ML20216C499
| ML20216C499 | |
| Person / Time | |
|---|---|
| Issue date: | 03/06/1998 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-3030, NUDOCS 9803160034 | |
| Download: ML20216C499 (181) | |
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~ OFFICIAL TRANECRIPT'OF PROCEEDINGS
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NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS?
Title:
1 450TH ADVISORY COMMITTEE'ON-REACTOR SAFEGUARDS TRD4 ACRs RETJRN CR E NE Dock'et.No.:
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Rockville, Maryland DATE:
Friday, March 6,1998 PAGES:288 - 421 K; ale u;34 soo F $
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ANN RILEY & ASSOCIATES, LTD.
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fRlidifeof the CorQ1 TIE
i 3(O DISCLAIMER UNITED STATES NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS MARCH 6, 1998 The contents of this transcript of the proceeding of the United States Nuclear Regulatory Commission Advisory Committee on Reactor Safeguards, taken on March 6, 1998, as reported herein, is a record of the discussions recorded at the meeting held on the above date.
This transcript had not been reviewed, corrected and edited and it may contain inaccuracies.
288 1
UNIT 3D STATES NUCLEAR REGULATORY COMMISSION 2
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 3
4 450th ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5
'6 U.S. Nuclear Regulatory Commission 7
Conference Room 2B3 8
Two White Flint North 9
Rockville, Maryland 10 11 Friday, March 6, 1998 12 13 The committee met, pursuant to notice, at 8:30 14 a.m.
15 MEMBERS PRESENT:
16 ROBERT SEALE, Chairman, ACRS 17 MARIO H.
FONTANA, Member, ACRS 18 GEORGE APOSTOLAKIS, Member, ACRS 19 JOHN BARTON, Member, ACRS 20 THOMAS KRESS, Member, ACRS 21 DON MILLER, Member, ACRS 22 DANA POWERS, Member, ACF.S 23 WILLIAM SHACK, Member, ACRS 24 ROBERT UHRIG, Member, ACRS 25 DR. WALLIS, Member, ACRS ANN RILEY & ASSOCIATES, LTD.
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PROCEEDINGS O) 2
(_
[8:30 a.m.]
3 CHAIRMAN SEALE:
Good morning.
The meeting will 4
now come to order.
This is the second day of the 450th 5
meeting of the Advisory Committee on Reactor Safeguards.
6 During today's meeting the Committee will consider IPE and 7
IPEEE projects, the Concerns for Deferred Research and, in 8
addition, we will meet with NRC Commissioner Nils Diaz to 9
discuss items of mutual interest.
10 This meeting is being conducted in accordance with 11 the provisions of the Federal Advisory Committee Act.
Dr.
12 John T.
Larkins is the designated federal official for the 13 initial portion of the meeting.
We have received no written 14 statements or requests for time to make oral statements from
'\\_s 15 members of the public regarding today's sessions.
16 A transcript of portions of the meeting is b'aing 17 kept and it is requested that the speakers use one of the 18 microphones, identify themselves and speak with sufficient 19 clarity and volume so that they can be readily heard.
20 I would also remind the members of the Committee 21 that this afternoon and then tomorrow morning we will be --
22 our discussions will include reports, comments on specific 23 research requirements from the Chairs of the various 24 Subcommittees of the ACRS.
So you will want to be preparing 25 yourself for that, for.those reports.
A)
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Do we have any other items that we need to mention
(~N
( )
2 before we go into the regular, the scheduled agenda of the 3
meeting?
4 DR. LARKINS:
The only change I think is the 5
Commissioner was coming over at 9:15 as opposed to 9:30.
6 CHAIRMAN SEALE:
Yes.
The Commissioner will be 7
over a little early, 9:10, 9:15, something like that.
8 DR. POWERS:
And if our discussions here aren't 9
finished?
10 CHAIRMAN SEALE:
We would hope that we could 11 impose -- we have given Wayne our notice of this, and I 12 think they have agreed that they would be willing to break 13 rather than cease their presentations, so, hopefully, we 14 will be able to -- you will be able to finish whatever it is O)'
(-
15 you wish to say.
16 MR. HODGES:
My expectation is that, unless you 17 have a lot of questions, we will be done by then.
18 CHAIRMAN SEALE:
However it works out.
Certainly, 19 we don't have to fill time unnecessarily, and I would make 20 that comment to everyone.
21 If there are no further comments at this time, I 22 will ask Dr. Powers to -- or is it Dr. Powers.
Yes, I think 23 so.
24 DR. POWERS:
The Commission has asked us a 25 specific question about the IPEEEs and IPEs.
Their question
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really is, okay, we have the IPEs, we will have the IPEEEs,
()
2 where do we go now?
It's really a very future oriented 3
question.
There seems to have been some persistent 4
confusion that we may be interested in reviewing the IPEs 5
and IPEEEs themselves.
That is not the case.
We are really 6
interested in the question of what can and what ought we do 7
in the future in this regard.
8 And, as any high level question is posed, there 9
are not many constraints on ycur thinking here.
This can 10 range -- so I presume an answer can range between what we do 11 with the actual piece of paper, to is there is some other 12 incremental effort beyona that that needs to be done.
Or, 13 having gained all these insights, what can we do with them?
14 I mean it's a fairly -- it is a very open question.
The 15 only thing I know for sure is that it is not directed at 16 what is the story on the IPEs and IPEEEs themselves.
That 17 seems to be a source of persistent confusion here.
18 I think she was really asking about where we go in 19 the future.
I suspect it is one part of a greater question 20 on the overall thrust of probabalistic types of analyses in 21 the future anyway.
22 With that clear cut guidance and close constraint 23 on where you go, Wayne it is your floor.
24 MR. HODGES:
I am Wayne Hodges.
Again, the 25 Director of the Division of Systems Technology in the Office ANN RILEY & ASSOCIATES, LTD.
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of Research, and I am joined at the table by Scott Newberry
)
2 from the Office of Nuclear Reactor Regulations.
Primarily, 3
the reason for that is, although the Office of Research did 4
the review on the IPEs, and is doing the reviews on the 5
IPEEEs, any actions that are taken in direct follow-up has 6
to go through NRR.
So we work closely with NRR on this.
7 I will give a very high level overview of what we 8
were talking about.
For more detailed questions, I have 9
members of my staff and there's memoera of NRR st_lf here 10 who can answer anything that we fail to answer also.
11 So, with that, -- just as background, and to be 12 very quick with it, the purpose of the IPE and the IPEEE 13 program was to have the licensees look at their own severe 14 accident vulnerabilities, to develop an understanding of 15 their plants and, if necessary, to make any changes to their 16 plants.
I think we have been successful in doing that with 17 the IPE program, and it looks like the IPEEE program, in 18 large measure, is --
19 DR. APOSTOLAKIS:
Excuse me, Wayne.
You said that 20 anything you do must come from NRR, so you have decided this 21 will be confirmatory?
22 MR. HODGES:
No, what we are saying is any actions 23 that you take with the plants.
Research doesn't do that, 24 NRR does that.
25 DR. APOSTOLAKIS:
So there may be research ANN RILEY & ASSOCIATES, LTD.
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projects that come from.these --
()
2 MR. HODGES:
There may be research. projects --
3 DR. APOSTOLAKIS:
-- without the blessings of NRR.
4 MR. HODGES:
That is correct.
5 DR. APOSTOLAKIS:
Okay.
6 MR. HODGES:
But any actions that are taken with 7
the plants, NRR is involved with that.
8 DR. APOSTOLAKIS:
Fine.
9 MR. HODGES:
That's all I meant.
So they have 10 identified vulnerabilities in a few cases.
They have done 11 their analyses, and I think, generally, the licensees have 12 greater appreciation.
13 They have actually made changes to the plants.
14 They have replaced these diesel generators in places.
They 15 have improved the busing across ties, have installed new 16 batteries.
A number of changes of that type have been made, 17' so they have actually upgraded the plants.
18 DR. APOSTOLAKIS:
Who is "they"?
19 MR. HODGES:
The utilities.
20 DR. APOSTOLAKIS:
And why did they do this?
21 MR. FODGES:
Because when they did their analysis, 22 they felt that the plant would be better if they did that.
23 DR. APOSTOLAKIS:
As I recall, in the IPE program, 24 nobody found a vulnerability, is that right?
25 MR. HODGES:
Not many, but there were a few that ANN RILEY & ASSOCIATES, LTD.
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did identify what they called vulnerabilities.
OQ 2
DR. APOSTOLAKIS:
And why did they do that, do you 3
remember?
Why did they call it vulnerability?
4 MR. HODGES:
Because they had established a 5
criteria for what would be a vulnerability from the outset 6
and if --
7 DP.. APOSTOLAK!S:
And what were these criteria, do 8
we know?
9 MR. HODGES:
It varies from plant to plant.
We 10 didn't set the criteria, they set their own criteria ahead 11 of time, what was going to be encompassed.
i 12 DR. APOSTOLAKIS:
But I am really curious what
)
13 they felt was the core damage frequency which made them 14 declare something as vulnerability.
15 MR. HODGES:
Mary, do you want to give a little 16 bit more detail on that?
17 MS. DROUIN:
Yes.
I mean it really did vary from i
18 plant to plant.
A year ago, I used to have these numbers
)
i 19 off the top of my head, but I am going to quickly go into 20 1560.
A lot of it was using 1E minus 4 as a core damage 21 frequency Some of it was the percent contribution, the 22 relative contribution.
About a third of the plants, I 23 recall, used the NUMARC 92 -- something, I can't remember 24 the document, and I think it was about 25 percent used that.
25 I think a lot of them used a 1E minus 4.
It really --
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DR. APOSTOLAKIS:
So if the core damage frequency
()
.2 was about 10 to the minus 4, some of them were prepared to
-3 say that the major contributors constitute vulnerabilities.
4 Is that a correct statement?
5 MS. DROUIN:
If their core damage frequency was 6
above 1E minus 4, then they would have a vulnerability.
But 7
what I recall is that the ones that used that definition, 8
their core damage frequencies were not above 1E minus 4, so, 9
therefore, they didn't find a vulnerability.
10 DR. APOSTOLAKIS:
I am confused now.
Some of 11 these plants said -- I thought the majority said no 12 vulnerability, even though we did something to improve the 13 plant.
14 MR. HODGES:
That is correct.
That is correct.
O 15 DR. APOSTOLAKIS:
Then a few said there is a 16 vulnerability, and we are going to do something about it.
I 17 am curious as to what criteria they used to decide that that 18 was a vulnerability.
19 MS. DROUIN:
Here we go.
20 DR. APOSTOLAKIS:
Now, you don't have to remember.
I 21 If you remember which section of the report these things 22 have discussed, I can find out later.
23 MS. DROUIN:
I mean if you look, it is in Section 24 2.1 in the Summary Report.
A bunch of them, as I said, used 25 the NUMARC 91-04, a lot of them used the CDF of 1E minus 4, ANN RILEY & ASSOCIATES., LTD.
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a large release of 1E minus 6.
Now, if you are asking for
()
2 those specific plants who defined a vulnerability and what 3
those were, I don't have that information.
That is in the 4
Volume 2 that I didn't bring down with me.
5 DR. APOSTOLAKIS:
But it is in the report.
6 MS. DROUIN:
It is in the report, yes.
7 DR. APOSTOLAKIS:
Can you let Mr. Markley know 8
later, or on Monday, where we can find this information?
9 MS. DROUIN:
Yes, I can.
10 DR. APOSTOLAKIS:
Thank you.
11 DR. FONTANA:
Were all the changes made 12 voluntarily, or were they nudged?
13 MR. HODGES:
At this point, all changes have been 14 made voluntarily.
15 DR. FONTANA:
Yes.
Thank you.
16 MR. HODGES:
Now, part of the follow-up, there may 17 be a need to backfit and that is part of what they will look 18 at, and we will 90t into that.
But, at this point, any 19 changes that have been made, have been made voluntarily.
20 With that brief introduction, I wanted to now go 21 into what we are doing with the IPE program.
It is a little 22 early to talk about what we will be doing with the IPEEE as 23 follow-up because we are still fairly early in the review 24 process, although we have put out an interim insights report 25 showing that, particularly for fire and seismic, the risk ANN RII EY & ASSOCIATES, LTD.
