIOT: Okay. I-can get into that, it is a 11 lot of detail. Oconee 1 has plate materials in their 12 beltline, so they have six axial welds and three 13 circumferential welds that make up. Of that, there are six 14 different heats of material that were used to fabricate () 15 those beltline welds. It turns out that for B&W fabricated 16 vessels, the welds are the critical locations. Of the six 17 heats that are in the Oconee 1 vessel beltline, four of them 18 are being monitored by the integrated surveillance program. 19 Two of them are relying upon the Reg. Guide 1.99 Rev. 2 20 chemistry calculations exclusively. 21 But I would say that if you have four -- if four 22 of the heats are following the Reg. Guide, it is a pretty 23 good chance that the other two are also following the Reg. 24 Guide. And so that you may miss a few, even though we 25 missed two heats here, there is sufficient data to confirm [ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 '
46 1 that everything is going according to what we think it is () 2 3 supposed to be. Oconee 2 and Oconee 3 are -- I am going from 4 memory -- are forging fabricated beltlines. So they only 5 have circumferential welds. I think they only have two I 6 circumferential welds in the beltline. In the case of 7' Oconee 2 there are two heats, both of those heats are being 8 -- are in the surveillance program, and in the case of 9 Oconee 3, there are three different heats making up the 10 beltline welds. All three of those heats are in the l 11 surveillance program. 12 So the thing is that in a typical, in a normal 13 vessel, you are lucky if you get one weld that is in the 14 beltline and you examine it. In this case we have multiple () 15 heats in the beltline and we are examining the majority of 16 them, because of the integrated surveillance program. 17 Any more questions on surveillance? i 18 DR. POWERS: Well, I guess I need to understand l 19 better this concept that if we examine n heats, and find 20 them satisfactory, that the n plus 2, the plus 2 is also 21 going to be satisfactory with an examination. l 22 MR. ELLIOT: Yes. 23 DR. POWERS: I mean what is the basis for 24 confidence that that is the case? 25 MR. ELLIOT: What is the basis for the confidence? r 1 O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 t
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47 1 DR. POWERS: Yes. The difference is we know the () 2 chemist ry of those two other heats, so we know how to 3 predict, you know, what is going to happen to them. We know 4 the chemistry of the other heats and we know what is going 5 to happen to them. We can compare the predicted values for 6 all the other heats that are evaluated, and if the 7 prediction method works for those heats, then we think they 8 will work for the two other heats.
-9 MR. ELLIOT: So you are confident that you are 10 working on an interpolative scheme and not in any 11 extrapolation?
12 DR. POWERS: No, we are not extrapolating here. 13 One reason we are not extrapolating is because we are 14 requiring that the actual surveillance data be exposed to a () 15 neutron fluence equivalent to the end of license, expiration 16 license. 17 Fatigue of metal -- 18 DR. SHACK: You would typically find that the Reg. 19 Guide 1.99 Rev. 2 predictions for the welds that you are 20 monitoring actually gives you conservative predictions, 21 wouldn't that be the case? 22 MR. ELLIOT: Yes. In fact, we do that all -- that 23 is our main job is vessel embrittlement, is we constantly 24 get from all PWRs and BWRs, we get surveillance reports and 25 we compare the test results to the currently prescribed
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48 1 method for. determining embrittlement. And I would say 99 () 2 percent of the time the actual data conforms with what the 3 embrittlement equation is predicting. 4 FatigueHof metal components is an issue that is 5 concerned with the impact of environmental fatigue on the 6 usage factor. The licensee has done an analysis based on 7 the environmental factors described in NUREG/CR-6335. The 8 staff has determined that the B&W Owners Group has 9 adequately addressed GSI 190 regarding environment fatigue 10 of reactor vessel components and the fatigue of the Oconee 11 reactor vessel will be managed during the period of extended 12- operation. 13 That is an open issue then only in the sense that 14 you haven't gotten the final report or -- () 15 MR. ELLIOT: No , that is not an open issue. We 16 have completed the fatigue of the reactor vessel. So all l 17 the issues with respect to the reactor vessel as far as 18 fatigue are complete. 19 As far as time-limited aging analyses, fatigue of 20 components is a time-limited aging analysis; pressurized 21 thermal shock, which is related to embrittlement, is a l 22 time-limited aging analysis. Part of that, the I 23 embrittlement is dependent upon the material composition and l 24 the neutron fluence, and as part of this review, the l 25 applicant submitted a report on neutron fluence, Topical , i [2
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49 1 Report BAW-2241P. We reviewed it and approved it. p 2 Another time-limited aging analysis is the effect 3 of embrittlement on Charpy Upper Shelf Energy. A topical 4 report was submitted on this, and staff has reviewed it. 5 This was an extension of the previous topical report, which I 6 had done for 40 years. This just modified it for 60 years. 7 A fourth time-limited aging analysis was the l 8 growth of intergranual separations in low alloy steel 9 forgings heat-affected zones under stainless steel weld 10 deposit cladding. This is an analysis as it describes of 11 the growth of these separations during the 60-year life of 12 the vessel, and also the impact of embrittlement to 13 determine that these separations will not grow to a size l 14 which will affect the integrity of the vessel. f (g) 35 DR. SHACK: Recently the French did a 16 reexamination of some of those cracks and sort of discovered 17 they were bigger than they thought they were. 18 MR. ELLIOT: Our analysis assumes that they're 19 much bigger -- and they started out -- the analysis we 20 originally -- when they were first discovered they were only 21 one-tenth of an inch. Our analysis started with -- assumed 22 that the crack not only was -- it was .165, which is larger l 23 than a tenth of an inch. But also we assumed that it went 24 right through the clad. So we assumed both that it was -- 25 actually it isn't our analysis, the applicant's analysis -- ['/ L
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I 50 1 assumed like .365 inches in depth, which is much, much -- () 2 three times larger than originally assumed. And then we 3 grew the crack from there based upon the operating cycles of 4 the vessel. 1 5 DR. SHACK: So they are no longer embedded cracks, 6 they are surface cracks in this analysis. l 7 MR. ELLIOT: In the analysis there, they are j 8 surface cracks. But in reality it doesn't represent that at 9 all. That's just a very conservative analysis. I 10 DR. WALLIS: Well, what was the purpose of picking i i 11 a size of crack which was much bigger than it really was? I 12 MR. ELLIOT: We wanted to have -- you know, there l 13 could be a flaw that's larger than a tenth of an inch, so we 14 want to make sure we encompass everything that's possible () 15 here. 16 DR. WALLIS: Did it also analyze the real tenth of 17 an inch? 18 MR. ELLIOT: You could analyze a tenth of an inch 19 also. ! 20 DR. WALLIS: Did you? It seems to make sense. 21 MR. ELLIOT: The applicant chose to make a larger 22 floor, and we agreed that it was conservative and i 23 appropriate to do that. 24 DR. WALLIS: I'd like to know how conservative it i L 25 is. I mean, is the tenth of an inch very different from the ANN RILEY & ASSOCIATES, LTD. O' Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 j Washington, D.C. 20036 (202) 842-0034
51 l 1 .165? You have a gut feeling it is, but it sort of makes
] 2 sense to analyze it to find out how different it is. Maybe
- 3. it's a factor of a million or something. I don't know.
4 Nice to know. 5 DR. SEALE: Actually there are two elements of 6 conservatism. I would imagine that the assumptions that go 7 into the evaluation methodology are tilted or skewed or 8 whatever the word is so that if you had a tenth -- if you 9 started with a tenth of an inch, you'd still be conservative 10 in the behavior of a tenth-of-an-inch crack. You then 11 assume .165. There's another conservatism that comes from 12 that. 13 MR. ELLIOT: These are just separations at the 14 boundary, i () 15 DR. SEALE: Yes. 16 MR. ELLIOT: That's all they are. They aren't 17 totally cracks. We're assuming that, and we assumed in the 18 analysis not only did they -- they grow right through the i 19 clad. And that's not true. That's the biggest assumption j 20 we make -- they made. i 21 DR. SEALE: Well, it would be worthwhile to know 22 if a significant fraction of your claimed conservatism is in 23 the basic set of assumptions that go into the crack-growth 24 analysis or are those conservatisms in the size of the 25 initial crack that you assumed to begin the analysis. O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r 52 1 MR. ELLIOT: I think we're doing both of those. () 2 DR. SEALE: I didn't say that. I said it would be l 3 interesting to know how much is -- or at least on the size, l 4 what the' magnitude of that conservatism is, and I think 5 that's what Dr. Wallis is driving at. l 6 DR. WALLIS: Can you supply that information? 7 MR. ELLIOT: I don't have that right here. We 8 have to do the analysis ourselves, or -- 9 DR. WALLIS: We hear a lot about conservatism and 10 margins and things like that in these presentations, and it 11 would be very useful if they could be quantified so we know 12 how close we are to stepping over some margin of safety or l i 13 whether we've got an enormous margin. i l 14 MR. ELLIOT: Well, let me just say this. The l
) 15 ASME -- we have an enormous margin in this case for the i 16 . flaws, I'll tell you that, and the reason I say that is not 17 only do we when we describe it -- we made these flaws cracks 18 and they aren't, and we made them go through the wall, but 19 we also put additional criteria on if the ASME code requires 20 margins on that, that's the square root of 10 safety margin l 21 above and beyond that. So we're talking margins on top of l
22 margins here to assure that the vessel is not cracked. 23 DR. WALLIS: You think of that as virtuous. Now 24 someone who is saying let's be realistic and let's not be 25 overconservative might review that as not virtuous at all, ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
53 1 to have something which-is conservative by maybe a factor of () 2 1,000 or something. 3 MR. ELLIOT: If we were asking them to repair 4 those vessels based upon these flaws or to do additional 5 inspections based upon these flaws, that would be a, you 9 6 know, they would have a legitimate complaint because of all 7 the margins that are here. But we're not asking them to do 8 anything here. We're 4;st asking them to evaluate the 9 integrity of the vessel. And they've done it. They've 10 evaluated the integrity of the vessel, and it's acceptable 11 with these flaws in them. 12 DR. WALLIS: But I think there's a different f 13 audience there. There's the public or even people like us 14 looking in saying yes, your conclusion is we don't have to () 15 make them do anything. 16 MR. GRIMES: This is Chris -- 17 DR. WALLIS: But the other need is if you could 18 sort of show the sort of materials community that, you know, 19 when you do the realistic analysis how that compares with
-20 the one you -- and that would give us more perspective on 21 what kind of regulations you're enforcing. Because maybe 22 your regulations are far too conservative.
23 MR. GRIMES: This is Chris Grimes. I'd like to 24 point out that this is an area where Barry is addressing an 25 explanation about how the current licensing practice relates ANN RILEY & ASSOCIATES, LTD. O. Court Reporters 1025 Conne;ticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
1 54 1 to a conclusion relative to extending the license period for () 2 20 years. We do not nor did we attempt to change that 3 practice for the purpose of developing a license renewal 4 conclusion that attempted to segregate out the degree of 5 margin in the calculations that we rely upon today within 6 the existing regulatory framework, nor did we conclude that 7 there was a need to do any additional analysis or a change 8 in the practice simply for the purpose of developing a 9 license renewal decision. 10 DR. WALLIS: Well, I understand, but do you 11 understand my point of view? What you're doing is you're 12 doing this for internal NRC purposes. There's no other 13 audience than your own folks making a licensing decision. 14 MR. GRIMES: I'm not sure that I agree, because I 15 believe that we're doing this from the standpoint of the 16 ASME community and the plant operators who have an 17 established practice that we rely on as an existing program 18 that manages an aging effect or set of aging effects 19 associated with the integrity of the reactor vessel. And I 20 believe that that established practice is something that, 21 like we explained to the Commission, we're relying on the 22 credit for that existing program as a practice that would 23 continue on into the period of extended operation. 24 MR. ELLIO7. This is my final slide in the 25 presentation, and I talked about the master integrated ANN RILEY & ASSOCIATES, LTD. O- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
55 1 surveillance program. It has data both from Oconee and also () 2 3 the other applicants who are participating in -- other participants in the integrated program, as well as 4 supplementary capsules. 5 The last~ issue affecting the reactor vessel is the " 6 PTS analysis, and initially Oconee's -- the limiting weld 7 for all three Oconee vessels is the Oconee 2 upper shelf to 8 lower shelf circumferential weld. When we received the 9 original report, BAW-2251, when we did our evaluation of J l 10 this weld, it turns out its reference material properties I 11 turn out to be higher than the PTS screening criteria by 12 four degrees. 13 We pointed this out in our safety evaluation, and 14 the applicant has made a plant-specific evaluation using () 15 more up to-date neutron fluence evaluation as well as 16 chemistry results, and has determined that the actual l 17 circumferential weld in this vessel is not above the 18 screening criteria. Its RT PTS value was 297. We have 19 confirmed by looking at surveillance data that this is a 20 conservative estimate for the RT PTS value for this weld. 21 DR. WALLIS: Well, in this case you don't make an 22 absurdly conservative assumption, you're actually so close 23 to some limit that you do something different. 24 MR. ELLIOT Now what we did, we do exactly what 25 we do with everybody when we review a PTS evaluation. We O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
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1 56 1 look at the surveillance data and we determine whether or fT G' 2 not, based on the surveillance data, the PTS evaluation is 3 adequate. We did that here. We looked at -- since they 4 have a substantial amount of surveillance data, we looked at 5 it, and we determined that the methodology that is used in 6 determining this number is conservative. 7 DR. WALLIS: Well, you may well be doing the right 8 thing. It's just that I'm struck by the difference between 9 the approaches in the two cases. 10 MR. ELLIOT: Well, I just want to say that this 11 methodology has conservatism built into it. 12 DR. WALLIS: A different kind of conservatism. j 13 MR. ELLIOT: We have -- i 14 DR. WALLIS: You're not assuming something is the (O,,) 15 way it isn't in order to be conservative. You're doing a 16 different kind of conservatism. 17 DR. SHACK: He makes an extremely conservative 18 screening limit, and then he calculates precisely whether 19 he's above or below -- 20 DR. WALLIS: That's very -- yes. 21 DR. SEALE: Yes. 22 MR. ELLIOT: Anyway, tnat's the end of my 23 presentation -- 24 DR. SEALE: Could I ask a related question? 25 There's a generic issue on fatigue that's been laying out l l [) N/ ANN RILEY & ASSOCIATES, LTD. Court Reporters I 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 t >
57 1 there for an awful long time, and I was wondering, we've
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(J 2 been told we're going to get a chance to look at that 3 sometime in the near future. I was wondering what the 4 status of that was. 5 MR. ELLIOT: That's John Fair's area. 6 [ Laughter.) 7 DR. SEALE: Well, I saw John flinch when I l 8 started. 9 MR. FAIR: Thank you, Barry. It's not exactly my 10 area. It's Research's program, and I believe that they're 11 working hard to get it done by the end of the year. But I 12 don't want to speak for them. 13 DR. SEALE: That sounds familiar. l 14 DR. WALLIS: Well, does it need to be resolved by () 15 the end of the year? 16 MR. SEBROSKYr Well, we have an open item on 17 GSI-190 that will come to Dr. Wallis, and we'll discuss how 18 we intend to resolve that on a plant-specific basis. 19 DR. WALLIS: How long has GSI-190 been in l 20 existence? 21 MR. SEBROSKY: I don't know. 22 MR. WESSMAN: Yes, this is Dick Wessman from the 23 staff. I think GSI-190 itself has been in existence for l 24 maybe two or three years, but of course it has precursors, 25 as you know, going back to GSI-166, and was it 157? [D ANN RILEY & ASSOCIATES, LTD.
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58 l p 1- MR. FAIR: -166 is the precursor. 2 But I think we should let Research
-( ) MR. WESSMAN:
3 describe when they're ready to come to the Committee and 4 talk about the program that is ongoing there, I think John 5 and Joe will address the aspects specifically related to 6 licence renewal and how the applicant and the staff are 7 addressing this issue in the light of a GSI that is not l l 8 fully resolved. 9 MR. SEBROSKY: My name is Joe Sebrosky, and I am 10 the Oconee license renewal project manager in NRR, and 11 before we get into the slides, just a high level on what 12 I'll be presenting. 13 We were asked to present high-level differences 14 between the Oconee and Calvert applications, and also unique () 15 plant configurations that affected the review, and I'll-have 16 a slide on that. 17 The packet that I gave you also contains a 1 18 synopsis of all 43 open items and six confirmatory items. 19 Because we'are limited by time, we are going to focus that, 20 as Dr. Shack had mentioned earlier, into the ones that are l 21 rising to the level of management attention today. l l 22 I don't know October 15th what that list in going l 23 to be, but I can tell you today what our list is, and in l 24 that list contains some of the things that we were asked to 25 look at. Specifically, the ACRS wanted us to talk about O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r? ( 59 ( 1 scoping. We have an open item on scoping. They also asked l 2 us to talk about void swelling, and we will talk about that i 3 a little bit later. So the list that I am going to go 4b R;ough of our management items today encompasses some of 5 the items that you wanted. 6 And the list that I will talk about is scoping, l 1 7 complex assemblies, form and content of the FSAR. I am then 8 going to turn it over to Barry to talk about the open items 9 associated with our Section 3.4, that is where void swelling 10 is , and 3.4 is on the reactor coolant system. So that is -- j 11 those open items are receiving a lot of management attention 12 now. And we will also discuss the open item related to 13 fatigue. 14 There is one item that is not on our management () 15 attention radar screen right now, but we will talk about the 16 reactor coolant pump oil collection system. We have an open 17 item associated with that. 18' And in addition to that, I do not have a 19 presentation on two subject matters that the committee had 20 expressed an interest in, and that is on fuses and boroflex. 21 We don't have a presentation on that, but we have people 22 here to answer questions when we get to that. 23 So I will go ahead. 24 MR. GRIMES: Actually, before you begin, Joe, I l 25 would like to point out that Joe's presentation is organized O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
60 1 in a way that we are going to describe matters that relate I 2 to our review of the Oconee application. And as Joe 3 mentioned, to the extent that the committee has any other 4 questions related to the staff's generic approach to license 5 renewal, or the p"actices, or positions that we have sent to 6 NEI relative to how we intend to apply Part 54, we would be 7 prepared to discuss those at the conclusion of the 8 presentation on where we stand with the Oconee review. 9 And we also have a meeting planned, I believe 10 September 23rd, to continue to pursue the subcommittee's 11 interest in generic license renewal matters. So there will ! 12 be an opportunity to continue a dialogue finally with any of 13 the topics of generic interest that you have. But we want 14 to try and keep the Oconee specific matters focused and the
- () 15 we will address any concerns that you have relative to the 16 generic aspects.
17 MR. SEBROSKY: As far as the application 18 differences go, Calvert Cliffs used a vertical approach by 19 system or structure. And by that, I mean if you look at 20 Calvert's application and you compare it with Duke's 21 application, the format is totally different. For example, 22 you would pick a system, reactor coolant system for Calvert, 23 and what you will do is you will find for that particular 24 system, in one section, how they scoped it, how they applied 25 the screening process, the aging effects, the aging rO ANN RILEY & ASSOCIATES, LTD.
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61 1 management programs and TLAAs all in that section. That is [ ) 2 what I mean by Calvert using a vertical approach. 3 Oconee, on the other hand, used a horizontal 4 approach, and their approach is more similar to the SER 5 formats that we have for both Oconee and Calvert Cliffs. 6 And, specifically, if you look at their Chapter 2, they have 7 identification of structures and components subject to an 8 AMR. Chapter 3 talks about aging effects. Chapter 4 of 9 their application talks about aging management programs and 10 activities. And Chapter 5 is TLAAs. 11 Oconee, also, to contrast the differences, 12 referenced several topical reports and the topical reports 13 are meant to be written in such a way that they can be l l 14 relied on by another B&W licensee. And the topical reports () 15 that Duke relied on for Oconee are one on RCS piping, 16 pressurizer reactor vessel, reactor vessel internals and 17 fluence methodology. And Barry gave you the discussion on 18 one of those, the reactor vessel. 19 The next bullet on the slide talks about the 20 safety evaluation reports for Calvert and Oconee have 21 similar formats. That is the format that the SER and we 22 expect future applications to be converging towards. And if 23 you look in Chapter 2 of our SER, you will find the 24 discussion about the scoping and screening process. Chapter 25 3 has aging effects and aging management programs, and l 1 1 rO
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L i L 62
.1 Chapter 4 is the TLAAs. So there is not a one-on-one
() 2 3 correspondence with Duke, but it is similar. As far as plant differences go, there is obvious 4 plant differences in the respect that the Duke plant, l 5 Oconee, is a B&W plant where the Calvert Cliffs is a I 6 combustion engineering plant. 7 I_tried in this slide to just give you some high 8 level differences and unique features at Oconee that the 9 staff had to spend extra time on. Specifically, those are l ! 10 Oconee has a standby shutdown facility. And the standby l 11 shutdown facility is meant to provide an alternate means to "t 2 achieve and maintain hot shutdown conditions following a 13 fire, sabotage, turbine building flood, station blackout and i 14 tornado missile events. That is a unique facility that did () 15 not exist at Calvert. And the other obvious plant 16 difference was that Oconee relies on the Keowee 17 Hydroelectric Station as the onsite emergency power source. 18 So both of those fell into our review. 19 Now, turning to the open item discussion, on page 1 20 3, the first two bullets involve the open item with scoping. j 21 The first bullet has actually been completed, and that is 22 that Duke was to provide us a discussion in writing of what 23 they told us in a May lith meeting. And where we are at 24 right now with this issue is the sectr.d bullet, that 25 subsequent to the receipt of the above information, the { ANN RILEY & ASSOCIATES. LTD. NJ Court Reportsrc 1025 Connecticut Avenue, JN, Suite '014 Washington, D.C. 20036 (202) 842-0034
63 1 staff will determine whether additional inspection l [) V 2 activities will be needed to verify the adequacy of the l 3 applicant's process for identifying structures and l 4 components that are within the scope of the rule. 5 We had a meeting with Duke, actually, we went to 6 the site from August 16th to August 18th and at this point, l 7 I would like to turn it over to Chris Grimes for further ! 8 discussion on that open item. i 9 MR. GRIMES: We brought this topic up at our 10 monthly management meeting, which was last Friday, and we 11 have found we are still overcoming terminology differences 12 and trying to avoid falling face first into challenging the 13 current licensing basis. We are still attempting to 14 understand what the current licensing basis is relative to
) 15 how Duke has scoped their safety-related systems, structures 16 and components that are relied upon to perform safety l
l 17 functions for design basis events. 18 And therein lies the problem. There is a 19 definition of current licensing basis in Part 54 that has a 20 very sweeping and broad approach to what is a design basis 21 event, and Duke has been maintaining the license basis for 22 Oconee with a different perspective on design basis events, 23 separate and apart from other commitments and responses to l 4 24 Generic Letters, for example. I And so we need to sort ; 1 25 through that in order to establish a clear understanding of !
)
I 1 [ ANN RILEY & ASSOCIATES, LTD. f Court Reporters 1 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034 l L
m< i 64 1 what the current licensing basis is and how it has been
')
[O 2 captured for the purpose of license renewal, and explain 3 that in a way that both -- that there is a shared 4 understanding between us and Duke on what that scope really 5 is. So we are going to continue that dialogue until we 6 achieve that shared understanding. 7 DR. WALLIS: That sounds a little odd. That you i 8 don't know what the current licensing basis is, yet the ; 9 plant is licensed. 10 MR. GRIMES: That's not -- 1 11 DR. WALLIS: 'itat not unusual? 12 MR. GRIMES: It ' not unurual for the staff to 13 not know all of the details e2 a current licensing basis 14 that is maintained in accordance with the regulatory process O( j 15 that permits the applicant to change -- excuse me -- permits 16 the licensee to change the design and to maintain it, and to 17 respond to NRC inquiries and take actions that result in 18 design changes. 19 DR. WALLIS: I thought you said there was a 20 difference between the licensee's interpretation and the 21 agency's interpretation of the current licensing basis. 22 MR. GRIMES: No. There is a difference in the way 23 that they use the term " design basis event" and the way that 24 we understood design basis event to be a much broader term. 25 We had to overcome that just to be able to start ANN RILEY & ASSOCIATES, LTD. ( Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l i
1 l 1 65 1 communicating with each other in terms of what events are l [%/ l 2 appropriate or applicable for the purpose of scoping. 3 In addition, it is further confused by -- Duke has 4 approached this from the standpoint of using one approach 5 for electrical. It recognizes that there are no clear 6 system boundaries for electrical like there are for piping 7 systems. There is a different approach for structural that 8 relies more heavily on a commodity approach and the fact l 9 that structures are, again, like piping systems, they don't 10 have clear boundaries, i i 11 And then there is a mechanical approach, and in l l 12 the mechanical approach, there is an extensive reliance on l 13 what are design basis events relative to safety functions. 14 And we are now mucking around in the details of, well, what () 15 is the difference between the safety function and the i 16 current licensing basis and a design basis event that is j 17 explicitly included in the FSAR and analyzed to perform a 18 particular function. And we are pulling that apart now in 30 such a way as to clearly understand what the design basis 20 events are for Oconee relative to what the safety functions 21 are that they rely on in their current licensing basis. 22 Those two are a little different. 23 DR. WALLIS: This has nothing to do with license l 24 renewal. 25 MR. GRIMES: This has everything to do with ( ANN RILEY & ASSOCIATES, LTD.
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II I 66 1 scoping for license renewal, to identify the passive () 2 3! systems,~ structures and components that are relied upon to l- . perform safety functions or non-safety functions that could l l 4 affect safety functions and our ability to make a conclusion t ! 5 on the methodology for scoping without having to list 6 component-by-component, item-by-item, each and every thing l
- 7. in the licensing basis that is subjected to an aging 8 management review.
l 9 The rule is predicated on a process approach, that 10 in order for us to make a finding on the process we have to 11 understand enough about the current licensing basis and 12 ' design basis events in order to establish reasonable 13 assurance that the process captures all of the 14 safety-related systems, stru ctures , and components.
)
15 DR. BONACA: The issue is the Part 54.again has a 16 very sweeping definition in the scope definition, and it 17 doesn't say look at all your Category 1 components. It
]
18 doesn't say that. 19 MR. GRIMES: Right. 20 DR. BONACA: It says components that perform a 21 safety function. It doesn't tell you how you are going to 22 go about that. That is one issue that needs to be 23 clarified. 24 MR. GRIMES: That's correct. As a matter of fact, [ ! 25 we look back and we see when the rule was constructed in ANN RILEY & ASSOCIATES, LTD. Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 l (202) 842-0034 i
p 67 1 1991 it was intended to be a much more sweeping rule, and at () 2 3 that point we put a definition of current licensing basis in the rule that was very broad. In 1995 when the scope was
.4 narrowed and we ended up with 54.4 defining a set of three 5 different kinds of design basis events, the safety 6 functions, the nonsafety functions whose failure could 7 affect safety functions, and the regalated events, we 8 maintained that definition of CLB, but then we didn't make a 9 clear distinction about what the expectation was about l 10 narrowing the event scope, if at all, so that is the area l 11 now where we are trying to focus on how big is the
-12 population that was intended when the rule was modified in 13 1995, 14 DR. BONACA: And the bottom line is that you want
) 15 to make sure that passive components which have to perform a 16 safety function will be in the aging management program.
l 17 It's as simple as that. l 18 MR. GRIMES: That's correct. 19 DR. BONACA: And so that is the important l 20 objective. l
- 21 MR. GRIMES
- Yes, and I want to emphasize we are 22 going to try to do that with a Commission expectation that l 23 was clearly articulated in the Statements of Consideration l
24 that the Commission expected us to be able to do that 25 without compiling this CLB, ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1 l-
i 68 1 If you recall many years ago there was an () 2
'3 initiative that would have caused -- the Commission considered whether all plants should go back and compile l 4 their current licensing basis and reconstitute their design, 5 and that led to a tremendous number of initiatives and some 6 special inspection programs to go'out and verify that the 7 current regulatory practice and process was maintaining the 8 current licensing basis in a satisfactory way without 9 requiring-compilation of that information simply for the i
1 10 purposes of communicating it to the NRC and the public. 11 MR. SEBROSKY: The next issue I would like to talk 12 about.is represented by the second bullet here -- on page 13 4 -- and that is passive, long-lived skid-mounted equipment 14 are excluded from an aging management review. 15 What the Oconee site has in the standby shutdown 16 facility is a diesel generator and this example is best l 17 represented by looking at that diesel generator. 18 On a high level, that diesel generator is i 19 considered to be within the scope of the license renewal 20 rule, but there is a screening process that is then done 21 after you determine the systems within scope and j 22 active-passive determination. l 23 Duke considers the diesel generator to be screened j 24 out for purposes of license renewal, and the Staff has no 25 objection to the diesel generator. It says right in the l l O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 (202) 842-0034 l l L
69 1 rule that diesel generators are outside the scope of the 2 license renewal rule. L ~3 What: the Staff is objecting to, though, is the 4 definition of diesel generator. Duke considers when the 5 diesel generator was supplied it was supplied on a skid. 1 i 6 Any of-that equipment that was supplied with the diesel l ' 7 generator on that skid is part of the diesel generator and 8 does not have to be looked'at to determine if an aging 9 management review needs to be done. 10 The Staff doesn't agree with that and specifically 11 in our SER we mention that there's components on that skid
- 12. such as the diesel engine jacket, water heat exchanger, and 13 portions of the diesel fuel oil system and starting air 14 system that would we believe fall within the scope of the 15 rule, so we have not seen an answer to this open item yet 16 but it is something that we expect because of the generic l'7 ramifications of it that we expect it will be elevated to j 18 management -- so that is the issue on complex assemblies.
19 I'll skip ahead a little bit here. The next issue 20 that right now is receiving management attention for i 21 Calvert, and we expect that it will also receive management l 22 attention for Oconee, is represented by the first bullet on 23 page 6, and that is form and content of the FSAR tsupplement. l l 24 I will give you a high level description and then l 25 I will again turn it over to Chris Grimes for discussion. i ANN RILEY & ASSOCIATES, LTD.
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70 l 1 What this open item represents at a high level is () 2 how the Staff.is going to capture the commitments for 3 posterity as'far as the license renewal application goes. 4 The license renewal application itself becomes a historical l 5 document at the time we give them a license. It is not 6 something that gets updated. ! 7 The rule requires though when a license renewal l l 8 application is submitted that the applicants supply the 9 Staff with an FSAR supplement and the form and content of l 10 what rises to the threshold of what will go into that FSAR 11 is what this open item is about. 12 I'll ask Chris if he wants to add anything to 13 that. 14 MR. GRIMES: Yes. I would like to point out that
) 15 the desired outcome in this instance is to make clear what 16 the Staff's expectation is relative to what additional 17 things will be managed under 50.59 as part of the 18 continuation of the current licensing basis into the future, 19 and so our end-game for this issue is to establish an 20 approach that will ensure that the specific details that the 21 Staff relied upon in commitments and explanations of program 22 attributes for the purpose of license renewal will be 23 appropriately captured in the regulatory process.
24 MR. SEBROSKY: As far as the next portion, I would 25 like to turn it over to Barry. The next couple of slides ANN RILEY & ASSOCIATES, LTD. O- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
71 1 start on page 9 and we'd like to talk about the reactor () 2 coolant system aging effects open items. 3 There was one-open item that we have that the ACRS 4 had expressed some interest in, and that was on void 5 swelling. I will go ahead and turn it over to Barry. 6 MR. ELLIOT: Before I start out, I would just like 7 to give you our engineering view of how we did this 8 evaluation. 9 It comes back to the discussion before a little 10 bit. We look at the existing program. We look at what we 11 think are the mechanisms or effects that affect each 12 component, and then we decide whether or not the existing 13 program or the proposed program is adequate for managing 14 that aging effect. O (_ ,/ 15 Now for the reactor coolant system, outside of the 16 reactor vessel there are three effects that we were 17 concerned about that we thought existing programs may not be 18 adequate and we needed more discussion with the applicant, 19 in this case Oconee and also Calvert Cliffs. 20 The aging effects are: the effect of irradiation 21 and how it affects the material properties such as void 22 swelling, fracture toughness, irradiation of system stress 23 corrosion, cracking of internals. Many of these things have 24 to do with that. We have an irradiation effect that the 25 existing program may not be adequate. O ANN RILEY & ASSOCIATES, LTD. Court Reporters ! 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 l (202) 842-0034 l i
72 1 The second effect would be thermal embrittlement l () 2 of cast stainless steel. This is an aging effect that 3 reduces the fracture toughness of a particular component 4 called cast stainless steel. 5 The third aging effect which would affect 6 materials in the reactor coolant system is primary water l 7 stress corrosion cracking of Alloy-600. 8 Then we have to look to determine whether the 9 existing programs are adequate for those mechanisms and 10 aging effects, so I will go through each one of these. 11 The first one is the pressurizer spray head which 12 is a cast stainless steel component, and it will have a 13 reduction in Iracture toughness, so we have begun discussion 14 with the applicant on how they are going to inspect this and () 15 evaluate it since it has a reduction in fracture toughness 16 due to the thermal embrittlement. 17 The next issue is void swelling. This is an 18 irradiation issue for the internals. There is a lot of 19 literature on this subject. Some of the literature says 20 void swelling is a problem for PWR internals. Some of the 21 literature says void swelling is not an issue. 22 At the moment -- 23 DR. WALLIS: Excuse me, what voids are these 24 voids? 25 MR. ELLIOT: This is a void in the internal lvh ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
73 1 material crystal structure.
) 2 DR. WALLIS: The void is what? What is in the 3 void?