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seems to be approaching comparable, or sometimes exceeding
()
.2-that from normal of rations.
But there is a lot more work 3-to be done before we are in a position to talk about the 4
follow-up for the IPEEEs.
5 But now we have the IPEs in-hand, essentially, the 6
reviews done to show, to say whether or not that they 7
satisfy the Generic Letter criteria.
And now we have got 8
all this information, there is more that can be done. LSo we 9
are looking at it from several perspectives, as plant 10 improvements to performance of the containment and reactor, 11 looking at strengths and weaknesses in the PRA.
i 12 One generic issue, in specific, was looked at in 13 all the IPEs and that was the A45, and there were a few 14 others for specific plants, for looking at resolution of i
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15 generic issues.
And then a fairly recent addition to what i
i 16 we have been looking at is looking at trying to assess the 1
17 regulatory effectiveness for the ATWS and the station 18 blackout rule.
So those are new wrinkles that are being put 19 into that.
20 DR. POWERS:
Go back to that previous viewgraph.
21 MR. HODGES:
I am going to go into more detail on 22 each of these.
I 23 DR. POWERS:
Each one, okay.
Fine.
24 MR. HODGES:
That was just kind of an outline of 25 what I was going to talk about but you will get more detail.
1
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The follow-up activities are a part of the PRA
,(\\)
2 implementation plan.
There is a plan for that follow-up in 3
the PRA implementation plan and all of this is coordinated 4
very closely with NRR in the plan because eventually they 5
are going to be the ones to implement it and we well may 6
assist them in various portions of that but anything, as I 7
said, that is done with the plants themselves is their j
8 responsibility, and so there is a very close coordination.
i 9
DR. POWERS:
Just to be sure I have all the 10 documentation I need, when I look in the quarterly update, 11 quarterly report on the PRA implementation plan, I could 12 find out about these follow-up activities?
13 MR. NEWBERRY.
Yes, you will find it in various 14 places and for the first time there was an Attacament 3 on
(,/
15 the last one which gives in a bulletized fashicn the basic 16 milestones for the next couple years.
17 DR. POWERS:
I have just gotten that, that most 18 recent one, and I will have to admit I haven't looked at it 19 yet.
20 MR. NEWBERRY:
Well, you can go right to the back 21 and the follow-up programs are in the last attachment.
22 DR. POWERS:
Very good, thank you.
23 By the way, I find that those quarterly reports on 24 the PRA implementation plan to be very useful.
25 MR. HODGES:
Good.
On the plant improvements, one r
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1 thing that I think is planned for NRR is to follow up on
.OQ 2
commitments that the licensees made in their IPE program.
3 Another thing is that there were a number of 4
improvements that were done by some plants.
It looked like i
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5 they might be more broadly applicable to a bigger class of 6
plants but were not implemented by everybody with that type 7
of plant and so we'll have to assess whether we think those 8
improvements should be implemented generically as opposed to 9
just in a few cases.
10 DR. APOSTOLAKIS:
I remember the letter, 88-20.
f 11 It said the purpose of doing, of asking the licensees to do 12 the IPEs was to gain understanding and so on, m them, and 13 so on.
Was it understood at the time that if you found
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14 something that required improvement you could ask them to do A()
15 it, or is it always understood that no matter what they do 16 if the NRC declares something as needing improvement they 17 will have to do it?
18 MR. HODGES:
If it satisfies our backfit rule, if i
19 the benefit exceeds the cost, then we can do that, or if it j
20 iEi an unanticipated safety issue that just has to be done, f
21 then that could be taken care of, but generally we have to 22 satisfy the backfit rule and so we would ausess any 23 improvements in light of our backfit rule.
24 But that being said, I think it is generally 25 understood and we clearly made it plain when we had the C) s ANN RILEY & ASSOCIATES, LTD.
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workshops on IPE last Spring that would be our int.ent for 2
those that would satisfy the backfit rule.
3 MR. NEWBERRY:
Just ste.rting to get into the 4
implementation of this on the NRR side and starting to look 5
at the research reports.
Just the' data would suggest there 6
was some level of understanding because over 500 7
improvements were made that we are going to have to go 8
through one by one, plant by plant, to ensure that they are 9
handled properly, and those are just the ones that were 10 volunteered considering the questions and criteria you were 11 asking about before.
That is a lot of work.
12 MR. HODGES:
But I think it is also fair to say 13 that the II: sights Report tried to group those kind of 14 improvements and be presented in such a way that the utility 15 management could see what plants of a similar design made 16 changes that they hadn't done, so hopefully they will also 17 pick up on some of this and we won't have to do arm-twisting 18 on it.
19 DR. APOSTOLAKIS:
Now coming back to the 20 vulnerabilities, are any of the changes of the licensees 21 proposed to implement changes in the current licensing 1
22 basis?
23 MR. NEWBERRY:
We could spend the next part of the 24 meeting discussing what the licensing basis is, but my view 25 on that is that all these are additional commitments made by r
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1 3icensees to modify the facility.
That is over 500
()
2 additional commitment to add a procedure, an alternate 3
cooling source, to add a hardware modification as 4
significant as a diesel generator.
In my view they are --
5 my personal view is that they are all a modification to the 6
licensing basis.
7 DR. APOSTOLAKIS:
So the next question is then do 8
they have to do an analysis to convince you that they have 9
to do it or is the IPE finding sufficient?
10 MR. NEWBERRY:
Right now I think the view is that 11 the utility's assessment, which includes the IPE, would be 12 sufficient.
13 I think the first part of the IPE follow-up 14 program will be to carry through in the proper way on the 15 licensee's commitment, that they volunteered those in their 16 responses to us and we will take a look and make sure that 17 they are properly put into the FSAR, put into the licensing 18 basis as the licensees said they intended to do.
19 That would be the first group of follow-up 20 activities.
21 DR. POWERS:
This smacks of being a pretty 22 resource intensive activity on the part of the NRC to follow 23 up on this.
Is my perception correct there?
24 MR NEWBERRY:
Yes, that's right.
As we work 25 through this with research, we are always concerned about
()
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how much time it is going to take, especially when we get
()
2 back into the next part of the follow-up when you say, well 3
I am going to compare Plant A to Plant B.
Plant A l
4 voluntarily offered this; Plant B didn't.
How are we going 5
to resolve that?
6 Now you have to interface with the utility.
We l
l 7
have to figure out how to do that properly -- to what extent 8
are you then going to go back and look at the IPEs.
i l
9 I don't want to re-review all the IPEs again as l
10 part of this.
l 11 DR. POWERS:
Just the first step of it, tracking 12 the commitments made by -- I mean the 500 of them, counting l
13 them, is a day's job.
Following them up with the I presume l
14 30 or 40 plants that made these commitments is a big job i
15 here.
16 MR. NEWBERRY:
I should say it is a big job but we 17 plan on doing the job.
We are treating it as a significant l
18 activity in NRR, to carry through on these things.
Yes, it 19 is a big job but we think it is important.
20 DR. POWERS:
My concern is that people say, well, 1
21 gee, there ought to be a lot of follow-ups and, you know, 22 there's a requisite number of bullets that ought to be under 23 follow-up but I mean if it is going to fill your plate to do 24 one, let's not try to fill the viewgraph here just for the 25 sake of filling the viewgraph.
I l
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DR. APOSTOLAKIS:
So as a result of the IPE
'f 2
findings, you will readily accept changes that they have to 3
make and for example since IPEs are probabilistic, you will 4
not ask them to use 1.174?
In other words, you will assume 5
that defense-in-depth is preserved and everything is 6
preserved because what they do will be conservative?
7 I don't understand how the regulations work.
I 8
mean if there is a perception that you will give relief to 9
the licensees, then they will have to go through the 10 process, but if the perception is what they are doing is v
11 conservative then it is okay?
12 DR. KRESS:
All of these things decrease risk.
13 DR. APOSTOLAKIS:
That is what I am saying.
The 14 perception is that they decrease risk --
O(s /
15 DR. KRESS:
But there seems to be a different 16 process in 1.174 for decreases in risk that didn't take that 17 much scrutiny.
18 DR. APOSTOLAKIS:
Well, given all the problems 19 with the IPE methodology it seems to me this will be a 20 perception that they decreased risk.
21 DR. h?.ESS :
That is what you meant, isn't it?
You 22 want to see for'sure that something else isn't --
23 DR. APOSTOLAKIS:
Yes.
Is there such a rule --
24 excuse me -- is there such a rule that says if we think it 25 is conservative, go ahead and do it; if we think it is not
()
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conservative, tt we will pull out all the Regulatory
()
2 Guides and you better follow them.
3 Is that what the regulations say?
All the 4
regulations say you should always follow the Regulatory 5
Guides.
6 MR. NEWBERRY:
There is a regulatory process that 7
is in place right now that allows plants to make 8
modifications to their facility and to continually improve 9
their facility and the way right now, and I am certainly not 10 done thinking about this bacause you are asking some good 11 questions, utilities have used the IPE tool to make many 12 changes to the plant and in their mind I would think -- Mary 13 can listen to me on this -- but I think in my mind in all 14 cases they thought these were improvements, safety 15 improvements.
16 They found things at their plant using the IPE as 17 a way to investigate and study the plant --
18 DR. APOSTOLAKIS:
That is my point, because they 19 think they are improvements then the approval will come 20 immediately.
21 MR. NEWDERRY:
I don't know that we have to 22 approve that.
23 DR. BARTON:
George, a lot of them have been done 24 under 50.71, the 50.59 review process --
25 DR. APOSTOLAKIS:
So they have to find a home like 3
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that?
The IPE is not good enough?
im()
2 DR. KRESS:
I don't think any of them will do it it would be done in 1.174 because it's not really in 3
e-4 effect there --
5 DR. APOSTOLAKIS:
I understand 1.174 but I mean 6
just because the IPE said that this is a vulnerability this 7
is not good enough.
They have to go to the right Regulatory 8
Guide, the right regulation, and say we are going to do 9
this --
10 MR. NEWBERRY:
That's right.
That is where we 11 come in.
You said it.
They have to find the right 12 regulatory home and in some cases that could have been done 13 in accordance with the procedures under 50.59.
In some 14 cases they may have had to come in with a technical A
vs 15 specification modification because it was in that part of 16 the license but our job --
17 DR. APOSTOLAKIS:
That is interesting what you 18 just said.
They have to come in with a technical 19 specification modification.
20 MR. NEWBERRY:
They may, yes.
21 DR. APO3rOLAKIS:
Now if they do that, this is 22 clearly probabilistic.
How are you going to handle that?
23 Are you going to handle it the way of 1.177 says?
1 24 MR. NEWBERRY:
Yes, yes, that is where we are 25 going to look and that is the way we are going to think.
O.
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DR. APOSTOLAKIS:
Okay.
2 MR. NEWBERRY:
Let me just jump ahead and give 3
this back to Wayn here.
4 It seems to me there's going to be three general 5
groups of these things.
6 The first group we have been talking about here is 7
the group of improvements that a utility wants to make has 8-made.
They have volunteered them.
9 The second group is going to be a challenge 10 because that's where we have to do some assessment and 11 compare plant to plant to say why didn't this guy make a 12 change that another plant did.
That is going to be a little 13 bit more resource-intensive where we are going to have to 1
14 set up some screening criteria perhaps to figure out what
[,
i
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15 events and what improvements to look at, and then I think we I
16 are going to have dialogue with the licensee to see if maybe 17 there are some more improvements they might want to i
18 volunteer on.
That is the second group.
19 The third would be do we want to require anything, 20 and then you are talking about the backfit process -- is 21 there anything we want to do to provide additional reactor 22 coolant pump seal cooling at a plant?
You know, there's a 23 large group of plants that made that modification and maybe 24
'someone didn't and there is a process to go through that.
25 MR. MARKLEY:
And George, to your point of whether ANN RILEY & ASSOCIATES, LTD.
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1 they have to use 1.
174 or not, they don't.
That is one
()
2 method that the NRC will accept.
Now it may be more 3
difficult to go another route but that is an avenue, but it 4
is voluntary.