4 MR. ELLIOT: It's hydrogen expands the lattice 5 structure and causes -- 6 DR. WALLIS: Gas. 7 MR. ELLIOT: Yes, hydrogen gas. 8 MR. HISER: This is Alan Hiser of NRR. It is 9 mainly helium bubbles that form. 10 DR. WALLIS: They don't diffuse out? 11 MR. HISER: No. 12 DR. WALLIS: Doesn't close off. 13 MR. HISER: No , they are constrained within the 14 lattice. They nucleate and then grow during additional l ) 15 irradiation. The main concern here is that the growth of 16 these voids can swell the overall dimensions of the 17 structure and in particular what we are concerned about with 18 the internals is either loss of dimensionality through, say, 19 tight fit components or maybe constriction of float levels 20 that are important. l 21 DR. WALLIS: Can these bubbles link up in some I i 22 way? l l 23 MR. HISER: I don't know that they so much link 24 up. It is just that the growth of them, just overall, 25 distorts the structure. l ANN RILEY & ASSOCIATES, LTD. (_/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
74 1 DR. BONACA: And the phenomenon'is also very much O '2 ' temperature-dependent, is it? U 3 MR. HISER: Yes, that is correct. The main 4 parameters'of importance are the flux temperature and also 5 the accumulated fluents. 6 DR. BONACA: If I understand the issue, it is that ! 7 for temperatures in PWR is they are borderline insofar as 8 there's periods that are applicable. 9 MR. HISER: Yes. The industry citations indicate 10 that void swelling may be on the order of 4 percent or 14 11 percent at end-of-life PWR conditions. That is a fairly 12 broad range and part of the problem is that the definitive 13 data at PWR conditions doesn't exist so there's a lot of 1 14 extrapolation from breeder reactor conditions and how one () 15 does the extrapolations and what assumptions one makes drive 16 whether you get a low estimate or a high estimate. 17 DR. WALLIS: Did you say there was a 14 percent of 18 what? 19 MR. HISER: That would be a change in dimension. ; 20 If you have a dimension that is one inch, it would become 21 .1.14 inches. 22 DR. WALLIS: A piece of steel becomes 14 percent 23 bigger? , 24 MR. HISER: That is correct. I 25 DR. WALLIS: I would think this might have quite a O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 r t
1 75 l 1 few effects. () 2 3 MR. HISER: DR. WALLIS: That is what we are concerned about. If it becomes bigger in all I l 4 directions -- becomes longer? 5 DR. SEALE: Three dimensional. 6 MR. ELLIOT: Yes, i 7 DR. SHACK: Yes. For fast reactors it is very 1 8 dramatic, where there is no argument over the existence of 9 the effect. As Allen said, the real question is at these 10 temperatures how important is it. l 11 MR. ELLIOT: Our approach to handling this issue
.12 is to look -- is to find out where the critical locations 13 are on the internals.
14 DR. WALLIS: If any piece of my house became 14
) 15 percent longer, the effect would be dramatic.
16 DR. BONACA: Drop in price too. 17 MR. BARTON: Real estate values would go up -- 18 DR. SEALE: -- 14 percent. ] 19 DR. WALLIS: A door that becomes 14 percent 20 bigger, it's sometimes embarrassing. l 21 MR. HISER: Well, my understanding is there are 22 problems -- I am not sure if it is in the breeder l 23 environment with fuel rod growth. 24 DR. BONACA: Yes. 25 MR. HISER: And, you know, it's just along those l l ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
r 76 1 same lines but just fuel rods you are able to remove and () f 1 2 replace -- 3 MR. ELLIOT: That's right. 4 MR. HISER: -- but the internals generally are not ! 5 replaced and that is a real concern that we have. ! 6 DR. SHACK: Well, in the breeder you design for i 7 the fact that it is going to get bigger and that really ; ! 8 wasn't a design consideration. 9 DR. BONACA: As well in the fuel assemblies. 10 Typically you have spread because you have growth, but isn't l 11 it something that inspections would cure insofar as 12 looking -- 13 MR. HISER: At the current time, the only ASME 14 required inspections on internals are a VT-3, which is
/^N
(_,) 15 basically a fairly gross visual inspection. If we are I 16 luoking for, say, growth of a one-inch component by 140 17 thousandths of an inch, I don't think that that is 18 observable. 19 DR. BONACA: Okay. 20 MR. HISER: Sort of the frame of' mind that we were 21 on this would be to try to locate some critical dimensions 22 and maybe monitor those through the standard ASME inspection 23 process. 24 DR. WALLIS: Well, I am really puzzled. I must be 25 naive. You have fuel elements and things that slide in and [dj N ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l 77 1 out through spacers and all kinds of devices. Do those () 2 3 spacers actually swell by this amount? MR. HISER: They could. 4 DR. WALLIS: They could? 5 MR HISER: One of the discussions -- 6 DR. WALLIS: Then you'd have things rattling 7 around tremendously when it's new or it's jammed in there 8 when it's old? 9 MR. HISER: That is some of the response we have 10 had from the applicants is that things like rod insertions 11 would indicate whether there is a problem. 12 Our concern is that if one needs to insert rods 13 and maybe they went in properly the previous time, but now 14 you have got an accident condition and you need them to i () 15 insert and you have had additional void swelling and now 16 they don't insert. That is not a good condition. 17 DR. WALLIS: That would seem to be an embarrassing 18 situation. 19 MR. HISER: It could be more than embarrassing. 20 MR. GRIMES: Yes. Dr. Wallis, that is really at 21 the heart of this issue is the fact that, you know, the 22 industry now is approaching this from the standpoint of they 23 are not convinced that the cost and personnel exposure 24 associated with trying to inspect dimensional changes inside 25 the reactor is justified by the data that suggests that void ANN RILEY & ASSOCIATES, LTD. On Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
78 1 swelling might or could occur. [)
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2 So we're at a point where we have to confront this 3 with is the data sufficiently persuasive to require 4 particular inspection requirements, and if so, what can be 5 the appropriate amount without being unnecessarily 6 burdensome. 7 DR. BONACA: We read a report in which -- again I 8 believe it was supported by EPRI -- in which a l l 9 recommendation was made for further research in this area. 10 It was not clear at all in the report on what research and ! I 11 who would be performing this research. Do you have any 12 comment regarding that? 13 MR. HISER: The industry has put together a group 14 called the NPR, Materials Reliability Project -- I guess (~% ( , ) 15 it's MRP, sounds better. And they're tackling a lot of 16 issues, basically the ones that Barry mentioned, neutron 17 embrittlement of stainless steel, void swelling is one of 18 the issues they're looking at. This is an industrywide I 19 program. 20 They also are obtaining materials from overseas, i 21 and a lot of collaboration overseas. What they're 22 basically -- my understanding is what they're trying to do 23 is assess the effects of things like void swelling. Since 24 there is limited data applicable to PWR conditions, they 25 want to try to get as much of the material and information l l [ ANN RILEY & ASSOCIATES, LTD.
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79
- 1. that's available and assess the significance of the issue.
()- '2 DR. WALLIS: Void swelling is progressive with 3 age, is it? 4 MR.-HISER: That's correct. 5 DR. WALLIS: So there must come some time in the 6 life of-these things when you cannot insert the control 7 rods. 8 MR. HISER: That may be 60 years. It may be 120 9 years. 10 DR. WALLIS: You seem to be very vague about it. 11 I would like to be reassured that it isn't going to happen. 12 MR. HISER: So would I. 13' MR. ELLIOT: But'that's the point of having a 14 research program, to look into issues like that, and that's () 15 what the program -- 16 DR. WALLIS: The program doesn't give the results 17 .always. You need the results now, don't you? 18 MR. ELLIOT: No, we don't need the results now. 19 DR. WALLIS: Relicense and then there will be some 20 method for monitoring this? l 21 MR. ELLIOT: The fast breeder program determined 22 that for the fast breeder, which is a much higher 23 temperature than we receive, the incipient point for a l 24 significant amount of void swelling was like 4 times 10 to l l 25 the 22nd neutrons per centimeter squared. That's way out in l [/\
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r l 80 1 the life of this plant. And it's not now, it's many, many,
) '2- imany-years from now before they ever reach that point. So 3 we have time to research this issue.
4- HMR . WESSMAN: Let me add to Barry's comments 5 briefly -- this is Dick Wessman again from the staff -- I 6 think to keep the operational aspects in perspective we need 7 to remember that things like the control rods are subject to 8 ' tech spec testing requirements and the BWRs have a 9 periodicity of moving them in and out, and there are 10- required scram times and this sort of things for them all. 11 And so I-think, you know, if there is an unexpected 12 situation where the rods aren't going to work properly, l 13 we've got enough surveillance history and enough 14- requirements to give this high level of confidence in the () 15 operating reactors. 16 I think I should also point out some of this work 17 by the MRPs is relatively in its infancy in our interaction l 18 with them. I think we've only been really working with them 19 and NEI on several issues for the last year or so. And so, 20 you know, specific work on void swelling may still be some 21 time in the future. But yes, there is work on it, and there 22 is attention being given to it. 23 MR. SIEBER: It would seem to me that for 24 insertion of control rods the dimensions there were related 25 to the thimbles and the fuel and the control rod guide tubes l
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81 1 as opposed to the structure of the internals. So that's () 2 3
. probably not a big issue. On the other hand, an issue that is important is the bolting that holds it all together. But 4 a small dimensional --
5 MR. ELLIOT: That's true. We agree with that 100 6 percent. That was one of the critical locations is about 7 the bolt. That's part of the research program to see that 8 in fact the void swelling and high neutron fluence, how it 9 affects those. 10 MR. SIEBER: And it seemed to me that some bolting 11 has failed in the past for other reasons. On the other 12 hand, the bolting is susceptible to a lot of different " 13 things. This is just another effect on bolting that can 14 cause an early failure. () 15 MR. HISER: Recent inspections at three plants in 16 the U.S. -- Farley, Point Beach, and Ginna -- have in at 17 least two of the cases indicated that some of the 18 baffle-former bolts are totally failed. 19 MR. SIEBER: Yes, that's what I would suspect, as 20 an aging -- 21 MR. HISER: These may be the kinds of precursors 22 that we need to look to. The failure analysis of the bolts 23 it ongoing at Westinghouse, but that's something that we're 24 closely monitoring to see whether it's more IASCC-oriented 25 or if there's some other sort of mechanisms going on. O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
1 82 1 MR. SIEBER: But that investigation has been going () 2 on for years. Is that not correct? MR. HISER: 3 The baffle-former bolts themselves of 4 U.S. plants is -- oh, this is within about the last 12 5 months. But the MRP again has taken over some of that 6 evaluation, and there is more extensive experience in Europe 7 that they are tapping into. 8 DR. BONACA: What MRP? What does it stand for? 9 I'm sorry, I lost -- 10 MR. HISER: Materials Reliability Project. 11 DR. BONACA: And that's sponsored by -- l 12 MR. HISER: I think it's EPRI is I believe maybe 13 the contracting agent for that. Greg may be able to provide 14 a little more specific information. () 15 DR. SHACK: But it's basically for PWRs. 16 MR. ELLIOT: Right. 17 MR. ROBISON: Greg Robinson, Duke. Yes, it is 18 EPRI. EPRI's the contracting agent for that, and it's an 19 attempt by the utilities to pull a variety of materials 20 programs together, the overall intent, so that we don't have 21 materials programs going on in the Westinghouse owners' 22 group, the B&W owners' group, EPRI, other contractors. It's 23 an attempt to put some oversight over all of that and focus 24 on topics so that we can apply industry resources in a 25 focused manner.
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83 1 DR. WALLIS. Is this a potential area for sort of 2 I mean, we have this tremendous ( ) the unforeseen event? 3 emphasis on design basis accidents which are sort of 4 scenarios concocted by various experts. This looks like 5 some situation where the bolts are stressed and then one 6 pops and then something moves which jams A, which then 7 prevents the motion of B, leads to some long thing which 8 eventually becomes serious, which is not in anybody's design 9 basis or previous analysis. Is this that sort of thing with 10 that sort of pote$tial? 11 MR. WESSMAN: Dr. Wallis, Dick Wessman again. I 12 guess let me take a crack at answering that and then perhaps 13 Al can supplement a little bit. 14 I think there's been fairly extensive work going () 15 on in the last several years, and Al referred to the three 16 facilities where there's been inspection of the bolts, and 17 the staff has looked at topical reports and done safety 18 evaluations for the Westinghouse community with various 19 postulated failed bolting patterns, and have determined an 20 allowable quantity of bolts that could fail, and what that 21 would mean, and, well, the plants still satisfy the accident 22 analysis and asymmetric LOCA loads and this sort of thing. 23 And it's a fairly considerable quantity. 24 For example, at a plant like Point Beach or Ginna I 25 there may be 600 or 700 bolts and the analysis can show a i ANN RILEY & ASSOCIATES, LTD. d Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
Y 84 1 pattern of failed bolts of maybe 100 or 200 or something n (G
) 2 like that, a number that's considerably in excess of what 3 has been seen so far from the domestic inspections.
4 Coming a little closer to what we're discussing 5 here today, and that's the Oconee facility, we've also met 6 with the B&W representatives regarding the postulated baffle j 7 bolt issue and failures in the B&W reactors, and they've 8 provided us some information that leads us to believe that 9 the configuration is somewhat different and the situations 10 that were experienced in the foreign reactors or what has 11 been seen at Farley or Ginna are quite unlikely, at least at 12 this time, in the B&W facilities. For example, the fluence 13 is different and some of the materials of construction are 14 different, and the water flow at one of them is upflow and O ( ,) 15 one of them is downflow, and I don't remember which, but 16 some things that contribute to a pretty high confidence 17 level on the B&W plants. 18 They have not dismissed the issue entirely, and I 19 think there is still consideration in planning by the B&W 20 community as their plants get a little older, to make a j 21 decision on whether an inspection is needed. And I think at 22 Calvert the baffle-former plates are welded construction, 23 and so the bolting issue is not relevant there. 24 A1, if you have anything else, go ahead and add ) 25 it. ANN RILEY & ASSOCIATES, LTD. k- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L
85 1 MR. HISER: No, I think the only thing I would add (, s) 2 is that the B&W owners' group, as Dick pointed out, does
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3 have an inspection as part of their program. I'm not sure, 4 I think the timing is a number of years off at this point. 5 DR. BONACA: Okay. And we need to move. We have 6 a little more than 15 minutes left, so -- 7 MR. ELLIOT: Continuing on, the next issue is the 8 Alloy 600 heater sheath-to-sleeve plate and heater 9 sleeve-to-bundle diaphragm plate weld. As part of the Alloy 10 600 program, this was one of the five most susceptible 11 locations to primary stress corrosion cracking. So we want 12 to make sure that they're given an adequate inspection. 13 The next issue is provide an assessment to ensure 14 that the repaired letdown coolers are operating to preclude i l () 1(~% 15 failure from thermal fatigue. 16 The next issue is a CASS stainless steel issue 17 which for Oconee affects valve bodies, pump casings, and the 18 pressurizer spray head, and we're trying to determine based 19 upon the evaluation procedures in EPRI topical report for 20 cast stainless steel whether materials are susceptible or 21 not, whether these components need additional inspection. 22 The next issue is an internals issue, that is, j 23 we're concerned about irradiation-assisted stress corrosion 24 cracking, and look at nonbolting wrought materials in the 25 internals, which is the most limiting, where should we be O
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7 86 1 looking in the future for potential cracking from () 2 irradiation-assisted stress corrosion cracking. 3 The next issue is to provide a plan for managing 4 aging effects of the baffle-former bolts, also an internals 5 issue. 6 The one after that is another internals issue, but 7 this is a synergistic effect of thermal embrittlement and 8 neutron embrittlement, that is, some of these internal 9 components are also cast stainless steel, so they get both 10 the thermal embrittlement, a reduction of fracture 11 toughness, pluo the neutron embrittlement fracture 12 toughness, where these components, how much do these 13 components get as far as reduction in fracture toughness, do 14 we need some more inspection of these components.
) 15 And then the last one is also internals. It's we 16 want to look at the pump and valve in-service test program 17 for the in-valve bodies and returning rings. These have 18 cast stainless steel, and we've got to look at that program 19 to see whether the inspections in this program are adequate 20 for irradiation-assisted stress corrosion cracking and 21 thermal embrittlement.
22 MR. SEBROSKY: That ends the discussion on the 23 three four open items. 24 The next open item that I'd like to talk about is 25 on page 12, and it's the second bullet. It talks about the ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 m
87 l 1 basis for the acceptability of the scope of the reactor 2 coolant pump motor oil collection system inspection. 3 I'll give you some background on what the open l 4 item is, and if you have any questions, we have a reviewer 5 here to hopefully answer that. 6 This open item, the basis for this open item is 7 Duke is saying that they would inspect one of 12 tanks to 4 I 8 characterize the loss of material from corrosion. The 9 reactor coolant pump oil collection system, there are four 10 tanks in each unit, for a total of 12 tanks. And the staff 11 is concerned they would like to have the basis for the one l 12 inspection being bounding for the other 12 tanks. And 13 they're also concerned that the inspection is focused on the 14 carbon steel tank, the collection tank, and there's other 15 materials present within that system. So the second part of I 16 that open item has to deal with how the inspection bounds, 17 what would happen to other materials in that system. 18 So that is the open item the that staff has on the 19 reactor coolant pump oil collection system. 20 DR. BONACA: One question I raised, or we raised i 21 during the subcommittee meeting was regarding the remaining j 22 portion of the collection system which is mounted on the ! 23 reactor coolant pumps and is subjected to significant i 24 vibration. We heard that that was not inspected. Now, I am i 25 surprised about that because the concern would be fire. I ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
88 1 would expect that that system would be inspected as part of () 2 3 the fire protection program. MR. SEBROSKY: Actually, I will turn that -- we 4 understood that the concern was with the mechanical 5 vibration of the system. 6 DR. BONACA: Yes. 7 MR. SEBROSKY: That is not an aging effect that 8 was identified in the application. l 9 And, Greg Robison, hopefully, you can address the 10 concern about mechanical vibration not being identified. I 11 MR. ROBISON: Can I borrow your spot for a second? 12 I thought it would be good to use a schematic, so l l 13 what I have done is pull the schematic from our mechanical l 14 diagrammatics. Highlighted in green are what we term ' () 15 " enclosure boxes" that were installed to capture oil should 16 a line rupture occur. Highlighted in red are flex hoses 17 that isolate those boxes, or those areas, actually from the 18 oil tank you see at the bottom of the figure, so there is a 19 vibration isolator, if you will, between the pump and the 20 oil collection boxes and the tank. 21 The.one line that you do see, the hard line that 22 you do see here is the original installation for oil being 23 drained from the tank, that line is no longer in use and, in I i 24 fact, is valved off inside the tank. So the lines that are ! l 25 in question that could contain oil are isolated in a l O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
I 1 89 1- vibration sense from,the tank and the equipment here. 2 You have to put this in additional perspective, 3 and I really apologize for the shape of this figure, this is 4 a scaled down version of a scaled drawing, and you can put 1 5 those large green boxes in perspective. This is the outline 6 of the pump here. I should have darkened that in. The 7 little small green boxes are actually the collection boxes 8 associated with the' oil. And I have been able to identify, i l 9 although it is straining my eyes to do so, two of the three 10 fle c hoses. You can see where they are located in 11 association with the pump, so that we have actually been l 12 able-to isolate the pump from the oil collection system via i 13 these flex hoses. l 1 14 DR. BONACA: I still have a question. That is, is 15 the system inspected periodically, I mean, or are you l 16 waiting just to see some splashing of oil on surfaces before i 17 you are going to inspect in this system? 18- MR. ROBISON: The aging effects that were 19 identified for the system are being inspected for, and Joe 20 has alluded to the tank inspection. We don't believe there 21 is really any aging going on in the tank. We do know that 22 from a vent valve off the tank here, as you can see on the 23 diagrammatic, there is an opportunity at this vent valve 24 from some spray and decontamination washdown to get into the 25 tank, and we have seen in the tank, some of the tanks, over O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l L
f~ l ! l 90 1 time, water. Although the tanks are lined with an oil film r [dD 2 in the air space, and they are going to full of oil when you 3 drain the oil from the pump, which is done during the 4 refueling outages, the likelihood of any kind of corrosion 1 5 occurring is very low. ) 6 We wanted to make sure that there really were no 7 problems going forward, so in order to assure ourselves, we 8 wanted to do the one time inspection. Beyond that, we 9 didn't identify mechanical vibration as an issue, you know, 10 so we have to kind of separate the two problems here, 11 because, literally, we are going to reach 10 to the 7th, 10 i 12 to the 8th cycles on pump operation within days. So were 13 the lines to be challenged by some sort of high cycle 14 problem with endurance limit challenges, we would have seen
/~')
s, 15 that long ago. ; 16 DR. BONACA: But those hoses, for example, are 17 they being inspected? 18 MR. ROBISON: Oh, yes. Yes, they are. The piping 19 system here and the enclosure boxes are all Class D, which j 20 is part of our scoping criteria there. Seismic-related, 21 require pressure boundary integrity. So the piping system 22 and the tank and the external surfaces certainly get the 23 examinations. 24 DR. BONACA: Okay. I didn't get a sense. I asked 25 the question and I didn't get a sense, and I wanted to hear I ANN RILEY & ASSOCIATES, LTD. (_- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l L
f l-i I 91 1 that. 2 MR. ROBISON: Okay. 3 MR. GRIMES: ~l Dr. Bonaca, I would like to point out ) 4 that we have -- you know, for the sake of trying to i 5 accomplish our conclusion relative to aging management l ! 6 programs, we have concentrated primarily on looking at 7 particular aging effects and then a series of inspections or 8 other programs that would look particularly for those aging i i 9 effects. 10 We haven't really delved into the details about 11 the extent to which there are normal plant walkdowns and 12 inspection activities that check for configuration and 13 conforming conditions. 14 DR. BONACA: Yes, I understand. () 15 MR. GRIMES: And so there are a lot of things that 16 we might not be aware of that occur and aren't credited or 17 aren't focused enough to look at, you know, how the current 18 licensing basis is reflected in an operability sense. 19 DR. BONACA: But the reason why this issue came up j l 20 was because I am less concerned about corrosion in the tanks 21 and the consequences of it than I am about vibration of a 22 system which is mounted on the pump, that may fail and cause 23 fire, because these events have occurred before. Now, all I 24 wanted to hear is that, in fact, these programs exist, 25 because I was surprised to hear at a subcommittee meeting O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
92 1 they didn't exist. And that is why I asked that que" tion () 2 and-that was the reason for it. 3 MR. GRIMES: No, and I understand that. You know, 4 if we had pursued a concern about vibration as a potential 5 aging effect, it could have been addressed that way, but we 6 didn't delve into that area. 7 DR. BONACA: Okay. Thank you. 8 MR. SEBROSKY: The next open item I would like to. 9 go to is on page 14 of your handouts, and it is GSI-190, it 10 is represented by the third bullet on page 14. And the open 11 item is the time-limited aging analysis of the reactor i, 12 coolant system is not adequate to address fatigue concerns f 13 for operation beyond 40 years. 14 In the SER the staff gave Duke one of three 15 options to address this open item, and the three options 16 that we gave them were to develop an aging management 17 program that incorporates a plant-specific resolution. So, 18 in other words, come up with a plant-specific resolution for 19 GSI-190. The second option was provide a technical 20 rationale for the staff on why it could be deferred. And 21 the last option is to adopt a GSI-190 resolution when it 22 becomes available. 23 And we had a meeting with Duke on August 25th, and 24 in that meeting, Duke basically gave us Option Number 2. 25 They gave us a technical rationale for why they think it ANN RILEY & ASSOCIATES, LTD. O. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
ll 93 1 could be deferred. And what the staff said at that meeting () 2 3 was that there is some. regulatory uncertainty associated with that option. If they had given us a plant-specific 4 resolution for GSI-190 and had done additional analysis, 5 that the staff would write off on that, and GSI-190 would 6 not be revisited at Duke. 7 What Duke said -- we had some feedback back and 8 forth. What Duke said is they would consider what the staff 9 told them at the August 25th meeting and then tell us by 10 October 15th what option they intend to pursue. 11- I will turn it over to you, John, if you want to 12 add anything. 13 MR. FAIR: No, there is no more need to add to 14 that, unless you have some questions. 15 [No response.] 16 MR. SEBROSKY: Now, out of the open items and 17 confirmatory items, that was the last issue that I had as 18 far as being highlighted. 19 DR. BONACA: I would like to ask just one more 20 issue that was raised was the issue of fuses, and the fact 21 that the staff agreed with the applicant and the NEI 22 position that they should be considered active components 23 and, therefore, excluded from the scope. However, the staff 2:4 still expressed concern about potential malfunctions of 25 fuses and their intent to pursue it potentially as a Generic O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i .
94 1 Safety Issue. I would like just to hear more about that. (m) v 2 MR. GRIMES: In particular, what more would you 3 like to hear? We pursued it from the standpoint of -- we 4 wrestled long and hard with this issue, much like we are 5 still wrestling with the issue of complex assemblies. What 6 is the right borderline for declaring a component that needs l 7 to be subjected to an aging management review? 8 And we looked at fuses long and hard and concluded 9 that it was hard for us to take the fuse out as a component 10 by itself and say here is a component for which we need to 11 identify aging effects and establish an aging management 12 program. And so we relied on the language in the rule that 13 talks about components that perform their functions with a 14 change of state. But deep in our hearts, it was more a l
) 15 matter of a fuse is a part of a circuit.
16 DR. BONACA: Sure. 17 MR. GRIMES: Which is, you know, more like a piece 18 part. But we do recognize that, while we haven't seen any 19 experience that fuses age and therefore are affected -- and 20 their intended function is affected by particular aging 21 effects, it seems like an area where that might warrant some 22 more research, and so we are going to -- we know that there 23 are industry initiatives that are developing now. There are 24 manufacturer recommendations on, you know, how fuses should 25 be treated in terms of age. So we would like to sort of see 1 l O
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95 1 those things come together, but we didn't view that as a () 2 necessary part of a conclusion for license renewal. 3 DR. BONACA: Yes, the reason for my bringing it up j 4 is that, first of all,'I mean it should be excluded from the 5 rule, it should be excluded because it is not a concern and i 6 not because it is active or passive. Now, I agree that if 7 it is in fact determined to be active, then it has to be 8 addressed in a generic sense, and GSI may be the case. I 9 wasn't surprised that this issue would come up for the first 10 time, at least from my perspective, at this time, and that 11 the issue has not come up yet in this industry, because I 12 mean plants are aging anyway, even within the 40 year life 13 they are licensed to operate today. And if there was, you 14 know, more information on this issue than anything else, I 15 think that would be valuable. 16 MR. PRATO: My name is Bob Prato, I work in 17 License Renewal and I had a hand in developing that l 18 position. The reason it hasn't come up before is because i 19 there is no operating history, and we were just looking from
- 20- a theoretical approach, whether or not that this was a 21 feasible failure mode. As a result, we initiated a generic 22 safety -- we put the issue into a generic safety process and
, 23 we asked Research to take a look at it. Okay. 24 The reason it hasn't come up is because it is not, 25 in our minds, a credible failure mode, but we just wanted to ANN RILEY & ASSOCIATES, LTD. , Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
I 96 1 be thorough and make sure that we covered all bases. ( '(,\ 2 MR. GRIMES: Okay. As Bob pointed out, we put a w)
- 3 lot of attention in this as we started to go through and try 4 and categorize electrical components.
l There is no operating l 5 experience that suggests that there is a credible aging l 6 mechanism here that warrants an aging management. But there 7 is intuitively a thought that there are probably aging 8 effects that would apply to the materials. There are l 9 practice issues that IEEE and the fuse manufacturers are 10 kicking around. And so it is something that we didn't 11 dismiss lightly, but at the same time we made a conclusion 12 that nor is there anything that we could point to right now 13 that justifies having to impose a particular requirement for 14 fuses.
) 15 DR. BONACA: Okay. Thank you.
16 MR. GRIMES: And Jose or Paula, do you want to add l 17 anything to that? 18 MR. CALVO: No , I think it has been covered very 19 well. 20 MR. GRIMES: Jose said I covered it very well. 21 Thank you, Jose. 22 DR. BONACA: With that, I understand the 23 presentation is completed. I would like to ask the members , 1 24 if they have any additional questions for the presenters. 25 [No response.] ! [ ANN FlLEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 l (202) 842-0034 1 L
97 1 DR. BONACA: There are none, so I would like to () 2 3 thank the presenters for very information presentations, and the applicant, too. And with that, I will pass it on to 4 you, Chairman. 5 MR. MATTHEWS: Dr. Bonaca. 6 DR. BONACA: Yes. 7 MR. MATTHEWS: Hi, I am David Matthews, the 8 Director of Regulatory Improvement Programs for the NRR 9 staff. I wanted to see if Greg did have any concluding 10 remarks, and if he didn't, I had a couple. Is it j l 11 appropriate to offer those at this time? l 12 DR. POWERS: Yes. j 13 MR. MATTHEWS: I just wanted to indicate with 14 regard to outcomes, which were discussed earlier today, () 15 there is an overriding outcome that the staff is driving 16 towards with regard to this process. And in regard to our 17 evaluation of methods or methodologies and individual 18 programs, we are striving towards outcomes that primarily 19 relate to four areas. And, obviously, the overriding 20 outcome that we are looking towards is one that will j 21 maintain safety through the period of extended operations. 22 You know, the findings that we make in the safety area are 23 outlined in detail in the regulations, but, in general, it l 24 is just that, that we maintain safety and have reasonable 25 assurance that safety will be maintained through the period O ANN RILEY & ASSOCIATES, LTD. k-m Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 ( Washington, D.C. 20036 (202) 842-0034
98 1 of extended operation. i 2 We want to do this'in such a way that there is 3 public confidence in the process for us to establish that.
'4 And, as you know, we had a discussion in the past with 5 regard to the amount of credit to be given for existing 6 programs, and one of the drivers towards the staff's view on t
l
-7 that i.ssue was this issue of ensuring that there was public 8 confidence in the staff's process for reaching that 9 conclusion that there was reasonable assurance that we would 10 maintain safety through this process.
11 You know part and parcel as we proceed in this new ) 12 arena, of course, is that we want to reduce unnecessary 13 regulatory burden when reaching our conclusions in this 14 regard. So we want to strive to perform this licensing 15 . action in an efficient and effective manner, and I wanted to 16 thank the Subcommittee and the full Committee for their l l 17 efforts in looking at how we're going about that because I l l 18 think you have, as well, the desire that we do this in an l 19 efficient and effective manner in the hopes that we'll 20 continue to improve that for subsequent applicants. So I 21 think this interaction's been very beneficial. l 22 My expectations are primarily, as I understand it, 23 that an interim letter will be generated with the hope that 24 in the February timeframe, we'll be able to come back to you 25 following the publication of the final SER and address these i O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L
i j 99 1 open and confirmatory items that we described in summary 2 detail, .and a few in some depth, leading of course to a l 3 final letter that will permit timely issuance of the 4 recommendation of the Commission. So with that, again, 5 thank you for your efforts. 6 MR. GRIMES: I'd like to clarify one point. We 7 haven't talked yet about the logistic detail about the 8 timing of a conclusion from the ACRS and publication of a 9 final. safety evaluation. And I would expect that Dr. Bonaca 10 and I could work that out in'a way that you can conclude 11 your review at about the same time we conclude the safety
-12 evaluation, try and time that, you know, optimally.
13 MR. BONACA: Yeah, I don't see any trouble with 14 that. In fact, I think that would be desirable that we are
-15 informed of your progress, and then we're not, you know, 16 faced with a long review after that. So that, I agree with 17 it. I think the meeting we have scheduled for September 23 18 should be a good step in the direction of setting up some 19 process. Yeah. And with that, we intend to write an 20 interim letter this week. I 21 MR. GRIMES: Thank you. i 22 DR. BONACA: Thank you. l 23 DR. APOSTOLAKIS: Thank you, gentlemen. We'11 24 recess until ten minutes past 12.
25 [ Recess.) ANN RILEY & ASSOCIATES, LTD. l Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
100 1 DR. APOSTOLAKIS: The next issue is the proposed () 2 3 resolution of generic safety issue 145, Actions to Reduce Common Cause Failures. I'm the cognizant member, so I'm 4 turning it over to me. And I believe Mr. Rossi has some 5 opening remarks. 6 MR. ROSSI: Yes. I'm the director of the Division 7 of Systems Analysis and Regulatory Effectiveness in the 8 Office of Research. And I just wanted to make a few 9 comments before Harold VanderMullen goes through his 10 presentation. 11 I would urge you to focus on - as he goes through 12 the presentation - on whether the NRC and licensees 13 currently have sufficient robust processes in place to look 14 for and address common cause failures, because that's the (' ,/ 15 important safety issue associated with this generic safety 16 issue. 17 And then also, consider whether additional generic 18 requirements are needed of licensees and if so, as you know, 19 those would have to meet the test of being a substantial 20 increase in the overall protection of public health and 21 safety, and also the cost would need to be justified by the 22 increased safety that's obtained. 23 I want to point out that the NRC has a systematic 24 process. We're looking for accidence sequence precursor 25 events, and part of that process, they can identify where I' ANN RILEY & ASSOCIATES, LTD.
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1 101 1 common cause failures have been a significant contributor to n (G ) 2 risk-significant events, The NRC also has a systematic 3 process for maintaining a common-cause failure database, 4 which I know has been discussed with the ACRS on a number of 5 occasions. Now, that systematic process includes a review 6 of all the licensee event reports and a review of the IMPO 7 equipment performance and information exchange system, as ! 8 well as other sources that mig.',t indicate where we have seen 9 or experienced common-cause failures. ; i 10 It should be noted also that our risk-based 11 analyses of operating experience, which I know you've been 12 briefed on also, is showing that the risk from common cause 13 failures is generally consistent with that shown in 14 licensees' individual plan examinations. () 15 Licensees have, over the past few years, become 16 sensitized to common cause failure issues, and they have 17 been given the common-cause failure database and supporting 18 reports for their use. And finally, the NRC's overall 19 process for review of operating experience addresses generic 20 common cause failures in accordance with their risk, as they 21 are found, and also generic insights related to common cause 22 failures will be a part of the risk-informed inspection 23 process. So I wanted to make those few comments, and now I 24 will turn things over to Harold to make a presentation on 25 closure of this issue. /'~h ANN RILEY & ASSOCIATES, LTD. (s- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
102 1 l MR. VANDERMOLEN: Thank you, Ernie. l
~3 i
; 2 My name, as some of you know, is Harold !
3 VanderMolen. I'm in the Generic Issues Team in the 4 Regulatory Effectiveness Assessment and Human Factors Branch 5 of the Division of Systems Analysis and Regulatory 6 Effectiveness in the Office of Research. We're here to talk l 7 about Generic Issue 145. The title of the issue is " Actions 8 to Reduce Common Cause Failures". This issue goes back a 9 long way, and the title is fairly obvious, is wide-open. I 10 It's important to go over some of the historical 11 context and scope of this issue to really understand what it 12 is. We'll take a look at - i 13 DR. APOSTOLAKIS: Are your slides - 14 MR. VANDERMOLEN: Slide 2. O ( ,) 15 DR. APOSTOLAKIS: Is the projector out of focus, 16 or is this deliberate? 17 (Laughter . ] 18 DR. APOSTOLAKIS: It's not a focus problem. 1 19 DR. SHACK: No, I don't think that's a focused ' 20 problem. 21 MR. VANDERMOLEN: No , we're recycling everything 22 around here; I think they're using recycled material in our 23 slides now. ! i 24 [ Laughter.) 25 MR. VANDERMOLEN: I didn't realize that until it O ANN RILEY & ASSOCIATES, LTD. (ms Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 ( (202) 842-0034
103 1 tore loose from the paper. It's it readable from back () i 2 there? 3 DR. APOSTOLAKIS: We have a hard copy here. 4 That's all right. 5 MR. VANDERMOLEN: Generic Issue 145 actually 6 originated in the Agency's response to Davis-Bessey loss of 7 all feedwater event back in 1985. This is one of 37 issues 8 that came directly out of the - well, it's one of 37 issues 9 that came directly from the event. Some of those issues in 10 turn generated daughter- and granddaughter issues. So 11 there's quite a few issues generated - 12 DR. APOSTOLAKIS: What, what happened to 13 Davis-Bessey? Is that the one where the operators were 14 caught not being alert? () 15 MR. VANDERMOLEN: No. This was a loss of all 16 feedwater event. The steam generators actually dried out. 17 DR. APOSTOLAKIS: So it was a common cause 18 failure? 19 MR. VANDERMOLEN: At the time, it was - things 20 were pretty active around here. It was not that long after 21 Three-Mile Island, so there was a lot of attention paid to 22 it. The plant obviously - the core was saved, but 23 nevertheless a lot of issues were started. You learn as i 24 much from the event as possible, l 25 DR. UHRIG: How long were they out? O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r 104 1 MR. VANDERMOLEN: That, I don't know. () 2 3 DR. UHRIG: I mean, how long was the plant -- MR. VANDERMOLEN: Was it down, you mean? 4 MR. ROSSI: I don't recall, but they lost the 5 turbine-driven auxiliary feedwater pumps for a number of 6 reasons. And then they went down, they had a motor-driven 7 non safety-related one that was down in the bowels of the 8 plant some place in a blocked room. And they went down and 9 got that started. But the whole thing progressed quite, 10 quite rapidly. It was like within 15 minutes to a 11 half-hour, as I recall - and again, this was a long time 12 ago, so, so that's my recollection. 13 DR. UHRIG: Fourteen years. The B&W plants have a 14 Jess, lower volume of water than the others. O) q, 15 MR. ROSSI: That's right. 16 DR. UHRIG: Do you remember - 17 MR. ROSSI: I don't remember, remember the details 18 of -- 19 DR. UHRIG: It would happen within a reasonable 20 time. 21 MR. ROSSI: Well, yeah - they recovered within -- 22 DR. UHRIG: Thirty minutes? 23 MR. ROSSI: Yeah, probably faster than that. But 24 again, I don't remember all the details. I happened to be 25 the leader of the first Incident Investigation Team, which ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
105 1 was associated with that event, but I still don't remember f~) G 2 all the details without going back and reviewing them. But 3 things progressed very rapidly and the operators did a lot 4 of things based on their knowledge of the plant, to obtain 5 stable plants conditions. 6 MR. VANDERMOLEN: Well, there were a number of 7 things that happened in that incident that involved common 8 cause failures, which is why it was such a matter of 9 interest at the time. l 10 Generic Issue 145 was one of them. It was a 11 general issue intended to cover the overall scope of common l 12 cause failures. I'm going to discuss the scope of it in 13 more detail in a moment. I did want to point out that there 14 were specific common cause failures with significant safety r~% ( ) 15 implications. These were not treated as part of Generic 16 Issue 145. They were, some of them became separate generic 17 issues. l 18 DR. WALLIS: Excuse me. GI-145 was born in 1965? l l 19 MR. VANDERMOLEN: Approximately then, yes. 20 DR. WALLIS: And it's now ready for high school or 21 college? 22 MR. VANDERMOLEN: At this age, it would be just l 23 about -- 24 DR. WALLIS: College? 25 MR. VANDERMOLEN: A very brilliant issue would be i ANN RILEY & ASSOCIATES, LTD. (~'/ (ms Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
{ 3 106 1 ready for college at this point, I would think. It's got 37 2 of its immediate family. 3 DR. APOSTOLAKIS: The issue was not created 4 immediately. I mean -- 5 MR. VANDERMOLEN: No. 6 DR. APOSTOLAKIS: Yes, but I didn't mean to 7 ' speculate on the thought behind the question. This may not 1 8 be the best issue to point to the age of the issue because 9 of what would be described now as a major research effort 10 into common cause, which has ramifications in the PRA 11 technology of major impacts. So, where some.of the GSIs are 12 a bit horrific for reasons that you don't understand quite, 13 this is not the one I would tag with that, tar with that I 14 brush right now. 15 MR. VANDERMOLEN: No , I'would agree with that, 16 certainly. 17 Going out a bit, a few others that came out of 18- that incident, these are just examples -- this is not 19 intended to be a comprehensive list. There's Generic Issue 20 125.I.5; it's title is " Safety Systems Tested in All
)
21 Conditions Required by DBA [ Design Basis Accidents] " . I 22 Generic Issue A-17; that one actually dates back to 1978. 23 It predates this issue by quite a margin - system i 24 interactions. Generic Issue 123, which was looking for any 25 deficiencies in our regulations governing the design basis l . ANN RILEY & ASSOCIATES, LTD. O Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
107 1 accidents. The' reason I mention these is, you really do () 2 3
.have to keep track of the scope of these issues. There are a lot of them that are inter-related.
4 Still other things related to, and significant to, 5 common cause failures - and these are just a plethora of l 6 things that have happened over the years in the Agency. 7 These again, I'm going from the Davis-Bessey incident now, 8 to the - , l ! 9 DR. APOSTOLAKIS: Excuse me, Harold. Excuse me. 10 Have these other issues been resolved? 11 MR. VANDERMOLEN: Yes. 12 DR. APOSTOLAKIS: All three of them? 13 MR. VANDERMOLEN: All three of them. 14 DR. APOST3LAKIS: Okay. O ( ,/ 15 MR. VANDERMOLEN: I can give you some details on
]
16 them, if you like. 17 DR. APOSTOLAKIS: No, that's fine. l l 18 MR. VANDERMOLEN: Other things the Agency has done l 19 or is doing relevant to common cause failures include the 20 IPE program - more about that in a moment. This, again, is 21 not an exhaustive list. These are just a few examples. The 22 station blackout efforts, which require an alternate AC 23 supply; our work on Atlas, which in essence required a 24 diverse way of getting the reactor to shut down. A number 1 25 of generic issues and information notices, as Ernie 1 i ANN RILEY & ASSOCIATES, LTD. I O Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 (202)- 842-0034 l I
108 1 mentioned a moment ago, on specific CCF mechanisms as they () 2 were identified. And finally, a rather major program in 3 the, I guess the former AEOD, developing a CCF database and 4 methods. 5 Now let's get back to Generic Issue 145 - 6 DR. APOSTOLAKIS: Now, the methods are not really 7 part of the resolution, are they? I mean, the methods are 8 really to support PRA? 9 MR. VANDERMOLEN: The methods actually are part of 10 the resolution. I'd like to hold off on that question just 11 for a moment to describe why I say that. 12 DR. APOSTOLAKIS: Okay. 13 MR. VANDERMOLEN: The reason I say that it's 14 important to talk about the scope of these issues is, as we
/
(,)T 15 saw a moment ago, we have a lot of generic issues. It's 16 very important that we do not duplicate efforts; we can't 17 afford it. It's even more important that we don't have gaps 1 18 between our issues and have a safety problem fall in the j i 19 gap. Finally, whenever you have any of these programs -- i 20 these are not intended to be open-ended; they are specific 21 jobs we have to get done. That is, it's just good 22 management practice that when you start something like this, 23 you have a destination in mind and have some way of knowing 24 when you're, when you've arrived there. ! 25 Fortunately or unfortunately, the early l ANN RILEY & ASSOCIATES, LTD. [~}
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1 109 1 documentation for Generic Issue 145 did not include a 2 specific description of its scope. [Vl What the early writers 3 did instead was they suggested four potential solutions. 4 These solutions are not intended to be alternative 5 solutions, but as all four of them were considered and had 6 it been justified, more than one of them could have been 7 pursued. These four together define the actually scope of 8 the issue as we carry it on our books. 9 The first area of Generic Issue 145 was to request 10 licensees to perform a systematic evaluation of common cause 11 failures based on their IPEs; now, this predates the IPE 12 program. In this possible action, we would request 13 licensees to -- evidently, you do importance measure on any 14 identified CCFs and look at them more carefully. () 15 The second bullet -- 16 DR. APOSTOLAKIS: Well, thay have done now the 17 IPEs. 18 MR. VANDERMOLEN: Yes. I'd like to describe that 19 on the next line. 20 DR. APOSTOLAKIS: All right. The second time you 21 do this to me, Harold. 22 (Laughter.] 23 MR. VANDERMOLEN: As long as I don't think -- 24 DR. APOSTOLAKIS: -- price list. 25 MR. VANDERMOLEN: -- the credit card will come. C' \ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l 1 110 1 DR. APOSTOLAKIS: Now, the second bullet, it's
/ / 2 data or dates?
U 3 MR. VANDERMOLEN: Well, it actually is -- 4 DR. APOSTOLAKIS: Rates? 5 MR. VANDERMOLEN: Dates. 6 DR. APOSTOLAKIS: Dates? 7 MR. VANDERMOLEN: The idea of the statistical 8 analysis, it's simple in principle. The mathematics can be 9 a little complicated depending on whether you're using a 10 shock or a non-shock model. But the idea here is that 11 you're having single failures all the time, just random 12 failures. At a certain rate, you expect to find multiple 13 failures by random chance. Two things may happen 14 " simultaneously." " Simultaneously" has to be defined a O( ,f 15 little bit more carefully when you're actually doing this. 16 If you observe multiple failures more frequently 17 than you would expect for the single failure rate, the 18 difference is presumably the fraction that comes from common 19 cause failures. To do this, you would look at the dates of 20 failures -- this is actually written up in the old 21 literature. I stumbled over that term a little bit myself. 22 One more slide. 23 The third bullet -- a suggestion was made that we 24 perform a detailed review of the most important systems. To 25 elaborate on this a little bit, the intent of this was to ANN RILEY & ASSOCIATES, LTD. k Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034
111 1 actually have licensees pick out the most important systems [} N/ 2 based on their PRA or IPE or whatever. Someone would have { 3 to then walk the system down looking for any possible common ) 4 cause failures, and address them. And here at the Staff we l 5 would have to review the whole effort. This is quite a l I 6 program, obviously. 7 The fourth suggested program from Generic Issue 8 145 was to simply develop methods and data to go with them 9 for everyone to use, basically a large research program. 10 This is why I say that, yes, the methods development was 11 also included as part of the resolution issue. Now, let's 12 go on to that next slide that we promised Dr. Apostolakis. 13 We're going to discuss each one of these in a little bit 14 more detail, and this time I will not go on to the next es ( ,) 15 slide; I will stop and answer questions. 16 When the IPE made systematic evaluation of CCFs, 17 we did indeed request licensees to consider common cause 18 failures when they did their calculations. We did review 19 it, too. There have been discussions with licensees where 20 we felt that they were using beta factors that were too 21 small. Common cause failures were treated, however, just as 22 any potential vulnerability. There was not a special effort 23 on CCFs as part of that program. Of course, now the program 24 is history. There are still discussions about it, but we 25 are not at the beginning point of it any longer. l [ ANN RILEY & ASSOCIATES, LTD. . (~ Court Reporters I 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l 112 1 DR. APOSTOLAKIS: Does the -- I don't remember
~D
[d 2 3 now, but does the insights report identify the treatment of common cause failures as something that we not, that was 4 less than perfect? 5 MR. VANDERMOLEN: I'd like to ask Dr. Flack to 6 address that one, because he was involved in that program. 7 He had the misfortune of sitting where I could see him. 8 DR. FLACK: John Flack, Office of Research. there 9 was -- the report itself, I'm not, it's kind of in the back 10 of my memory. But there were instances with certain 11 methodologies and treatment of common cause failure that did 12 show optimistic use of beta factors and multiple Greek 13 letters. Now those were pursued as part of the review 14 process. These licensees were brought to task to justify 'O( ,) 15 and defend those positions, and in some cases they had in l 16 fact came back with revised IPEs, which were more consistent 17 with the bulk of them. So, as part of the process, yes 18 there were bumps and problems, but they were kind of worked 19 out as part of that process. And we, at the end, when l 20 everything was said and done, there wasn't anything really l l 21 outstanding that we felt needed correction or raised a 22 potential backfit concern. 23 MR. VANDERMOLEN: Any other questions? 24 DR. APOSTOLAKIS: Were they, did they confirm the 25 finding, did the IPEs confirm the finding that common cause ( ANN RILEY & ASSOCIATES, LTD. A Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l 113 1 failures are an important contributor to system () 2 vulnerability? 3 DR. FLACK: Confirmation-wise, I would say, in 4 retrospect, it would be consistent with that position, that 5 common cause failures drive risk at plants. I think you'll 6' end up at that point when the independent failure rates 7 become a smaller contributor and you get the point where 8 common cause failures then begin to stick out, but it 9 becomes very plant-specific. It depends both on the 10 analysis and the design of the plant. 11 DR. APOSTOLAKIS: But they don't derive the risk l 12 though, John. Maybe they are contributing to the 13 unavailability. But I remember a few lists of important 14 contributors to core damage frequency, and I don't remember () 15 common cause failures. I mean, you see things like l 16 non-recovery of offsite power within 50 minutes, or you 17 know, loss of diesel. I'm not sure they are major 18 contributors to risk. But system unavailability -- I 19 believe, yeah, that's probably true in most cases because of 20 the redundance. You've got your square, the round failure l 21 rates from random events, so they go down very quickly. l l 22 DR. FLACK: Yes, yes. Right. 23 MR. VANDERMOLEN: And the second possible program 24 and statistical analysis, it was just judged to be 25 impractical. To do that sort of analysis you have to have a ! l O, ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i l
114 1- lot of data and get the. error bands low, because you're () 2 3'
.taking the difference between two numbers that have wide uncertainty bands. And in addition, with the advent of the 4 maintenance rule, we're really asking for rcot cause 5 analysis on these things anyway, which we all believe, I 6 think, would be a better way of identifying specific means 7 of common cause failures; there's a lot more information 8 there.
9 DR. WALLIS: Well, it's not impractical; 1J statistical analysis is easy. It's just a question of 11 whether your data justified a conclusion. I don't know that 12 until you've done the analysis. If all the events turned 13 out to be common cause, this would show up pretty clearly. 14 MR. VANDERMOLEN: Oh, definitely. I mean, in () 15 principle it's, it's mathematics -- 16 DR. WALLIS: -- data, which is perfectly data 17 which is perfectly suitable for statistical analysis. Until 18 you do it, you don't know. 19 DR. APOSTOLAKIS: I think what happens here is 20 that most of the relevant information comes from common 21 cause failures that were not completed, potential common 22 cause failures. In other words, they look at one element of 23 a redundant system and they identify a cause -- maybe it has 24 failed already. And then they find that the same cause has 25 been active in the other redundant elements, but they have O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l 115 1 not failed yet. () 2 3: the -- DR. WALLIS: Yeah, but his method would identify
- 4. DR. APOSTOLAKIS: The complete cause.
5 DR. WALLIS: -- complete cause, without knowing 6 what the cause was. 7 DR. APOSTOLAKIS: That's right. And for those, 8 you can -- 9 DR. WALLIS: There's a correlation between -- 10 DR. APOSTOLAKIS: And for those -- 11 DR. WALLIS: That would be very useful.
.12 DR. APOSTOLAKIS: But the statistical basis for l
13 this analysis is -- I mean, statistical data are very poor 14 for that. 15 DR. WALLIS: Well, that's true, but you'd have to,
- 16 well, I'm just saying it's impractical.
17 MR. VANDERMOLEN: We really don't have that data. 18 DR. APOSTOLAKIS: Well, there are some. There are l 19 some, but -- 20 MR. VANDERMOLEN: There are some. 21 DR. WALLIS: But it's so easy to do, but it's not 22 impractical. It's just that whoever tried to do it l l 23 presumably found there wasn't enough data. I hope that's 24 it, rather than just discarding it without any thought. : i 25 MR. VANDERMOLEN: Yes. No , it's not discarded l O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l l Washington, D.C. 20036 (202) 842-0034
s 116 1 without any thought. I can assure you of that. j'% i 2 ( ) The third potential program to perform a detailed 3 review, which would be guite extensive, expensive, and a bit 4 intrusive, we do not feel is justified under our current 5 regulatory analysis guidelines. To require that of 6 licensees, we would have to make a, come to a valid finding i 7 quantitatively that there is a problem that we are likely to 8 find. l 9 DR. WALLIS: If you can't find common cause i 1 l 10 failures by looking at statistical analyses of all the l 11 plants, because there's insufficient data, it's highly l 12 unlikely that one plant's gonna find sufficient data or any 13 conclusions either. i 14 MR. VANDERMOLEN: Probably not. You know, it's l () 15 just -- 1 16 DR. WALLIS: So it's a very peculiar plan. 17 MR. VANDERMOLEN: We would hope that they would 18 not have that much data. 19 DR. APOSTOLAKIS: It also depends very much on 20 what, how you define it, because as Harold says, 21 simultaneous occurrence -- I mean, what does " simultaneous" 22 mean? 23 MR. BARTON: They tried to find that NUREG -- 24 DR. APOSTOLAKIS: It has to be some time interval 25 between the failures. Maybe we could use 50-59 terminology. T ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
~ l l 117 1 It should be minimal but not negligent. () 2 3 that term. MR. BARTON: I think the NUREG attempts to define It does talk about what is -- l 4 DR. APOSTOLAKIS: Yeah, but they are not really i 5 simultaneous failure now, f l 6 MR. BARTON: No. 7 DR. APOSTOLAKIS: So the question is now what kind 8 of time interval do you -- 9 DR. WALLIS: Does this exclude common cause l 10 failures caused by operations? TMI could be called a common l l 11 cause failure as the result of several operator -- 12 MR. BARTON: It does not exclude human 13 performance. Human performance is -- 14 DR. WALLIS: That's hard to say that the common
) 15 cause is that the operator's responded inadequately. Is 16 that a common cause failure? I 17 MR. BARTON: No. It's --
18 DR. WALLIS: It's the same person doing it, but 19 it's not quite the same thing as common cause. 20 DR. APOSTOLAKIS: No. 21 MR. VANDERMOLEN: I think the analysis, if you 22 just looked at data -- 23 DR. APOSTOLAKIS: The right perspective here is 24 the following: We are doing systems analysis; we're doing I 25 the PRAs, we have identified certain classes of failures O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
118 1 that we model explicitly -- earthquakes are a major cause of () 2 dependence. Then we're asking ourselves, we have this 3 redundant system; we've done the best we could with the . i 4 kinds of things we've identified, like the operators 5 forgetting to reopen a valve and so on. But we know from 6 experience that there are many other things that can happen 7 that can cause to loss of redundancy and we are not modeling 8 them explicitly. 9 So we'll define this new class of failures, which 10 we'll call common cause failures, that we'll try to put a 11 number on. So essentially what we're trying to do here is, 12 we're trying to put a lower bound on the unavailability of 13 the system, because if you go with the traditional methods, 14 the more redundant elements you add, the lower the () 15 unavailability, then we know that's not true. So that's the 16 right perspective, I think, for this. 17 It's not -- I mean dependent failures in PRAs are 18 handled in many different ways; this is just one small part 19 of it. It's the causes that are not treated explicitly. l , 20 They are treated as a class. Something will happen that l 21 will lead to loss of redundancy that I have not modeled , 22 explicitly. That can be environmental causes or maybe human l 23 error -- though there now, there's a problem because we are l 24 modeling human errors separately. 25 DR. WALLIS: But they're not independent. I mean, O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 (202) 842-0034 t _
F 119 ( 1 the same person who fails to open some valve during 2 maintenance may fail to open another valve at the same time. 3 DR. APOSTOLAKIS: That's right, and that's, that's 4 more the explicitly, so it's not part of this class. If 5 it's modeled -- like fives, they're model-explicit so l 6 they're not part of this. However, humidity is not modeled 7 explicitly. ! 8 MR. VANDERMOLEN: No, that definitely is not. 9 DR. APOSTOLAKIS: So it may be part of this. 10 MR. VANDERMOLEN: Right. 11 DR. APOSTOLAKIS: But deciding what is part of the 12 class is sometimes a subjective call. But I think that's 13 the right perspective. I mean, it would be really l 14 misleading to think that dependent failures in PRA are 15 handled this way; I mean, there are many other things we do l 16 in PRA to handle dependencies, like systems interactions 17 that you mentioned -- l 18 MR. VANDERMOLEN: Right. Right. 19 DR. APOSTOLAKIS: Fires, earthquakes, and all the 20 human errors. So this that other class. 21 MR. VANDERMOLEN: The others are modeled 22 intentionally and explicitly. 23 DR. APOSTOLAKIS: Yes, exactly. If you're 1 24 modeling it explicitly, it's not here. It's not here. 25 MR. VANDERMOLEN: Right. O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
120 1 MR. SIEBER: It seems to me though that common () 2 cause failures are generated during plant events, as opposed 3 to random occurrences from day to day. For example, 4 Davis-Bessey, as I recall, had a number of MOV failures. 5 MR.-VANDERMOLEN: Yes. 6 MR. SIEBER: Surry, when they-had the pipe rupture 7 and the fire system went off, caused a lot of electrical 8 problems. We had one at our plant where both diesels failed 9 to load because there was a design defect in the cystem. 10 MR. VANDERMOLEN: Yes. 11 MR. SIEBER: You can pick those out when you do 12 your post-trip analysis as to, you know, I've got four or 13 five of these things that have failed in this particular 14 event, and that immediately triggers you into some kind of () 15 common cause investigation. That seldom goes to a database, 16 unless it goes through INPO, or an information notice, where 17 everybcdy else will know that there's a susceptibility for 18 this kind of compound. 19 MR. BARTON: Except if it ends up in an LER, then 20 it ends up documented that way. 21 MR. SIEBER: Right. 22 MR. BARTON: That's sort of -- 23 DR. APOSTOLAKIS: And that creates another problem 24 for the analyst here, because typically when a utility, a 25 you just said, Jack, identifies a cause -- I mean, it's not l O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034 i
121 1 a class now; it's a specific cause. It said the diesels () 2 3 failed because of.this. They take some corrective action. So the problem now is, is it legitimate then to take that 4 failure and put it in the database since corrective action 5 has been taken? And the question is, how much of that is a 6 failure -- 7 [ Laughter.] 8 MR. SIEBER: That's right. 9 DR. APOSTOLAKIS: And the assumption is -- I mean, 10 most of the time, people do put it in the database, and they 11 say, in another plant maybe they didn't take this action. 12 MR. VANDERMOLEN: That's right. 13 DR. APOSTOLAKIS: The original argument of the NRC 14 staff when they came back to the ATWS issue, was that the
) 15 actual cause really is not relevant, but what we saw was the 16 manifestation or a realization of a failure due to this 17 other class. Next time something else will happen, so we 18 should include it.
19 MR. SIEBER: Right. 20 DR. APOSTOLAKIS: But it is a little conservative 21 to do that. I mean, there was a fire in five cabinets -- 22 there were five fires due to the same cause in different 23 cabinets of the plant. They finally replaced all of them. 24 Is it one fire, is it five fires, or is zero fires in the 25 database? l O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
122 1 DR. WALLIS: Certainly not zero fires. () 2 DR. APOSTOLAKIS: It is not zero, but to say it's' 3 five, it's way too conservative, right? 4 DR. POWERS: It's just fire and fire progression. 5 DR. APOSTOLAKIS: Yeah, but if you eliminate them, l ) 6 as you keep eliminating causes, there should be some impact 7 on the rate. But that's why they produced four or five ! 8 volumes -- they had to deal with that. l 9 [ Laughter.] 10 MR. VANDERMOLEN: As long as the volumes 11 themselves did not create a fire hazard. l 12 [ Laughter.] l 13 MR. BARTON: Maybe that's why the rate trend -- 14 there's a graph in Maury's office that shows the rate () 15 trend's going down. 16 DR. APOSTOLAKIS: Yes, the rate trend is going l 17- down. 18 MR. VANDERMOLEN: Yes. I 19 DR. APOSTOLAKIS: But I think the main value of 20' all this is that it really puts a lower bound on the 21 numbers, so we don't come up with ridiculous numbers that we 22 used to see in the early '70s, like unavailabilities of 23 hydraulic systems of 10 to the -- ! 24 MR. VANDERMOLEN: Minus nine. 25 DR. APOSTOLAKIS: -- minus nine for demand, and O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
I;
)
123 1: major-failure of a plant, 10 to the - I've seen that, () :2 3 10 to the -41. It's crazy. l MR. VANDERMOLEN: I must admit, I've never seen it 4 that low. I l 5 DR. POWERS: Oh, yes. Yes. l l 6 DR. APOSTOLAKIS: Yes. So it's really putting a 7 lower bound, making it more real. 8 MR. VANDERMOLEN: it is, yes. It's routinely put l
- 9 in any time you do a fault analysis.
1 10 DR. APOSTOLAKIS: Well, the age of the earth's 11 crust is three-ten to the ninth years by the way, so that l 12 gives you a perspective. 13 DR. WALLIS: Put it in seconds, milliseconds. 14 [ Laughter.)
) 15 DR. POWERS: It doesn't help.
16 [ Laughter.] 17 MR. VANDERMOLEN: Well, we focused on the last 18 solution -- that is, developing methods and data as the only 19 practical cost-beneficial solution left to do. Let me go on 20 to the next slide -- i 21 DR. APOSTOLAKIS: No, don't do that yet. 22 MR. VANDERMOLEN: No -- really? l 23 DR. APOSTOLAKIS: Provide information -- that's l l 24 where I have a problem -- question really, not a problem. I 25 read the letter. Is that the only information you can O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1 i
124 1 ' provide? The Administrative letter 98-04, dated July 30, 2 1998? ! [x._/) ! l 3 MR. ROSSI: The only -- well, all of the database 4 ( and the reports and the disks that they're based on were 5 sent out, and that's just to tell people that they're 6 available. But the licensees have been sent all of the 7 information here in the report. 8 DR. APOSTOLAKIS: Oh, so each licensee received 9 the -- 10 MR. ROSSI: Each utility received it, right. And 11 the Administrative letter told them that they were going to 12 get it. 13 DR. APOSTOLAKIS: Okay, so this is the only action 14 then that you have taken. 15 MR. ROSSI: Right. 16 DR. APOSTOLAKIS: Right. 17 MR. ROSSI: But it's been widely distributed and 18 it's been discussed in a number of meetings on PRA also. 19 DR. APOSTOLAKIS: The thing that perplexes me a 20 little hit -- being vice-chairman, I learn from the chairman 21 that this work has become now infamous in the PRA community. 22 DR. POWERS: Yeah, You can go from perplexed to 23 puzzled. ; 24 DR. APOSTALAKIS: Well that's worse? i l 25 DR. POWERS: Well I don't know. g ANN RILEY & ASSOCIATES, LTD. N-- Court Reporters i 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
b L 125 l 1- (Laughter.] h 2 DR. APOSTOLAKIS: I want to use the stronger b 3 statement. 4 DR. POWERS: Perplexed. 5 DR.-APOSTOLAKIS: Perplexed. 6 DR. SHACK: Befuddled. 7 [ Laughter.] 8 MR. BARTON: Totally confused. 9 'DR APOSTOLAKIS: Yes. I think Harold waits for 10 my question. And I would like my colleagues with utility 11 experience perhaps to contribute to this a little bit. When 12 you provide information to somebody -- that's the age of 13 communication, right? So what kind of information would 14 make sense and so on. And when I read the report, I thought () 15 that what you have in Section 4 -- I mean, this is a summary 16 of 6268, Volume 1. You've got some very useful insights, 17 you know, from analysis of CCF data, in the form of bullets. 18 "A major contributor to CCF events is programmatic ! 19 maintenance practices. A vast majority of CCF events are 20 not due to multiple failures in response to an operational 21 demand, but result from the condition of the equipment." 22 And there is an elaboration. 23 I'm wondering how many licensees would really take 24 the time to look at the five reports and then spot this and 25 say this is useful. [ ANN RILEY & ASSOCIATES, LTD. (_- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 ) Washington, D.C. 20036 (202) 842-0034 1 i l
126 1 DR. WALLIS: Well, I'm wondering if this is I V) 2 information. If you don't have enough information to make a 3 statistical analysis, how can you reach the solid I 4 conclusions that George is leading up to? 5 DR. APOSTOLAKIS: Because as I say, they didn't l 6 look just as the completed common cause failures; there were t 1 7 partial, potential common cause failures. So a lot of these 8 things came from those. But, but wouldn't it be more useful 9 in your communication to them to say, yes, all these reports 10 and so on, but in particular -- I'm putting now myself in 11 the shoes of a utility person who has to make a decision. 12 Here is a number of insights that may help you, you know, 13 focus your efforts. And I wonder whether John or Jack feel I 14 the same way. To just say, here are 5 reports, use them -- ( ) 15 MR. BARTON: The problem I have -- 16 DR. APOSTOLAKIS: -- then they open it up and they j 17 see alpha factors and MGL -- 18 MR. BARTON: The problem I have with, with the 19 recommendation and the way you propose to close it is that 20 you sign an Administrative letter. You foldered all this 21 stuff and, you know, what means does the NRC have to assure j 22 that licensees are using this good stuff for common cause 1 23 failure analysis in identifying common cause failures? 24 There's no requirement; you've got a shot at the maintenance 25 rule. reg. guide, to make it a requirement in there, and you 1 ( ANN RILEY & ASSOCIATES, LTD. (> Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
p. 127 1- chose not to there either. Reg. Guide 1.160. So, there is () I I 2 no requirement that utilities follow this good stuff in 3 here. 4 MR. SIEBER: That's right. l 5 MR. BARTON: So how do you know that this is l 6 really being done to satisfy the Agency? I may or may not 7 choose.to do all this stuff. 8 MR. ROSSI: Well, the licensees come to us from 9 time to time with amendment requests and so forth based on 10 risk, and they support them with various PRA analyses. And 11 when we review those PRA analyses, we look to see -- or at 12 least NR looks to see what sort of assumptions have been 13 made about the common cause failures. So we believe this ! 14 information is the best information available on common 15 cause failures and it's gonna be used. Plus the fact that l 16 we look at events on a daily basis and so forth for things 17 that show up. And we now have Dale Rasmussen here, who is 18 reaching for the microphone as I speak. 19 MR. RASMUSON: I'm Dale Rasmuson, Office of 20 Research. In addition to the volumes that you currently l 21 have, we have always had plans to take the database and go 22 through it and glean out engineering insights. We are in the l 23 process of doing that now. 24 DR. APOSTOLAKIS: You've already reported some. I 25 MR. RASMUSON: Those were some very general ANN RILEY & ASSOCIATES, LTD. O- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 l (202) 842-0034 i
F 1 l 1 l 128 ! 1 insights. What we are doing is, we are going through, in a
^T 2 systematic fashion, looking at these with the first report 1 .[G 3 that we're about ready to release for internal, you know, 4 for peer review, dealing with diesel generator insights.
5 It's about, on the order of 100 pages. This is going into 5 the specific events and looking at them, trying to j 7 characterize them, show trends in these things. And the 8 purpose of these insights reports -- we plan to have about 9 eleven or twelve volumes on this, of the information that's 10 on the database to look at it. This will be available to 11 the licensees. 12 And also, we are structuring them in a way that it 13 can be used in the risk-informed inspection so that they 14 have those insights available to the inspectors and to the (m) 15 utilities. 16 May I say one other thing here. You know, as we 17 delve in and look at these events and try to characterize 18 them, you know, there's not a lot of events that happen the 19 same way. Most of them are very unique. And so, what we 20 are trying to do is provide that information out there so ! t 21 that people have it and can at least take it and evaluate it 22 and evaluate their practices and gain something from the 1 l 23 lessons learned from it. I 24 DR. APOSTOLAKIS: Yes, the issues, the two issuts 25 that we just raised, I don't think question the validity of l O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 I I Washington, D.C. 20036 (202) 842-0034
129 1 your insights or whether you're making an effort to derive 2 those insights. I think what Mr. Barton said is, you are 3 informing the licensees without having any means of finding 4 out whetaer they are taking advantage of all this monumental 5 effort of the Agency. Mr. Rossi said that now we will start 6 seeing this as they come back with requests and maybe PRAs 7 -- although the main effort here is not PRA. 8 MR. ROSSI: Right. 9 DR. APOSTOLAKIS: The way I understand it, this is 10 not PRA, although the project itself has done a lot of 11 things to help the PRA analyst. The generic issue is not a 12 PRA-related issue. My suggestion was, can you summarize the 13 information that is relevant to a utility manager? And I 14 brought up as an example the bullets that you have on pages 15 .13 and 14 of Volume 1 of the report. And maybe the 16 additional, more detailed reports that Dale mentioned, and
-17 communicate them to the utilities and say, you know, there 18 are these reports that are available. In fact, you're 19 sending them to them. But here is what, you know, the 20 insights are. And then, see whether they would do something )
21 about that. 22 DR. WALLIS: The real payoff would be if -- you 23 know, this is entitled " Action to Reduce Common Cause 24 Failures". The real payoff would be if, as the result of 25 something you do, common cause failures are reduced. ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 ;
130 1 DR. APOSTOLAKiS: They are being reduced. 1 () 2 3 MR. ROSSI: We provided -- I think we provided curves showing the common cause failure trend in there. 4 DR. WALLIS: -- without any sort of issue. 5 DR. APOSTOLAKIS: In the notebook -- 6 MR. ROSSI: Well, recognize that this, this 7 database is only one part of the process the agency has for 8 dealing with common cause failures. We deal with it through 9 our very robust events assessment process on a daily basis, 10 and when we find new insights of any sort that rise to the 11 level -- I mean, it has to rise to a level where it warrants 12 an information notice or a generic letter or bulletin. We 13 put one of those things out, and we put a number of 14 bulletins and generic letters out to licensees on common () 15 cause failures that they need to be aware of and need to
'16 address. And we put information notices out also.