5 DR. APOSTOLAKIS:
How can it be voluntary when the 6
result is based on probabilistic reasons?
7 MR. MARKLEY:
All Reg Guides are voluntary.
8 DR. APOSTOLAKIS:
Right.
9 MR. HODGES:
Part of how we will go through this 10 process of identifying where things may be need to be done 11 is we will start by looking at plants that have very high 12 CDF or high LERF and look to see if within the constraints 13 of the backfit rule we should take action.
14 DR. KRESS:
You would consider the high CDF and n\\_/
15 high LERF, those things, in the backfit rule?
16 MR. HODGES:
We would consider those as an 17 indicator of where we need to look.
18 DR. KRESS:
Yes, but the numerical values would be 19 those that are in the backfit, regulatory analysis?
20 MR. HODGES:
Then we'd use the criteria in that 21 guidance to determine whether or not it was appropriate to 22 take action.
23 DR. APOSTOLAKIS:
Now regarding that aspect, I 24 assume that NRR was informed about results as the IPEs were 25 submitted?
I mean you guys are not finding out right now
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what the spectrum of CDFs is.
Right?
2' MR. HODGES:
Right.
3 DR. APOSTOLAKIS:
Right.
4-MR. HODGES:
That is correct.
5 DR. APOSTOLAKIS:
Now when a licensee submitted an 6
IPE,'say,-with five 10 to the minus 4 core damage frequency, 7:
did you do anything?
Or did you just say, gee, that's 8
interesting?
'9 MR. NEWBERRY:
No, we have done things.
In fact, 10 and this goes years back, maybe Mary can think of a specific 11:
' example, I forget the plant but a particular sequence even 12 was in that range and what we would typically do is we would 13 be consulted with Research and even put a team together and 14 go visit the utility to see what should be done and could be 15 done and many times modifications were made near term, right 16.
after they'd done the study.
17 DR. APOSTOLAKIS:
So I guess what my interest is 18 is in finding out what was the warning range?
I mean you 19 didn't do that if it was two 10 to the minus 4?
20 At which point did you start saying, hey, we 21 better look at this?
22' MR. NEWBERRY:
I don't know that I could answer 23 for the whole staff on that very example but it was in the 24 range of where you are starting to ask your questions.
It 25 is certainly in the 10 to the minus 4 range that causes you ANN RILEY & ASSOCIATES, LTD.
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to look, sure.
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2 DR. APOSTOLAKIS:
So anything above 10 to the 3
minus 4 you say, gee, let me look at it and you may decide 4
to look at it for five minutes, or if it is six 10 to the 5
minus 4 you look at it longer?
6 MS, DROUIN:
George, I mean it was a combination 7
of looking at the number and then trying to find what was 8
the basis for the number.
9 DR. APOSTOLAKIS:
Sure.
10 MS. DROUIN:
And whether it was design driven or 11 assumption driven, but there wasn't one specific number that 12 we said, okay, if you fell above this or below this we 13 weren't going to look in more depth.
14 Certainly there were flags, and as Scott 15 indiuated, when you start getting up into, you knce, the 16 minus 4 range, that is not to say if someone didn't come in 17 with a 90 minus 5 that we wouldn't have taken a closer look 18 at it.
19 We took a pretty close look at all of them --
20 DR. APOSTOLAKIS:
No, I didn't mean that.
I know 21 you did that, but as the submittal arrived here, you were in 22 contact with NRR, right, so I am curious to know how the 23 point at what -- the point estimate that you got is in some 24 range.
25 I am curious to know how you reacted to that.
I
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mean clearly if somebody submitted a 10 to the minus 5, you 2
may -- of course you would look at it, because you have to 3
review the IPE.
That's no big deal.
4 As we approach 10 to the minus 4, as you say, or 5
exceed it, and maybe you make a phone call or something 6
happens.
You guys get together for awhile.
Of course you 7
want'to find'out why it is up there and the first thing you 8
ask is is it analysis-driven?
If they used a very 9
conservative model someplace, you want to convince yourself 10 that that is what they did, but let's say that is out now.
11 You have screened that.
So what is happening now, 12 as we move up?
Two 10 to the minus 4?
Three 10 to the 13 minus 4?
Is there a level?
14 Let me go to an extreme, -:ary.
Is there a level 15 in your opinion where you would have to actually pick up the 16 phone immediately, call Scott and say, hey, we have got 17 something here, we have to do something?
Where is that 18 level?
19 Now it doesn't have to be a specific number but 20 can you give me an idea?
21 Wha.re would you, as Mary Drouin, feel that you 22 would have to let the Agency know that something is 23 happening?
24 MS. DROUIN:
Wait -- why did it come back to Mary 25-Drouin?
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MR. NEWBERRY:
George, my personal view is
)
2 certainly in the range of 10 to the minus 3, certainly --
3 DR. APOSTOLAKIS:
Good.
4 MR. NEWBERRY:
Certainly --
5 DR. APOSTOLAKIS:
Good.
GoUd. Good. Good.
6 This is very good.
The court reporter took that 7
down.
8 MS. DROUIN:
Thank you, Scott.
9 DR. APOSTOLAKIS.:
Wonderful.
10 MR. NEWBERRY:
That is my own --
11 DR. APOSTOLAKIS:
Now let's go down a little bit.
12 MR. HODGES: -Well, clearly when we saw the Quad 13 Cities IPEEE, you know, the fire results were at five 10 to 14 the minus 3, we reacted in that fashion.
15 DR. APOSTOLAKIS:
And I MJnk you were absolutely 16 right.
17 Now let's keep going down.
Then it is really a 18 matter of shades of gray.
Certainly a 10 to the minus 3 and 19 then you begin to relax as the number becomes smaller, but 20 that doesn't mean that you don't look at it, right?
And 21 then when it goes below 10 to the minus~4 you feel better.
22 DR. KRESS:
George, I think you are putting words 23.
in their mouth.
24 CHAIRMAN SEALE:
Yes, I think so.
25
[ Laughter.]
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DR. APOSTOLAKIS:
They can always say no.
(~ss
(
)
2 DR. MILLER:
It is pretty hard though.
3 CHAIRMAN SEALE:
Yes, but 10 to the minus 3 i
4 certainly has got to carry with it then certain additional 5
or special considerations on things like defense-in-depth G
and so forth, 7
MR. NEWBERRY:
Certainly.
8 CHAIRMAN SEALE:
It is not a number that stands 9
out there by itself.
It has to be buttressed by other 10 things in order to be an acceptable stopgap measure.
11 DR. APOSTOLAKIS:
Well, they said they will look 12 into it first-hand to understand why the number is there.
13 CHAIRMAN SEALE:
Sure, but the compensatory 14 measures also have to be looked at.
)
15 DR. APOSTOLAKIS:
Of course.
These things are not 16 done, you know, without -- and in all fairness, lady and 17 gentlemen, I am using you to make a point to my colleagues 18 here, so --
19 DR. MILLER:
We understand that.
20 DR. APOSTOLAKIS:
My colleagues understand that.
21 You don't.
22 MR. NEWBERRY:
I think I.do.
23 DR. MILLER:
You don't underestimate him.
24 MR. HODGES:
The other thing that we are doing, 25 that we look at, is for those plants that had very low CDF
{ h ANN RILEY & ASSOCIATES, LTD.
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and LERFs we want to understand why and see if there was
()
2 some artifice of the analysis that if you changed it and 3
made it more realistic they might fall into a problem.
4 DR. APOSTOLAKIS:
So you are saying if somebody 5
submits something that is 10 to the minus 9 you worry again?
6 MR. HODGES:
We worry, yes.
7
[ Laughter ]
8 DR. APOSTOLAKIS:
But for different reasons.
9 MR. HODGES:
For different reasons, that's 10 correct.
11 DR. POWERS:
Your concern about low values must be 12 on a different priority scale.
It didn't even make the 13 viewgraph, so it's -- it's stretched in time or stretched in 14 intensity or something like that.
15 MR. HODGES:
Well, it may also be a different set 16 of people as well, so, I mean, well, maybe something that we 17 look as opposed to them.
That has to be negotiated.
But 18 yes, it's not quite the same.
But yes, it still needs to be 19 looked at.
20 MR. NEWBERRY:
Just a quick one.
My vision of 21 that is the low values we will end up focusing on sooner are 22 the ones where we have information like another IPE that 23 suggests it's not all.
24 DR. POWERS:
I guess I understand that somebody 25 coming in with a 10 to the minus 6 versus somebody that made ANN RILEY & ASSOCIATES, LTD.
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voluntary commitments to get himself down to 10 to the minus
(
,]
2 4 you would probably look at that real closely.
3 MR. HODGES:
Yes.
And actually Susquehanna was 4
the very lowest of the I think the BWRs and we did even 5
approve their IPE, and now they've come back and I think 6
they're doing a much better job, so it should be a rather 7
easy thing to do at this point.
8 One of the problems with the IPEs is we didn't 9
have any standards for doing what they were doing, and so 10 the approaches were widely varying.
We are in the process 11 of now working with the ASME to try to develop some 12 standards that can be used for PRAs, and we also, you know, 13 they pointed out probably things we already knew as far as 14 needing research like better human reliability research or
'O 15 methods.
It does focus some of that for us.
16 DR. POWERS:
Human reliability of course gets 17 mentioned immediately, and in fact my perception's that as 18 tte screening kind of review went on with the IPE 19 submissions that people look specifically at the treatment 20 of the human reliability analysis.
In all the reports on i
21 the IPEs that I naw there was a section that dealt 22 specifically with that.
23 Are there other topics that generally received 24 closer scrutiny and anticipation that there would have to be 25 more research or technology development?
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MR. HODGES:
Do you want to try to take that one 2
on, Mary?
3 MS. DROUIN:
I guess that, one, I'm not real sure 4
about.your statement, what you mean by_that, because we 5-looked at all those facets when we were doing the review 6
that could potentially-affect the results in a significant 7
manner.
HRA was just one of them.
8 DR. POWERS:
But HRA is the one I remember -- I 9
can't say that I've read ten percent of the summary reports, 10 but several of them, and every one of them had a specific 11 discussion of the HRA modeling.
12 MS. DROUIN:
Right.
Every one had a specific 13 discussion on HRA.
Every one had a' specific discussion on 14 the severe accidents.
Every one had a specific discussion 15
'on accident sequence, on data.
So on all of those different 16 technical disciplines tha enter into the PRA, we tried to 17 provide some insights of what was done in the analysis on 18 each one of them.
I don't think that we selected HRA above 19 any of the others.
I mean they were, you know, all the 20 different technical disciplines we tried to address.
21 DR. POWERS:
I didn't suggest that you did, Mary.
22 I asked if there were other areas that you have looked at
'23 that might be a springboard to additional research.
24 MS. DROUIN:
Oh, in that area there are things 25 that are coming out for additional research across the IPE
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and IPEEEs.
I mean, fire being one of them.
I don't know (O) 2 all the different things that are going on from Charlie 3
Ader's branch, but there were things that came out on the 4
severe accident phenomenon side that --
5 DR. POWERS:
Well --
6 MS. DROUIN:
For some additional research.
1 7
DR. POWERS:
I have a good feeling what's going on 8
in Mr. Ader's organization.
It's retrenchment.
I don't 9
think he's springboarding to look at anything.
10 MR. HODGES:
No, but there were things that were, 11 you know, things like direct containment heating, as it was 12 treated in the IPEs, had not taken advantage of some of the 13 research that has been done, and I think --
14 DR. POWERS:
I thought DCH had been restricted out n
k_s 15 of the IPEs.
I thought it had been declared that that was a 16 phenomenon that the people did not need to take into 17 account.
18 MR. HODGES:
Many of them did not take advantage 19 of the research which says it was a low probability, and so 20 it was treated as a problem in many of the IPEs.
21 DR. POWERS:
Okay.
So they took like a NUREG-22 1150 approach or something like that.
23 MR. HODGES:
Right, right, right.
So there are 24 things like that that research could improve upon and has.
25 And it was generally ongoing research anyhow.
A)
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MS. DROUIN:
One of the things, I mean, another
()
2 one was the RPC LOCAs, steam generator tube rupture, I mean, 3
there are a number of issues.