17 But we are limited in terms of what we can ask 18 licensees to do because we have to ask them to do things 19 -that are gonna be important in the safety space and are 1 20 cost -j ustified . And that's why, in terms of closing out a j 21 generic safety issue, we have to ask ourselves the question, 22 do we need new generic requirements? And you have to 23 recognize that for new generic requirements, there has to be 24 a significant benefit to safety, and you have to be able to 4 1 25 justify it by cost. And I think that if you look at all of ANN RILEY & ASSOCIATES, LTD. O. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
1 131 1 the Agency's activities related to common cause failures, I (/') 2 that there are not, there's not a need for new requirements 3 of any sort to further reduce them. 4 DR. WALLIS: Is there a way to get rid of a 5 generic issue by the process of showing that because of 6 other things that have been happening, not necessarily as a 7 result of addressing a GSI, the issue has gone away? 8 MR. ROSSI: No -- I think, I think that the 9 question is, when you look at all the things that the Agency 10 does in the way of common cause failures, is there a basis 11 for new generic requirements that are cost-justified? 12 That's the question you have to ask with respect to generic 13 safety issues. And if the answer is "yes", then, then you 14 proceed. But here, the answer is no. Now, this issue began ('% s ,) 15 in 1985, and since 1985 we have done many, many things to 16 address common cause failures. And now it's our belief that 17 there's nothing more that needs to be done to close out this 18 generic safety issue. And I do have some continuing, 19 ongoing things that we're going to do. Dale talked about 20 things. We have the events assessment process. But is 21 there a basis for leaving this generic safety issue open at ! 22 this point in time? And our answer is, we do not believe 23 there is. l 24 MR. BARTON: Let me ask you a question. There's a l 25 party input to analyze CCFs. You've got LERs you're looking l T ANN RILEY & ASSOCIATES, LTD. l [/ ks Court Reporters 1 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L
132 1 at. You're Jooking also at NPRDS data. What happens when j j 2 NPRDS goes away? All the stuff here talks about using NPRDS 3- data. That's being phased out. What happens? 4 MR. RASMUSON: Can I answer that? 5 MR. ".3 A R T O N : Sure. 6 MR. RASMUSON: The industry has put together a 7 database called EPIX. 8 MR. BARTON: Okay. 9 MR. RASMUSON: We will be taking advantage of that 10 database. In fact, it is much better, has much more detail 11 in it than NPRDS did. There are a lot of, there's warts and 12 that on it right now. We're working with industry to get 13 these things taken care of in that. So EPIX will be the 14 main source for our, the data, for our risk-based () 15 performance indicators and things like that. 16 MR. BARTON: Okay. Thank you. 17 DR. APOSTOLAKIS: Is this the new way of 18 pronouncing it, " EPIX"? 19 MR. RASMUSON: That's how I pronounce it. 20 "E-PIX", " EPIX". 21 DR. POWERS: EPIX. E-P-I-X. Yeah, coming back to 22 Mr. Rossi to discuss his comments, I don't think that either l 23 Mr. Butler or I question the validity of the overall 24 conclusion, although of course we're not speaking for the 25 Committee. The Committee will have to deliberate on this. l
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Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
i 133 1 But all we're saying is, is there anything in addition to () 2 just providing the information that you are currently 3 providing that the Agency can do to do things a little 4 better? That's all. 5 And I was pointing out that here is a class of 6 causes that has been observed and this and that, and maybe 7 you can do something about it, and addressing the issue of 8 feedback, that something actually is happening out there. 9 Now on the other hand, I myself would answer that and say, 10 yeah, obviously something is happening because the rates are 11 going down. So, whether that is a result of the NRC's 12 efforts or the general realization that this is an important 13 issue and people are taking action anyway, or a combination 14 of the two, I don't know and I don't know that it's worth () 15 trying to find out. But the truth of the matter is that the 16 rates are going down. And it's a good thing. It's a good 17 thing. So let's keep the questions in perspective as well. l 18 I personally think that, yeah, there really isn't j 19 much else we can do. We should really close it out. But on j l , l 20 one of the ten. I 21 MR. VANDERMOLEN: Well, we're using the 22 avenues that are normally used that are available to us. 23 DR. APOSTOLAKIS: You're using what? l 24 MR. VANDERMOLEN: We're using the avenues that are 25 available to us. We're just essentially -- I O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
134 1 DR. APOSTOLAKIS: No, you're making things worse. () 2 3 The avenue that you have does allow adding a few bullets. HMR. VANDERMOLWEN: hat can I-say? 4 DR. APOSTOLAKIS: Just go to the next slide. 5 MR. VANDERMOLEN: Okay. 6 [ Laughter.] 7 DR. APOSTOLAKIS: Sometimes it's a good idea. 8 MR. VANDERMOLEN: The next slide -- 9 DR. APOSTOLAKIS: Yeah, we know that. 10 MR. VANDERMOLEN: You know that. 11 DR. APOSTOLAKIS: So is there anything else you 12 would like to tell us? 13 MR. VANDERMOLEN: That one, I just want -- 14 actually, if you'll indulge me for just a moment slide 7, I i () 15 have used these a lot myself. I wanted to give credit to 16 Dale Rasmussen and his colleagues because I do think there 17 was a lot of very good work done on this. 18 DR. WALLIS: Can I ask something? 19 MR. VANDERMOLEN: sure. 1 20 DR. WALLIS: You put out these -- they're used ! 21 only by the Staff or do utilities actually use them? 22 MR. ROSSI: These are the reports that have been ' 23 sent to all of the utilities. 24 DR. WALLIS: Is there evidence that they used 25 them?
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135 1 MR. ROSSI: Well, that's the question that was [G 2 i raised a while back. 3 MR. BARTON: That's my issue. 4 DR. APOSTOLAKIS: Has anybody in the IPE program 5 said, or cited any of these reports as their source for the 6 analysis of common cause failures? 7 DR. FLACK: This is John Flack. I believe 4780 8 was the one we recommend they use -- 9 DR. APOSTOLAKIS: Okay. 10 DR. FLACK: -- in the IP program. 11 MR. VANDERMOLEN: The others are more recent. 12 5485 came out in 1998. 13 MR. BARTON: 6268s are real good, except they're, 14 they're recent also, right? 15 MR. VANDERMOLEN: Yes. 16 D,R. WALLIS: These are older than the ones John 17 was saying. This good stuff, you meant the stuff you're 18 putting out now, asking if that has been used? This has 19 been out there, and the question that I'm asking is, is 20 there evidence that what's been out there has been used? 21 MR. RASMUSON: This is Dale Rasmussen. I can tell 22 you that the database is being used by utilities, because -- 23 at least when they go to install it, they have to call me up 24 and get a password to use it. So I know who has it and, you 25 know, who has installed it on their computers. ANN RILEY & ASSOCIATES, LTD. x_- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
136 l 1 MR. ROSSI: I thought, by the way -- and somebody 2 may want to check this out -- I thought that what we sent 3 the ACRS on closing this out indicated that the PRA standard
)
4 that's being developed,. referenced -- 5 MR. BARTON: Yeah, it's in your letter. 6 MR. ROSSI: Okay. That's very important because 7 if the PRA standard references this, the PRA standard, of 8 course, that we're continuing to develop will be the basis i i of how PRA is done in the future and how risk-informed i 9 ; 10 regulation is implement to a large extent. So if it's l 11 referenced in there, that's going to push people to use it. 12 DR. APOSTOLAKIS: Now, I don't remember when we ; 13 reviewed the program. Dale, do you remember the ACRS, or i 14 the Subcommittee had the review? l 15 MR. RASMUSON: Yeah. We did. It was like two or 16 three ago. 17 DR. APOSTOLAKIS: Two or three years ago. I don't 18 even remember whether we wrote a letter. We couldn't find 19 it. I remember writing a list of questions that were
'20 addressed at the at the Subcommittee level.
! 21 DR. WALLIS: So what is the desired outcome? The 22 outcome is not producing paperwork; it's that something is 23 actually done in the field. What is the desired outcome l 24 from producing this paperwork? 25 DR. BONACA: Well, it seems to me, you know, that ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l l 137 1 what I would like to see is, when you have a failure of some [w ]' 2 type and you perform a cause, the stuff will be able to 3 identify in fact those which result from common cause 4 failures. 5 DR. WALLIS: The desired outcome is to help the 6 Staff? 7 DR. BONACA: The Staff -- l 8 DR. APOSTOLAKIS: No, no, no. 9 MR. BARTON: It's to understand the common cause 10 of common cause failures and take the appropriate corrective I 11 action so you don't have them again. That's, that's where 12 you're trying to go with this program. 13 DR. APOSTOLAKIS: the desired outcome is what's on 14 page 110 of this notebook, on the top 3. The rates are i 15 going down. 16 MR. BARTON: That's right. 17 DR. APOSTOLAKIS: So there is no urgency to this 18 anymore. 19 PR. WALLIS: So the outcome has already been 20 achieved -- 21 MR. BARTON: Yes, it is. 22 DR. APOSTOLAKIS: Exactly. The outcome is already 23 there, and I agree with Herman. Given this and given that 24 the Agency is doing many other things as well, is it worth 25 pursuing this? ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
1 l 138 1 DR. WALLIS: So the outcome extrapolates to zero () 2 now? The graph extrapolates to zero now. 3 DR. APOSTOLAKIS: No , it stops at .05, the way I ! 4 see it. If it continued a straight line, then probably you , 5 would hit zero. 6 DR. WALLIS: No, no. It's -- 7 MR. ROSSI: We would not want to set zero for 8 common cause failures as our goal for closing out this or 9 any other generic safety issue, thank you. l ! 10 DR. WALLIS: It looks very good though. It looks 11 very good -- it is extrapolating to zero. 12 MR. VANDERMOLEN: I'd be reluctant to extrapolate 13 to zero. 14 DR. WALLIS: Yeah, but that's still a good sign. () 15 I'm not trying to be -- 16 MR. VANDERMOLEN: A decreasing trend is, I think, l 17 all we can see from a graph like this. l 18 DR. APOSTOLAKIS: Okay. Why don't you, uh -- l 19 slide 8 and then we'll come back. 20 MR. VANDERMOLEN: Well, with the provocation 21 reports, as we've discussed, we feel that the issue is 22 essentially complete and should be closed. We will consider 23 doing more work on the general subject of common cause 24 failures, but only in the context of a regular research 25 program. It would essentially have to compete for funds O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 j Washington, D.C. 20036 (202) 842-0034
i 139 1- with all of our other research programs. That we consider l l l)
'd 2 it as a generic issue.
i 3 But I do want to make it very clear that we do, as 4 Dr. Rossi mentioned a few minutes ago, we do have a very 5 robust program that is vigilantly looking for such problems, 6 such interactions, and will continue. It does indeed use 7 all available data, including what we get from other -- 8 DR. APOSTOLAKIS: But what would say to somebody, 9 that you've been so successful -- we're looking at figure 1 10 here that shows that trend going down, that there really is 11 no need to continue with the program? 12 MR. VANDERMOLEN: well, I would say, perhaps it 13 was the vigilance of the program that has made it go down. 14 If we stop the vigilance, it may go up again. m () 15 MR. ROSSI: To continue with which part of the 16 program? 17 DR. APOSTOLAKIS: The CCF analysis, all the stuff 18 that Dale mentioned. 19 MR. ROSSI: Well I think as we go along, we want 20 -- I mean, we have developed a very good, solidly based 21 process for looking at operating experience in a risk-based 22 way. And you know, that's going to ba very useful to us in 23 this. It's one part of it. 24 DR. APOSTOLAKIS: By the wa; , we are not reviewing 25 today the methods that you have developed. We are just l . t ANN RILEY & ASSOCIATES, LTD. s Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
140 1 reviewing the generic issue and disclosure. I remember -- () 2 3 as I' started saying earlier -- we had a Subcommittee meeting I believe,-maybe a-full. Committee, meeting where we 4 challenged some of the methods that are being used. And I'm 5 wondering whether.there's been any impact from those 1 j 6 comments on what you're doing or have been doing the last L 7 couple years. I still see'here the alpha factors, the MGL. 8 Has there been anything else that you did? 9 MR. RASMUSON: Well, we looked at your questions ! 10 and. addressed them, and evaluated them, as such. l 11 DR. APOSTOLAKIS: I think -- I mean, you're j l 12 showing,'say, on figure 3, page 2, alpha factors and
)
13 multiple Greek letter factors. Why don't you also show the l 14 basic parameter, model parameters? It wouldn't be difficult () 15 for you to do this, would it? 16 MR. RASMUSON: No. They're all related there.
- 17 You know, one's just a transformation of the other and so l
l 18 forth. l J 19 DR. APOSTOLAKIS: Sure. The thing is that -- 20 MR. RASMUSON: But for the basic parameter model, ; 21 I need the failure rates of the components themselves and I l 22 don't have those. i 23 DR. APOSTOLAKIS: But you have already looked at 24 random failures, and your tables do have those. 25 MR. RASMUSON: Right, but I don't have demands. I ANN RILEY & ASSOCIATES, LTD. O-Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
141 1 do not have demands, George, or run times. I have l (f%) 2- independent failures but I don't have the other part that I 3 need for estimating that. 4 DR. APOSTOLAKIS: I'd like to know, when you find I 5 out that the licensee used the alpha factor model, I would 6 be curious myself to read what you've done, because I think 7 it's a bit complicated and I'm not sure that people would 8 spend the time to do this. Now, your experience may be 9 different, and this is not relevant to the generic issue. 10 So I'm not pursuing it any further. But I mean, simplicity 11 is a great virtue in these things, and I don't know whether 12 a PRA person out there is familiar enough with these alpha 13 factors to do it. That's why perhaps trying to give also 14 basic parameter models by using some examples would help. , f'% i () 15 But again, I don't want to pursue that; it's not part of the 16 generic issue. What? 17 MR. VANDERMOLEN: I'll leave it at that. 18 DR. APOSTOLAKIS: So, do any of my colleagues have 19 any comments? On what they have heard? l 20 DR. SEALE: I have one comment. I i 21 DR. APOSTOLAKIS: Sure. Go ahead. l 22 DR. SEALE: The research program in general has 23 gotten a lot of gratuitous and not necessarily warranted 24 criticism from various sources. Here's an example where you 25 are winding up something which has made a contribution in ANN RILEY & ASSOCIATES, LTD. C) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
E l 142 1 the past and which, in the risk-informed mode of doing () 2 3 things, certainly should make contributions in the future. I don't see where you're hanging the head of this beast on 4 the wall. You need some, a little bit more visibility for 5= having done the thing and gotten it behind you. Clearly, 6 the common cause failure problem is recognized in the 7 industry as much as it is by the Commission and its staff. 8 And it seems to me you need to figure out a way to get a 9 little bit more visibility for an accomplishment of the 10 research program. 11 MR. ROSSI: Well, we will take a look at that 12 comment. I agree with you. You do recognize, of course, 13 that we report each month to Congress on the progress we're 14 making on the generic issues, so there is that visibility. () 15 DR. SEALE: Yes. 16 MR. ROSSI: And it's probably true that there's 17 more visibility if we miss a date than if we make it, but 18 that's the way life is. But we will look at how to make -- 19 DR. SEALE: When you make your report to Congress, 20 if you could make a citation in that report on how many 21 utilities have now accessed this thing, with the implied 22 result that they are now using it in their analyses of 23 failure rates and so forth, it might provide some of the 24 kind of visibility that I'm speaking of. 25 MR. VANDERMOLEN: We'll certainly look into that, O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
143 1 yes. 2 DR. WALLIS: On another note, is there a payoff as l 3 to something in burden reduction as a result of having done 4 this work. 5 MR. VANDERMOLEN: Well, it would depend on what 6 the particular~CCF mechanism was. 7 DR. APOSTOLAKIS: This was inherited from the 8 AEOD, yes? ) 9 DR. SEALE: Yes. 10 DR. APOSTOLAKIS: And we've seen many times that 11 one of the things they didn't do very well was advertise l 12 what they were doing. 13 DR. WALLIS: But is there a payoff to the 14 utilities for resolving this issue? 15 DR. SEALE: Well, the meaningfulness of their risk ! 16 assessments, you know. The quality of the product. 17 DR. APOSTOLAKIS: I think there is a general 18 awareness of the problem now that was not there fifteen 19 years ago, the issue of common cause failures. 20 DR. SEALE: But the Congress report might be a j 21 particularly useful thing to do. 22 MR. ROSSI: Well, it is, but recognize it's a very 1 23 short report with a list of, you know, what we did and 24 didn't do. l 25 DR. SEALE: Well, maybe you ought to make it a ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW , Suite 1014 Washington, D.C. 20036 (202) 842-0034
144 1 little longer. () 2 3 MR. ROSSI: But we will take a look at the mechanisms for making this work a little more visible. 4 DR. SEALE: Cite the utilities that are -- 5 MR. VANDERMOLEN: I'm one of the individuals who 6 actually has to provide text to it, so yes, I'll certainly 7 take that into consideration. We do report when they are 8 completed. 9 DR. APOSTOLAKIS: Are there any other comments? I 10 have one last question: Is this Administrative letter of 11 July 30, 1998 the last communication from you to the 12 licensees, or do.you plan to send other letters as well, in l 13 the future? 14 MR. VANDERMOLEN: Dale, I'll pass that one to you. () 15 DR. APOSTOLAKIS: I'm sorry? 16 MR. VANDERMOLEN: I have to pass that one to Dale. 17 MR. RASMUSON: I don't think we have considered i 18 one way or the other on this. I think that when we finish l 19 our insights, it may be very good to do another i 20 Administrative letter and provide the general summary of 21 common cause, and some things and -- 22 DR. APOSTOLAKIS: I would really -- l 23 MR. ROSSI: I believe all of the reports 24 themselves, the total reports, are distributed widely to the 25 industry. O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
145 1 DR. APOSTOLAKIS: I understand that, but you know ( 2 how it is. I mean, if I get five volumes, unless somebody 3 puts a gun in my head, I'm not gonna read them. But if you 4 put in the letter, look, this is the useful stuff that's in 5 the report, I think you're helping people; that's all. So, 6 you would not be arerse to sending another letter, perhaps 7 in the near future, maybe summarizing the insights to 8 supplement what you have already sent them, and without 9 tying that to the closure of the issue? 10 MR. ROSSI: We'll certainly consider it, but those 11 kinds of letters have to go out of NRR, and we'd have to 12 coordinate it with them and make sure that it meets their 13 criteria for sending something like that out. But we 14 certainly will consider it. 15 DR. APOSTOLAKIS: Yes, okay. Jack? 16 MR. SIEEER: I think the bottom line is the fact i 17 that it's going to go into the PRA standard. it's not clear 18 to me that licensees will recognize that they ought to save 19 and start using this information because it will become a de 20 facto standard for them against which their performance will 21 be measured. 22 DR. APOSTOLAKIS: Well, the thing is that the 23 project that Dale is running is doing many things, and 24 that's why I kept saying, let's not just look at the PRA. 25 We're not looking at the PRA issue here. So the PRA guys or [) ANN RILEY & ASSOCIATES, LTD. \ms/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
146 1 the utilities would probably become very aware of it, or
,m t 2 they already are. But are these the same people who would (J
3 be making a decision regarding potential couplings the 4 diesel generators? I'm not sure. 5 DR. BONACA: In some places. 6 DR. APOSTOLAKIS: In some places, perhaps. 7 DR. BONACA: It depends. 8 DR. APOSTOLAKIS: That's why I think summarizing 9 issues that are more important to management -- 10 DR. BONACA: That's why, by the way -- I wasn't 11 here -- you know, look at an executive summary and see for 12 attributes here, which one specifically talks about PRA 13 admission time. It's a concern somewhat because already ) 14 this documentation addresses itself to the PRA groups, you ,- m ( ,) 15 see. 16 DR. APOSTOLAKIS: Look at Section 4. There are 17 some very good insights in Section 4. 18 DR. BONACA: Oh , I agree. In fact, this is 19 incredibly valuable to people doing essentially root causes, 20 and the question is, are they going to be tapping into it? 21 In some cases, they will. 22 DR. APOSTOLAKIS: Exactly. 23 DR. BONACA: But in some cases, they won't. 24 MR. ROSSI: One of the things that we have been 25 doing with the risk-based analysis reports is, when they're h) \/ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
147 1 sent over to NRR by memo, the forwarding memo does give f x\ (
%-]
2 insights and ways they can le used in the inspection program 3 and that kind of thing. So it does give that information to 4 NRR for use in the inspection program. That's been done 5 with, I believe, all of these. 6 DR. APOSTOLAKIS: Are there any other issues? 7 DR. WALLIS: I have to ask -- clarification point. 8 This figure 1 is very impressive about occurrence rate for 9 complete CCF events per year. But the scale is .05. Now 10 you cannot have a twentieth of an event, so does this -- 11 this must be per-reactor. You must take all the events in 12 the country and divide by the number of reactors? 13 MR. RASMUSON: No, it's per operating year. 14 DR. WALLIS: It doesn't say that -- no, it says l'O s ,/ 15 "per year"; it doesn't say "per reactor year". 16 MR. RASMUSON: Oh, okay, that's -- 17 MR. ROSSI: Let's correct that. But that's what 18 it is, or we'd have a twentieth of an event. 1 19 DR. WALLIS: Well, a twentieth of an event is a 20 bit hard to measure. 21 (Laughter.) 22 DR. APOSTOLAKIS: This is a rate. : l 23 DR. SLACK: Not if it's one over twenty years. 24 DR. WALLIS: No , but it's per-year. 25 DR. SLACK: It's a twentieth-per-year rate. (\/ ) IJRJ RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r' l 148 l ! 1 MR. ROSSI: That rate is per year.
- ( ) 2 DR. APOSTOLAKIS
- Per calendar year or per reactor 3 year?
4 MR. SIEBER: Per reactor year. 5 DR. APOSTOLAKIS: Any other comments or questions? 6 Any comments from the Staff? Well, thank you very much, 7 Gentlemen. i 8 MR. VANDERMOLEN: Thank you. l ! 9 DR. POWERS: Thank you, George. I will recess
+
l 10 until twelve minutes after one. 11 [Whereupon, the meeting was recessed, to reconvene 12 at 1:12 p.m., this same day.] j l l 13 14 ! 15 16 17 18 l 19 i 20 l i 21 l 22 l 1 23 24 25 O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L
149 1 AFTERNOON SESSION 2 ( [1:12 p.m.] 3 DR. POWERS: I will go ahead and bring the meeting 4 back into session. We are going to now pursue the use of 5 the alternative source term at operating reactors and the 6 associated regulatory guide, and, Tom, are you going to walk 7 us through this issue? 8 DR. KRESS: Not very far, but I will introduce it. 9 You remember that the NUREG-1465 source term was developed 10 to make it more realistic, but it was meant for future plant 11 uses, and the issue before us has been the potential 12 voluntary use of the same source term for operating plants, 13 to make changes. 14 We previously reviewed the efforts that were done () 15 by the staff to evaluate and identify any issues associated 16 with that, and we wrote a letter on that, and I don't know 17 if you recall or not, but we thought that was a pretty good 18 job that they did, and it made a good basis for developing a 19 . rule on it. So what they now have done is developed a final 20 rule and a draft regulatory guide and the associated 21- standard review plan sections. And that's what we're going 22 to review today is those parts of it. 23 I guess I would particularly like for the 24 Committee to pay attention on some specific items, and the
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o 150 1 carefully to, are the redefinition of the source term to () 2 make it more broadly applicable to all design basis 3 accidents rather than just LOCAs. That's one. 4 A second item would be the adjustments made and 5 the rationalizations for these for use of source terms for 6 extended burnup, t 7 The third item I want you to perhaps think about 8 while you're listening is the staff's intent to look at the 9 effects of any changes based on the new source term, the 10 effects of these changes on CDF and LERF. i 11 A fourth item would be the question of potential 12 reductions in safety margins. 13 And a fifth item would be the draft regulatory 14 guide requirement to use 1.02 times the license power level () 15 to determine inventories consistent with Appendix K use of 16 1.02. 17 And I guess another item would be to think about 18 is the question of selective use versus full use if a plant 19 voluntarily decides to use the source term. 20 So those are the issues I want you to think about 21 as we go on. I don't know, who on the staff wants to 22 introduce -- 23 MR. REINHART: I would just turn it over to Steve 24 and let him give his presentation. 25 MR. LAVIE: Well, good morning. Good afternoon, ANN RILEY & ASSOCIATES, LTD. [])
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151 1 actually. I'm Steve Lavie with the Probabilistic Safety [V) 2 Assessment Branch in the Division of Systems and Safety 3 Assessments in the Office of Nuclear Reactor Regulation. 4 The effort I'll be presenting this morning started 5 out several years ago, as Dr. Kress mentioned. We've had 6 the opportunity to brief the full ACRS on this topic on 7 several occasions, the most recently being November 1998. 8 And we briefed the Severe Accident Subcommittee on August 10 9 of this year. This morning I'll be discussing the status of 10 this effort. The staff is expecting the ACRS to notify the 11 Commission of its position on publishing the final rule for 12 use in the draft guide for public comment.
]
13 In my briefing this morning I intend to discuss 14 the status of the final rule, and then changes made to the j O 15 proposed rule language. I will then briefly update you on 16 some of the changes that have been made in this document as 17 a result of office concurrence, comments, and CRGR review. 18 The document you have in front of you when it was j 19 transmitted pointed out that the office review and your 20 review were being done in parallel. So I'll update you on 21 the changes that have occurred. 22 I then get into the draft guide, and when we get 23 to the draft guide we'll look at the staff's objectives in 24 the draft guide and then a brief discussion of some of the 25 more significant policy decisions the staff has made in that ANN RILEY & ASSOCIATES, LTD.
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152 1 guide. 2 We'll'first get into the final rule. The {} 3 objective for the final rule was to enable the use of the 4 alternative source terms by operating reactors. It's not a 5 mandatory approach. It's strictly an enabling rule. In 6 keeping with the direction provided by the Commission, the 7 total effective dose equivalent criteria were incorporated 8 in the rulemaking. The final rule is voluntary and it is 9 applied only to those facilities who desire to use an 10 . alternative source term, and this will also include renewal 11 licensees as well. 12 Now included in the rule are some conforming 13 changes made for the Part 52 and the Part 100 rules that 14 were issued previously in December of 1996. These () 3 ,j 15 particular changes are necessary for future licensees under
\
l 16 Part 52. We just use this opportunity to get these things 17 done without a separate rulemaking. 18 The proposed rulemaking was published for public 19 comment on March 1999, and the staff received seven public 20 comment letters, none of which raised an objection to 21 publishing the rule. 22 We're working to resolve the comments we have 23 received, and one of the public comments forced us into a 24 change in the definition -- actually two comments. One 25 comment noted that the phrase in the original language "from ANN RILEY & ASSOCIATES, LTD. Court Reporters ' 1025 Connecticut Avenue, NW, Suite 1014
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153 1 the reactor core to'the containment," while accurately . I~h 2 describing the NUREG-1465 characterization, did limit this b 3 definition for a LOCA. It could give rise to the j 4 interpretation that the staff's intent was that selective 5 implementations were not allowed. Okay? That was certainly 6 not our intent. We needed to do something to change that 7 definition. 8 The second comment we received, from one of the 9 utilities, was that the phrase " magnitude and mix" as used 10 in the original language could be interpreted in a way that 11 would prevent. licensees from implementing desirable fuel 12 management techniques without approval under 50.67. Changes 13 such as changing their reactor power levels, as long as 14 they're still within their tech spec limits, moving the fuel () 15 around in different regions, these type of things could be 16 prohibited by 50.67, since some were interpreting core 17 inventory to be included in the term " magnitude." The 18 bottom line we had here is that we were trying to control 19 the gap fraction specification, not the core inventory. 20 The final language in the discussion of the 21 statements of consideration established the staff's intent, 22 which was to control the fractions. 23 Obviously the core inventory is controlled by 24 other regulations already in place, technical 25 specifications. 1 ANN RILEY & ASSOCIATES, LTD. w/ Court Reporters i 1025 Connecticut Avenue, NW, Suite 1014 ! Washington, D.C. 20036 I (202) 842-0034 l i
E l 1 I f 154 l l 1 The other change to the final rule, and this is ) , ! ) 2 something new since we briefed the Subcommittee, is that in I
%s l 3 our CRGR presentation it was identified that the language we 4 had used excluded renewal licensees issued under Part 54.
5 This was not the staff's intent, so we revised the language 6 to bring this class of licensee into the applicability. 7 You might be wor.decing, the January 10, 1999 date 8 was the effective care for Part 52, and also the changes to 9 Part 100. Apolicants for construction permits, design 10 certifications, combined operating licensees under Part 52 11 are licensed against the TEDE criteria and the revised 12 source term already. Therefore, Part 50.67 would have no 13 effect for Part 52 1.1.censees and additionally because under j l 14 Part 52 the source term would be part of the design l (s\ l
,f 15 certification which would require processing under 52.97 to 16 be revised.