They're discussed in 1560 in 4
chapter 8.
5 MR. HODGES:
One of the major questions that was 6
looked at though is was additional research needed for the 7
reactor coolant pump seal LOCA because of the wide variance 8
in results that was identified in the IPE.
And I think at 9
this point the conclusion is no.
10 See, the licensees were specifically asked to look 1
11 at A45 in the IPEs to look at potential resolution there, 12 and so that was addressed in all of our SERs.
There were l
13 other generic issues that were treated by some licensees in I
i 14 their process, and then we addressed those as well.
There's 15 a report -- do you know when that report is to be issued, 16 Mary, coming out on the generic issues?
17 MS. DROUIN:
In the next couple of months.
18 MR. HODGES:
Okay.
19 MS. DROUIN:
It should be available.
20 MR. HODGES:
And then finally one of the things 21 that's been added recently is a task to use the IPEs -- is 22 to try to asses regulatory effectiveness of the station 23 blackout rule and of the ATWS rule, just to see how good a 24 job we did there.
25 DR. UHRIG:
Are those arbitrary choices just for
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1 examples or are those -- is there a reason for the choice of
()
2 those two?
3 MR. RUBIN:
I could provide a little bit of the 4
background.
Marc Rubin.
I'm the Acting Chief of the NRR 5
PSA Branch.
6 Historically PSA PRA were used or the development 7
of the rule requirements going back many years to ATWS.
A 8
lot of risk calculations were done.
Much more recently 9
station blackout also used PRA to help formulate the various 10 options for implementing the rule.
11 There were some target values of what residual CDF 12 should remain after the station blackout rule was 13 implemented.
I think it was e to the minus 5.
So even 14 though they were not formal requirements of the rule, they 15 were significantly used in the formulation of the rule, and 16 now we have a chance to go back and see if those goals or 17 expectations can be satisfied.
18 DR. UHRIG:
Thank you.
19 MR. HODGES:
And unless there's further questions, 20 that's really all I have prepared to present.
21 DR. FONTANA:
There is no intent to -- because 22 these are uneven quality apparently --
23 MR. HODGES:
Well --
24 DR. FONTANA:
Presumably there's no intent to go 25 back and try to even them up or anything like that.
(
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MR. HODGES:
No.
2 DR. FONTANA:
No.
3 MR. HODGES:
I mean, if they're used for licensing 4
applications there are things that they will have to do to 5
them, but --
6 DR. POWERS:
The question that seems to have 7
emerged from the IPE submissions and the 1.174 is that if 8
indeed we have a flood of people wanting to use -- take 9
advantage of 1.174 that staff will be confronted by a 10 substantial range of techniques and approaches and data 11 bases and things like that and any kind of risk assessment.
12 Now -
and that's going to be a challenge in the NRR field.
13 It's going to be difficult to say well, that's 14 been handled and now let's -- before and I can skip over 15 that section and get to the heart of the matter.
You're 16 going to have to go back.
In some respects you're handling 17 that through the standardization activity, and we don't know 18 exactly how that's going to come out, but it'll -- that's an 19 approach.
~20 Have you thought about the organizational 21 challenges that are likely to arise if you have a flood of 22 applications under the 1.174 reg guide?
I mean, is there 23 more beyond just this, whatever limited impact 24 standardi::ation?
And I keep get'ing punched in the side by 25 the Chairman suggesting that maybe I ought to declare this ANN RILEY & ASSOCIATES, LTD.
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as a time to let you go think about the question.
(
2 CHAIRMAN SEALE:
I was going to suggest.
Maybe we 3
ought to --
4 DR. POWERS:
Actually my ribs are quite sore at 5
this point, so maybe I better turn it back to the Chairman.
6 He is armed with a stick.
7 CHAIRMAN SEALE:
Well, Commissioner Diaz has 8
arrived to speak to us.
As I indicated earlier, we wanted.
9 to start this at the earliest opportunity, since he has a 10 busy schedule, and certainly we're interested in hearing 11 whatever he may be able to help us with.
And we thank you 12 for coming by.
13 COMMISSIONER DIAZ:
I don't know whether to stand 14 or sit-down.
Sit down, I am more at risk.
O 15 CHAIRMAN SEALE:
I don't know.
Whatever.
16 Whichever.
17 DR. PO!dERS :
I believe 10 to the minus 6 is the 18 maximum level of risk in this sort of thing.
19 COMMISSIONER DIAZ:
I'll sit down then.
20 Is this recorded?
That limits my freedom.
21
[ Laughter.]
22 CHAIRMAN SEALE:
We share that problem.
23 COMMISSIONER DIAZ:
First I wanted to say that 24 although it has been a long time coming, it is for me a real 25 privilege to be with you.
And it's not just a simple word,
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but it's because I see on the other. side so many people that
()
2 I have such a high regard for, and so many people that I 3
have looked on, even when I was starting in this field, as 4
people that I should emulate or come to their standards or 5
demanding performance.
And so it is a real privilege, and I 6
appreciate the opportunity to talk to you.
7 That'also means, that seems -- you know, I have 8
such a high respect for you, that means that you're older 9
than I am, because that's part of my culture.
10 CHAIRMAN SEALE:
I would like to think there was 11 more to it than that.
12 COMMISSIONER DIAZ:
Well, I just want to provide 13 some checks-and balances.
14
[ Laughter.}
15 I think that maybe it was the section of Dr.
16 Uhrig, you probably don't know about my earlier background, 17 and I thought that this might be a quick moment to just say 18 a couple of things.
I am actually a mechanical engineer, 19 and I did practice as a mechanical engineer, and the thing 20-that I did a little better than others was plant design.
21 And in 1959 I started to design the first nuclear reactor 22 that was going to be built in this continent outside of the 23 United States in the Province of Havana, in Cuba, and that's 24~
the reason that I started down in this field.
25 It was going to be a boiling water reactor, 80
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megawatts, which doesn't sound like much, but it was a real r~(Tj 2
significant plant.
It would have provided 10 percent of the 3
electricity of the country at the time.
And of course 4
things did not work out, and I had to leave the country.
I 5
spent many months under political asylum in an embassy.
And 6
most of my family was in similar positions, either in jail 7
or some way out.
We eventually managed to rescue all of 8
them, came to this country, and I immediately started to 9
work again on mechanical design.
10 And of course that led to some interesting 11 mechanical design of nuclear powerplants.
And then I 12 decided that I did not know enough about it, and so I 13 decided to go back to school.
And this is where the great 14 act of faith of Dr. Uhrig took place, in which I went in (3
\\s,/
15 there and said I assure I can do all of these things.
And 16 he said, "Well, show me your transcript."
I said, "It's 17 lost."
18
[ Laughter.]
19 And he said, "Okay, let me think about it."
And 20 eventually I think he thought about it, or whatever, so I i
21 was admitted to graduate school without a transcript, on 22 probation.
And I would like to remind him that I made all 23 As.
24
[ Laughter.]
25 And that's how it all started, a long time ago.
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By 1962 I was back enrolled in school, and because I didn't (n) 2 get paid enough, I used to moonlight in plant design, and 3
that's how I got connected with architect engineers and 4
started my secondary career which continued for many years 5
on plant design.
6 I have placed you in a very high regard all of my 7
life, because I know that what you do is very important, and 8
I will continue to support and strengthen your operations, 9
because you are needed and because I have known that for a 10 long time, and you have my trust.
11 That places you.
Now let me place myself.
I am 12 an advocate of prudent government, and that means as a 13 Commissioner I am an advocate of prudent regulations.
- But, 14 you know, those are good words, but what do they mean?
How b)
\\_
15 do we define them?
You know, how do we put some bounds J
16 around it?
17 Fundamentally it is that I want to get the 18 regulations that we have our licensees implementing to be 19 better, to be fewer, and to produce minimal burden, because 20 I envision that the safety infrastructure that we develop 21 has to be both necessary and sufficient to cover safety.
22 But the burden has to be only necessary, really minimal.
23 And if you think of these words of being an.
24 advocate of prudent government, you will immediately see how
]
25 I didn't fit in Castro's Cuba.
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I think I will expect as a Commissioner that the 2
ACRS will play a major role in the transformation of this 3
Agency to one that has necessary and sufficient safety 4
conditions, but minimal burden.
You need to play a major 5
role as an independent advisory to the Commission.
You 6
provide checks and balances that are very important to us, 7
so that safety is-defined and burden is minimal.
And I 8
expect your role to go beyond the ones that sometimes we 9
scientists and technologists do best, which is to look at 10 high-end sophisticated analysis, because we find some amount 11 of security in it.
12 I think you have to work for us where the rubber 13 meets the road, because if something is going to break, it 14 is not going to break of importance in the analysis.
We can
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N_
15 fix those.
If something is going to break, it is far away i
16 from when analyses are being made.
And I see your role as 17 getting deeper and deeper into what are the processes that 18 implement our safety structure and how can a improve those.
19 I talk about safety and I have a vision of it.
A
)
20 lot of people always talking about, you know, the first 21 barrier, we even do that, you know, from the fuel out, you 22 know, first barrier.
And second barrier.
And third 23 barrier.
What happens with you when you run outside the 24 third barrier?
That's a real problem.
1 25 I see yourself as a net that is webbed so tightly
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and is so strong that there is no need to define which is (Gj 2
the last piece of it, because even in the processes that we 3
generate we can always add a safety net, but in that is a 4
great danger, the danger of thinking that it's easy to add 5
another layer, and forget the burden.
Because the purpose j
6 is not to regulate.
The purpose is to improve the well-7 being of the American people, and that is the bottom line.
8 Therefore, when I see the mission of the NRC, I I
9 don't see it as a single point.
I don't see it exclusively 10 as protection of public health and safety, although of 11 course that is the center.
12 Really our mission has three parts.
The first is 13 to promote common defense and security.
And those are big 14 words.
It's electricity generation reliability,
(,_h
\\s /
15 economically, a part of common defense and security.
I 16 would say so.
Protection of public health and safety, 17 undoubtedly the center that we revolve around.
And then 18 protection of the environment, protection of the environment 19 again with consideration of protection of public health and 20 safety and promotion of common health and security.
There 21 is a feedback loop.
They are not independent issues.
They 22 are tied together.
23 We have to be aware that this safety net has been 24 developed through the years many times, strong but not 25 consistent within itself, that it has many patches, that it D\\
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has inconsistencies, that sometime we even get into the use 2
of words that are wishy-washy, that don't express what we 3
really want to say.
But we have become content with them.
'4 And the licensees say I better adopt that 5
language.
I don't really know what it means.
But if they l
6 use it, I better use it.
And.therefore it's practically 7
established, and everybody now knows what generally means --
8 I think.
And everybody knows what significant means -- I 9
think.
And everybody knows what having a questioning 10 attitude means -- I think.
But do we know?
Your role is a i
11 role of bounding and definition and bringing together issues 12 that might be isolated, but there is a feedback, and you are 13 the ones that can look at it from the outside and see the 14 feedback loops.
15.
DR. APOSTOLAKIS:
Could I ask you a question?
16 COMMISSIONER DIAZ:
You could.
17 DR. APOSTOLAKIS:
Okay.
18 COMMISSIONER DIAZ:
But I am not -- I haven't 19 gotten to you yet, but I will.
20 (Laughter.]
21 DR. APOSTOLAKIS:
I find this statement you made 22 the last minute extremely interesting, so I would like to 23 try and understand it.
It is a correct understanding that 24 you are against things sort of happening by themselves 25 without the proper scrutiny, without us really knowing and ANN RILEY & ASSOCIATES, LTD.
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scrutinizing what we are doing?
n 1
2 COMMISSIONER DIAZ:
Yes, that is correct.
That is
%J 3
correct.
Within the bounds of what you do.
4 DR. APOSTOLAKIS:
Exactly.
Thank you very much.
5 COMMISSIONER DIAZ:
Because I think the entire NRC 6
issue is an issue of definition.
Okay.
We thought for many 7
years that establishing this structure was good enough.
8 Now, those are not the words.
Was adequate.
Was adequate.