17 So we felt this language brought the renewal 18 plants into the fold without bringing in more people than 19 was justified. 20 Some of the additional changes that occurred, as i i 21 we already discussed, we changed the definition of source 22 term. There were obviously caveral editorial clarifications 23 and typos that didn't change the intent. We revised the 24 text of some of the public comments based on discussions we 25 had with the Office of General Counsel in the interest of
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I i t 155 i l t 1 improving the responsiveness and establishing a clearer )
<~ >
l 2 record of how the cuament was dispositioned. 3 There were some changes made to the environmental 4 assessment to provide a clearer, more legal conclusion by 5 expanding on the draft. We had said changes are covered by 6 existing regulation and therefore safe. This was expanded 7 to demonstrate how the existing regulation assured that the 8 environmental assessments would be done. 9 We also had to add a section on a new 10 administrative requirement regarding the voluntary consensus 11 standards. The bottom line for this particular rulemaking 12 was no appropriate voluntary consensus standard was found. 13 And as we pointed out just a moment ago, we clarified the 14 applicability of 50.67 to renewal licensees. () 15 Okay. That's the final rule. We'll move into the 16 draft guide. This is where most of the technical meat is. 17 As we pointed out, the rule was intended to be enabling, 18 with much of the guidance being given in the regulatory 19 guide. Our objective in preparing this draft guide was j l 20 given here. Representatives from NRR and Research served in ' 21 a working group to put this document together. 22 A preliminary draft was circulated to all the 23 affected technical branches, and a preliminary draft was 24 made available to the public in a meeting on June 2. We 25 have had a good deal of discussion with affected l ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
156 1 stakeholders in this. I
<~si 2 One of the main points I need to emphasize in our V
3 objective is that the draft guide was written to support the 4 staff's traditional design basis deterministic analysis 5 approach. No attempt was made in this draft guide to l 6 risk-inform the entire process. As you are well aware, the
]
7 staff currently has a separate effort in progress to l 8 risk-inform Part 50. If it comes out of that effort, we'll 9 be revisiting this draft guide. 10 As we identified in the November 19 -- 11 DR. POWERS: You say suppose they come through and 12 they risk-inform Part 50. 13 MR. LAVIE: Okay. 14 DR. POWERS: Okay? I'm not going to prejudice it (O) 15 by saying what that's going to look like. A thesis that 16 exists maybe more in myth than in reality is that when we 17 risk-inform things, we make the analyses and what not much 18 more realistic. Is this revised source term that we find 19 coming out of 1465 sufficiently realistic that you think it 20 qualifies within that myth, or do we do something different? 21 MR. LAVIE: Okay. The authors of 1465 indicated 22 that their objective was to provide a representative source 23 term, that it met no single sequence, nor did it envelop all 24 sequences, that there was still some need for defense in l l 25 depth, which we believe we currently have in the way we do 1 i f)
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l 157 1 these analyses. () 2 3 The source term.itself is risk-informed in the sense that they looked at risk-significant sequences to 4' develop it, but no way did 1465 envelop all possible , 5 sequences. l 6 Did I answer your question? 7 DR. POWERS: You've set up a better preamble to 8 the question. 9 MR. LAVIE: Okay. l 10 DR. POWERS: Hit me with the bottom line. I think i 11 what you're saying is no, that whereas this is a step in the j 1 l 12 direction that if you went the whole way, and we don't know 1 13 what they'll do -- 14 MR. LAVIE: Right. () 15 DR. POWERS: In this, but if aspirations were met, 16 no, that what generated this source term, what was used to 17 create this source term would be used, not the source term 18 itself. 19 MR. LAVIE: I have to think about that some more. 20 Let me try taking a different tack. Maybe I've -- when we 21 refer to risk-informing Part 50 of course you're aware that 1 i 22 the Agency's position is that we are risk-informing, not 1 23 risk-basing, that the Agency's policy on the use of PRA and 24 risk information includes balancing both the PRA analysis l 25 with the deterministic analysis. I believe what we're O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 l (202) 842-0034 i i
o 158 1 looking there is is that right now we have licensees () fs 3 2 analyzing sequences such as locked rotor accidents, fuel-handling accidents, accidents which are not 4 risk-significant to the overall plant. We believe that many 5 of these analyses can be eliminated. 6 There is also, the Committee I know is very 7 interested-in moving to frequency-consequence curves instead 8 of doing all the calculations based on point values. These 9 are the type of-changes we would see coming out of 10 risk-informing Part 50 as regards these accident analyses. 11 DR. KRESS: Yes, that's interesting that you said 12 that, because a lot of those sequences that you mention that 13 are in the deterministic world that are said not to be 14 ret'.ly risk-significant, when we say that, in our mind we're () 15 thinking of risk as being CDF and LERF. If we want the 16 frequency-consequence curves -- 17 MR. LAVIE: Right. 18 DR. KRESS: These things, those particular 19 accidents may have a significant effect on parts of those 20 curves. 21 MR. LAVIE: That's correct. 22 DR. KRESS: And that's been a concern of mine, 23 that we don't really want to lose that, I don't think. 24 MR. LAVIE: You're talking to the choir a little 25 bit on that. O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
159 1 DR. KRESS: Okay. () 2 3 MR. LAVIE: I feel very strongly about that myself, is that our choice of CDF and LERF as risk metrics 4 may not serve us in some of these other events. You take 1 5 the fuel-handling accident. Some plants can estimate as l J 6 high as 45 rem at the site boundary for a fuel-handling 7 accident. It's not risk-significant. 8 DR. KRESS: That's right, but you wouldn't want it 9 to happen. 10 MR. LAVIE: The public would really feel strongly 11 about 45 rem at the site boundary. I.would, if I was at the 12 site boundary. 13 DR. KRESS: Yes. That's been exactly my concern 14 about going fully risk-informed, and -- () 15 DR. POWERS: Well, on the other hand you can 16 predict 10,000 rem at the site boundary if you give me free 17 rein to invent the accident. 18 DR. KRESS: Oh, yes, free rein. I can invent that 19 accident too. 20 DR. POWERS: I mean, you've got to constrain me a 21 little bit about the probabilities. But I guess I'd come 22 back and say yes, there are some analyses that are currently l 23 done that may be eliminated. I think that's not quite 12 4 right. They'll be replaced. l 25 MR. LAVIE: That probably would be a better [] v ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
160 1 characterization. () 2 DR. POWERS: Yes. And I think when you replace 3 it, the question comes up is do you want to replace it and 4 still provide it a fairly prescriptive source term, or do l l 5 you want to take a source term that is a function of the l 6 accident is the real question that comes forward. 7 It really doesn't make any difference to me i 8' whether I have a prescription out of 14-844 or a ) l 9 prescription out of 14-65. It is still a prescription, 10 okay, and so if we are going to go to risk-informed 11 regulation, do we want to retain a prescription on the 12 source term? I mean it is an approximation and there is 13 nothing wrong with it. l 14 I mean I am not criticizing it. I am just
) 15 characterizing it right now -- or do you want to say no, the 16 real insight that was gained in all the research that was i
17 done on the source term is they are a function of the l 18 accident and the prescription is just not a right i 19 characterization. ' 20 DR. KRESS: Yes, I think if you want to go that i 21 route, you would have to be sure that you, if you are going 22 to have accident sequence specific source terms, which I 23 believe in also, you would have to be sure you have a look 24 at the complete range of accidents then like a PRA. 25 DR. POWERS: That leads to the question of when we O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
161 1 do a PRA, carrying it out to consequences, a full-blown PRA, () 2 3 we still have some relatively stylized accidents in there. DR. KRESS: There definitely are. l I 4 DR. POWERS: And the biggest feature of those 5 accidents is that typically actions that are not l 6 proceduralized are not included, but when I go and look at 7 accidents that have happened or accidents that have nearly 8 happened I find these non-proceduralized things affect them 9 a great deal and so the question comes up are we analyzing 10 the right accidents. ) i 11 DR. KRESS: That is a good question, but I don't 12 believe we will ever -- for a long time -- do away with the 13 design basis concept. 14 MR. LAVIE: No, I think you are correct. We won't. (,) 15 DR. KRESS: So there is a need for a design basis 16 source term that accomplishes what you want and I think this 17 happens to be a particularly good one. 18 DR. POWERS: Well, I mean this one is based on a 19 closer approximation of reality than we have ever had 20 before. 21 DR. KRESS: Right. 22 DR. POWERS: And has a diversity to it that is 23 very attractive when you are using it to assess the adequacy 24 of safety systems. It is not just all gas and it's not just 25 all particles. It is kind of a mix. ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
162 1 DR. KRESS: As a matter of fact, that is where its ( 2 greatest value is because, you know, the proposed use of it 3 as a site qualifying source terms and as a containment 4 . thing -- actually I could care less. You could use the 5 other one just as well. It is actually in these other areas 6 that it is most useful. 7 DR. POWERS: Yes, I think you are right because it 8 doesn't appear all at once. It appears over time. I mean 9 there are lots of things'that make it very useful for 10 assessing the adequacy of the design. 11 DR. SEALE: Yes, in putting together your version 12 of this source term for your reactor you have to understand 13 your system a hell of a lot better than you would if you 14 just used the 14-844, and that is the virtue of the change. b g ,/ 15 DR. POWERS: Sure. Sure. 16 MR. LAVIE: It also puts a lot more burden on the 17 Staff because everybody has its own way of doing it. Back 18 in the old days we could say you will assume this, you will 19 assume that, and it was very easy to review. 20 DR. POWERS: That's what puts such a burden in the 21 Regulatory Guide of articulating carefully what the 22 philosophy is behind that. 23 MR. LAVIE: Right. 24 DR. POWERS: Rather than just the specific 25 numbers. [\ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 , Washington, D.C. 20036 i (202) 842-0034
163 1- DR. BONACA: One place that I see an enormous () 3 2 benefit 1 coming from this opportunity is in some cases, for example, the timing of release. That timing of release has 4 been used as a criterion for design on systems that are not 5 easy to operate -- the HVAC systems -- and as you know, I 6 mean it challenges almost every site of their meeting the 7 one minute requirement for either pulling a vacuum in an 8 enclosure building or for realigning HVAC systems and so on, 9 and I feel it is really a detriment to safety, the fact of j 10 imposing requirements that force the equipment to do things l 11 the equipment can't do. I 12 DR. POWERS: I think if we were to characterize 13 the one thing we have learned it is that in taking something 14' that looks on the face of it to.be a very bounding thing, we () 15 have created something that may be a detriment to safety. 16 DR. BONACA: Absolutely. 17 DR. SEALE: Yes. 18 DR. KRESS: That's right. 19 MR. LAVIE: Well, that's why the Staff feels that 20 this rulemaking will not only_ reduce burden but the results ! 21 are definite possibilities for improvement in plant safety l 22 as well as worker protection. 23 If we don't need to have that main steam valve 24 shut in 14 seconds or have the leakage of 14 CFM, we are 25 going to spend less dose in repairing that valve. i ANN RILEY & ASSOCIATES, LTD. Court Reporters , 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L
f 1 l i 164 1~ As we mentioned in the November, 1998 briefing of () 2 the ACRS, the Staff chose not _ to simply endorse l'UREG-1465, 3 but we established the concept of an alternative source 4 term, recognizing that there could be additional source 5 terms generated in the future, and then we would have the 6 situation where we would have the revised revised source l
- 7. term, so we decided to call it " alternative" and the draft 8 Guide contains some minimum standards for what constitutes 9 an acceptable alternative source tenn and that also provides 10 the source term we currently feel is acceptable. Obviously 11 in any Regulatory Guide they can pose alternatives.
12 Based on our discussions with the subcommittee 13 last. week, we changed the language in the standard slightly l 14 to emphasize the Staff's intent that an awful lot of work () 15 and effort was put into 1465 and we would expect any L 16 alternative to have the same level of pedigree. 17 We have also addressed accidents other than the l 18 LOCA here because they part of the traditional deterministic i 19 approach and in some cases vendor analyses project some 20 amount of fuel damage, for instance, with a steam generator 21 rupture or main steam line break, so it was decided we would I 22 need to address all of the accidents at this point, l l 23 I am going to shift now to the scope of 24 implementation. Dr. Kress mentioned this briefly in his l 25 charge to you on things to listen for. The Staff's original i [~ \ ANN RILEY & ASSOCIATES, LTD.
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r 1 l 165 l ! l 1 view on the alternate source term was recognizing that the ! l () 2 3 source term has its tentacles over a large portion of the plant design and procedures. Initially the Staff had this 4 feeling that if you went with the new source term it was 5 going to be an all-or-nothing situation. We were going to l 6 let the plants pursue timing enly applications, but the 7 philosophy was if yce are going to do a dose calculation you 8 are going to do all of them. 9 The Commission rejected this approach and directed 10 the Staff to allow the maximum flexibility while maintaining 11 a clear, consistent logical design basis -- a very, very 12 tall order to try to comply with. Much of the complexity 13 you see in the draft Guide is directly associated with that 14 sentence -- being not too prescriptive, giving a great deal '( 15 of flexibility but also maintaining the consistent logical 16 design basis. 17 Now the Staff does believe that regardless of what 18 type of application he comes in with that the applicant must 19 evaluate all the impacts of the proposed change. That would 20 include risk. 21 'The rebaselining study provides a basis for 22 discounting most source term related impacts, for instance, 23 increased cesium. Now, however, the other aspect of the 24 impacts here is that a licensee who uses the new source term j 25 is likely going to do plant modifications and there will be I ("'
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T. l i 166 1 impacts associated with that modification. Obviously, the () 2 3 licensee will need to address those as well. Now, we have decided with regard to the minimum 4 number of analyses is that'if the licensee performs the full 5 LOCA analysis as outlined in the Draft Guide, the staff can l 6 make'a finding with reasonable assurance that the alternate 7 source term implementation is safe and that future 8 modifications of that facility can use the design basis that 9 has been updated for the AST and TEDE. Thus, the licensee 10 would be able to pursue future extensions under 50.59. 11 Now, if the second implementation, since the staff 12 may have not had the opportunity to evaluate an extensive 13 evaluation, for instance, a licensee who comes in and says 14 that he would like to delay a particular valve closure time () 15 from two seconds to five seconds, we wouldn't necessarily do 16 a very large amount of analysis associated with that 17 application. However, we would feel very uncomfortable if 18 chat licensee was then to decide that he could extend this 19 to removing the filters or containment or something of this 20 nature. 21 So, therefore, under the selective implementation, 22 the current language has the licensee must come back in if 23 he is going to change the other aspects of his design. 24 This, incidentally, is an issue that has got a great deal of 25 interest amongst our stakeholders. l
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167 1 Now, the scope of reanalysis, depending on the ( 2 pedigree of the plant, you can find anywhere from a couple 3 of hundred to maybe 500, 600 radiological calculations 4 associated with the design basis. Obviously, t'o recalculate 5 all these would be a great deal of effort and no one would 6 pursue the new source term. So we needed to put some 7 guidance on what we thought was the minimum requirements, 8 and I pointed out a minute ago, we expect that all l 9 radiological and non-radiological impacts will be addressed. 10 Early on in this process we heard people saying we 11 could eliminate containment sprays on the basis that we 12 don't need to scrub the iodine, perhaps forgetting that the l l 13 containment sprays also serve a pressure transient function. ' 14 So we are looking at all impacts. () 15 We don't expect a complete recalculation of the 16 design basis. We do expect licensees could use scaling or 17 scoping analyses for certain evaluations. For example, in 18 the EQ area, you very typically have one calculation that 19 provides the source term and then 75 additional calculations 20 use that. If you can show that that is conservative, then 21 you can make a conclusion regarding the rest of them. 22 And we point out if a calculation based on the old 23 source term, a TID 14844 and the traditional dose methods, 24 can be shown to bound the results that would be obtained if 25 you updated the analysis, then there is no need to update l ANN RILEY & ASSOCIATES, LTD. O' Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
c 168 1 it. However, in this situation, the staff feels that if you () 1 2 subsequently have a reason to revise that calculation for l 3 whatever reason, that you would update to what was currently 4 in your design basis, that would be alternate source term 5 and TEDE. 6 DR. POWERS: Suppose you did that, you had some 7 reason to update a calculation that you had done previously 8 because -- i 9 MR. LaVIE: Yeah, it was bounded. 10 DR. POWERS: -- it was bounded, whatnot, and you 11 did so. Do you have to bring that to the staff? 12 MR. LaVIE: It depends on the application they are 13 going for. If it involves a tech spec change or is going to 14 end up with a license amendment, then, yes, it would have to () 15 come to the' staff. The staff would have to make a finding 16 about the appropriateness. 17 DR. POWERS: That is because it involved a tech 18 spec change or a licensing amendment. 19 MR. LaVIE: Right. But if he can do it on a 20 50.59, there is no reason to come to us. l 21 DR. POWERS: But suppose that it didn't involve 22 those, then you could invoke 50.59. 23 MR. LaVIE: That is correct. If he can meet the 24 criterion of 50.59, no increase in consequences, no increase j 25 in the riske no new accidents, whatever ends up in the Reg. O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 1 Washington, D.C. 20036 (202) 842-0034
i 169 4 1 Guide, then they would not necessarily have to come to us l 2 for review. Now, we believe that that situation is safe, as i 3 you will see when you read the regulatory analysis and the 4 Environmental Impact Statement, because the type of changes 5 that can be approved under 50.59 are not expected to have 6- significant offsite impacts. 7 DR. KRESS: Yes. The likely risk-informing 50.59 8 is, in my opinion, going to allow probably more severe 9 changes in terms of effects on risk than the current one 10 does. That is just an opinion, because I don't know that. 11 But in my view, the changes that can be made as a result of
)
12 adopting the new source term in a plant, and still meet the 13 dose requirements that are in, say, 10 CFR 100 -- 14 MR. LaVIE: Oh, certainly. l 15 DR. KRESS: -- and things like that, you are still ! 16 going to have to meet those. But in my opinion, those 17 changes would probably qualify under a risk-informed 50.59 18 and that you could almost say any changes resulting from the 19 source term, you look at it from the standpoint of 50.59 and 20 you don't even have to bring it to the staff. Would that be 21 a good perspective? f 1 ! 22 MR. LaVIE: I am not familiar with the language on j l I 23 50.59 regarding risk-informing it. l I 24 DR. KRESS: Yeah, I don't think they have that. , 25 MR. LaVIE: I have read the most recent version O ANN RILEY & ASSOCIATES, LTD. U ' Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
170 1 and we are still in deterministic space in the current 2 version. 3 DR. KRESS: It hasn't been risk-informed yet. 4 .MR. LaVIE: So I am not familiar with it. I would 5 hope that when we get ready to do that type of an action 6 that we would be considering the types of things you are 7 addressing. We would have, in radiological space, we would 8 have a problem. As we mentioned earlier, what is our 9 metric? If it is CDF or LERF, we probably are going to have 10_ a problem. If it is frequency consequence curve or actually 11 going to the qualitative health objective or something of 12 that nature, we may be more comfortable with it. But that 13 is -- I am talking off the top of my head here because I 14 haven't seen the language. () 15 DR. KRESS: Well, that is an interesting concept. 16 MR. LAVIE: As I alluded to a couple of times, 17 there are some impacts of using the new source term. If you 18 are familiar with the tables, you will realize that not all 19 the nuclides went down. Some went up. 20 I do want to mention something that Dr. Kress just 21 reminded me of is that one of the reasons we even have the 22 enabling rule 50.67 is the concern that the new source term 23 in most cases will reduce the dose and as such 50.59 24 criteria for increasing consequences would never have been 25 met. This is why the Staff has got the enabling rule that O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
171 1 the first implementation you do we want to see. () 2 On the alternate source term impacts, as opposed 3 to the plant modifications, the rebaselining study done by 4 Research showed us that the analyses based on the 5 containment atmosphere, okay, that the alternate source term 6- results would be less limiting, a conservative situation -- 7 less limiting in comparison to TID-1484. 8 However, the study also showed that the increased 9 Cesium in the containment sump water would increase 10 long-term integrative doses. The crossover between the 11 TID-1484 source term and the NUREG-1465 results would occur 12 between 30 to 40 days post-accident. 13 With the exception of the equipment environmental 14 qualification calculations, the post-accident integrated () 15 dose requirements in Part 50 are based on a 30-day exposure 16 period, thus there is no significant impact. 17 For EQ doses, the Staff has a difference of 18 opinion. However we now have a-generic issue to resolve it. 19 It. believes that this impact must be considered. However, 1 l 20 the Staff also believes that this impact could apply to all 21 reactors whether or not they use the new revised source 22 term. 23 As a result the generic safety issue has been 24 identified to determine whether or not regulatory action is 25 justified in this area. ( ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L
172 1 DR. BONACA: Before you move on -- O 2 MR. LAVIE: Certainly. Q) 3 DR. BONACA: -- this could be a very significant 4 impact on existing power plants, right? 5 MR. LAVIE: Yes. It is going to vary largely on 6 the plant and how the analyses were done. Several of the 7 architect engineers routinely throw in what they call 8 " designer margins" into their calculations, very often a 9 factor of two. If you can do a scoping calculation based on 10 the stated source term and show that the source term MEV per 11 second in the various entity groups only went up by 2 12 percent, then you are well within that factor of two margin 13 and you could by an engineering evaluation conclude that 14 your EQ calculations are good. () 15 That particular facility may not have an impact. 16 Another facility that didn't have that designer 2 margin 17 could have some impacts. 18 DR. KRESS: What equipment are we talking about? 19 Is it the sump pump and -- i 20 MR. LAVIE: Thir would be the equipment that is 21 relied upon to operate beyond 30 days that would be most 22 likely the residual heat removal system components, pumps, 23 heat exchangers, seals, valves -- 24 DR. BONACA: Cables. l 25 MR. LAVIE: Pardon? q l
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T. , 173 1 DR. BONACA: Cables. () 2 MR. LAVIE: Cabling -- anything that is reliable 3 to work longer than 30 days. 4 DR. KRESS: Are those cluse enough to the sumps -- l 5 you know, you are assuming this stuff is in the sumps -- l l 6 MR. LAVIE: No, what we are looking at here is not j 7 so much what is in the sumps. What is inside containment 8- has already been we believe adequately addressed. Most of l 9 the components in containment are designed to a 10 to the 10 7th rad -- very, very high numbers. 11 What we are looking at here is there's a lot of l 12 components outside the containment that recirculate 13 containment sump water -- 14 DR. KRESS: The stuff they recirculate -- () 15 MR. LAVIE: Right, and that dose, that activity 16 being pumped around can irradiate components in those areas 17 usually in the auxiliary building and continuous areas. 18 It may be in some plant designs be, particularly 19 in the older plants where TMI lessons learned type of things 20 were put in, I remember one plant I was associated with had 21 put their ATWS implementation panel right above, right 22 adjacent to the RHR system because of lack of space to put 23 it anywhere better. It was the best location they could 24 find. So it is going to vary from plant to plant what the l 25 impact would be. ANN RILEY & ASSOCIATES, LTD. Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 ' Washington, D.C. 20036 ) (202) 842-0034 l l
i 174 1 You are dealing strict 3y with the circulation 2 liquids. 3 DR.. BONACA: That would affect, for example, 4 back-flowing into RWST after a period of time and therefore 5- also site -- 1 l 6 MR. LAVIE: Right -- 7 DR. BONACA: -- limit, impact on the control room? 8 MR. LAVIE: The backflow in the refueling water 9 storage tank is addressed in the draft Guide as a pathway 10 the licensee needs to consider. l 11 DR. BONACA: I understand that. I am saying that 12 it has extreme ramifications. I mean it could affect 13 significantly a lot of things. All right. 14 DR. KRESS: But this is just not part of the real 15 rule or anything. You are just saying that is something you 16 are deferring to a generic letter possibly. 17 MR. LAVIE: Generic safety evaluation to find out 18 what happens. If the generic safety issue comes back and 19 says it is a valid issue, then the draft Guide will be 20 revised. In addition, there will undoubtedly be some sort 1 21 of generic communication to the other licensees for which it 22 would not be voluntary. 23 That is a decision that has to be made on the 24 generic safety issue -- is there a basis for backfitting the l 25 other utilities. Obviously the plant that is going to after t O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L
175
'I a new source term is expecting to get some cost benefit, and
() 2- you get a plant that is going to cut its budget by $2 l 3 million due to deferring some maintenance on components 4 because they no' longer need to do it as stringent standards 5 or something, for that licensee the cost of doing a couple 6 'more EQ cales.is kind of balanced, but for a licensee who 7 wants to have nothing to do with the new source term it is 8 all cost to him and burden to him, and perhaps unnecessary 9 burden, and that is what the generic safety issue will try 10 to determine. . 11- Extended burn-up fuel -- those of you familiar 12 with 1465 will recognize that 1465 source terms were based 13 on fuel behavior pertaining to burn-up levels lower than -- 14 there's a typo in my notes but it is correct in the
) 15 slides -- 40 gigawatt day per metric ton uranium.
16 As a result 1465 contained a disclaimer regarding 17 the applicability of the results, particularly gap activity, 18 to extended burn-up fuels. 19 DR. KRESS: Let me ask you about that. 20 MR. LAVIE: Okay. 21 DR. KRESS: The NUREG-1465 used calculations and l 22 expert opinion that was based on, quote, " currently 23 operating plants." 24 MR. LAVIE: That's correct. t 25 DR. KRESS: Were those people not aware that those
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I i-176 plants have high burn-up fuel in them at the peak and
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l 1 1 () 2 3 _ places, or was it'just ignored or was it accounted for in some way? That is the question I have. MR. LAVIE:
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4 I don't believe it'was accounted for, , l 5 otherwise there wouldn't have been a need for the 6 disclaimer. I believe the situation is that the people 7 developing the 1465 -- maybe Charlie from Research could I 8 -help me out here -- is that the data-they had to work with 9 was from the plants with that pedigree and no one was 10 thinking about operation beyond 40. 11 DR. KRESS: Well, let me ask the question another 12 way. In currently operating plants, about what percentage l 13 of the fuel has burn-ups higher than 40? 14 MR. LAVIE: The way we-are currently regulating, '( ) -15 we define burn-up to be the average over the peak rod. We 16 assume that that. peak rod has got the maximum burn-up and 17 also is in the peak power position, okay? That is an
'18 impossibility. It can't be.
19 DR. KRESS: Yes. That is a different issue. 20 MR. LAVIE: Okay. 21 DR. KRESS: No, my real question is if I go to a 22 plant and measure the whole burn-up of every fuel in there 23 and average it, what would that average end up being, 24 roughly? 1 25 MR. LaVIE: I think I have heard numbers, I am ( -_ [' ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
177 1 trying to recall now,' that the 62 gigawatt day metric ton 2- uranium equates to approximately 45 averaged. 3 DR. KRESS: Yes, that was the number I am after. 4 That's right. 5 MR. LaVIE: Okay. 6 DR. KRESS: Is it not a good concept to think that 7 the source. term, a realistic source term, which involves 8 supposedly a significant melt fraction of the core, would be 9 more dictated by the average than the peak rod? 10 MR. LaVIr- Okay. 11 DR. KRESS: That is the question I am trying to 12 get to. 13 MR. LaVIE: The question, okay. The staff used 14 that rationale in looking at the extended burnap issue. For ,/'~h (, J 15 the loss of coolant accident, we realize that the average is 16 the appropriate thing to use because all the fuel elements I i 17 are equally potentially affected. Where we kind of have a I 18 problem now is when we go to an accident like the fuel 19 handling accident where you are pulling out one assembly. l 20 Okay. You could pull out the worst assembly. It is l l 21 unlikely because usually that is the third region, it has t 22 had a chance to be outside the peak power region for a l l l l 23 while. i 24 So the analyses methods and the way the source I 25 term has been applied to these other accidents takes into O ANN RILEY & ASSOCIATES, LTD. V Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i . . .. . . .
178 1 account, we believe, the fact that it is appropriate to use () 2 3 an average for some accidents and not for others, and that is part of the justification for why the staff believes we 4 can use the 1465 numbers as high as 62 gigawatt day per ; 1 5 metric ton uranium. And that is explained in the rationale, j 6 it is a part of the regulatory analysis, j i 7 DR. KRESS: Okay. But you did adjust the gap I i 8 inventory? l 9 MR. LaVIE: Yes. For the non-LOCA. l 10 DR. KRESS: But you did that for all accidents. l 11 MR. LaVIE: For the non-LOCA accidents, yes. 12 DR. KRESS: Oh, I guess I missed that. , 1 13 MR. LaVIE: Okay. We used the fraction specified 14 in 1465 for the LOCA. 4
;x (j 15 DR. KRESS: Okay.
16 MR. LaVIE: It was the non-LOCAc. 17 DR. KRESS: I think I missed that. 18 MR. LaVIE: Okay. 19 DR. KRESS: The adjustments to the gap was for the 20 other accidents. 21 MR. LaVIE: Other accidents. Because part of the 22 rationale was we really didn't need to address in the LOCA 23 space because the gap is such a small portion of what we are ; I 24 assuming is going to get out eventually. 25 DR. KRESS: Right. I i i 1 i
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179 1 MR. LaVIE: It affects the timing of things n 2 slightly. (v) 3 DR. KRESS: Of course it affects some of the valve 4 isolation stuff. 5 MR. LaVIE: But, significantly, we didn't feel it 6 was an impact, that we could take the data from 1465 and use 7 it up to 62, 62 being what we are currently licensing people 8 to. l 9 DR. KRESS: Thank you. That helps a lot. l l 10 MR. LaVIE: Okay. I am sorry, I didn't understand l 11 the question. , I 12 Okay. In developing that rationale for extending 13 1465 to the current plants, we had meetings with 14 representatives from Research, Reactor Systems to address () 15 how the data could bc extended, and we r?me up with what we 16 believe is an appropriate rationale. One has to keep in 17 mind that this rationale is based on deterministic design 18 basis considerations. We are certainly not suggesting that 19 what we have put in there is accurate, however, we do 20 believe it is conservative. 21 Okay. The staff, with regard to the reactivity 22 insertion accidents, rod drop accident, rod ejection l 23 accident, we are handling those pretty much on a 24 case-by-case basis as they come in, although the Reg. Guide l l l 25 does give some default numbers. l II Y' ANN RILEY & ASSOCIATES, LTD. Court Reporters
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f 180 l 1 This particular event is being considered under I [~ 2 the agency's high burnup program. As you are aware, Ralph o V) 3 Meyer of the staff presented the program to the ACRS in a 4 meeting earlier this year. As the data comes out, if there 5 is a need for us to change, we will change the guidance we 6 are putting out. j 7 One of the other extensions we needed to do in 8 getting from 1465 to something we could put in to address ! 9 all the accidents in the design basis is to look at the 10 iodine species. NUREG-1465 provided excellent data i 11 regarding iodine species for the release of activity in the 12 containment atmosphere, and, basically, to summarize, 95 l
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l 13 percent cesium iodide, 4.85 percent elemental and .15 l 14 percent organic. Okay. We had no reason to feel that that j j qp) l 15 was inappropriate and we obviously decided to stay with it. 16 Although 1465 did identify a few other accidents, I l 17 they provided no additional iodine species value. So the l 18 staff, in our meetings, developed what we currently believe i 19 to be the approach on iodine species. The data are 20 generally based on adjustments to existing regulatory l 21 guidance. This is deemed appropriate given the traditional i i 22 design basis deterministic use of these data. They may not 23 be 100 percent accurate, but we believe them to be 24 conservative. 25 Now, late in the preparation of the Draft Guide,
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r ' 181 1 industry provided a technical position of iodine species for 2 a fuel handling accident, advancing cesium iodide as a [V) 3 predominant form other than elemental iodine. We will be ! 4 considering this position as we consider other public 5 comments that come in during the public comment period. 6 I want to also point out that in many of the j 7 deterministic analyses, the assignment of the iodine species 1 ! 8- is largely irrelevant, because most of our design basis l 9 analysis assumptions make no distinction on species. For l l 10 instance, dose conversion factors do not change if it is l 11 elemental or organic. 12 We may have decontamination factors in various 13 process streams that are iodine species consistent, but most l 14 of the assumptions, they are not affected by the iodine
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( ,j 15 species. l 16 We did take the opportunity, although we didn't go i 17 all the way to risA-informing it, we did take the t 18 opportunity to do some updates in the guidance we have been l 19 giving licensees on doing these analyses. A lot of this was ; 20 based on the work done in the pilot projects. Jay Lee is 21 going to talk about the pilots when I finish. The guide 22 also contains some improved assumptions and methods 23 developed outside the pilot reviews. This slide kind of ! 24 summarizes some of them. 25 We have a new containment spray removal model, new O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l (202) 842-0034 i
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l 182 1 to the regulatory space. We allow credit for main steam () 2 line deposition _in boiling water reactors. We have allowed 3 licensees to propose. fuel. damage estimates based on 4 integrated enthalpy rather than DNBR. This is for the 5 non-LOCA accidents, except for the rod drop accident, rod 6 ejection accident, because there is significant doubt right 7 now regarding the criteria which are used for those 8 accidents. 9 There is -- we reduced the iodine spike multiplier 10 from 500 to 335, not a big change, but -- 11 DR. KRESS: What was the basis behind that change? 12 ! MR. LaVIE: It was worked on on the steam 13 generator, alternate repair criteria effort. There was some 14 research done apparently that justified reducing it from 500 () 15 , to 335. I do not know all the fine details. l 16 DR. KRESS: Yes, I recall that. 17 MR. LaVIE: Okay. I know there was a lot of 18 industry work done on that. There were several papers by a 19 gentleman named Iglesias vho did some work on that. I think i 20 at point the industry was advocating a multiplier of 20, but j 21 when the staff looked at it, they found that the best they 1 22 could support was 335. Of course, that only applies to the steam generator tube rupture. l 24 DR. KRESS: Yes, I remember now. It was based on , l 25 actual data that they -- they bounded it to some extent. l O ANN RILEY & ASSOCIATES, LTD. ' Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 , (202) 842-0034 1
y 183 1 MR. LaVIE: Right. Okay. We also put in the () 2 guide that there will'be no rad analysis required for the 3 locked rotor accident unless you postulate fuel damage. And
-4 this change regarding integrated enthalpy ought to pretty l
5 much do away locked rotor accident analysis for radiological 6 purposes. 7 DR. KRESS: Did you, in this allowing credit for ! 8 that main steam line deposition of BWRs, does that include l 9 the suppression pool? i l 10 MR. LaVIE: I am going to defer to Jay. l 11 MR. LEE: Yeah, this is Jay Lee. No, we do not. L 12 DR. KRESS: Did you put any new guidance in the 13 guide on how to deal with suppression pool contamination 14 factors or not? 15 MR. LEE: The Draft Regulatory Guide does. l 16 MR. LaVIE: Okay. The Draft Guides identifies 17 reduction by the suppression pool and says the staff will 18 consider it on a case-by-case basis. ) 19 DR. KRESS: Okay. 20 MR. LaVIE: The problem with the suppression pool 21 is that the three reactor -- the three containment designs 22 all have different performance. I believe they determined 23 in the case of the MARK 3 types that it could have been l 24 appropriate, but the licensee chose not to use it, so we 25 didn't analyze against it. l ANN RILEY & ASSOCIATES, LTD. O- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i l-
184 1 In a MARK 1 design, maybe taking credit for 1 2 suppression pool might not be adequate. So that is why we { 3 are treating it strictly as a case-by-case basis. 4 DR. KRESS: Okay. This new containment spray 5 removal model, is that the one developed at Sandia? 6 MR. LEE: Yes. 7 MR. LaVIE: Yes. 8 DR. KRESS: Okay. I am familiar with it. 9 There were some changes that occurred during the 10 office concurrence and the CRGR. I will highlight these for 11 you. 12 The most significant ones are originally in 1 13 section 1.4 of the draft guide there was an exclusionary 14 statement regarding downgrading of control-room habitability 15 features. We indicated that the staff would be reluctant to 16 consider such changes. The statement has been removed on 17 the basis that if the licensee can come in and provide 18 sufficient justification, we will consider it. Of course 19 the burden of proof will be on the licensee. l 20 DR. KRESS: Is this new stuff -- l 21 MR. LAVIE: There's a risk impact there as well. 22 DR. KRESS: Is this new stuff beyond the 23 subcommittee meeting? 24 MR. LAVIE: Yes, this occurred out of CRGR. 25 DR. KRESS: Yes. So this stuff we haven't h) V ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
g-185 i 1 heard -- J) 2 3 correct. MR. LAVIE: You haven't heard it yet. That's l 4 There weren't that many changes, but these are the ! 5 ones.
-6 -Footnote 12 to section 3.6 of the guide contained 7 a warning regarding the inapplicability of fuel damage 8 estimates for rod-insertion accidents based on methods other 9 than DMBR. This was the Cabri issue, where some foreign 10 research. reactors feel that damage occurs earlier than we 11 previously thought. The applicability of that to United 12 States designs is kind of questionable. However, it's being 13 evaluated by the Agency.
14 We put a footnote in there as a warning to say_ () 15 that we may not be willing to accept enthalpy for these 16 events. The decision vas made that Section 3.6 enables the 17 licensee to propose these thingc, It doesn't tell him he 18 has to. And therefore there was no reason to having a 19 specific exemption -- exclusion for these events. But the 20 staff will review whatever the licensee proposes. j 21 There were four footnotes in Appendices E through 22 H. They were changed to clarify the applicability of Draft 23 Guide 1074. This was with regard to the steam generator 24 alternate repair criteria. That's what this Draft Guide 25 1074 is. That that draft guide contained a different method O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
186 1 for calculating -- a slightly different method for [') s_-- 2 calculating the doses, and also had different dose criteria 3 for steam generator tube rupture and main steam line break 4 accidents. That's why it was referenced in the footnote, to 5 realize that there may be other criteria out there that we 6 need to use in conjunction. We clarified that slightly to 7 point out that all we're referring to in the draft guide is 8 the radiological assumptions and not the other material in 9 the draft guide. That was asked for by the Department of 10 Engineering. 11 We had a reference to USQ in the draft guide that 12 hadn't been caught. That's been taken out and the language 13 made more generic to fit the current 50.59 or the current 14 final not-yet-published 50.59. Response to request, we had A (_) 15 references to alternate source term impacts. The language 16 used to say the impacts of plant -- used to say the impacta 17 of plant modifications and the source term. We've changed 18 that to the impacts of the plant modification in the context 19 of the source term. We've already concluded that with the 20 exception of that EQ issue that's being handled generically 21 that there is no impact from the alternate source term. So 22 therefore the only impact comes from the plant modification. f 1 23 So that language clarified the staff's intent. j 24 Okay. 25 DR. KRESS: Okay. O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
187 t 1 MR. LAVIE: With that -- I've tried to give you a l ' .- () 2 3 brief' overview. It's a big document. We'd be here for days if I'went through every word. 4 DR. KRESS: No , I think you did a good job of i 5 hitting the important highlights. 6 MR. LAVIE: Okay. 7 I'll be happy to entertain any more questions. 8 DR. KRESS: If there are any more questions, we'll 9 go to the pilot studies then. 10 Seeing none, I guess -- 11 MR. LAVIE: Okay. Thank you for your attention. 12 MR. LEE: Good afternoon. I am Jay Lee, and I'm 13~ also with Probabilistic Safety Assessment Branch, as Steve 14 Lavie is in NRR.
) 15 My presentation this afternoon will deal with 16 studies of pilot plant review programs, and I will touch on 17 some of a few alternative source term technical issues.
18 DR. KRESS: How did this happen to end up in the 19 PRA Branch? You guys were available? Is that it? 20 MR. REINHART: I could make a comment on that. 21 The hope is, looking down the road at Level 3 PRAs is having 22 the source term radiation people with the PRA people that 23 we'll be in a better position to make that integration. 24 DR. KRESS: That's a good idea. 25 MR. LEE: Implementation of Alternative Source t ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 (202) 842-0034 I i
188 1 Term at' operating reactors really involves three source term () 2 tasks. One is rebaselining. The second one is pilot plant i 3 application reviews that I'll be discussing this afternoon. 4 And the third and last item is of course rulemaking and 5 development of a new regulatory guide that Steve Lavie just 6 did. So pilot plant application review is just a part of 7 the overall effort for implementing alternative source term 8 at operating reactors. 9 For this program we received five pilot plant 10 applications. By the way, Dr. Kress, this account is 11 slightly different from what I gave you last August 10 to 12 the subcommittee meeting. Since then we did complete one 13 more pilot plant review for the Grand Gulf, so now we 14 completed two pilot plant programs, the Perry and Grand () 15 Gulf. One is still under review. That's Indian Point 2. 16 One on hold in response to the licensee's request to be 17 hold. And the last one, the Browns Ferry, they just 18 withdrew their application. 19 DR. KRESS: Oh, they did? 20 MR. LEE: Yes, they did. 21 DR. KRESS: I see you've got large dry, a Mark 3, 22 and a Mark 2. 23 MR. LEE: Right. 24 DR. KRESS: What's Oyster Creek? Mark I? 25 MR. LEE: Perry and Grand Gulf both are Mark III. O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i l
I- l i 189
.1 And Indian Point, Unit 2 is of course PWRs.
2 DR. KRESS: Yes. 3 MR .. LEE: i For the Perry Unit 1 pilot program, they 4 requested to eliminate the main steam isolation valve 3 5 leakage control system. Also they wanted to increase 1 6 allowable MSIV leakage rate from 25 CFH per line or per 7 valve to 100 CFH, and 100 CFH from all four steam lines to 8 the~250 CFH. 9 We completed this review last February, and we 10 issued the license amendment in March this year. And I'll 11 be discussing more in detail about how we did it for the I 12 Perry station. ) 13 For the Grand Gulf Station, their request was just 14 limited scope application. This is selective implementation l {
/)s
(, 15 of fission product release time. They requested to increase l 16 onset of fuel rod gap release timing from 30 seconds I i l 17 currently specified in NUREG-1465 to 121 seconds. ! 18 Now we're not sure we're going to go to 121 19 seconds. Probably we'll go to draft guide something like i 20 120 seconds, which is 2 minutes. l 21 We completed review just a few weeks ago, and we l 22 have not issued the license amendment as yet. I think that l 23 is in the process right now by the project managers. We do 24 expect another submittal from Grand Gulf for the full scope 25 application using these alternative accident source term O
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ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034
190 1 sometime this month.
) 2 For Indian Point Unit 2 they requested to remove 3 the in-containment filtration system, which is a bit unusual 4 for the PWR to have such a filtration system inside the 5 containment. So therefore using these alternative accident 6 source term they would like to eliminate this in-containment 7 filtration, 8 We just received -- as a matter of fact I think we 9 received yesterday more information from Indian Point that 10 we requested through our request for additional information.
11 And we didn't really have the chance to look at the review, 12 but we expect -- we certainly hope to complete review of 13 Indian Point Unit 2 by the end of November this year. 14 DR. KRESS: Was that intended to knock down the 15 elemental iodine concentration in containment? 16 MR. LEE: Yes. 17 DR. KRESS: So they can meet the dose criteria a 18 little earlier? 19 MR. LEE: Right. This is engineered safety 20 feature system inside containment. Not very many PWR have 21 these features, and certainly the Indian Point, they would 22 like to -- 23 DR. KRESS: So it consists of a prefilter and 24 charcoal filters? 25 MR. LEE: And hepa filters. T ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
191 1 DR. KRESS: And hepa filters also. () 2 MR. LEE: Yes. Whole filtration systems. 3 DR. KRESS: So they're going to take the new 4 source term and take credit for natural deposition of 5 aerosols and show they can still meet the TEDE criteria 6 without this' thing. Is that -- 1 l i 7 MR. LEE: Correct. Yes. i 8 DR. KRESS: Okay. 9 MR. LEE: As I mentioned earlier, the Oyster Creek l 10 is on hold, and the Browns Ferry unit withdrew their 11 applications. 12 DR. KRESS: Do you know why Browns Ferry withdraw 13 theirs? 14 MR. LEE: Pardon? ( 15 DR. KRESS: Do you know why Browns Ferry withdrew 16 their application? 17 MR. LEE: They said they have some problem with i 18 the resource. They just -- l 19 DR. KRESS: Oh, they just can't put the resources 20 on there. l 21 MR. LEE: Right. And so they withdrew. 22 For the Perry nuclear powerplant of course we used 23 the NUREG-1465. Now this NUREG-1465 is actually severe 24 accident source term, and for the design basis accident, for 25 the fission product release magnitude we used only the j l g ANN RILEY & ASSOCIATES, LTD. ( Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 1 (202) 842-0034 !
y 192 l' _ releases'from the gap and in-vessel releases. We assumed l I' 2 the_ vessel itself is intact, along with the containment. L 3 Therefore, we did not use ex-vessel release and late 4 in-vessel specified in the NUREG-1465. 5 DR. KRESS: That was based on an assessment that 6 the probabilities of the accident going that far in the 7 first place is pretty small?
'8 MR. LEE: Yes. We really like to differentiate 9 the DBA from severe accident. DBA definition itself is the j l
10 reactor vessel itself is intact. 11 DR. KRESS: Um-hum. 12 MR. LEE: And therefore we used fission-product 13 release portion that generated through in-vessel releases. 14 DR. KRESS: Does that look like a little bit of an
) 15 inconsistency to you in the sense that if you had this
~
16 . extent of core melt that is represented by this source term, 17 that means you have melted core in the bottom of the l 18 vessel -- 19 MR. LEE: Yes. 20 DR. KRESS: And it takes what, another 15, 20 21 seconds for it to melt through and end up in the cavity 22 below, or -- 23 MR. LEE: Well, we're thinking about like a 24 TMI-type accident -- 25 DR. KRESS: Oh, I see. r ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l l.
g 3~ 193 1 MR. LEE: Yes, the reactor core is melted, but it (' 2 didn't go through the reactor vessel. k]/ 3 DR. KRESS: Boy, that's one in a million. 4 MR. LEE: That is just the definition of the 5 design basis accident for radiological assessment, and we 6 didn't want to go beyond the vessel failure or core concrete 7 interaction or containment failure or containment bypass. 8 Those are really severe accident sequences. 9 DR. KRESS: But it really wasn't based on 10 probabilities? 11 MR. LEE: No. 12 DR. KRESS: That you would go further, 13 MR. LEE: No. 14 DR. KRESS: Because of -- () 15 MR. LEE: It was deterministic. 16 DR. KRESS: The likelihood you would go further. 17 MR. LEE: Yes. 18 DR. KRESS: Okay. 19 MR. LEE: And also we used the new rules Steve 20 described earlier, that's 10 CFR Part 50.67, which has 25 21 rem TEDE for site boundaries, and 5 rem TEDE for control 22 room operator. 23 And we gave credit, like Steve briefly discussed 24 earlier, tha credit for the aerosol deposition in the main l 25 steam line. Also we gave credit for dry well aerosol ANN RILEY & ASSOCIATES, LTD. ! Court Reporters ! 1025 Connecticut Avenue, NW, Suite 1014 ) Washington, D.C. 20036 l (202) 842-0034 :
194 l' deposition'inside the dry well.
'r(~'} 2 DR. KRESS: Let me ask you about main steam line
(./ 3 deposition. 4 MR. LEE: Yes. 5 DR. KRESS: I thought that credit was already in i 6 1465 source term. 7 MR. LEE: No -- 1465 source term really deals with 8 release magnitude, timing and chemical forms.
'9 DR. KRESS: That's out of the core. It makes its 10 way through this main steam line and ends up into the 11 containment.
12 MR. LEE: Well, main steam line is really -- it is 13 not part of containment and the source term that defined 14 itself earlier, the fission product release from the reactor () 15 coolant system into the containment. 16 DR. KRESS: Right. I 17 MR. LEE: And it is not part of release into the 18 main steam line or -- 19 DR. KRESS: Or a part of the reactor coolant 20 system? 21 MR. LEE: Yes -- it's really from the reactor 22 vessel itself. You are right, main steam line is a part of 23 reactor coolant system. Well., it is really steam line. 24 DR. KRESS: My impression was that that position 25 was already accounted for in 1465. 1 (( j
)
ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 , (202) 842-0034 l
195 1 DR. SEALE: No. () 2 MR. LAVIE: This is Steve LaVie again. The BWR 3 design basis LOCA is generally involving with the 4 recirculation piping and not the main steam line so that 5 would be the direct path into the containment and the dry 6 well would be from the recirculation piping. l l 7 I mean steam piping is a pathway bypassing 8 containment. 9 MR. LEE: I guess NUREG-1465 dealt with any 10 deposition inside the vessel itself but did not include any l 11 deposition in the main steam line. Yes, Charlie? 12 MR. BOEHNERT: Charlie, identify yourself, please. 13 MR. TINKLER: This is Charlie Tinkler from the 14 Office of Research.
) 15 NUREG-1465 does already account for deposition in 16 the RSC. That is because it is released to the containment.
17 The main steam line aerosol deposition that is 18 being referred to in this analysis is deposition of aerosols 19 between the isolation valves, between the MSIVs. That is 20 another section of the main steam line. 21 DR. KRESS: Okay. 22 MR. TINKLER: So there is an opportunity if there 23 is a small leak break past the first isolation valve, a 24 large volume, and then the outboard isolation valves, so 25 there's ample time for additional deposition. ( ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l 196 1 DR. KRESS: I understand what you are talking (3 2 about, 3 MR. LEE: Now aerosol deposition in the main steam 4 line as well as inside the drywell, we use the methodology 5 developed by Sindia. It is NUREG-6189, a simplified method 6 for aerosol removal by natural processes in containment. We 7 use that methodology. 8 Also we gave full credit for the containment spray 9 and the methodology we used at Perry we also used the 10 methodology developed by Sandia. 11 DR. KRESS: Is that a change from the previous 12 design basis giving full credit to containment spray? I 13 thought you used to give only partial credit. 14 MR. LEE: Well, chemical forms are different. Now ( ,, 15 we are dealing with the mainly 95 percent is aerosol form. 16 Only 4 percent is elemental iodine. Back in the TID source 17 term 95 percent is in the elemental iodine. 18 DR. KRESS: Right. 19 MR. LEE: And we still use the SRP method for 20 giving a credit for elemental iodine but aerosol deposition 21 or aerosol removal by spray we used this new method 22 developed by Sandia. Yes, that is different. 23 DR. KRESS: You don't assume some failure of that 24 spray system? 25 MR. LEE: Pardon? l l [~ ) ANN RILEY & ASSOCIATES, LTD. (_/- Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
197 1 DR. KRESS: You assume Ahe spray system is 2 available -- 3 MR. LEE: Yes, typically they have two trains. 4 DR. KRESS: I thought previously you assumed one 5 of those trains had failed and only used the other one. i 6 MR. LEE: Right. 7 DR. KRESS: For the elemental. 8 MR. LEE: Right. Perry, I believe we used one 9 train with the two trains designed and they are engineered 10 safety features system. 11 DR. KRESS: Are you telling me now you don't, you 12 just automatically use both trains? 13 MR. LEE: No, one train. 14 DR. KRESS: Okay. That is what I didn't i 15 understand. Okay. 16 MR. LEE: For suppression pool water pH that Perry 17 proposed to use, the sodium pentaborate they have in their l 18 existing stand-by liquid control system, and we got some 19 help from Oak Ridge to calculate the resulting pH using the 20 full amount of sodium pentaborate in a standby liquid 21 control system at Perry, what the resulting pH might be, and 22 Oak Ridge calculated and we reviewed it to the basic above 7 ( 23 and actually the number is like 8 -- 8.3 pH. 24 DR. KRESS: I have a question about that. It may 25 sound a little oblique. The question I have is what does i ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
i l l 198 1 that have to do with the use of the alternative source term? () 2 MR. LEE: Not directly related, but in BWR the 3 licensees didn't really claim that the pH control or pH 4 additive while the PWR used chemical additive to control the 5 containment water sump. 6 DR. KRESS: Is that a condition in the alternative 7 source term that in order to use this source term you have 8 to control the pH? Is that in the rule somewhere? 9 MR. LEE: Well, they don't have to control pH but 10 we don't think they can meet the dose criteria without 11 controlling pH. 12 DR. KRESS: That is my question. That doesn't 13 show up in the alternative source term. 14 MR. LAVIE: This is Steve LaVie. Where it shows () 15 up in the alternative source term is in the specification of 16 the iodine species -- the 95 percent and the 4.85 percent 17 and the 1.8 percent species apply only if the pH is 18 maintained above 7. 19 DR. KRESS: Does it say that in the rule? 20 MR. LAVIE: It says that in the Reg Guide. 21 DR. KRESS: There is a place in there that says 22 you have to control the suppression pool pH in order to use 23 this source term. 24 MR. LEE: That is not conditional. If they can 25 meet the relevant dose criteria, they don't have to control, l O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
199 1 but we don't think they can meet without the controlling pH> fs i l 2 DR. KRESS:
) I don't think they can either. Okay. )
3 MR. LEE: You know the Regulatory Guide is always 4 guides, but they can propose alternative to it, and if they 5 can show us they can meet those criteria without controlling 6 pH we will certainly deal with that case by case but we l 7 really don't think they can do that without controlling pH. 8 DR. KRESS: But if they did not -- my point was 9 that if they did not control pH, then they have to use some 10 other source term. 11 MR. LEE: No, no. They still can use alternative 12 source term, even if they don't control pH, if they can l 13 meet -- l 14 DR. KRESS: I don't understand -- because the
) 15 reason for the pH is to keep additional iodine from coming 16 back into the containment, which is another source term.
17 MR. LAVIE: This is Steve LaVie. The way the 18 draft Guide is written is that they can use the assumed, the 19 95 percent cesium iodide only if they can control the pH to 20 7. If they can't control the pH to 7 then we need to look 21 at the iodine species over again. They would be forced into 22 some work like -- Oak Ridge has got a code that will do 23 this. 24 DR. KRESS: And would have to calculate a new 25 source term? ANN RILEY & ASSOCIATES, LTD. O' Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
I 200 I l 1 MR. LAVIE: Right, given the different species. [) 1LJ 2 Right. Because the species would affect the efficiencies of 3 the sprays -- 4 DR. KRESS: So basically I was right. The source 5 term in 1465 is conditional basically on controlling pH, , l 6 otherwise the Guide says you are going to have to do j 7 something else. Okay. 8 MR. LEE: Also we used updated ARCON96 called for 9 determining control room dispersion or control room factors. { 10 This is a new code to estimate the dispersion in the 11 vicinity of buildings to calculate relative concentration at 12 the control room intakes. 13 DR. KRESS: Is it something like HABIT? 14 MR. LEE: Well, it is like HABIT code, but it is a
,r
( ,)\ 15 complete different code. Then we used the new, more updated 16 dose conversion factors given in Federal Guidance Report 11 17 and 12, which is really based on ICRP-30. I 18 Using those parameters and assumptions the I 19 relaxation to the operating license in this case changes in 20 the tech spec. They were able to delete main steam 21 isolation leakage control system. Without this system they 22 can still meet the new rules and also they can meet the new l 23 rules with increased allowable MSIV leakage rate. 24 Here are some relaxations to the design basis. I 25 just listed some of them here for Perry Station. There are [\- ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
I I 201 l' annulous effluent gas treatment system, this is equivalent ' ( 2 to, typically, BWR standby gas treatment system, charcoal 3 absorber not used. They didn't have to use this filter. l 4 'The control room HVAC -- ) 5 DR. KRESS: I guess one of the problems I have had 6 with this is that such a charcoal absorber could be a very 7 useful device for long-time accident management, well beyond 8 the time when it is risk significant and when you start 9 converting iodine into organics and rereleasing the other 10 forms of iodine that are not aerosol. But it would be nice 11 to have a charcoa3 usorcer in there, even though it is not 12 risk significant 3 terms of CDF and LERF. This is one of 13 those places where it would probably affect the FC curves, 14 if one had FC curves. 15 I was wondering what -- I see you say it is not 16 . used here, but it is used some places. 17 MR. LEE: Physically still they have this ! 18 particular absorber. 19 DR. KRESS: They have in there, that they could 20 turn it on if they wanted to? 21 MR. LEE: Well, they are still using it as a 22 matter of fact, but in our calculation, and also their 23 calculation, we just assumed that this particular charcoal 24 absorber does not exist. It is no credit. 25 DR. KRESS: Yeah, it wouldn't affect your ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
n 202 1 calculation-anyway. 2 MR. LEE: But because it is a relatively small 3 amount of elemental iodine and organic iodine, no. 4 DR. KRESS: Well, my concern about is having it 5 removed from the design basis when actually it may be a very 6 useful device to have if one had FC curve criteria. 7 DR. APOSTOLAKIS: That was my question. Has 8 anybody.done these calcu2ations to see, you know, how 9 sensitive the curves are to changes of this kind? 10 DR. KRESS: No. I don't think so. I haven't seen 11 it, I have looked. j i 12 DR. APOSTOLAKIS: Well, we do have a set of curves 13 from NUREG-1150, so I don't know how -- 14 DR. KRESS: How sensiti're they would be to 15 something like that. 16 DR. APOSTOLAKIS: -- feasible it would be to do 17 the calculations. Bob says no. 18 MR. LEE: You mean with and without charcoal 19 absorbers? 20 DR. KRESS: Yes. 21 DR. APOSTOLAKIS: Yes. Or other changes. I mean 22 we have been talking about the FC curves. 23 DR. KRESS: I don' t know how sensiti"re they are. 24 That is a good question, because that is the que.stion. If 25 they are not sensitive, who cares? f) U ANN RILEY & ASSOCIATES, LTD. Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 ! Washington, D.C. 20036 ) (202) 842-0034 I i
T-203 1: 'DR. APOSTOLAKIS: Yeah. 2 MR. SIEBER: (} Well, I think from a practical l 3 standpoint, Perry at one time had a history _of fires. 4 DR. KRESS: Well, yeah, it may have other -- it 5 may have risk implications that are different, you are 1 6 right. 7 DR. APOSTOLAKIS: That is an interesting point. I l 8 DR. KRESS: But that has been my problem with CDF 9 and LERF all along. These kinds of things don't really get 10 captured in it. 11 . DR. APOSTOLAKIS: They are summary measures as you 12 said. I think we need to understand that a little better. 13 DR. KRESS: Yes. But, anyway, it doesn't impact 14 this at all, it is just a side issue. () 15 DR. APOSTOLAKIS: Yeah, that is why he is happy, 16 MR. LEE: You know, of course they do have HEPA
- 17. filters and this NUREG-1465 source term itself, more than 95 18' percent of iodine is in.the form of aerosol, which is 19 subject to be removed by HEPA filter.
20 Control room HVAC initiation, now they were able 21 to delay that for 30 minutes. Also, control room charcoal 22 absorber efficiency, they were able to reduce from 95 to 50 23 percent, they degraded charcoal absorber in the control room 24 emergency filtration system. They were able to increase 25 allowable engineered safety feature leakage from 10 to 15 t ANN RILEY & ASSOCIATES, LTD. Court Reporters ! 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
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6 204 1 gallons per hour. This is leakages outside the containment, 2 such as ECCS system. 3 They were also able to increase allowable 4 containment bypass leakage. There the primary containment 5 is designed to leak .2 percent per day leak rate. From that 6 .2 percent per day leak, I think they used 7 percent of that 7 will bypass the annulous or shield building, go discharge 8 directly to the environment. Now, they were able to 9 increase that to the 50 percent from previously assumed 7 10 percent, so it goes from 7 percent to the 10 percent. 11 Now, for the control room unfiltered air 12 inleakage, I set it here high. We used -- the licensee and 13 NRC both used unfiltered air inleakage of 1,300 CFM, which 14 is very inleakage indeed. 15 DR. KRESS: Yeah, but it matches some of the 16 measurements that have actually been made. 17 MR. LEE: This inleakage, what they do is in the 18 current tech spec, they are required and that they are doing 19 this, a positive differential pressure test 18 months. And 20 they do not have any toxic chemicals stored at the Perry 21 site. And with this high inleakage rate, they were still 22 able to meet 25 -- excuse me, 5 rem TEDE in the main -- the 23 control room operator. 24 DR. KRESS: That's good. 25 MR. LEE: So I guess this is my feeling that not ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1 .
205 1 every reactor need such as trace, I guess, test, for
) 2 example. This is really highly specific to the plant 3 design, the way they design the control room. So a plant 4- with such a high inleakage 1,300 CFM, and if they have a 5' . positive differential pressure test in the containment 6 relative to'the surrounding buildings and with no toxic 7 chemicals, I believe they certainly can get by with 8 differential pressure testing rather than going through such 9 as more detailed trace gas testing.
10- DR. WALLIS: 'As long as it only an air inleakage 11 and not that the net inleakage is a result of in and out, 12 because if you have in and out, there is a net and something 13 coming from a place where the air isn't clean, -- 14 MR. LEE: The Perry -- () 15 DR. WALLIS: -- it will make -- it will 16 contaminate. 17 .MR. LEE: Right. 18 DR. WALLIS: It is the just net effect, there is a 19 net balance in, it doesn't mean they are okay. 20 MR. LEE: That's right. Well, Perry control room 21 have the ability, envelope design is such a way there is no 22 other, any duct work, for example, going through that that 23 envelope, so there is no other contaminated source 24 potentially leaking into the envelope. So, as I say, this
- 25. is very specific to each control room ventilation design.
( ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 j (202) 842-0034
I 206 1 In the case-of Perry, we felt that this positive l j [-) x-2 differential pressure test is sufficient with such high 3 inleakage assumed with no toxic chemicals stored onsite. 4 DR. KRESS: The transient toxic chemicals that go 5 by is sufficiently low in probability that you don't have to ) 6 worry about those? 7 MR. LEE: Right. I believe there are no major 8 highways or railroad or any such transportation pathways l 9 near or through the Perry plant. 10 DR. KRESS: We can't assume that this would be a 11 general thing for other plants, though, because they have 12 the chlorine stored onsite. 13 MR. SIEBER: Roads. 14 DR. KRESS: Roads going by. s 15 MR. BARTON: Near highways where you have got 16 chemical trucks. 17 DR. KRESS: So this would be plant-specific? l 18 MR. LEE: Right. Very plant-specific. And then 19 we feel some plants do need trace gas testing, for example, 20 but not every plant. It really depends on design-specific 21 nature. l l 22 DR. WALLIS: When we heard about control room l l 23 habitability, there seemed to be a tremendous uncertainty in l l 24 just where the flows came from and went to, and how much 25 leakage there was. The uncertainties were enormous. ANN RILEY & ASSOCIATES, LTD.
\ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 tu
r 207 1 MR. LEE: Once you are able to maintain a positive ; () 2 pressure during normal operation in the control room L 3 habitability envelope, I think you are safe to say that -- l 4 DR. WALLIS: Assume nobody opens the door. l-L 5 MR. LEE: Well, the do open the door, but here you l 6 will see the tolerance they have, like with 1,300 CFM 7 inleakage, their control room operator dose was 4.1 rem l j 8 TEDE. Now, they still have room to go to the 5 rem TEDE. l 9 DR. KRESS: Not much. l
- 10. MR. LEE: About 20 percent or so. So, in fact, l l
11 you are saying then, 1,375 CFM plus minus 20 percent. And I 12 their recirculation rate is I believe in the order of 20,000 13 CFM, so you are talking about 10 percent inleakage in the
- 14 air. That is a lot.
'Q ( f 15 DR. KRESS: When they calculate the TEDE, for the 16 control room, do they take credit for masks? 17 MR. LEE: No, they do not. 18 DR. KRESS: No credit for donning protective 1 19 equipment. I 20 MR. LEE: No. No KI either. This is strictly -- 21 DR. KRESS: No KI either. Okay. It is strictly 22 if they were standing there breathing this stuff in? 23 MR. LEE: Right. We did not count that aspect in ? ! 24 the dose calculation to come out with 4.1 rem TEDE, for 25 example.
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7 208 1 Last - during the subcommittee meeting, Dr. I 2 Kress, you asked me about the dose numbers using a TID 3 ' source term against the NUREG-1465. 4 DR. KRESS: I did?
- 5 MR. LEE: Yes.
l 6 DR. KRESS: Okay. I l 7 MR. LEE: So these are the numbers then, using a 8- TID source term, the site boundary dose was 140 rem thyroid,
- 9 not the TEDE, and the dose criteria is, of course, 300 rem, 10 so they were about halfway. Now, with the NUREG-1465, they 11 calculated it to be, site boundary to be 22 rem TEDE and 12 .they are more closer to the limit, which is 25 rem TEDE.
i 13 For control room operator using a TID source term
~
14 at the .29 rem thyroid and, of course, 30 rem is those l 15 criteria and so they are very close to the limit. 16 DR. KRESS: The questions I have about this is if l 17 the 22 rem is to site boundary? 18 MR. LEE: Yes. l 19 DR. KRESS: Is that without any of the changes? I l 20 .mean, is that -- does that -- ! 21 MR. LEE: With all the relaxations. l l 22 DR. KRESS: That's actual relaxations? 23 MR. LEE: Yes. 24 DR. KRESS: Rem 40 is without any relaxation? ;
)
25 MR. LEE: Without any relaxation and using the TID 1 O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014
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p 209 1 source term. 2 DR. KRESS: And using the TID? 3 MR. LEE: Yes. 4 DR. KRESS: So, actually, I guess I was -- okay. l 5 I appreciate that; thank you. 6 MR. SIEBER: It almost appears to be on the same 7 calculation as in -- l 8 DR. KRESS: Well, I thought you would have gotten 9 something like -- 10 I MR. SIEBER: Yes, 250. l 11 DR. KRESS: Yeah, that's what I would get. 1 12 MR. LEE: For site boundary, yes, they had the j 13 larger margin than now. The margin just -- l 14 MR. BOEHNERT: You have 1.o speak closer to the 15 microphone. 16 MR. SIEBER: 'Okay. 17 MR. LEE: On the other hand, the control room, as l l 18 you can see, they were almost up to the most acceptance l -19 criteria and now, it's more -- there's about 20 percent or
- j. 20 so difference.
21 Now, here is -- Dr. Kress, you expressed about the i 22 Ph control. The iodine source term management, you know, 23 this TID source term, we deal mainly the iodine for thyroid 24 dose and normal gas for whole body. Now, we went to the 25 TEDE concept, which considers not only the thyroid and whole
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p i 210 1 body. dose, but other organ doses along with it. So, 2 therefore, I suppose the importance of iodine is perhaps a 3 little bit de-emphasized; but, nevertheless, we believe 4 iodine is still major, critical isotopes that we have to 5 deal with,- because iodine has such a unique characteristics 6 of it being a volatile nature. 7- DR. KRESS: Yes, very biologically effective -- 8 MR. LEE: Right. 9- DR. KRESS: -- because, it goes straight to the 10 thyroid. 11 MR. LEE: They can -- they can petition from the ! 12 liquid phase. -They can, also, petition from deposited l 13 sulfates. So, it's really -- if it can control the iodine 14 source term, we believe really you can control the efficient 15 part of that behavic and transport in a reactor accident. 16 So, our first line of s'efense is then the Ph control. We do 17 that by adding -- or using the chemical additives, such as 18 trisodium phosphate or sodium pentaboric, in the case of a 19 petty station. 20 DR. KRESS: Which reminds me, I need to detract a l I 21 conflict of interest on the Ph control part of this, because l 22 it's based on some work done at Oak Ridge that I was 23 involved in. That's just for the record. 24 MR. LEE: Okay. So, the purpose of this Ph l 25 control is, of course, to mitigate iodine petitioning into i
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-(202) 842-0034 ,
211 1 the containment atmosphere form either PWR sub-water or PWR () 2 3 suppression pool. In other worde, you just keep iodine in the water. 4 The second line of defense is then its containment 5 spray, even thcugh containment -- main purpose of having a 6 containment spray, is, of course, containment pressure 7 reduction. But -- 8 DR. VALLIS: That's to put it in the water. First 9 of all, you keep it in the water and then the spray puts it 10 in the water. 11 MR. LEE: Yes; right. The spray puts into it; the 12 Ph will keep it there. And in the case of spray, of course, 13 removal of iodine in the aerosol and elemental forms, it 14 doesn't remove organic. On the other hand, organic portion () 15 of iodine is relatively small. 16 DR. VALLIS: Is it advantageous to put something 17 in the spray that absorbs or interacts with iodine or is 18 just the salability good enough? 19 DR. KRESS: No , no, you need something in there 20 for it to be effective. 21 DR. VALLIS: Something to mop up -- 22 DR. KRESS: Right. 23 DR. VALLIS: What do you put in the spray? 24 MR. LEE: The additives, such as sodium hydroxide. 25 The stuff will increase the removal efficiencies. l ANN RILEY & ASSOCIATES, LTD. \- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 j (202) 842-0034 l J
r l 212 l 1 The last line of defense is the engineer safety () 2 features filtration, of course. This filter will remove all 3 forms of iodine. It is a safety-related system and we're 4 depending on these filters to remove all iodines. 5 DR. VALLIS: It removes all forms of iodine? 6 MR. LEE: Including organic iodine, yes. 7 DR. VALLIS: Gaseous forms of iodine, combined 8 with gas? 9 DR. KRESS: These are activated charcoal filters. i 10 MR. LEE: Yes, they are activated. l 11 DR. VALLIS: Not just filters, they're absorbers. 12 MR. LEE: Well, charcoal absorbers and hepa 13 filters and they are impregnated filters. 14 My last slide is some of the items that -- for our
) 15 future consideration,'all the iodine source to management in 16 the reactor accident. These are the areas that we are 17 looking into and for the future studies and following this 18 technical topics. The chemical form of cesium. Of course 19 with cesium, we think cesium will be in a cesium iodine or a 20 cesium hydroxide or cesium carbonate, all different form of 21 chemicals, including cesium molybdate. Cesium is really 22 much more abundant and efficient compared to iodine. So, we l 23 think --
24 DR. KRESS: Ten times as much. 25 MR. LEE: Ten times, yes. So, cesium iodine will ANN RILEY & ASSOCIATES, LTD. k Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
L 1 213
-1. represent about 10 percent and the rest of the 90 percent j.
() 2 will-be in some form of the chemical forms.
~3 DR. KRESS: .How do you expect to control the j l
4- chemical form of cesium? i 5 MR. LEE: Control them? , L 6 DR. KRESS: Anywhere? i Cesium is in aerosol form. 7 MR. LEE: 8 DR. KRESS: Yes. But the time it gets to the 9 control room, it's probably carbonate. 10 MR. LEE: Yes. Cesium carbonate or, of course, . 1 11 even cesium bicarbonate reacted with the carbon dioxide in -j 12 the' air. l 13 DR. KRESS: But, I don't know what you do with it- l l 14 then. It's pretty well fixed? l () 15 MR. LEE: But still in the form of aerosol and 16 subject to be removed by filtration. 17 DR. KRESS: Oh, yeah, you can do that. 18 MR. LEE: Yeah; right. 19 DR. KRESS: You didn't intend for that bullet to 20 'mean you're going to do something to change the chemical 21 form of cesium; you're just going to deal with it? 22 MR. LEE: Right. 23 DR. KRESS: Oh , I see. 24 MR. LEE: Yes. 25 DR. KRESS: Okay. jO ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
f~ 214 1 MR. LEE: And, also, we are looking into formation [N 2 of organic acid in containment water and the suppression 3 pool due to any organic compound going into the sump. For l 4 example, painted surfaces or that type of a material going 5 into the sump and get irradiated and -- l 6 DR. VALLIS: You put something in the sump, which 7 could be almost as bad as some of the mixes in the tanks at ,
- 8. Hanford.