9 But the point is that adequate has never been defined and, 10 therefore, it is our role, and pretty much yours, to help us 11 define our role, define our structure, define our processes, 12 and define adequate.
Because regulatory agencies always 13 have a tendency to be more than adequate, and sometimes that 14 is okay.
And I am diverting now because Professor O
(m l 15 Apostolakia is, you know, a part of my feedback system.
And 16 it is important that the balance is there.
Okay.
17 I talk about safety and I see safety, and I like 18 pictures because I used to do a lot of drafting, plans 19 drafting, and I used to do some drafting for Dr. Uhrig.
I 20 can not even understand what he was trying to do, but there 21 was a lot of arrows all over the place.
But I knew it meant 22 something.
So I always try to put things in some pictures.
23 I envision safety as an envelope, not as a line, not as a 24 point, not as something that is not flexible.
I see safety 25 as an undefined glob or blob that each characteristic is O)
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identifiable to every one of our facilities, and each one of 2
those are going to be different.
3 I see this safety envelope as having the 4
capability of contracting and even changing slup because 5-the area that it defines is what is real.Ly important, is the 6
area under the curve, not just the simple boundary, and that 7
the boundaries can Clex can flex and change as long as you 8
accommodate that change by other measures that maintain 9
your, quote, " safety margin", and I am not going to talk 10 about safety margin.
Okay.
I am going to avoid that 11 dangerous ground today.
I'll be back some other time.
12 But it is important to know that that envelop is 13 what we say provides adequate protection.
And, therefore, 14 the identification and becoming cognizant, more just than 15 knowing that is there, this envelope, is very important not 16 only for us, but for the licensees.
They need to be able to 17 work within an envelope.
18 And how do we bound that envelope?
And you will 19 see Professor Apostolakis immediately waking up, alt.' ough he 20 pretty waken up a while up.
Because risk should bound it.
21 Risk should bound the envelope.
And performance, rather 22 than process, would be the expression of conformance when it 23 needs to conform to a set of regulations.
24 So having the said the four-letter word " risk",
25 let me just go a little bit about it.
You know that the ANN RILEY & ASSOCIATES, LTD.
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Commission has actually expressed itself, not me, not any
()
l 2
one Commissioner, but the Commission says that the NRC is to 3
be risk-informed.
And I even asked you, a very pointed 4
question to some of you -- Are we capable of being risk-5 informed?
And I asked the staff whether they knew what that 6
meant, and the answer was very long, and I am sure you have 7
seen it.
8 But the issue is that the Commission in DSI-12 and 9
other ascuments has said, first, we become risk-informed 10 and, ultimately, we become risk-informed, performance-based.
11 Because, as you know better than I do, it is not possible to 12 define the processes of evrerything we need to do in terms of 13 risk-informed, performance-based.
But I have tried, and I i
14 will keep trying to work for our tapestry, the safety fabric 15 that we have created, which is thick and is strong, although l
16 patched, to become risk-informed, i
17 And I see risk information not as a play of_words, 18 not to let somebody think that we are very intelligent.
Not 19 to let somebody think that we are into the game that the 20 general United States government is going.
I see it as i
21 quantitative definition that supports everything else that 22 we do and we have been doing, not exclusively, but as a 23 supporting, quantitative measure.
Because, if not, it will 24 be just like the others, it will be more subjective and more 25 easily interpreted, and more easily changed.
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f tN We need the quantification that risk insight can i
(,)
2 and will provide us and, in this, I know you play a major i
3 role.
l 4
We can also become performance-based in certain 5
specific applications.
It doesn't even have to be risk-6 informed, performance-based, it could be purely performance-1 l
7 based.
It is when these two things get together, and people 8
think we can do them, or some people are absolutely adamant 9
can not, where the problem gets, when we link them into 10 risk-informed, performance-based.
We might be able to do 11 some.
I guess, you know, I wasn't here when the Maintenance 12 Rule was created.
I think that was probably one of the 13 sneakiest things the NRC has ever done.
They, you know,
)
14 they just went -- shoom -- went right in and went right l /~S kl 15 over, under people, people didn't realize what was m
16 happening.
17 The fact, in a very elegant fashion, it mixed 18 safety-related and not-safety-related system structures and 19 components, which we have carefully maintained separated by 20 something we call the Q List and innumerable regulations for 21 many years, and we mixed them in one pot.
l 22 The significance of that is tremendous.
The 23 Maintenance Rule is the beginning of the end of the 24 regulation as we know it, because what it did it said, you 25 know, it doesn't matter how you define these things, if you
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are risk-informed, you can make good decisions about the OQ 2
entire set of systems, whether they have been fully QA or 3
not.
It actually was a comprehensive look at what will be a 4
good start.
I claim that if we make 50.59 risk-informed, 5
then there is no reason why not to make Part 50 risk-6 informed.
Because this tool, major initia3 steps, provide 7
the framework from where to launch an all-out assault on the 8
subjectivity, the lack of clarity, the lack of definition, 9
the "I know what you mean, you know what I mean" deal that 10 might have worked very well for many years, but is present1v 11 invalidated by Informatics, by the Internet, by the 12 visibility of those things.
It is no longer working, and it 13 needs fixing.
14 And the only fix that we know enough about to 15 cautiously but consistently insert into the system is risk 16 insights.
There is nothing else.
And if you look at the 17 time that it has taken,'it was 25 years that Norm Rasmuson 18 was given that contract, nothing will be on time for what 19 needs to happen in the next few years, and I will talk about 20 that.
21 There is a danger with becoming bound to risk 22 information and risk insights, and the danger is to start 23 believing decimal points.
Okay.
That is definitely not the 24 idea.
Okay.
The idea is do we have additional quantitative 25 information that supports decision making.
We get lost on ANN RILEY & ASSOCIATES, LTD.
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what -- how large the uncertainties, and lose sense of the 2
fact that we, for generations, when something was uncettain, i
3 we tried to decrease the uncertainty by dividing it by 4
itself.
Like Dr. Uhrig showed me many years ago when we 5
were trying to do cross-correlation, just mix a number with 6
itself and you can do something about it.
And the fact that 7
in the relative importance of risk, there is a tremendous 8
amount of information that we are not consistently using.
\\
9 That doesn't mean that we should not -- should not 10 continue to reduce uncertainties or to know what they are.
11 But I don't think we need to know them all to use them, 12 because they can be used now.
13 So, on risk-informed regulation, you know where I 14 stand, and I am looking forward, and I am not even going to v
15 profess myself on the issue of elevating CDF to a 16 fundamental safety goal.
We have talked aoout it.
Okay.
17 We are asking you precise questions.
I have looked last 18 night at a series of ACRS papers on it.
And we seem to be 1
19 going, you know, yes, and yes, but -- and yes, -- yes, 20 but -- yes, but, -- and I know it is a difficult issue.
But 21 we need your advice, we need your counsel.
We need to see 22 how you think.
We will make the decisions, but we need to 23 have it founded on multiple inputs and yours is one of the 24 most important.
25 We know from our lawyers, very clearly, that we
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can not become risk-based, you know, we have to do a lot of 2.
things before we do that.
I say le'u become risk-informed, 3
because that is not too far from where we are.
And, in 4
fact, if you look at it, you know, this is amazing, we do it 5
all the time, and then we are still arguing about it But 6
any time needs some additional definition out there, whether
(
7 the Commission knows or not, somebody is doing it, and they 8
are doing it effectively.
Why not institutionalize it?
A 9
risk-informed Part 50 will be better than what it is.
I 10 To bring the NRC to Second Millennium regulation
(
11 structures would allow us addition information from which to 12 make decisions.
13 I am sure you don't want me to leave without 14 talking about 50.59.
Right?
O 15 CHAIRMAN SEALE:
It crossed our mind.
16 COMMISSIONER DIAZ:
It crossed your mind?
Well, I 17 empathize a lot with 50.59 because it was created in 1961, 18 the year that I arrived at this great country of ours, so 19 you know, and that was a long time ago -- really a long time i
20 ago.
It had endured, okay, I don't know how, you know, 21 through all of this time and this magical combination of 22 give-and-take and still asking for require:S safety, but it 23 doesn't have to be like that, because we have learned a lot'.
24 If you don't think we have learned a lot, look at 25 your gray hairs and you will see how much learning is in ANN RILEY & ASSOCIATES, LTD.
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every one of them -- or lack of hair, I will say.
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2
[ Laughter.)
3 -
DR. APOSTOLAKIS:
Somehow I knew it was coming.
4
[ Laughter.]
5 COMMISSIONER DIAZ:
50.59 was broken and it needs 6
to be fixed and we are working on that.
7 I took objection a year ago to the fact that it 8
wouldn't look very good in the Congress of the United States 9
if some chairman of a committee received a document that 10 says last year the NRC reviewed 15,878 unreviewed safety 11 questions.
My god -- unreviewed safety questions?
They 12 still have questions that are related to safety and they 13 have not reviewed them?
Fire them all.
14 You know, the term from the beginning was 15 intended, yes, you know, something needs to be reviewed.
We 16 didn't know about it, but that is no longer the case.
17 Is there something more reviewed than a safety 18 question at a nuclear power plant, and once it is reviewed 19 it is no longer a question, it is an issue.
We are getting 20 to these issues of maintaining our vocabulary and people 21 resist it because they say I know what that means.
22 I say things change and that definition is no 23 longer there -- the agreement is broken.
You need to do 24 something about it.
25 There is no doubt that in 50.59 it was never i
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intended, nor do I think it is in the best interest of this
()
2 nation, to maintain a de facto zero increase in 3
consequences, okay, or on the actual probabilities, or any 4
of those things.
5 I advocate -- here goes the words again -- you 6
know, minimal -- and that is going to throw you into, you 7
know, a discussion -- minimal is of course larger than zero, 8
okay?
It is significantly smaller than significant.
It is 9
somewhere that is workable, is understood, is not zero.
It 10 is small.
It is within the boundaries that we would like to 11 say we can work with, and since we like to create problems I 12 think that a very good thing-to do to define what minimal 13 is.
14 As you do that, would you please define 1F significant also, because we are being told that they have 16 to be quite less than significant, and of course we haven't 17 defined that yet.
18 But, no, no joking, it is important that the de 19 facto zero increase be abolished because it was not the 20 intention of the rule and it doesn't serve this country 21 well.
22 I have been t2 ying to make the 50.59 process more 23 risk-informed and especially I thought that in the long term 24 it certainly deserves to be, and that is as far as I can go 25 on it because the rule is being voted on and I need to stop ANN RILEY & ASSOCIATES, LTD.
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Now somebody tells me that I always get close to
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2 the edge, and then back off.
I just -- I'm backing off, all 3
right?.
4 The integrated review assessment process is a i
5 critical issue because many times we look at processes as l
6 single issues, as singularities, and we don't see them as 7
what they are, as part of a chain with multiple feedback i
8 loops that are interactive and they need to be accounted 9
for.
10 I think it was a good thing that we started this 11 pathway.
I believe that a lot of what we are going to 12 interact on licensee basis is going to be based in these 13 processes.
We actually look -- and, you know, I was 14 concerned with the fact that sampling frequency was not an 15 issue that was considered when we installed processes. As 16 you know, our processes were mostly event-driven, and I 17 think that that is not the way of doing things, okay?
You 18 have to respond to events but you don't have to drive your 19 processes by evento.
20 The processes should be established to deal with 21 events, not processes established because of an event, 22 although that even can become a feedback loop that enhances
'23 the processes if there was a need to enhance it.
24 We need to get away from the f act tr at we 25 established for many years many, many processes exclusively i
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because of an event and maintained them for years --
i 2
maintained them for years.
They cannot be maintained.
They 3
need to be reviewed and updated and I believe we know 4
enough to do that, and I believe we have a tool that will i
5 also make it better and that tool is risk insights.
6 I do have a couple of issues with you that, you 7
know, I thought you probably expected that I will take'some 8
crack at you, and you wouldn't really want me to'get out 9
here without taking a good shot at you?
No, you wouldn't.
10 That wouldn't be natural for me and I will leave you all 11 anxious about what will be coming next.
12 AP600 -- now you and I disagree on something, and 13 that's great.
Isn't it great to be able to disagree and 14 still be alive?