3 9 DR. KRESS: Not quite. 10 DR. VALLIS: All this stuff in there. 11 MR. LEE: Right. And this will include some 12 formation of weak acid. And, also, the other area we're 13 interested is silver reaction from the typical most of the 14 Westinghouse type reactor control route, which consists of
/~N
(,,) 15 silver, and the silver reacted with iodine become insoluble 16 silver iodine. So, it, again, retains the silver in the 17 liquid phase. 18 DR. VALLIS: Why do you do all these things with 19 the cesium and iodine, which are fine for short-term? There 20 are other things in a really severe accident, like 21 actinides, which come out. Now, if you -- 22 MR. LEE: Actinides -- 23 DR. VALLIS: -- the chemistry for cesium purposes, 24- you make it worse for the actinides purpose. 25 MR. LEE: Well, if you look at the NUREG-1456, the ANN RIL3Y & ASSOCIATES, LTD. ('s- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
~
215 1 magnitude of cesium release is much, much greater than --
~s ~
2 DR. VALLIS: Oh, this is the beginning; yeah, 3 that's right. Eventually, you'll have to worry about what 4 happens'to other things, too. 5 MR. LEE: Such as, right, tellurium or -- 6 DR. VALLIS: Right. If it's like the tanks at 7 Hanford, everything is in there, in some form or other. 8 MR. LEE: That, we have really no source for. 9 DR. KRESS: I think from a long time, cesium will 10 probably control your problems from the long-term and the 11 iodine early on. 12 MR. LEE: But, particularly, cesium has such a 13 long half-life than iodine. 14 DR. KRESS: It's got a long half-life. And it's 15 active and it's in there in abundance, so I think it's 16 probably the one to worry about-for long-term. 17 MR. BARTON: It's the one you worry about during 18 -TLI cleanup for four or five years -- 19 DR. KRESS: Yeah. 20 MR. BARTON: -- with cesium. 21 DR. KRESS: Sure. 22 MR. SIEBER: Just to clarify in my own mind, I had 23 the impression from somewhere that a charcoal absorber 24 really doesn't absorb iodine; it just delays emission 25 through the absorbent path; is that correct? 'O ANN RILEY & ASSOCIATES, LTD. \w / Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 843-0034
m 216 1 MR. LEE: It's really one we call chem absorption. () 2 It does react -- 3 MR. SIEBER: To some extent. 4 MR. LEE: Some. extent with impregnated charcoal. 5 And, yes, you are quite.right, it delays, also, yes. That's 6 the benefit, as well. 7 DR. KRESS: You want to delay it long enough for 8 it to decay. 9 MR. SIEBER: Well,-from the licensing standpoint, 10 you're interested in TEDE for 30 days. 11 MR. LEE: Yes. 12 MR. SIEBER: The fact that you're actually 13 delaying the emission, is that significant from the 14 standpoint of that 30-day licensing basis for -- () 15 MR. LEE: Charcoal absorber will not give you l 16 30-day delays. You will delay somewhat, but -- 17 DR. VALLIS: Picks it up again? 18 MR. SIEBER: To some extent. 19 MR. LEE: It stays with the impregnated charcoal 20 absorber. 21 DR. VALLIS: That must be interesting, then, 22 charcoal filter saturated with iodine. It must be 23 interesting to deal with later on. 24 MR. LEE: The removal capacity is in such a way 25 that it has a great exchange capacity and it will reactivate e ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
i l 217 i . 1 iodine and hold on to it supposedly. It's a chem absorption , I"'1 2 process; chemical, as well as a physical exchange taking 1L) 3 place in the impregnated charcoal. 4 DR. KRESS: Especially for elemental, it latches 5 onto it. Organic iodines will tend to move on through; but 6 the elemental, it will latch onto it and stay there. 7 MR. LAVIE: Excuse me, my response to Mr. Sieber's 8 question, I_believe -- the treatment systems, where you have 9 low fluorides, it typically takes credit for the absorption 10 of hold up of xenon and noble gasses in the filter. But the 11 filters we're talking here have fluorides of 30,000 cfm 12 through them; the hold up is going'to be negligible, 13 compared to the chem absorption. 14 MR. SIEBER: Okay; thank you. l ( ,) 15 DR. VALLIS: And then once you've got the iodine 16 in the charcoal and other things come along, you have all 17 sorts of secondary chemical reactions, as other things come 18 along and interact with the iodine that may be freed up. 19 MR. LEE: That's a potential problem, you are 20 quite right, such as a chlorine gas, for example. Chlorine 21 will degenerate it, as a decomposition of organic material 22 inside the containment. So if chlorine comes along after 23 you remove and retain the iodine in the charcoal, then how 24 would that react? It appears that they are looking into l 25 that. We are certainly following it with an interest. l
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j-218 1 DR. KRESS: Are these mostly part of operative
\
! [O 2 programs with -- 3 MR. LEE: Yes, such as PHEBUS test, for example. { 4 And the other item is zinc polymer. Zine is, also, reacting 5 l l with iodine and it will. retain in the containment -- I mean, 6 iodine in the containment. Zine will react with iodine, 7 will hold on to it on the paint surface, if you have a zinc 8 polymer paint, for example. So, these items -- 9 DR. VALLIS: It just seems to me, you refer to l 10 Europeans as if they were one species. l 11 DR. KRESS: You resent being locked in with the
- 12 French, do you?
13 DR. APOSTOLAKIS: Certainly not with the Greeks, 14 though. l l
^f~
r 15 [ Laughter.] 16 DR. SEALE: Mr. Churchill said give the Americans 17 50 years-of occupation time. 18 DR. VALLIS: And? 19 DR. SEALE: And -- 20 MR. LEE: So, I listed these items to show you l 21 that even though we do have the text and source term and we 22 will have sometime next year final Regulatory Guide, but l 23 that's not really the end of it. We will continue to l 24 improve and will continue to interact with stakeholders. 25 And as more additional information come along, we will be ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l L
219 1 . revising at times the Regulatory Guide and sometime in the ; rs l () 2 future even source term. And we will have branch technical l 3 positions or somebody will communicate with our licensees 4 and the applicant, if we are sure we have more additional 5 and technical information on these subject areas. ' 6 That ends my presentation on the pilot plant 7 review program. Do you have any questions? l 8 DR. KRESS: 'Are there any questions for Mr. Lee? 9 -DR. VALLIS: I think one result of the pilots will 10 be to identify these areas where you need research. That's i 11 one of the purposes, isn't it? ! 12 MR. LEE: Well, yes, but I don't think the pilot 13 program review, itself, will give any answers to these. 14 DR. KRESS: I don't think so either, because 15 you're not going to have any tests in those pilots for you 16 to actually put the source term in. 17 MR. LEE: We do have interest, though, Dr. Kress, 18 that if you can give us some -- some suggestion or guidance, 19 perhaps in which item is perhaps more cost beneficial -- 20 DR. KRESS: Oh, yeah. 21 MR. LEE: -- we ought to more closely follow. 22 It's sort of setting a priority. And I think Dr. Powers, 23 during the last subcommittee meeting, he expressed great 24 interest on these areas. 25 DR. VALLIS: I think we have suggested that when [ ') N-ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l l l 220 1 you do pilots, it's good to have a list of the things you () 2 expect to learn from the pilot -- you know,.which questions 1 3_ to keep asking; you know, which areas are cost effective or . l 4 which areas are most important and so on. 5 MR. LEE: Right. Yes, we could develop such 6 lessons learned -- 7 DR. VALLIS: Lessons you expect to learn. 8 MR. LEE: Right. 9 DR. VALLIS: Even then some already. 10 MR. LEE: We'll look into that. 11 DR. KRESS: More questions? 12 (No response.] '
.13 DR. KRESS: Seeing none, I wish to thank Jay and 14 Mr. Lee, very good presentations, very informative, and we 15 appreciate it very much.
16 MR. LEE: Thank you, very much. 17 DR. KRESS: I'll turn it back to you, Mr. 18 Chairman. 19 DR. APOSTOLAKIS: Thanks. Okay, we'll recess 20 until a quarter of. 21 [ Recess.) 22 DR. POWERS: Let's come back into session. The 23 next subject we have has to do with control room I l 24 habitability during a toxic gas release event. The members 25 'have in front of them a digest of some of the information O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
1 l 221 l 1 that came out of the subcommittee meeting on this -- ! ()
)
2 reviewing this Regulatory Guide. The safety issue is that 3 accidental release of noxious chemical on or in the vicinity 1 4 of a nuclear power plant could debilitate the operators. j 5 Noxious chemicals are indeed on many of the nuclear power ! 6 plant sites and noxious chemicals are used near nuclear 7 power plants. 8 The regulatory objectives of this Regulatory Guide 9 certainly include providing the licensees with less 10 burdensome and more realistic information on acceptable ways 11 to analyze the magnitude of the threat posed by noxious ; 12 chemicals and acceptable ways to mitigate the threat. They 13 are anxious, also, to reduce the shutdowns due to spurious 14 alarms. And finally, they're trying to combine the guidance r"' ) ( 15 that's available now for offsite chemicals and on-site 16 chemicals. One of the important issues t.o bear in mind in 17 looking at this item is its risk significance. And I notice 18 in looking in the speaker's view graphs, that he'll go into 19 that in sowe detail. 20 Scme of the key elements in the approach that the 21 members will want to pay attention to is they do provide 22 screening criteria for when the licensee needs to consider ! 23 chemicals offsite, based on distance away from the site, the 24 frequency of which chemicals are shipped, and the mass of 25 chemicals that are available. They are endorsing an [~ ANN RILEY & ASSOCIATES, LTD.
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222 1 approved model for the dispersal of chemicals on the site, () 2 3 the HABIT code. They are providing some limits on the control room concentrations, which actions have to be taken 4- to protect the operators. And the final sheet provides the 5 members with some indication of the points that we might 6 want to raise in some report to -- on this particular piece 7 of work. 8 With that introduction, I'll turn to the speaker, 9 I guess it's you, Sud, and introduce Sud Basu from the 10 Office of Nuclear Regulatory Research, who has been given 11 responsibility -- I don't know how he's taken responsibility 12 -- but he has been given responsibility for this Regulatory 13 Guide. 14 MR. BASU: That's a very correct accura:ation. A () 15 comment: we do anticipate writing on this particular 16 subject. 17 Good afternoon. I'm Sud Basu. Can you hear me? 18 I'm Sud Basu, the Office of Research. I was actually hoping 19 that your previous presentation would run late. 20 [ Laughter.) 21 MR. BASU: I didn't hope to speak too much. 22 , MR. BARTON: Well, when you see 7:00, you'll get 23 off. 24 [ Laughter.) 25 DR ., POWERS: You see, Sud, this is part of our g ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 (202) 842-0034 m
[ 223 1 performance improvement program. () 2 MR. BASU: I'm really impressed. 3 Okay. Well, what I want to do is give you a i 4 rundown on the proposal to revise Regulatory Guide 1.78, 5 dealing with the evaluation of control room habitability, 6 given a toxic chemical release -- toxic chemical gas 7 release. The presentation was given before the Subcommittee 8 on Severe Accidents. It was about three weeks ago, I 9 believe August 9th and 10th. It is going to be pretty much 10 the same presentation, with some very minor changes. Those 11 subcommittee members, who heard my presentation previously, 12 please excuse. If you are getting bored, you have the 13 permission to snooze. 14 DR. POWERS: And they certainly don't have the
) 15 permission. We'll be looking for any slight discrepancy 16 between what you said before and what you say now.
17 DR. VALLIS: I think you should look for the 18 hazardous chemical release, if we all start snoozing. 19 [ Laughter.) 20 MR. BASU: Talking about discrepancy, I was 21 reading the transcript from the subcommittee briefing and I 22 notice the transcript says, at some point when I was 23 introducing myself, that I'm not a chemist and then I went 24 on to say I'm not a toxicologist, but the transcript says 25 I'm a toxicologist. So, please make that correction, I'm i l
~
ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i I
l . 224 1 1 not a toxicologist. () t 2 DR. POWERS: So, we shouldn't be asking you about 3 MLH and IDLH.and the differences between the two. 4 MR. BASU: You can certainly ask me; but whether l 5 you get an answer, that's another thing. 6 The presentation outline: I'm going to give you a l 7 brief introduction and background; and then, I'll -- you're 8 going to get the post-revision to Regulatory Guide 1.78. I 9 will attempt to give you a reasonably clear regulatory 10 analysis of the post-revision. I know we talked about it in 11 the subcommittee briefing and I certainly expect that we'll l 12 discuss more about it in this meeting. And then, finally, 13 schedules and milestones, with the conclusion of the 14 activities.
) 15 Before I get into this, I should also acknowledge 16 that Mr. Chris Parczewski from NRR is here in the audience.
17 Please, if you'll raise your hand. He is the user of the 18 product. So, if you have any regulatory questions, 19 concerns, he's certainly the person that they should be 20 targeted to. 21 Regulatory Guide 1.78 has to do with the control j l 22 room habitability regulation during a postulative release or 23 accidental release of hazardous -- 24 DR. VALLIS: The accidental term, I'm not sure 25 that's good, because if I wanted to sabotage and there are h - ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 I
225 1 chemicals on site, this might be a way of doing it. I mean, ( 2 someone who willfully -- since the probability is so low 3 anyway, I think you shouldn't ignore a willful release. 4 MR. BASU: You mean accidental and non-accidental? 5 DR. VALLIS: Not non-accidental, the willful 6 release. 7 MR. BASU: Or intentionally accidental -- 8 DR. VALLIS: Yeah. 9 MR. BASU: -- so to'say? Okay. 10 DR.' VALLIS: They may be made to look like an 11 accidental. 12 MR. BASU: Your point is well taken. The title of 13 the Regulatory Guide says during a hazardous chemical l 14 release. It does not distinguish between accidental and () 15 other form, as in my description. Thank you. 16 And, of course, the list of hazardous chemical 17 does include chlorine. And I mention that because there is 18 a separate Regulatory Guide, which deals with the on-site 19 release of chlorine. That's 1.95. That was published about 20 three years later, three years from the application date of 21 Regulatory Guide 1.78. And one of the purpose of this 22 revision is to combine 1.95 with 1.78, those appropriate 23 changes and revisions. l l 24 By way of background, you are familiar with the I 25 generic safety issue 83, control room habitability, in a O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
i 226 1 broader context. You heard a presentation -- subcommittee () 2 3 presentation, also, about a month or so ago on that. issue led to the -- led to reassessment of control room That ] 4' habitability and control room exposure to toxic chemicals. 5 And of course, the. work that went on resulted in new 6 information on toxicity limits and new information on f 7 atmospheric dispersion modeling. NRR identified subsequently I 8 a need to revise Reg Guide 1.78, incorporating this new 9 information on toxicity limits and atmospheric dispersion 10 modeling and asked Research to carry out that task. 11 DR. POWERS: This raises the issue of when we look 12 at the probabilities that are recorded in the Reg Guide, 13 they're all down in the 10 to the minus seventh per year for 14 plant kind of event. That's a pretty low prcbability of () 15 occurrence -- 16 MR. BASU: That's correct. 17 DR. POWERS: -- especially if you think the 18 . conventional estimate on the probability that the reactor 19 vessel will shatter and fall apart is 50 times that -- those 20 numbers. I guess I can't help but wonder why didn't NRR 21 just decide to dispose of this Reg Guide. 22 MR. BASU: Good question. I'm not sure if I'm 23 really that qualified to answer that, NRR being the user of i 24 the Reg Guide. i 25 DR. POWERS: Now, you told us you got a Reg Guide ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
227 1 -- reg person here. () 2 What I can tell you -- and I think you have it in 3 your handout, if you flip to page -- I'm jumping to page 14, 4 and that kind of gives you a synopsis of operating license ! 5 amendment applications over the last 10 years. There, of 6 course, many more applications. These five were taken out 7 as an example to illustrate that there are applications from 8 the operating licensees for amendment of the toxic gas 9 monitoring system or surveillance of that or something that 10 has to do with the detections, especially for the chemicals, 11 the isolation of control rooms, etc. So what I'm leading to l 12 is that there is -- these applications do come to NRR and 13 NRR has to review these applications and make some judgment 14 as to whether or not the amendment should be a code. 15 DR. VALLIS: Well, I'll ask you though, in i 16 relation to Dana's point now, I'm not sure that's the right 17 measure. The spill of noxious chemicals, which led to 18 debilitation of the operators, would be a significant event, 19 whether or not it led to core damage. I'm not sure that l i 20 core damage frequency is the right measure of concern that 21 should be given to this sort of an event. I mean, it just i 22 seems to me that there may well be noxious chemical spills, j ! 23 which seem to me far more likely than vessel failures, but , 24 they won't lead to core damage. The fact they won't lead to 25 core damage doesn't mean to say you shouldn't defend against () ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 j Washington, D.C. 20036 (202) 842-0034
228
-1 them.
l () '2 3-MR. BASU: risk analysis part of it. Well, actually, maybe I can jump to the But, if-you look at maybe a 4 couple of view graphs-before -- l 5 DR. POWERS: Well, don't let us disrupt your 6 presentation, but we can come to risk analysis when -- as 7: you want to. Let me -- let me -- well, we'll come to that. 8_ _Let me ask this question: suppose I am a licensee and I 9 say,; gee, I'm tired of these toxic gas measuring systems and 10 all the headaches they cause, Can I come in under 1.174 and 11 this Reg Guide and say, I've looked at my site and, indeed, 12 the probabilities calculated in the Reg Guide are bounding 13 for my particular site and the delta risk I have is cne 14 times 10 to the minus seven; I have done my IPE and I know
) 15 my CDF is three times 10 to the minus four; so, you've got
-16 to let me do this?
17 MR. BASU: But, that's what these amendment 18 applications are. They don't -- I mean, I haven't seen in 19 these direct reference to IPE or IPEE, but they do go as far 20 as giving you the CDF for this kind of events that goes to 21 10 to the minus seven or even more of that 10 to the minus 22 seven. And then they say, well, because that's what it is, 23 could I sort of do away with PGMS or, you know, frequent 24 surveillance or whatever is currently required. ; 25 DR. POWERS: To be fair, they don't really get rid i l ANN RILEY & ASSOCIATES, LTD. O- Court Reporters j i 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
229 1 of it. They take it out of the licensing basis. I t () 2 3 MR. BASU: DR. POWERS: Yes, that -- I bet your chlorine tanks still has a 4 detector on it. 5 MR. BASU: And physically taken out of the system. 6 They just don't do -- 7 DR. POWERS: Yeah. 8 MR. BASU: -- the surveillance as currently 9 required. 10 DR. POWERS: I guess -- I mean, what all of that 11 . leads up to is that it strikes me, in reading the Regulatory l 12 Guide, that it hasn't been written with a great deal of 13 recognition that this could be the chain of events that 14 somebody followed; that they -- the risk is low, the delta () 15 CDP is low, so I can put in an amendment under 1.74 and get 16 rid of the thing. 17 An alternative approach to writing 1.78 would have 18 been to say this is what the licensee is going to do. And j 19 so, the guidance would provide them with here are the kinds 20 of things we expect to see when they do this and essentially 21 alert the licensees, we're going to ask this question, this 22 question, this question and we expect to see these kinds of 23 numbers and if you want to get rid of it, you can do it this 24 way. l i 25 MR. BASU: So, would you go one step further O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
230 1 saying that you subsume all these things into 1.74? [ } 2 DR. POWERS: Well, the next question is, do we 3 really need it at all. 4 MR. BASU: I don't know. Chris, would you like to 5 field that question?- 6 MR. PARCZEWSKI: Chris Parczewski, the Chemical 7 Engineering Branch. What was exactly _the question? 8 DR. POWERS: Well, the probabilities that are 9 _ quoted in 1.78, example probabilities are extremely low for 10 CDF. There are a few times 10 to the minus seventh. With 11 the 1.174 Reg Guide, people can make arguments for 12 eliminating -- or amending their license, based on small 13 changes in CDF. This certainly qualifies as small. You got 14 rid of the whole thing. You're making a small change in () 15 CDF, almost regardless of what the current CDF is that would 16 qualify as small. And so I'm asking two questions really: 17 why we need the Reg Guide, if we're dealing with small risks 18 like this; and the second question is why wasn't -- if we're 19 going to keep the Reg Guide, why wasn't it written in a 20 fashion that would facilitate licensees, making applications j 21 to eliminate their toxic gas measuring system based on 22 1.174? 23 MR. PARCZEWSKI: Well, I think that what'we are 24 saying is that it's probability of core damage due to the l 25 incapacitating the operator is very small. As a matter of l O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 , Washington, D.C. 20036 (202) 842-0034 i
231 1 fact, this argument is being said by several of the (],, 2 licensees and we are accepting this type of analysis. 3 However, several of them are still submitting the whole 4 analysis. And this is -- I think that the only application 5 that would be -- the probability of incapacitating the 6 operator is very high -- much higher. It's probably very 7 few cases it's going to happen; but, you know, as a 8 precaution, in case it happens, you know, we should have the 9 guide. And some -- there are a lot of licensees still 10 submitting their probability -- the deterministic analysis. 11 I mean, they're still using that, you know, approach. 12 DR. POWERS: And they're asking for changes in l 13 their licensing basis, based on -- for what? What are they 14 using this Reg Guide for, other than getting rid of the O)
's , 15 PGMS?
16 MR. PARCZEWSKI: Well, they are using it to 17 determine their -- if their operators are incapacitated. In 18 most of the cases, apparently, they have enough margins, so 19 the operator is not getting incapacitated. You know, there i 20 are two -- there's two minutes criteria. As long as the 21 toxic gas doesn't reach the limit of toxicity, in two 22 minutes, the operator has probability to get the equipment 23 -- breathing equipment and he's not incapacitated. 24 DR. POWERS: I guess I'm still a little lost. I 25 look at these events back here and I see since 1991, the O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
232 1 ones that'are quoted, they all eliminate expect requiremento 2 for PGMS, for surveillance requirements. So, it appears 'f) 3 that this particular Reg Guide is used largely for amending 4: the license to get rid of some requirements. 5 MR. BASU: If I may just interject here, that 6 simply is wrong use, at least that's what's illustrated in 7 this view graph. There is -- it's used where you are 8 actually providing guidance for the operator protection in 9 the control room. You have a spill and you won't know what 10 sort of. concentration level an operator is going to be 11 subjected to, so you need to do some_ computation, l 12 calculation, or what not. And the Reg Guide is providing. 1 13 some guidance for you to be able to do so. It's providing 14 guidance to the licensee. It's providing guidance to the () 15 NRC staffer.to review the license applications. So does l 16 that answer your question? 17 DR. POWERS: Well, I think I'm going to go on. 18 Maybe we'll come back to this after we get to the risk 19 analysis. 20 DR. VALLIS: I'm sitting here wondering why you're 21 concentrating only on chemicals in the control room. If you 22 have on-site major chemical release, it might well be a 23 result of a vehicular collision, in which case it might well 24 be fire as well. You'd have to worry about the effect of 25 the' toxic on the fire brigade and everything, as well as the i [ : ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014
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.233 1 control room people. ;
1
- .2 MR. BASU: Absolutely. There is -- I 3 DR. VALLIS: It's all tied together, 4 MR. BASU: There is a separate Reg Guide --
5 separate Reg. Guide -- 1.120 on' fire. ) 6 DR. VALLIS: But, they actually overlap? 7 MR.'BASU: Yes. I mean, in the broader context of 8 control room habitability issue, all these things do tie 9 together. I'm addressing just a very narrow aspect of 10 control room habitability. 11 DR. VALLIS: But the event might well involve then 12 several Reg Guides simultaneously --
- 13 MR. BASU
- I would --
l L 14 DR. VALLIS: -- analysis of such an event? 15 MR. BASU: -- certainly think so, yes. 16 I think we're done with this view graph. I'm 17 going to go through very quickly, and I think we've kind of 18 touched upon it already in our discussion, as to how the Reg 19 Guide 1.78 process works, as to the screening measures for 20 determining releases that must be considered for control 21 room habitability evaluation. And I have given you in the i J 22 following bullets these screening measures. 23 The first one is the distance screening. All it 24 says is if this release occurs at a distance more than five 25 miles from control room, then you not consider -- you do not O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r l l I l 234 1 need to consider it. It's screen out. l 2 The second -- I 3 DR. VALLIS: Is this based on analysis of typical 4 events, say train collisions or derailments and things like l 5 that?
)
6 MR. BASU: I think it's more of the former. It's 7 based on analysis, if you have a spill of some magnitude of 8 that distance and if you do use the dispersion model to see 9 what the concentration is going to be five months downstream 10 and you find that the concentration level is either zero or 11 very small -- 12 DR. VALLIS: Five months doesn't seem much for a 13 major chemical spill, as a result of a train accident. 14 MR. BASU: We -- well, it does not; but then when i () 15 you use the Gaussian dispersion model, the exponential l 16 decreases. So, that's -- I mean, we didn't -- I l 17 DR. VALLIS: So, five miles is justified by ) 1 i l 18 analysis, rather than being placed -- ; ! 19 MR. BASU: At the time. Remember, this is back in i ; ! 20 '74, based on analysis that was prior to '74. That's how I 21 the five miles was made. I think the good news perhaps is l 22 that with the improvement in models and all that, it l l 23 basically confirms that data. 24 The second screening, and that is after you have 25 gone through the first screening, that is you've screened O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
L I' 235 1 out anything and everything that occurred beyond five miles, 2- whatever is left, then you look at the frequency. And this 3 is from a lot of sources, like trucks, trains, and barges.
'4 'And there's some frequency screening measured there. For i
5 truck accidents, that's 10 accidents per year. So, in other l' 6 words, if you have 10 -- more than 10 accidents per year -- 7 DR. VALLIS: Accidents or shipping? ! 8 MR. BASU: I'm sorry, 10 shipments per year -- 9 DR. VALLIS: Yeah. l 10 MR. BASU: Thank you, 10 shipments per year. So l 11 if you have more than 10 shipments per year, then you 12 consider that for further analysis or computation. If you 13 have less than that, you screen out. 14 DR. POWERS: Let me come back to the distance r 15 screening criteria, I think it's also recognized and 16 established in that screening that if something occurs, it's i 17 very large outside five miles, that there's going to be some 18 warning available to the operators that it occurred. The 19 use of Gaussian analysis and what not for many of these 20 chemicals is often suspect, because they're typically not 21 very good for these denser than air chemical sources, which 22 do tend to be directional in terms of ground cutting. But, i 23 you still -- there probably would indeed be a warning for
)
24 things outside of five miles. 25 And I would just comment that in an independent i I ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
i 236 l 1 examination of exactly this issue that was done for the DOE ({ 2 sites, they came to basically the same conclusion, that 3 things outside the site boundaries, which were at least five 4 miles, sometimes more, they can never get a hazardous level 5 at the installation of interest -- 6 MR. BASU: That's right. 7 DR. POWERS: -- from chemicals. It just turns out 8 the dispersals with Gaussian plume models is always too 9 great. And if you denied the. Gaussian plume model, then. 10 you've got warning and they've got reaction times. 11 DR. VALLIS: Well, Terrain matters, too. I mean, 12 if you're in a valley and it's heavier than air, you can get 13 the flow patterns, which are far worse. 14 DR. POWERS: But, you always get -- you always () 15 have the warning. 16 MR. BASU: Right. As a matter of fact, between 17 the subcommittee meeting and this meeting, I did go through 18 some -- looked at these onsite locations, their geography, 19 and what I found for many, but not for all sites, they are 20 -- I mean, they have either the exclusionary zone or site 21 boundary or something that are more than five miles. So, I 22 mean -- 23 DR. VALLIS: I'm wondering how you know something 24 like frequency per year. Here, you've got a reactor and 25 there, you've got a highway. How do you know that some O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
l 237 1 chemical company isn't going to decide next year they're [d \ 2 3 going to ship a truck a day of some chemical along that highway? 4 MR. BASU: In the future? 5 DR. VALLIS: Anytime. How do you know it's going 6 to happen or not going to happen? How do you -- do you 7 monitor everything that goes along that highway? 8 MR. BASU: The interstate highway, the shipment -- 9 particularly the hazardous shipments are monitored. 10 DR. VALLIS: So, you might then prevent them from 11 shipping along that highway? 12 MR. BASU: Well, in some interstate highways or 13 some segments of some highways, there are warnings that you 14 can't simply transport hazardous chemicals. p (, 15 DR. VALLIS: So, this may not be under the control 16 of the licensee. 17 MR. BASU: Right. This is an external event. 18 DR. POWERS: The current hazards on most of the 19 state and federal highways is not under the control of the 20 licensees, but he has access to the information. 21 DR. VALLIS: He'll know if it changes? 22 DR. POWERS: The frequency can change. I mean, l l 23 you can -- everything can be fine and then next year, l 24 there's a new route for some chemical shipments. It may be 25 worse than that, different chemicals get shipped. l l ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
238 t 1 MR. BASU: Different chemicals. () 2 3 DR. POWERS: DR. KRESS: Life does change It's just like Bill's shutdown risk, 4 we don't. 5 [ Laughter.] 6 DR. KRESS: We've just got to account for all of I 7 those changes in your estimate. 8 MR. BASU: If we pass the screening criteria, then 9 we move on to weight criteria. When I say " pass the 10 screening criteria," I mean the screen out, those that are 11 not frequently shipped and then we take those that are l 12 frequently shipped within five miles at the weights -- you l 13 know, the weights. So, this is the weight of chemicals -- l l 14 DR. VALLIS: It seems to me you're indirectly
) 15 using a probability of a certain dose rate of the site of 16 whatever this stuff is; that you're indirectly doing this.
17 MR. BASU: You're absolutely right. Yes, there's i 18 a probability context here. There's a risk context here. 19 So, we go into the weight or the mass screening criteria and 20 that, of course, depends on the nature of chemicals to its 21 toxicity. It depends on the control room time and the core 22 meteorology of the site and all that. But, they are, in the 23 long term, compared. And as long as the weight criteria is 24 met, you're going to screen out. So then you are left with 25 a fairly small subset of those chemicals and the shipment O ANN RILEY & ASSOCIATES, LTD. k/ u Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
239 l 1 that need to be considered for the control room evaluation. 2 'So that's the process. I 3 Now, what we are proposing in this evaluation is 4 to observe the atmospheric dispersion model that is 5 currently reference in the Reg Guide 1.78 to an improved l 6 model that is in the HABIT code. And I'll come back tc it 7 in a little more detail. We're, also, proposing an update I 8 of the toxicity, and, again, I'll explain on that. And l 9 finally, we're proposing changes in the shipment frequency 10 and exploring the definition of shipment frequency than l 11 anything else. 12 Aspects that are covered in Reg Guide 1.78, but 13 which are not subject to this revision, and so I'm not going 14 to talk about it, the detection of hazards and isolation of (h 15 control room -- control room characteristice, including 16 in-leakage and detection system. They are in the Reg Guide, 17 but they are not changes proposed. So, that's why I'm not 18 going to talk about these things. And I said a couple of l 19 times earlier that the most of the revisions subsumes 1.95 j 20 and that deals with the control room operator protection 21 against on-site chlorine release. 22 DR. POWERS: When I look at Reg Guide 1.95, as it 23 stands now, there's a lot of useful technical information on 24 how to set up detection systems and what they should look 25 like and things like that. Much of that information seems ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034
r j 240 1 not to have been carried out in'the unification. Is there a i 2 reason for that?
- 3. MR. BASU: If the' relevant information is not 4 carried over, and I really don't know where you're pointing 5 to, but if indeed it's not carried over, that certainly 6 should have been done. It's an oversight and it will be 7 done. Relevant information from 1.95 to be carried over to 8 1.78, _that is the objective. And at least, in my mind, I 9 thought it was done.
10 DR. POWERS: .Well, there's a table and a couple of 11 figures that didn't seem to come over. 12 MR. BASU: Oh, if you are referring to the 13 different control room characteristics, there's a table 14 there. There is, also, a similar table, not identical, a () 15 similar table in 1.78 -- the existing 1.78. We retained 16 that table as an illustration. We're going to compute the 17 control room flow of various other control rooms, using very 18 simplified model that we have provided in the appendix. So 19 one can reconstruct the table in 1.95, if one wishes to. 20 DR. POWERS: When I look at this analysis that you 21 go through to find out what their in-leakage is for control 22 -room, it says you take the information from design 23 . characteristics construction drawings. We previously had a 24- presentation here that said, gee, these guys designed these 25 control rooms to have in-leakages that are very small; when ANN RILEY & ASSOCIATES, LTD.
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241 1 1
~
1 we measure them, they're huge; can't infer that from the '() 2' 3 construction drawings. I'm wondering _why does the Reg Guide seems to be so' confident in the ability to calculate , 1 4 in-leakage, based on either design or construction drawings? 5 MR. BASU: Yeah, I'm not sure that I can answer j 6 that question. I know that we, in an ACRS meeting, talked 7 about -- there was a couple of presentations on that issue 8 and I think there's an ongoing debate on that, as to what is l 9 appropriate in in-leakage. I'm really not qualified to l 10 address that. 11 In this Reg Guide, what we basically said is that I 1 12 if you have this kind of in-leakage characteristics, that 13 this is going to be your concentration level. So, 14 calculations -- or the example calculations have been () 15 provided. If you have a different kind of in-leakage l 16 characteristics, you'll have different kind of concentration l 17 level. To argue whether or not this is the right in-leakage l l 18 for a particular control room type, I really don't know if I 19 can do that at this point. 20 DR. VAIiLIS : It was very impressive when we heard 1 21 about control room habitability, how these in-leakage 22 characteristics could be off by orders of magnitude from -- 23 the actual measurements could be off orders of magnitude 24 from this equation model. It's a very striking piece of l 25 I evidence. 1 l i l I ANN RILEY & ASSOCIATES, LTD. l Court Reporters
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r0 1 I l l l l 242 1 MR. BASU: Yeah. If you're referring to the () 2 analyzedimagnitude versus the observed measure of magnitude, 3 yes. I was here, so I certainly saw the same thing. And I 4 don't know if we can resolve that particular issue here. 5 But, I thought you were talking about if you take one 6 particular in-leakage characteristic, as opposed to another 7 one, within, of course, reasonable bounds and you compute 8 the concentration level in the control room, whether you get 9 an order of magnitude difference, I cannot seriously doubt 10 that you will do that, because you're using the same model 11 anyway.
.12 DR. SEALE: Well, that bothers me, because 13 presumably a Reg Guide contains within it a statement of 14 position, which we would like for the regulated community to
() 15 have confidence in. And certainly what you are attempting 16 to do sith the rest of this Reg Guide is to update and 17 integrate the information that goes into it, so that you're 18 able to present your best assessment of the problem. And 19 here, we have a whole set of -- or a whole part of this 20 thing, which is terribly suspect, as a result of 21 measurements that have been made by various people and we 22 don't even caution the regulated community that they may be 23 walking out into a mine field and that when they really get 24 into a situation, they may have an environment which is much 25 more severe than what is presented here, as a credible level y O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
243 1 of that environment. I -- that's almost not ethical. () 2 3 MR. BASU: That's a fairly valid comment. I'm not sure -- I'm not really qualified to address that comment. 4 Let me just mention one thing: of the three sub-bullets 5 that I indicated there that are not subject to litigation 6 and that are not subject to this discussion here, there's 7 only one on here that I know of -- correct me if I'm wrong 8 -- there's only one of them that I know of that is kind of 9 suspect, that is the in-leakage characteristic -- 10 DR. SEALE: Sure. 11 MR. BASU: -- of control room. 12 DR. SEALE: I think that's correct. 13 MR. BASU: So -- and that, I have already 14 considered. 15 DR. SEALE: But two out of three bad is not the 16 kind of criteria you want to use in something like this. 17 MR. BASU: No, I like two out of three. But, I 18 can't -- I consider that in-leakage is a continuing debate. 19 I don't have an answer. So, I really don't know what I can 3 20 do about it, other than basically telling the community that 21 if you have this kind of control room, this is how -- this 22 is how you compute and instead of saying that, okay, this is 23 the in-leakage characteristic. 24 DR. SEALE: There's somebody back over there 25 standing up. Maybe he knows. O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 j Washington, D.C. 20036 (202) 842-0034
244 1 MR. CUZEN: This is Curt Cuzen from NEI. I maybe () 2 stepping beyond my own expertise, but based upon the experts 3 that I have talked to concerning toxic gas, we need to be 4 careful about the definition of terms. The term which we 5 have been concerned with from the tests that we have seen 6 from control rooms is " unfiltered in-leakage;" whereas . 7 during the radiological event, the control room frequently 8 will isolate and recirculate. And it is this unfiltered 9 in-leakage during that recirculation that causes a 10 radiological concern. 11 During a toxic gas event, which is my 12 understanding, and I qualify this, maybe somebody else more 13 knowledgeable than me, that the control room only isolates. 14 Therefore, the unfiltered in-leakage, which we're talking O 15 (,,/ about with the tracer gas test, is not of concern here, 16 because you are not recirculating, you did not have that 17 flow characteristics, and, therefore, that is not of the 18 direct concern for tracer gas, certainly for toxic gas. 19 Now, I hope I've got that right. I'm calling on j 20 my memory from discussions I've had and it seems to fit with 21 the questions that have gone on and possibly that can be 22 validated later. But, that's maybe one way you might want 23 to think about it, before you go too far down that path. 24 DR. SEALE: That may be very true, but it strikes 25 me then that the differences of the circumstances that
)
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l' 245
.1 characterize the response to a toxic release, as opposed to .( ) 2 a radiological release, ought to be clear in this Reg Guide 3 that deals with toxic releases.