15
[ Laughter.]
\\
i 16 COMMISSIONER DIAZ:
Isn't that really wonderful?
17 CHAIRMAN SEALE:
When you put it that way, yes.
18 COMMISSIONER DIAZ:
I think that is a great thing 19 in this country is -- and this is what democracy is all 20 about and this is what this body is all about.
t 21 I would have never mixed an active system that i.
22 not safety-related with a passive design, but you said that 23 it was okay and the Commission, 4 to 1, voted with you.
24 I still think that, you know, although I am a 25 minority in that case, as any minority has a right to say I ANN RILEY & ASSOCIATES, LTD.
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was right, but I'm sorry.
(.m) 2 DR. APOSTOLAKIS:
Can I say something?
3 COMMISSIONER DIAZ:
Sure. Sure.
4 DR. APOSTOLAKIS:
In my mind what happened in that 5
case really emphasizes the fact that it is not just us, the 6
regulators, who have to use risk information in a 7
reasonable, rational way.
I thought the case that was made 8
before us using risk information was really mediocre.
9 Perhaps the information existed someplace, but to 10 tell somebody go find it and convince yourself that this is 11 not needed is not the way to use risk information.
12 In large part the advice you got from us was 13 influenced by that.
14 COMMISSIONER DIAZ:
I see, okay.
I didn't know 15 there was an issue of documentation --
16 DR. APOSTOLAKIS:
Exactly 17 COMMISSIONER DIAZ:
-- that I did not capture and 3
18 I am glad you brought it up, that it was on the exact 19 assessment of the risk information that was provided, that 20 that was not up to par.
It was not state-of-the-art.
.1 DR. APOSTOLAKIS:
You see, we don't know.
They 22 never showed it to us.
They just said, well, core damage 23 frequency is low and then I have to go and find out how low 24 it is, why it is low and so on, and how the whole thing 25 fits.
i
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That is not the way to do it, so I thought that it
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2 is a good idea to let you know that it is not because the 3
committee does not like risk-infonaed approaches, but we 3
4 really have to be informed.
5 COMMISSIONER DIAZ:
Yes.
Informed means informed.
6 I agree.
No, I think the issue is, the way I see it, in the 7
fact that to put a ncn-safety related system in this case, 8
to be able to put into a containment, okay, during a severe 9
accident water that is coming from fire pumps that are not 10 being graded for severe accident and for real strong 11 stringent standards was mixing, and to use the words I used i
12 one time, apples and grenades, not apples and oranges, and, 13 you know, I would have of course been -- and I told the i
14 Staff -- very supportive if the Staff comes and says this is O
\\m l 15 definitely completely needed.
If this is the way we should 16 go, then if it's needed I would say, hey, we need it -- put 17 a safety-related system in there.
I probably would buy 18 that, but I was calling that I am not doing this, by the 19 way, to actually do anything but have a chat with you, and I 20 think it is so important that when we chat I tell you where 21 I am coming from, okay, and I have been a systems engineer, 1
22 nuclear systems engineer for many years.
I mean I am a i
23 nuclear systems engineer and that's what I did, okay, in and 24 out of this country, and to me arbitrarily we have, maybe 25 some of you remember Appendix A, we said all of the (f
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structure, systems and components that were important to 2
safety and then we said, very simple -- that's the Q List, 3
and then we put others which now risk shows are as 4
important, sometimes more important than some of the ones we 5
put in there, and that is what I say.
6 If we look at Part 50, does it make sense today?
7 And the ans% r is it doesn't because things that needed to 8
be fixed and were intended to be fixed shortly thereafter, 9
like Appendix A, do no longer capture that techntlogy.
They 10 are no longer up to state-of-the-art, and to make them 11 state-of-the-art we need to add all of the things we have 12 learned including the valuable quantitative risk 13 information.
14 That is really why I bring this up.
I'know that 15 you are looking at the AP600 again.
Okay.
And I read, you 16 know, your very detailed analysis.
It is important that we 17 hear from you what is the difference between being able to 18
' license -- or certify, I'm sorry, a new design where the 19 information is necessary and sufficient, but that can be 20 updated in the process, versus that that is indispensable 21 for the certification process.
We need to be able to 22 distinguish between those two things.
23 We need to be able to work towards an 24 understanding of when enough is enough for a particular 25 purpose, although we knov that it needs to get better, that T
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it needs to be improved, that it needs to actually come
()
2 closer to predictions.
And it is in this area that I think 3
that your contributions can be so valuable, because they 4
could be, in fact, decisive..
5 I am going to talk a little bit about fire 6
protection.
I am going to talk a little bit about research.
7 I want a return trip to talk about research, because I think 8
that is one area that, you know, I did occasionally for a 9
few years and I still have an interest in it.
And it not 10 appropriate that we take all this time, and I could have 11 talked the entire time about research.
12 I want to spend my last few minutes so we can have 13 some questions on the. issue of license renewal and the 14 importance of license renewal to this nation.
Yesterday, I O
15 was in the Senate of the United States and we talked 16 different issues with the Senators, and the one that struck 17 the chord on both sides of the
-ale is when I say --
18 Senator, do you know that in the year 2008, just ten years 19 from now, 1 percent of the capacity to generate the i
20 electricity of this country will disappear every year for 20 21 years?
Now, that is a staggering figure.
And how do you i
22 replace it?
Oh, we got gas, we got this.
23 But what about the investment?
What about the 24 society costs?
You know, are we really assessing the impact 25 an our economics of losing 1 percent of the kilowatt hours ANN RILEY & ASSOCIATES, LTD.
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that are produced in this country every year, for 20 years?
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2 And what is the only thing that can stop that?
It is not 3
building new nuclear power plants, because new nuclear power 4
plan's are not going to be built until plants are relicensed 5
or, sorry, the license is extended, which is what it really 6
should be, it is a license extension.
7 And why?
Well, there are multiple economical, 8
manpower issues.
There is one fundamental issue is that if 9
there is no nuclear supply infrastructure that serves many 10 plants, who is going to build one?
Who is goinc ou build a 11 new nuclear power alant when there is nobody out there to 12 make pumps and valves and gaskets, and circuits and board, 13 and relays, and pipes?
It is not possible.
Not possible.
14 Therefore, license renewal is a critical issue to this
(]
G 15 country.
16 And from my standpoint as a Commissioner, I see 17 that is a priority in this agency.
We need to serve the 18 American people, and to do that, we need to provide a 19 regulatory structure that is capable of licensing these 20 plants into extended operation, extending their period of i
21 operation.
Twenty years is what is in the books right now.
22 Whatever it is that we do in the next few months, in the i
23 next year, a priority has to be given to license renewal.
24 And that means that the NRC needs to be ready --
25 to be ready to do this in an efficient manner.
We need to O
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be able to justify the safety of this plant.
We need to
()
2 certify there is adequate protection on health and safety, 3
and maybe with more knowledge than we have done it before.
4 We need to be able to say to the people of this country, 5
this energy is needed in your energy mix, and that is part 6
of promoting common defense and security, because the 7
economics and the electricity supply of this country are 8
issues of common defense and security.
l 9
If not, see what happens to the country when oil 10 gets a little bit expensive or some people think it is going 11 to be scarce.
And look at what happened in the years of the 12
'73,
'74,
'78,
'79, which we have forgotten.
Those two oil 13 crises that were financial crises, in reality, that drove 14 the price of nuclear power plants out of this world, because D
(m-15 of the incredible interest rates and incredible inflation, 16 way beyond norm, out of the control of practically anybody.
17 Nobody had control over it.
It is was an uncontrollable 18
- process, 19 We can allow us to get into that at the present 20 time, with the great economy that we have, with low interest 21 rates, low inflation.
You know, you want to call it global 22 economics, whatever you want to add to the picture, it is 23 indispensable that we do not close, as an agency, the 24 license extension process by making it burdensome, by having 25 a hearing process that doesn't serve the people of this j
i l
1 f*%
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country, and in that sense, okay -- and in that sense, risk
()
2 insights would be an invaluable tool to assert that whatever 3
we know now has a quantitative gauge, that adds tua it and 4
allows us to say yes or no -- yes or no, this plant can 5
extend its life for 20 years.
6 And with those words, I would like to stop and 7
open it for questioning.
8-DR. BARTON:
Commissioner, I would like to ask you 9
a question on the subject you were just touching on.
It was 10 the license extension and will there be more or new 11 generation plants built in this country.
Being before the 12 Senators, it must be a frustrating experience.
In my i
13 previous life, we tried to convince local politicians that 14 plants were safe.
Of course, I worked for the company that
(%/
15 had a TMI accident, so that was difficult at times.
16 COMMISSIONER DIAZ:
I would say so.
17 DR. BARTON:
But we still gave it a shot.
And 18 what I found was that the politicians only really care what 19 their constituents are nervous about.
Until, I think, we 20 educate, and this is not new stuff, educate the public to 21 get the public behind -- or believe nuclear is safe and 22 getting them to get to their politicians and not wanting to 23 waste gas or oil, or whatever, I think that is the only 24 incentive that noliticians have to support nuclear.
At this 25 point they don't care, the gas supply is plentiful.
All of ANN RILEY & ASSOCIATES, LTD.
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- a. sudden, you know,. gas was going to be ---we were going to
-2 run out of gas, we were going to run out oil.
All of a 3
sudden, we found all this gas.
Gas is cheap.
It's an easy.
4 way out, just use gas.
Nuclear is tough.
5 And do they really care whether there is.a healthy 6
nuclear industry in this_ country?
I am not sure they do.
7 And if we end up sometime with gas being another crisis, oil 8
being another crisis, well, there is always the French and 9
' Japanese who will sell us lots of nuclear power plants.
10 COMMISSIONER DIAZ:
Well, I think that 11 politicians, at least politicians I talked.to, they do care 12 about macroeconomic factors and macro public health and 13 safety issues.
A clear issue is the interest on 14 decommissioning regulations and EPA.
I think they also 15 care, and I think we need to thank Senator Domenici for 16 elevating the nuclear issue to a debate.
I am a' regulator.
17 I, of course, do not -- do not promote nuclear power.
I do 18 not talk to Senators about the promotion of nuclear power.
19 I talk to Senators about the importance to this country of 20 having a regulatory process that is necessary and sufficient 21 but not burdensome.
22 I think it is important that we concentrate on 23 things that we can do.
I would agree that this country 24 probably would be better served, it will become more 25 '
educated on issues, to deal with not only nuclear power, ANN RILEY & ASSOCIATES, LTD.
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with technology, in general, and I once gave a Presidential 2
lecture that went in these terms.
3 If we demand that our engineers learn history and 4
English, you know, all of the things in the curriculum,.
5 which I think they should, shouldn't we have one course that 6
tells them what the first law of thermodynamics is?
And 7
even, in general, shouldn't we have them?
And the outcry --
8 of course, they were mostly from the other side of the 9
bench, meaning they were historians and social, political 10 sciences, this is an outrage.
What are you trying, to take 11 over curriculum?
I said one course, all I want is one 12 course.
13 That -- your issue is a far-ranging issue.
I am 14 trying to zero in on what we can do as an agency, and what I 15 can personally push for as a Commissioner.
And I am pushing 16 for a regulatory infrastructure that is capable und flexible 17 of extending the life of plants, of our nuclear power 18 plants, under safety merits, expediently, at little cost.
19 DR. BARTON:
And I think that's appropriate, and 20 that's what you can do.
But I think you also will support 21 the position -- my point was I think we need to get the 22 public to where they feel that nuclear is okay, need to 23 have, or whatever.
I think we hurt ourselves by these low 24 threshold events.
That's all the public is fed, is how 25 unsafe nuclear is because of the low threshold events that ANN RILEY & ASSOCIATES, LTD.
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1 we continue to beat ourselves up over.
()
2 COMMISSIONER DIAZ:
My first CONSECY in this 3
agency CON NJD 97-001, the very first one is how should we l
4 improve our public communications and public affairs.
You 5
haven't read it, I suggest that you do.
And there is a task 6
force in this agency that is working, now at the very end 7
with a plan to improve the way we communicate with the l
8 public.
Because it is our responsibility not to mislead the 9
public, not to inflame.
Our responsibility it to provide i
i 10 accurate, even sensitive information that is necessary for 11 public health and safety.
12 We used to go practically anywhere, no matter what 13 happened -- and I have a record of this, by the way.
The 14 very first words that were uttered were always the same,
('*
(_ g a
/
15 this is a very serious incident and we are going to take all 16 necessary actions to fix it.
It is always the same.
It 17 didn't matter what it was.
Didn't matter what it was.
And 18 that is not acceptable, because we serve the people of this 19 country, and that doesn't serve the people of this country.
20 I have not heard any arguments against that.
Il DR. BARTON:
Thank you.
22 COMMISSIONER DIAZ:
More questions?
23 DR. KRESS:
I have a follow-on question about 24 license extension.
25 Do you have a thought to share with us on what you ANN RILEY & ASSOCIATES, LTD.
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thi is probably the major regulatory impediment at the
()
2 moment-to being able to do this expeditiously?
3 COMMISSIONER DIAZ:
Yes.
I believe the license 4
renewal process will be difficult unless we fully and 5
legally incorporate risk insights into it, and-I'll tell you 6
why -- because the thing that was introduced into the rule 7
was this aging management process, which is a difficult 8
issue, okay, and that could actually create very contentious 9
litigations.
10 We have the responsible to define and clarify what 11 we mean and if necessary to demand that certain issues be 12 risk-informed, to able to set them in the proper context.
13 All right?
14 CHAIRMAN SEALE:
Any other specific comments or 15 questions anyone would like to address?
16 DR. FONTANA:
Well, let me indicate that it 17 appears that we have an uphill climb with respect to putting 18 risk-informed approaches into license renewal.
I think it 19 can happen, but at this point it's not in it -- yet.
20 COMMISSIONER DIAZ:
That is correct.
But think --
21 think of a strategy.
Think of a strategy.
What would 22 happen if we would make Part 50 risk-informed?
Everything 23 else will have to come, and you know, Part 50 is practically 24 easier to do -- it's a lot bigger, okay, but we know so much 25 more about it and we have, you know, twiddled it here and ANN RILEY & ASSOCIATES, LTD.
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there, okay?
That is the importance of Part 50.
O fy,)
2 Part 50 is our nuclear power reactor key 3
regulation, okay, where all the regulations in 10 CFR it's L
4 the one that deals more directly with --
5 DR. APOSTOLAKIS:
Commissioner, the activities of 6
this Agency in the last two years have been directed towards 7
developing Regulatory Guides, as you know, that would use 8
the risk information in decision-making regarding requests 9
for changes in the current licensing basis.
10 Changing Part 50 is much bigger than this.
Is the 11 Staff doing anything or will they be asked to do soon?
12 COMMISSIONER DIAZ:
Well, I certainly have tried.
13 I am not sure I am succeeding, but in terms of doing things 14 and economics, look at Part 50.
Lay it out.
I have.
Lay 15 it out and look at it, and then mark -- rip the pages apart 16 and mark whatever -- we patch it up.
17
[ Laughter.]
18 COMMISSIONER DIAZ:
It just doesn't look very 19 pretty.
That doesn't look very pretty and every time we did 20 it we did the same type of processes.
We went one, two, 21 three, four, five, six, seven, okay?
22 I am saying do one process, one legal approval, 23 one change of approvals, one major review, one set of 24 analyses, and then, you know, you have really economical, 25 efficient regulation.
'(r]
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This thing of taking this enormous fabric of Part
()
2 50 and I think right here, you know, a singular point -- we 3
are going to fix it, right?
Boom, there is another one in.
4 The one surrounding it says ch, my god, I don't know what 5
this means.
So here, side by side in the regulation, and 6
one is denying the fact that risk would be appropriate and 7
the other is saying it is the only way of doing it.
8 The only way of doing it is to make Part 50 risk-9 informed.
Anything else is misusing this Agency talent and 10 resources because we will go step by step and, you know, we 11 might be celebrating the Third Millennium before we get to 12 it, you know, at the pace that we are going.
13 Is that serving the American public?
The answer 14 is no.
The answer is no.
We looked at little points and it 15 was okay because we didn't know any better.
I don't hear 16 anybody that says we don't know any better now.
We know 17 better.
We know better.
18 Have I said this?
Even when I was, say, a 19 beginning faculty member I said we need to make Part 50 20 risk-informed -- probably lost my job and my tenure, you 21 know, put in an asylum --
22
[ Laughter.)
23 COMMISSIONER DIAZ:
-- and probably right.
I was 24 close several times anyhow, but it didn't make sense, didn't 25 make sense right after TMI.
No, it didn't make sense, but ANN RILEY & ASSOCIATES, LTD.
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it makes sense now.
Now we know.
Now we can do it.
()
2 DR. APOSTOLAKIS:
Well, I wonder what the 3
mechanism would be though.
4 COMMISSIONER DIAZ:
Oh, I am not smart enough to 5
do that.
You' figure it out.
6
[ Laughter.]
7 CHAIRMAN SEALE:
There you are, George.
8 COMMISSIONER DIAZ:
Why do you think I came here 9
for?
To provide answers?
Or questions?
10 CHAIRMAN SEALE:
Well, certainly you have made it 11 very clear that we share an agenda and you have made us 12 appreciate that we have some very.real responsibilities and 13 opportunities to work on the items in that agenda and I want 14 to assure you that we are very seriously looking at a lot of 15 these things.
We are trying to think out of the box.
16 We are trying to encourage the steps that will 17 rationalize the process in a helpful and meaningful way as 18 far as understanding risk and applying that understanding in 19 appropriate places.
20 I guess it was late October or perhaps early l
21 November when we had the opportunity to talk to you I think i
l 22 just prior to your discussions at the ANS meeting in 23 Albuquerque.
A few of us had that opportunity to meet with 24 you and certainly we are interested in responding to those 25 kinds of questions when they come up.
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Sometimes they are a little quick, but certainly
()
2 our experience is that when the questions are articulated 3
they are both interesting and provocative and that makes it 4
fun to do.
E I think it is also important that we get together 6
like this so we can understand the nuances where we have 7
differences.
Comments earlier on the AP600 are a case in 8
point and I hope any differences we may have as we go on 9
finishing up the AP600 review, we'll have the opportunity to 10 explain those in some detail as well if we have differences.
11 Your comments about renewal are fascinating.
I 12 noticed this last week that Baltimore Gas & Electric has in 13 fact announced that they are submitting a renewal petition 14 and we have seen some of the preliminary information on 15 that, and I think the important thing there is that we 16 learned that when we say it is different and we have learned 17 things over the years, it is exactly that sort of thing and 18 the industry pilot plants' proposals that indicate that as 19 much as anything else the industry has learned a lot over 20 the last few years.
21 Those people are a lot more informed and 22 responsible in the things they do, and I think we have got a 23 lot in front of us if we are going to keep up with it.
24 Any other comments anyone would like to make?
25 (No response.]
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CHAIRMAN SEALE:
Well, thank you very much and we 2
_look forward to hearing from you on the Research program.
lPerhapsbythenyouwillhavereceivedfromusourdetailed 3
4 comments on part of this Research program and so we can 5
really get down to some of the nitty and the gritty.
6 COMMISSIONER DIAZ:
Well, I appreciate the 7
opportunity.
I an sorry I have to leave.
8 CHAIRMAN SEALE:
Certainly.
9 COMMISSIONER DIAZ:
I have a Commission meeting 10 that deals with international issues and I am supposed to be 11 there, but please allow me the opportunity to come back and 12 we will talk about research -- which is also very close to 13 my heart, and thank you so very much.
It's a pleasure and a 14 real privilege to be with you.
15 i DR. FONTANA:
I do have a comment.
I think we 16 ought to congratulate Dr. Uhrig for letting you into school.
i 17
[ Applause.]
18 CHAIRMAN SEALE:
Now we will reconvene at a i
19 l quarter of eleven.
i 20 l
[ Recess.]
l';
l 21 CHAIRMAN SEALE:
Go ahead, Dana.
j!
22 DR. POWERS:
We closed off the session on l
23 :!
IPE/IPEEEs abruptly.
I neglected to ask you if there were
- l questions that any of the Members have, 24 since we have the 25 major protagonist still here.
I'll afford everyone the l
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opportunity now.
()
2 We do recognize that if we have additional 3
questions that arise in formulating an answer to the 4
Commission on IPE and IPEEE, followup plans, we will have an 5
. opportunity to raise those in the next couple of months if 6
nothing comes to mind immediately.
7 So first, are there any additional questions we 8
would like to pose on IPE/IPEEs?
9
[No response.]
10 Seeing none, we will move on to --
j 11 MR. HODGES:
Well, before you move on, since we're 12 on the record for that one, I will say that the answer to 13 the question you asked before we broke up was yes.
14 DR. POWERS:
Oh, okay.
15
[ Laughter.]
16 Good.
17 CHAIRMAN SEALE:
As I recall, it took three weeks 18 to ask the question correctly.
19 MR. HODGES:
Correct.
20
[ Laughter.]
21 DR. POWERS:
It did have a long introduction; yes.
22 DR. SHACK:
Repeat the question, please.
23 DR. POWERS:
I'll hold you to that, Wayne.
24 We're now going to turn to a question that really 25 came to the fore in our subcommittee meeting held in ANN RILEY & ASSOCIATES, LTD.
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November, and that question is what research is not being O(,;
2 done that the-professionals in the research management think 3
ought to be done?
And we included in that question not just 4
research that you can't do because you can't afford it, but 5
research that you can't do for any other reason.
And we 6
'also include within that question user need requests that 7
are not formulated or not submitted because of the 8
finiteness of budget.
9 So with that introduction, Bill, you're going to 10 lead this discussion?
11 MR. MORRIS:
Good morning.
I'm pleased to be 12 standing in for Mel Knapp.
I'm Acting Deputy Director for 13 the Office of Research, and Mel is on foreign travel, wanted 14 to have been here, but had that scheduled a long time ago.
O 15 1
I know he called in the other morning to you, Dr. Seale, and 16 I'm sure he's anxious to have us do a good job of responding 17 to your concerns and issues.
We may or may not be able to 18 resolve all the issues that were on your mind as you 19 formulated the question.
i 20 I've taken the approach here that one thing that i
21 we wanted to be sure to call to your attention were some of
]
22 the ideas for possible future research initiatives, and I
)
23 want to do that, though, in the context of the research 24 planning process, because there are various opportunities 25 that occur for initiating projects in various time frames,
()
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and as we think about what we would like to be doing that we
()
2 have not yet started because of funding shortfalls or 3
whatever reason, what we've tried to do is take stock of the 4
ideas and thoughts that a number of people have.
5 So what I would do here, start off by talking 6
about the planning process, go back to a few of the issues l
7 that have an impact on this that you've already heard about 8
in the last couple of days, and I won't spend much time on 9
any of these topics.
And then go on in the subsequent 10 pages, pages 5 and 6 I would provide some indication of the i
11 status of some of the issues that the ACRS raised in its l
12 letter to Congress, and beyond that talk about in pages 7 to 13 10 some of the issues that the staff has identified that 14 they would like to get initiated in the near future.
1 s
15 So let me begin by talking about some of the 16 drivers for this process.
I think you heard the other day 17 Denny Ross talk about the role that the strategic goals, the l
18 strategic plan, and the performance plan have in this i
19 process.
They are essentially the high-level objectives of 20 the Agency as formulated for the Agency as a whole, and they 21 include those objectives for which the research program is
{
22 providing key information.
As I said, those are high-level 23 documents.
We've developed for the first time the FY '99 24 performance plan, the strategic plan for '97 through 2002, l-25 but those are'being refined, because we're learning as we go
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along how to best formulate those documents.
(
2 Those documents then are providing the guiding x
3 overall principles for the budget development which allows 4
us to meet those goals and those plans, those strategic 5
goals, and ultimately, once the budget is formulated and has 6
been approved by OMB and Congress, the Research Office 7
develops its operating plans.
8 We are now, for example, implementing the FY '98 9
operating plan.
The FY '99 budget has gone to Congress.