4 MR. CUZEN: That may be incorrect. I've not seen 5 the document yet, so I cannot comment on that. But, it 6 sounded like there was a question about terminology that we 7 could get confused on, if we're not careful. 8 DR. SEALE: You are certainly -- that's an 9 appropriate observation. 10 MR. BOEHNERT: And I'll just comment, we have a 11 subcommittee meeting on this coming up on the 17th. We're 12 going to get -- we're going to have people there, who are 13 intimately familiar with the control room layouts and how 14 they work and they can -- we can get to the bottom of this O) (, 15 issue at that meeting. 16 MR. BASU: Okay. It looks like this subject is 17 generating a lot of interest. 18 DR. POWERS: You haven't heard nothing yet. 19 (Laughter.) 20 MR. BASU: I've seen nothing yet, huh? ) 21 DR. POWERS: You've seen nothing yet. 22 MR. BASU: Okay. The simple one first, frequent 23 shipment, the definition. If you look at the Reg Guide 1.78 1 24 text, that's on the top of -- the top, and it says, 10 per l 25 year for truck traffic, 30 for rail, and 50 for barge, j [ ANN RILEY & ASSOCIATES, LTD. A-- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
c i 246 l 1 something like that. And I don't know if I -- it's in the s' 2 ' Reg Guide.
) But, the important thing to look at here is in 3 the draft Reg Guide -- revision to Reg Guide, it sort of 4 qualifies those shipments as total shipments; and by " total 5 shipments," what is meant here is the totality of the 6 hazardous chemical shipment. And considering the shipments 7 in the singular category, we ask for the distinction to what 8 chemicals are being shipped.
9 And let me further expand on that. When we said 10 10 shipments per year, there is a -- there's always a 11 provision to interpret that as 10 shipments per chemical per 12' year. And so, here, we're saying there is 10 total 13 shipments. 14 DR. KRESS: Trucks appear to me to hold less than (Oj 15 trains and trains hold more than barges. 16 DR. SEALE: Not necessarily. 17 DR. KRESS: I am surprised that there's not a l 18 correlation.between what the -- unless they can carry in l 19 these frequencies. I don't -- 20 DR. POWERS: It's frequencies of accidents. 21 MR. BASU: These are frequencies -- 22 DR. POWERS: You have to weigh -- 23 DR. KRESS: You multiply this by the frequency of 24 accidents? 25 MR. BASU: Yes. ANN RILEY & ASSOCIATES, LTD. O- Court Reporters '
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247 l 1 DR. POWERS: There's an inherent weighting to the /~N 2 frequency of accidents. Trains have fewer accidents than N' /) i i 3 trucks and barges have very, very few accidents. 4 DR. KRESS: That would explain it. Thank you. 1 5 MR. SIEBER: It seems to me that the original ' 6 documents in guidance use the individual chemical l 7 commodities as a way to determine what you should monitor 8 for. For example, at our plant, chlorine was the only one, 9 even though we had a major railroad line and a major highway 10 and a river, and probably under those circumstances, we 11 would have exceeded the frequency limit. But the fact was 12 that the cargos were so dispersed, you might have one or two 13 shipments a year of certain chemical and, therefore, you 7" 14 would knock that out, because you would not want to set up a k ,x) 15 separate monitoring system just for that. So, I'm not 16 exactly sure what the rationale is for making the Reg Guide 17 much more restrictive than it used to be. 18 MR. BASU: Well, it's more of a clarification and 19 I believe here the rationale is a very simple way. If you 20 take 10 shipments per year of truck and if you take the 21 liberty to interpret that as 10 shipments per chemical per 22 year, it is, at least in theory, possible that in a 23 particular site, you have in a particular year, you have 24 some 15 different chemicals shipped. So, you'll get 150 25 shipments per year. That's going to raise your CDF by an ANN RILEY & ASSOCIATES, LTD. [) %- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
248 1 order of magnitude, because these are all connected 2 ultimately to the calculation of risk. (} So that's where the 3 line is drawn. l 4 DR. VALLIS: I'm wondering about barge traffic. I 5 mean, there are some reactors on estuaries, where there's a i 6 lot more than barge traffic on the water. ) 7 MR. BASU: Yes. 8 DR. VALLIS: Or is restricted to barge traffic? 9 MR. BASU: Why it is not -- 10 DR. VALLIS: Well, there are ships. There are 11 .other things than barges that come by. Out on the 12 estuaries, there are some estuaries that serve major ports 13 and have reactors on those estuaries. 14 MR. BASU: That's correct. () 15 DR. VALLIS: More than just barge traffic that 16 goes by on the waterway. Ships serve as chemical -- 17 refineries and so on. There are not just barges on the 18 water. 19 MR. BASU: Yes. I think I understand what you're 20 saying. Let me ask for clarification, so I can respond to i 21 your question. Are you saying that maybe some chemicals are 22 transported in ships? 23 DR. VALLIS: Yes. ! 24 MR. BASU: I think when we say barges here, the 25 U.S. Coast Guard keeps statistics of barge traffic and barge l O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
I 249 1 accidents. And I may be wrong, but.I don't think that if f) 2 you have an accident in the waterways caused by a ship 3 collision rather than a barge collision, I don't think that 4 they're going to say, okay, no, that's not barge, so that's 5 out of the accident scenario. I think they will count that 6 as an accident and I think they will consider that as a 7 barge accident. 8 DR. VALLIS: You think? 9 MR. BASU: I think, yeah. I cannot be absolutely 10 certain. I have to check with the U.S. Coast Guard. But, I 11 -- 12 DR. SEALE: Well, ocean going vessels go up to 13 Mississippi all the way to Baton Rouge. 14 MR. BASU: Yes. () 15 DR. SEALE: And that's above waterford. l 16 MR. SIEBER: In the case of Calvert Cliffs -- l 17 DR. VALLIS: That's what I was thinking of, 18 Calvert Cliffs. 19 DR. POWERS: I think that if I was waterford and 20 someone wanted to lump together ships and barges, I would 21 strenuously object, because the probability from the 22 collision of the ship is going to be much, much lower than 23 it is for a barge. Now, I don't think that obviates the 24 need to -- maybe you need to stick a word in here and say f 25 " ships," as well as barges. But -- C[ ANN RILEY & A650CIATES, LTD. Court Reporterd 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
250 1 MR. BASU: Yes. I think when the counting is [D -N/ 2 done, they count the number of accidents. 3 Okay, so, now onto the modeling, atmospheric 4 dispersion modeling, Reg Guide 1.78 has -- or makes 5 reference to the Murphy Kemp model, which is -- the Reg 6 Guide is 74 and this one was developed, I think, in '68 time 7 frame. It's about 30 years old at a minimum. 8 THE SPEAKER: I'm having a hard time hearing you. 9 MR. BASU: Oh. 10 THE SPEAKER: You could move that mike up further 11 in your -- 12 DR. POWERS: If you could just move the mike up a 13 little higher on your tie. 14 Can you hear me now? (O,) 15 DR. KRESS: Yes. 16 MR. BASU: I am not a toxicologist. The age of 17 that model, that's one thing, but I think more importantly 18 it is what that model contains. It is a Gaussian plume 19 model all right, but it does not have the diffusion 20 coefficients in that model as basically normal diffusion 21 coefficients it does not incorporate the effect of wakes in 22 the vicinity of building and structures, something Dana was 23 referring to in the beginning of this presentation. 24 It also does not include the effect of sort of 25 near-field effect or the near-ground effect. O ANN RILEY & ASSOCIATES, LTD. U Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
f l l 251 I l 1 So what has been done in the interim on the time s I I 2 the GSI-83 was formulated to now is that some improved (_/ j l 3 models were developed and these models are put into the l 1 4 HABIT code. 5 The revision to the Reg Guide makes reference to 6 the HABIT models and that is what this proposed revision is 7 all about and I have given you some indication of what this 8 improved model does. 9 DR. KRESS: Quite often NRC develops codes, 10 particularly in the severe accident area, and they have a 11 fairly robust peer review process. Has HABIT been subjected 12 to that peer review? 13 MR. BASU: You know, I really don't know. I would 14 think so. What I can tell you is that the model, the rm ( ,) 15 improved model that went into HABIT, was subjected to peer 16 review. I 17 DR. KRESE: Okay, that is a -- 18 DR. POWERS: That is only a step unless whoever 4 l 19 coded up HABIT has written the only code without error. l 20 DR. KRESS: He gets a bottle of champagne if he ) 21 does that? 22 DR. POWERS: Most of the codes with the notable 23 exception that maybe we will hear about later have physical 24 equations in them that have a certain universality of 25 approval in them. The problem is when you put it into a ANN RILEY & ASSOCIATES, LTD.
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252 1 numerical vehicle for doing the calculations and have to () 2 3 interface it with other things is where all the difficulties come from. 4' I mean just having good equations is a necessary 5 but not a sufficient step for having a decent code. 6 MR. BASU: If you ask that question to Jay Lee, 7 the previous presentation, you have got an answer because I 8 think it was during his time that this model was put into ; 9 the code -- ; h 10 [ Laughter.] 11 DR. KRESS: I asked him but he uses a different 12 model, 13 DR. POWERS: It is a new concept. 14 MR. SIEBER: Does the HABIT code include the
) 15 effect of the density of the released gas?
16 MR. BASU: Yes, it does. 17 DR. POWERS: It has density terms in it. It does 18- not include this ground-hugging kind of thing and it 19 presumes ipso facto at the beginning that it is a Gaussian 20 release. It does not have the transition from the release , 21 point to a Gaussian plume, which is where the problem comes. 22 MR. SIEBER: That's right. i 23 DR. KRESS: I don't recall them having density j 24 terms in it. 25 MR. BASU: I think it does. ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW,-Suite 1014 Washington, D.C. 20036 (202) 842-0034
253 1 DR. POWERS: I think it does. I () 2 MR. BASU: That will make a difference only for 3 the near-term -- if it does. It will make a difference in I 4 the near-term concentration calculations, and I think I 5 mentioned in the subcommittee briefing that the HABIT model 6 was compared with Wilson-Lamb and Wilson-Chui models, which 7 are non-Gaussian models for near-term concentration, and 8 they came out right on top of each other. 9 DR. KRESS: Very good. 10 MR. BASU: So it is really -- 11 MR. SIEBER: So this would be useful for an 12 on-site release that is close to a control room intake? 13 MR. BASU: Yes. Let's see now. We are talking 14 about revision, toxicity limits. Again the toxicity limits
) 15 that were listed in Reg Guide 1.78 are taken from Sax's 16 " Dangerous Properties of Industrial Materials" that was 17 published way back in 1968 based on the knowledge of l
18 toxicity limits of however many chemicals we had at that ! 19 point identified or we could measure toxicity limits and if 20 you want to know the number of chemicals listed in Reg Guide 21 1.78 that is 27. 22 Now since then of course there has been a lot of l L 23 work that went on on toxicity or the toxicological area and 24 which sort of culminated among many documents into one 25 document that I have cited here, and that is the "NIOSH ANN RILEY & ASSOCIATES, LTD. N/ Court Reporters r 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034 L
254 1 Pocket Guide to Chemical Hazards." In 1997 -- they update [Gi ) 2 this guide every so often or every five yearc or so. I 3 think the last update was '97. We are proposing to use the 4 immediately dangerous to life and health exposure level that 5 is included in this NIOSH Pocket Guide and I have given you 6 a definition of what immediately dangerous to life and 7 health exposure level is, and that is basically that it is 8 basically that it is the level which is likely to cause 9 death or immediate or permanent adverse effect if no 10 protection is provided within 20 minutes. 11 That is important, so if you subject an operator 12 in this environment, in the IDLH environment for 30 minutes 13 without providing any protection, then it is likely to l 14 cause -- ( ,f 15 DR. KRESS: If he dons his protective mask at 29 16 minutes is he okay? 17 My next question is going to be how about 31? 18 MR. BASU: That is an interesting question. I 19 don't know if anyone is going to volunteer to do it, but I 20 think in fairness to that issue in the Reg Guide we are 1 21 describing a two-minute donning time. When you take two { i 22 minutes in that context you have plenty of time to don the ! 1 23 protective gear and verily the next bullet says that because i 24 the IDLH level can be tolerated for two minutes without any l l 25 physical incapacitation. ! (~ N- ) ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 I l
255 1 DR. POWERS: What I am hoping that we get a chance
/
V)
; 2 to do is let the committee members attempt to don protective 3 equipment in a 300 PPM ammonia environment in two minutes.
4 [ Laughter.]
'5 DR. POWERS: I think we had better move right 6 along here and not pursue that flippant remark because we 7 need to move right along on this presentation.
8 MR. BASU: I think I am going to skip the next 9 viewgraph, which is actually an example of comparison 10 between the IDLH and the Reg Guide -- 11 DR. POWERS: Well, I guess we really have to 12 understand both why things are lower under Reg Guide 1.78 13 and the IDLH and why things are higher. ! 14 DR. WALLIS: Why isn't there a criterion for how ' x_/ 15 quickly the operators have to be made aware of this. They 16 have to know that they are. If there is no physical 17 incapacitation they don't know that there is a toxic 18 atmosphere unless something has happened. There has to be 19 some criterion for their awareness of that being 20 appropriately quick and everything. 21 MR. BASU: The alarm goes off or goes on, 22 whatever -- I mean one could detect, say, a certain level of 23 concentration. 24 DR. WALLIS: There has to be criteria for 25 detection and everything. ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L
m . . . . . . . . . . 256 1- MR. BASU: There are, in 1.78. If you recall, I e 2 said, you know, that is an area that has not been revised 3 but there are criteria. Yes? Did you want me to project 4 this? 5 DR. POWERS: Just explain a little bit to me. 6 Let's take acetaldehyde. You have Reg Guide 1.78 -- it says 7 it has a 200 PPM; IDLH is 2000. Why is the Reg Guide 8 different from the IDLH or this the old Reg Guide? 9 MR. BASU: This is the old Reg Guide -- based on 10 the information that was available back in '68 -- 2000 is 11 the limit that is prescribed for 30 minutes of exposure. In 12 two minutes though you may not have 2000 PPM in the control 13 room. 14 DR. SEALE: What are you going to go to? I mean
) 15 this is your new -- the first column is your new listing?
16 MR. BASU: First column is the old Reg Guide, the 17 existing Reg Guide. 18 DR. SEALE: Okay. What are you going to go to in 19 the new one? 20 MR. BASU: IDLH, 21 DR. SEALE: IDLH. 22 MR. BASU: That's right. 23 DR. WALLIS: I'm sorry, but I have to ask you 24 where in the control room? If this is leaking in through a 25 window or door or some port, some leak, it doesn't [v 'j ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
257 1 'immediately mix in the~ control room. It may be, you may () 2 have 10,000 Parts Per Minute near the source and 10 at the 3 other'end of the control room. 4 MR. BASU: You have 10,000 at the source level -- 5 DR. WALLIS: Near the leak -- near the inflow -- 6 and you may have 10 on the other end of the control room. 7 MR. BASU: This is measured -- l 8 DR. WALLIS: It may take minutes to mix up. 9 MR. BASU: Yes, but the detection is at the l 10 control room intake. 11 DR. WALLIS: How do you know where it is coming in , 12 if it is leaking all over the place? ! 13 DR. POWERS: The ventilation to the control room. 14 This is what they are pulling into the control room. ; i ) 15 MR. BASU: As long as there are intakes in the 16 control room and you have detectors placed at the intake. 17 DR. WALLIS: As long as you have your flows 18 controlled well enough. 19 MR. BASU: Okay, moving then on to regulatory 20 analysis, and I think that probably the first bullet answers 21 something that you raised, Dr. Wallis, chemical spill -- 22 what has that got to do with the core damage, so I think -- 23 I don't know if that answers your question. 24 If the chemical spill or the release by itself is 25 not going to result in a core damage event, but the operator [~ ANN RILEY & ASSOCIATES, LTD. \me Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l l 258 1 incapacitation may -- human error may at some point lead to 7s 2 a core damage event. ( ) 3 DR. WALLIS: Well, it could be that the system is 4 so robust that if all the control room operators die, the 5 reactor is perfectly safe. If this might have happened at 6 TMI they would be better off than they would be otherwise -- 7 [ Laughter.] 8 MR. BASU: They we don't need to worry about it, 9 right? 10 DR. WALLIS: Do you not care about the death of 11 the control room operators? 12 MR. BASU: I think that kind of rings a bell that 13 somebody from the SES committee mentioned that we don't care 14 about the control room operators, do we? O) s w 15 DR. WALLIS: Is that true? 16 MR. BASU: No. No, of course that is -- we do 17 care about control room operators very much, otherwise the l l 18 Reg Guide is not Ocing to de here, but I am just saying that l 19 the chemical release in itself is not going to lead to core 20 damage. 21 MR. SIEBER: Is there a probability that would 22 tell us what the relationship is between a toxic release 23 greater than 1.78 and core damage? 24 MR. BASU: There is an IPEEE insight report. It 25 probably has not come out for publication as a NUREG report l l l l i /~h ANN RILEY & ASSOCIATES, LTD. (msl Court Reporters I 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 , (202) 842-0034 j
l 259 1 .yet, but it is in the making and what I can tell you is that () 2 there are I think 78 plants studied in that report and only 3 one plant showed anything in terms of -- they looked at 4 various attributes, if you will, for the core damage 5 frequency, like earthquake, fire -- these are external 6 events -- and then of course there was some classified as 7 other events," which included the chemical release and so 8 on and so forth. 9 There was only one plant that came out with a 10' measure of CDF for chemical release and that is actually 11 less than 10 to the minus 7 and I think the cutoff is 10 to 12 the minus 7. 13 DR. WALLIS: What is the incapacitation of control 14 room operators' probability as opposed to CDF? What is the () 15 probability of them being incapacitated? 16 MR. BASU: That is also 10 to the minus 7 or less. 17 DR. WALLIS: So it is more likely that there is a i 18 CDF relating from this, resulting from this than the control ! 19 room operators are incapacitated? 20 MR. BASU: No. That CDF was for -- no. I'm 21 sorry -- 22 MR. SIEBER: Go ahead. 23 MR. BASU: No, it said that the CDF that came out 24 in the IPEEE is due to chemical release and chemical release 25 was associated with operator incapacitation and what they / ANN RILEY & ASSOCIATES, LTD. D) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
260 1 did is they said once an operator is incapacitated the () 2 probability is one that it will lead to -- 3 DR. POWERS: The two are identical numbers? 4 MR. BASU: Yes. Now that may not be the case, but 5 for the sake of submitting the report, that is what they i 6 used. I 7 MR. SIEBER: I I guess that I would express my 8 concern because my personal experience, even though it is 9 anecdotal, is that on-site chlorine releases occur more 10 frequently than these numbers would suggest. 11 I am not aware of any significant one at a nuclear 12 plant. I am aware of them in coal fire plants and oil 13 plants and water-treating plants. 14 DR. POWERS: I think if you look at their analysis
) 15 that they have an appropriate measure for the frequency of j 16 that, i 1
17 But then they multiply it by what's the 18 probability of incapacitated control room operators and i 19 that's what gets the numbers down. l 20 MR. SIEBER: Well, yes, our Cheswick plant, which 21 is a coal plant, they incapacitated the control room 22 operators there, were lucky to trip the plant. Put them in l l 23 the hospital. l ! 24 MR. BASU: I think the release -- onsite chlorine 25 release is also for nuclear plants also predominant amongst O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r 261 l 1 other release. l Well, I think we have to take it one step [b \ 2 further. It's not just the release, it's the release that 3 will then raise the concentration level in the control room 4 to the point that it'll incapacitate an operator. 5 DR. WALLIS: So you're probably saying that a 6 control room in a nuclear plant is much better protective 7 than his coal-fired plant? 8 DR. POWERS: That's true. 9 DR. WALLIS: So this has at least happened once in i i 10 a coal plant. So there's 10 to the minus 7 probability a 11 thing has happened once. 12 MR. BASU: In a coal-fired plant; yes. 13 DR. WALLIS: Were you aware of that? 14 MR. BASU: I didn't look at coal-fired plants.
/~N
( ,) 15 MR. SIEBER: You see, I don't know where you would 16 get the data, either, because that kind of stuff, unless it 17 results in serious injury, would not be reported. 18 DR. POWERS: You can actually start -- there's 19 actually a mechanism to start getting it now, because the 20 American Institute of Chemical Engineers is starting to keep 21 track of those things. But if you wanted to go back five 22 years, you're dead. 23 MR. SIEBER: Right. 24 DR. POWERS: They just -- things have in the 25 chemical business, chemical risk analysis has vastly IN ANN RILEY & ASSOCIATES, LTD. l
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262 I 1 improved, starting with the Bhopal accident, but it didn't () 2 3 really get serious until there was a fairly dramatic event that' occurred in Philadelphia a few years back, and now 4 there are institutes that are really trying to do chemical 5 risk assessments and what not, and they're even now being 6 required in California and a few other localities. But, l 7 you're right, the data base on this is really anecdotal, you 8 know, I remember when. ; l 9 MR. BASU: So anyway, the bottom line from the 1 10 previous slide is that the baseline risk is in the noise 11 range. And so now we're going to talk about the change in . i 12 baseline risk because of this proposed revision, and we're 13 saying that factors that will potentially affect the 14 baseline risk are the revised toxicity limits and the () 15 revised atmospheric dispersion modeling. And the other 16 value at revised toxicity limits may be viewed as 17 relaxation, because you see in that illustrative viewgraph 18 that for some chemicals anyway that the limits are higher 19 than the Reg Guide 178 limits, but keep in mind that the 20 operators are not going to be necessarily subjected to the
-21 IDLH values. They are going to have the opportunity to don 22 their' protective gear within two minutes, and the IDLH 23 values may not be reached for many chemicals within two 24 minutes. So change in baseline risk if any on the revision 25 would be minimal in the worst case.
[] U ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue,'NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
263 1 Use of atmospheric or improved atmospheric
\ dispersion models will likely result in some changes in
[G 2 3 concentration levels in the control room. For some 4 chemicals, the levels may be higher. For others, they may 5 be lower. But even for those chemicals, and if they happen 6 to be higher, the risk is only going to be imposed -- 7 additional risk is only going to be imposed if either the 8 IDLH values are exceeded, because that's the reason that we 9 are setting, or if the protection is not provided within the 10 prescribed time, and this is two minutes. So I think the 11 control room operators are not afforded any protection or 12 the IDLH values, then you're going to see additional risk. 13 So given those arguments, we're saying that the total change 14 in baseline risk with the proposed revision is not () 15 considered significant. 16 DR. WALLIS: The measure is change in CDF? 17 MR. BASU: Yes. 18 DR. WALLIS: So dose CDF is 10 to the minus 6, and 19 that's what you -- 20 MR. BASU: Hopefully it will be less than 10 to 21 the minus 7. Baseline is 10 to the minus 7, we don't 22 want -- well -- 23 DR. WALLIS: You've made a conclusion that it's 24 not significant, and it's based on some numbers. 25 MR. BASU: The cutoff number is 10 to the minus 7, s
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l 264 1 yes. Well, if the change in risk is not significant, at
\ 2 least if we are able to conclude that far, then what
[~
\_ /
3 3 I'm showing here in this viewgraph is that you are likely to 4 have some burden reduction, by combining 178 with 195 you 5 are going to have some administrative burden reduction on 6 the part of licensees as well as on the part of NRC review 7 process. 8 Revised guidance is likely to reduce plant 9 shutdowns from spurious actuation of detection systems, and 10 in one of the viewgraphs earlier you have seen some examples 11 where licensee amendment applications came because there 12 were some spurious actuations of detection systems, whereas 13 the hazardous chemicals were not detected, not at least at 14 the level that would be a concern. So by reducing the plant 15 shutdowns, you are definitely going to reduce burden. It 16 certainly will result in consistent and comprehensive 17 control room habitability evaluation. 18 I think there was a question or comment in the 19 subcommittee briefing about the list of chemicals not being 20 exhaustive, and I do agree it's not exhaustive, but it is 21 certainly much more comprehensive than 27, because we have 22 listed 406 chemicals in this revision. And as and when more 23 chemicals are included in the NIOSH pocket guide, they will 24 be included also by reference. 25 The atmospheric dispersion model will provide best ANN RILEY & ASSOCIATES, LTD. ss / Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
E 1 l \ I 265 1 estimate -- (J,,) 2 DR. WALLIS: What do you mean by best estimate? 3 MR. BASU: It certainly will provide you more 4 realistic computational -- 5 DR. WALLIS: I would think it would be better to 6 say improved dispersion will provide better estimate? No 7 way that you can say it's best without some kind of 8 criterion for best, and you get into a morass there. 9 I think what you're saying is that this is to 10 provide a better estimate, more confident estimate, you 11 think, and this probably adds to public confidence, because 12 you've got better representation to what's happening 13 physically. Best estimate -- 14 MR. BASU: Has a different connotation. I agree
) 15 with you. It's a wrong choice of --
16 DR. SEALE: If it's a morass, he has a lot of 17 company. 18 DR. WALLIS: So there are some -- this is just 19 your sense that the dispersion model is better, or is there 20 some measure of its being better? 21 MR. BASU: The comparison between Murphy-Campe 22 model and the improved model and a comparison with the 23 experimental data and the improved model has done 24 significantly better in terms of predictive accuracy. 25 DR. WALLIS: I think this does help at least ['} ANN RILEY & ASSOCIATES, LTD.
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i 266 1, professional people's confidence. I don't know if it's 2 public confidence. 3 MR. BASU: Yes. I don't need to dwell on this 4 one. I just want to emphasize that there is a plan to issue 5 this draft revision to reg guide for public comment by the 6 end of this month, so there is a line item there for 7 resolution of ACRS comment, that is, if ACRS chooses to 8 provide comments to us in a fashion that we can incorporate 9 them before releasing'it for public comments, we'll do so. 10 If not, there is always going to be an opportunity to 11 provide comments even after releasing for public comment. 12 So it's your call. 13 And I think that about does it. 14 DR. POWERS: When you say you now have 480 ' () 15 chemicals -- 16 MR. BASU: 406. 17- DR. POWERS: 406 chemicals listed, and I look at 18 Table 1 in the Draft Guide, I see 27. 19 MR. BASU: Well, the Draft Guide, that is exempt 12 0 in the Draft Guide. The Draft Guide makes reference to a 21 NUREG/CR Report 6624 and that lists 406 chemicals. Does 22 that answer your question? 23 DR. POWERS: I suspected that was the answer. 24 DR. WALLIS: I am interested in something you 25 didn't talk about, which is accidents per mile for barges ANN RILEY & ASSOCIATES, LTD. Os Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
267 l. 1 seem to be sometimes worse than for trucks. It doesn't seem 2 to be consistent.
- 3. MR. BASU: .Say that again.
4 DR. WALLIS: Oh, you are saying the spill 5 _ probability is less, even though there has been an accident. 6 I see. 7 MR. BASU: Yes. Yes. > 8 DR. WALLIS: Okay. Sorry. 9 MR. BARTON: I am. concerned that this guide has 10 contained within it some requirements on licensees that I 11 don't think are appropriate, or this is not the way to 12 impose requirements on licensees. For example, on page 2 of 13 the guide, under " Discussion," you talk about the fact that 14 "Thir. guide does not address protection of individuals 0% 15 (,) outside the control room." However, you say, " Breathing 16 apparatus should be provided and readily accessible 17 throughout the plant in order to eliminate the need for 18 personnel to seek shelter in the control room during 19 release." That tells me you have got to provide SCBAs for 20 everybody onsite so they don't all run to the control room 21 because that is the only place onsite that is safe during a 22 toxic release. 23 And that -- I can just see inspectors going and 24 saying, well, where is all these SCBAs for all these 600 25 people that are onsite when you have got a chlorine release? g ANN RILEY & ASSOCIATES, LTD. i
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(202) 842-0034 j i l I
268 1 So I think that is a problem. () 3 2 MR. BASU: that question? Chris, would you like to respond to 4 MR. PARCZEWSKI: I think you are prepared to 5- answer his question. 6 'MR. BASU: I think you are raising a valid 7 concern. I don't know, though, if there is a data point in 8 all the LERs submitted, LER database, data event report and 9 whatnot that you would submit to that schematic. 10 MR. BARTON: Well, I think you need to do 11 something to take that out here, which could be implied to 12 be a requirement. You have got the same problem on page 11, 13 Item -- Section 9, Isolation Systems, where you make a 14 statement that says, "A control room exit leading directly (m ( ,) 15 to the outside of the building should have two low leakage 16 doors in series." 17 I can name a whole bunch of plants where you walk 18 out of the control room and you are in an office building, 19 administrative building or turbine building and you don't 20 have any airtight door other than the control room door 21 itself. Now you are saying -- now you are changing the 22 design of all the plants where they have got to have two 23- airtight doors in series once you exit the control room. 24 MR. BASU: I don't know if I am going to be able 25 to respond to your concern. I might just say, though, that O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
269 1 this is one of the challenges when you combine two different IT 2 Reg. Guides written at two different times, at two different L.) 3 -- or different orientation, and try to import relevant 4 features of one into the other. That particular statement 5 was taken out of Reg. Guide 1.95 and imported into this 6 revision. 7 DR. BONACA: But to me the examples suggest that 8 certainly there should be a reading. 9 MR. PARCZEWSKI: Parczewski. Reg. Guide is only 10 recommending -- gives only recommendation, there is no 11 requirement. I agree, maybe the language should be changed. 12 MR. BARTON: I have lived on the other side of the 13 fence, and don't tell me a Reg. Guide is only a 14 recommendation when the inspector comes and says, you know, q_) 15 you guys signed up for Reg. Guide 1.78, now where is your 16 two watertight doors? You know, stuff like this is 17 dangerous putting in the Reg. Guide because it is -- it can 18 be interpreted to be a requirement. 19 MR. PARCZEWSKI: Maybe the language should be 20 changed. 21 MR. BARTON: Well, I agree. 22 MR. PARCZEWSKI: Maybe instead -- state less 23 definite statement maybe. I I 24 MR. BASU: Less prescriptive, less regulatory i 25 language, j [/) s-ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l (202) 842-0034 j
270 1 DR. BONACA: As a minimum it seems to me that this () 2 3 Reg. Guide should have a thorough reading to see what kind of requirements it identifies or suggests that do not exist 4 right now in regulation, because these are just two 5 examples. 6 MR. BASU: I think I will echo what Chris said, 7 that the Reg. Guide is meant for guidance and not sort of 8 requirement. But I do sympathize with your comment. 9 DR. APOSTOLAKIS: So you are not going to change 10 it, is that what you are saying? 11 MR. BARTON: He is not going to change it. 12 MR. BASU: No, no, no. I mean it is not that we 13 are not going to change it. There is always -- this is 14 going to be published for public comments and we will have
) 15 to incorporate whatever we receive.
16 MR. BARTON: Well, you just received a comment 17 from the public. 18 MR. BASU: Yeah. 19 [ Laughter.] 20 MR. BASU: Good. So page 2 and page 11. Is that 21 -- I'm sorry. It is not page -- 22 MR. BOEHNERT: Twelve. 23 MR. BASU: Page -- 24 MR. BARTON: Page 11, Item 9, Section 9. 25 MR. BASU: Section 9. [ ANN RILEY & ASSOCIATES, LTD. Court Reporters 102E Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 r
r' l l 271 1 MR. BOEHNERT: The second paragraph. () 2 DR. POWERS: Are there any further comments that 3 members would care to make on this Regulatory Guide and l= 4 presentation?. 5 DR. SEALE: I have a comment, it is a more general l l 6 one, though. We have heard that these are the kinds of 1 l 7 things that are difficult to assess because the CDFs are 8 suppressed, if you will, in the sense that the difficulty ! 9 lies with other things besides core damage, worker peril and 10 so on. And the risk from 1.78 are low. Why does it get NRR 11 endorsement as a task item? 12 DR. POWERS: Well, I think that is what we began 13 this discussion with. Why are we doing this? 14 DR. SEALE: That's right. And what I am saying
) 15 now is, instead of asking Research to prioritize their 16 research program, perhaps we ought to ask NRR, for their set 17 of priorities for task orders that they send to Research, 18 what is the basis for putting this thing at the level it is 19 relative to some of the other things?
20 DR. POWERS: Good point. Any other comments? 21 (No response.] 22 DR. POWERS: Thank you, Dr. Basu. 23 MR. BASU: You're welcome. Thank you. 24 DR. POWERS: We are going now to turn -- I think 25 we have come to the end of our need for a transcript. ANN RILEY & ASSOCIATES, LTD. [dl
\ Court Reporters l
1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 (202) 842-0034 1
1-l [ 272 1 [Whereupon, at 4:42 p.m., the meeting was , 2 recessed, to reconvene at 8:30 a.m., Thursday, September 2, 3 1999.]
'4 5
6 7
. '8 l
l 9 l 10 11 12 13 l 14 O 15 16 17 18 19 20 21 22 23. 24 25 i ANN RILEY & ASSOCIATES, LTD. J Court Reporters i 1025 Connecticut Avenue, NW, Suite 1014 I Washington, D.C. 20036 (202) 842-0034 l
REPORTER'S CERTIFICATE This is to certify that the attached proceedings before the United' States. Nuclear Regulatory Commission in the matter of:
.NAME OF PROCEEDING: 465TH ADVISORY COMMITTEE ON REACTOR SAFEGUARDS CASE NUMBER:
PLACE OF PROCEEDING: Rockville, MD were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings. b Mark Mahoney Official Reporter Ann Ri]ey & Associates, Ltd. O
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