At 10 some time in the future we will begin to develop the 11 detailed operating plans with the detailed projects that I
12 will implement that budget.
13 The budget that goes to Congress is a pretty 14 coarse-level document.
It gives general broad numbers, and b
\\m) 15 it gives some description, very general, of what we might be 16 doing, but it doesn't give the kind of detail, for instance, 17 that Dr. Powers was interested in learning about that you 18 would see in a statement of work, in a detailed work plan.
I 19 And it is during the process where this committee that you j
20 may not have heard about much before, the Program Review 21 Committee, just established last year, reviews the budget 22 proposals that the offices make and they review the 23 operating plans, and then they monitor as to whether we're 24 meeting the operating plans as we spelled out.
We may make 25 adjustments to those operating plans during the year, but f't
( }/
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the PRC, Program Review Committee, would have oversight of
()
2 that.
3 DR. UHRIG:
Bill, who is on that?
l 4
MR. MORRIS:
That would be Ashok Thadani is a 5
member, Patricia Norry, and Hugh Thompson, who are the 1
l 6
Deputy Executive Directors for Operation.
The Deputy Chief l
7 Financial Officer, Pe_e Rabidieu.
There may be -- Deputy 8
CIO, a representative of the Chairman's office.
Is Jim l
9 Blahaha on it or -- he runs it.
Those kind of people.
I l
10 think that's the gist of your question.
11 And then there's another committee, the Executive 12 Council, essentially, that is the EDO -- Executive Director
{
13 for Operation, the Chief Financial Officer, and the Chief 14 Information Officer who essentially provide the final 15 approval before something goes to the Commission.
But the 16 Program Review Committee is going to be meeting almost every 17 day I think during the month of May or thereabouts reviewing 18 the budget proposals.
19 DR. UHRIG:
Thank you.
20 MR. MORRIS:
So that's the kind of process we're 21 in, and so the opportunity to examine any what I'm calling i
22 deferred research, research that we would like to initiate 23 but have not yet had an opportunity to do so because of one 24 reason or another, could be put on the plate, put on the 25 table for action.
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And as we do this, you've heard that -- and I
-(
)
2 spoke to Mel Knapp this morning, and he still very much 3
wants to develop a more transparent, a more risk-informed 4
prioritization process'than we're.able to just demonstrate 5
up to now.
6 You heard Denny Ross talking about his attempt to 7
use a ranking process.
Ultimately in this budget cycle 8
we're still probably going to be using primarily the same 9
tools we have before, and that's judgment, and hopefully we 10 are doing that on the basis of some knowledge of the risk 11 implications and the safety implications and the licensing 12 implications and the practicality of achieving the research 13 results we want, just those criteria that Denny Ross was 14 using in his prioritization. process, we won't have that 15 detailed analysis in the statistics probably ironed out.
16 And you've raised a number of questions about that 17 so we've got to think hard about just how far and how fast i
18 we can use that process.
But those factors are used by i
19 everybody that works on this budget formulation and in the 20 review of Ashok Thadani, he will exercise risk-informed 21 judgment, you can be sure, as he goes through the process of 22 deciding which programs we pursue and how fast and in what 23' way.
And so that's the way it's going to be, I believe, for 24 the near future, and ultimately we won't be able to get away I
i 25 from the fact that judgment will be involved somewhere in i
(
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the process.
()
2 As we do that, we are always conscious as we 3
interact with the user office, and this goes back to the 4
issue of user needs that may or may not have been put 5
forward because of concerns about budget limitations and so 6
we are going to be concerned about striking that balance.
7 And I think each case, you have to judge on a case by case 8
basis just how important and urgent the matter.is and, as.we 9
discussed yesterday, you have got to worry about how 10 disruptive a new start would be, given where you are in the 11 operating plan implementation cycle, what kind of funds you 12 have got available.
13 So there has got to be a balancing &ct that is 14 done.
The reason that we in the Research Office feel that 15 we need to be concerned about this, of course, is the 16 anticipatory research is where are we looking farther into 17 the future where we exercise some vision about what we 18 should be doing, as opposed to meeting the more immediate 19 and, certainly, important needs of the agency.
So that is a 20 balancing act that is important to us.
And we are going to 21 continue to be concerned about those points at which we 22 would be getting to the point where we would no longer have 23 a viable core capability to meet the basic needs of the 24 agency at one level or another, expertise-driven or 25 workload-driven.
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So all.those factors are part of what we think 2
through.
3 DR. POWERS:
Before you leave that viewgraph, just 4-because it has a nice title --
-5 MR. MORRIS:
I'm sorry?
6 DR. POWERS:
Before you leave your first 7
viewgraph, but that's okay, this has a nice title, too.
8 Maybe I am asking.a question out of turn, in which case, I 9
~ willing to wait.
My first question is, when you go 10 through all these review processes, is that done at the sub-11 activity level, or does it go down into the projects 12 themselves?
13 MR. MORRIS:
I have believe we pretty -- some 14 examples of projects, but probably it is sub-activity.
15 MR. SHAO:
Okay.
Go at -- really, I am the 16 program manager, called, structural behavior and material-17 research and Wayne Hodges is a program manager, too, in 18 charge of this.
So Research really has four projects, major 19 projects.
I have one project, Wayne Hodges has one project, 20 and Joe Murphy has one project, and Curt Stanley has one 21 project.
So, really, if SPRC comes soon, we have four 22 projects in Research, and I am called a program manger for 23 one project.
24 MR. MORRIS:
But I th:.
he asking when you go 25 through the review.
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MR. SHAO:
When we go to review, I am really at (s-)
2 the sub-activity level.
3 DR. POWERS:
Sub-activity.
But below the sub-4 activity is here a bunch of things that yesterday, I think 5
we called projects, I --
4 6
MR. HODGES:
Well, yea'.
it is really a program, 7
not a project, I think.
And under that I have, you know, a 8
number of areas like thermal-hydraulics and severe accidents 9
and PRA.
But as far as what we actually go over with the 10 PRC, it is really at the sub-activity level from the 11 operating plan.
12 DR. POWERS:
So you don't go into, like under 13 thermal-hydraulics you have, what, Thermal-Hydraulics 14 Research Institute?
(,)
(_/
15 MR. HODGES:
Well, it wouldn't have necessarily 16 that, but it would have -- there are some things, some 17 specific projects like that are spelled out explicitly, so 18 it's kind of a mix.
19 DR. POWERS:
Okay.
True.
Sure.
20 MR. SHAO:
Maybe they read this operating plan, 21 they read the operating plan, they may ask any question.
22 DR. POWERS:
Sure.
Now, let me ask this next 23 question, and I am not too sure how to formulate it, but 24 I'll do my best.
And maybe you can answer it, and maybe you 25 can't, and maybe it is hidden in this, you are going to t
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cover it.
But we have a federal budget cycle which has
()
2 always been a challenge for any research activity that goes 3
more than one year, the federal budget cycle poses a 4
challenge.
5 What I am interested in is, when you go into this 6
review process, and, for instance, I have a program, for 7
exataple, environmentally assisted cracking, it is one that, 8
in Fiscal Year '97, say, a judgment was reached that that 9
was an important research to carry out, c.nd it was well 10 planned and well placed and a set of milestones were set, 11 which everyone knew were going to take more than one year to 12 accomplish.
Do you go through a rigorous re-defense of the 13 existence of that program?
Having done it in '97, do you do 14 it again in '98?
Or is that, people say we have made
)
15 decisions on that before, you know, you are making good s-16 progress, go ahead and we will go on to the next ones, or is 17 it a rigorous defense every time?
18 MR. SHAO:
I think what they do is something very 19 obvious, okay.
Suppose you have budgeting '97,
'98, if you 20 have a major increase in '99, they will question you.
21 DR. POWERS:
I see.
22 MR. SHAO:
If you keep on a level, there is less 23 questioning.
Anything they see a major increase or major 24 decrease, they are going to ask you questions.
25 DR. POWERS:
Okay.
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MR. MORRIS:
In principle, this Commitmee, and 2
anyone in the process who is managing these programs, will 3
ask any question, and they could challenge the continuing of 4
any effort and they could be asking, isn't it time, haven't i
5 you milked this for all that you need to?
That's always 6
part of the process.
7 CHAIRMAN SEALE:
Yeah.
That is exactly part of 8
the problem.
I think what we tend to do is we almost tend l
l 9
to bore people to death with the sameness, even in the face 10 of changing dollars, of what the external perception of the l
11 research program is.
And you also mentioned the fact that J
12 any change in the planning process would be very disruptive 13 earlier, in another context.
i 14 It strikes me that what you need to think about is 15 a change which handles your needs but also, hopefully, 16 re-packages the program in a way where it is clear that 17 there are tasks that are being completed, and things come 18 off of the table as they finish, and new things come on the 19 table as they finish -- or as they begin.
And there is a j
20 sense that milestones are being passed.
21 I think we bore everyone to death with the 22 research program and that is part of our problem.
23 MR. MORRIS:
In this planning process, I would say 24 that we have done what you are talking about in the past, I
25 but in this planning process, the Program Review Committee ANN RILEY & ASSOCIATES, LTD.
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is reviewing operating plans, and the operating plans have
()
2 just what.you state.
They show the initiation of a task, 3
the completion of the task, the deliverable, a product.
And 4
in some cases, Dr. Wallis was talking about yesterday, the 5
question is going to come, how does our product affect, say, 6
NRR?
l 7
And what we have talked about recently is the fact l
8 that, for some products, they are very crucial to NRR L
9 initiating a step in their process.
So we are tieing our 10 operating plans to the NRR operating plan, so that you can 11 see a cross-correlation between the end of -- this is a sub-12 project, mind you.
Now, it may not be the end of a program, 13 there may be a continuing program in human factors research, 14 but one of the projects in that will have a deliverable and ksl
-15 it will have a termination point.
The program may have i
16 another project initiated in another year.
So I think we 17 are moving in that direction.
You don't see that detail in 18 your reviews, but one of the Subcommittees probably could 19 look at that and see that level of detail.
20 DR. POWERS:
There is one theme that has come 21 clear in the last two days, to me.
Is I get the distinct 22 impression that there is a good deal more interaction 23 between the research organization and the line organizations 1
24 coming along today than mayt e there has been in the past.
I
~
25 mean there seem to be more mechanisms and built-in processes I
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that lead to this interaction.
()
2 MR. MORRIS:
The process I just mentioned in a new 3
one as it is executed at the agency level.
I believe there 4
has always been a lot of interaction between the technical 5
staffs rind the different offices.
6 DR. SHACK:
Let me just give Dana, as a guy who is 7
at the very end of the line on the research planning 8
process, you know, this question of when you have a program 9
for five years, if the agency re-prioritizes, things change, 10 you know, they certainly do change year by year, even though 11 you have initially approved it for a five-year plan.
If 12 NRR, for example, feels it is no longer a burning issue, the 13 thing -- you know, something is changed.
It changes.
I can 14 guarantee ti. ;.
15 MR. HODGES:
But to follow-up on a comment that 16 Dana just made, I think in the last year, maybe even two 17 years, we have been working much closer with some of the 18 program officers than previously.
So I think that is where 19 it is better.
20 DR. POWERS:
It just -- I mean at one point I 21 listed down the number of times it had been cited yesterday, 22 and now I have got another citation here today, that there 23 is something new, something different in the way the 24 interaction was done.
25 MR. HODGES:
There has always been some
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interaction and, previously, when we would go for our budget 2
process, we had to have the program officers there to say, 3
yeah, we support or don't support, and we had periodic 4
meetings and things.
But I think we have also increased the 5
interaction, I think we are working more closely together.
6 DR. POWERS:
Obviously, it is a conclusion I would 7
like to draw, and I just wanted to get some affirmation of 8
that conclusion.
9 MR. MORRIS:
I think it is true that when we go 10 before the Program Review Committee, I know in one case, 11 when the Research Program Manager is there at the table, 12 quite frequently either his cohort or his colleagues in the 13 other offices will be at the table or right near by to 14 indicate the interaction that is going on.
So I think you 15 are right.
)
16 DR. POWERS:
I have to comment that, based on the 17 Subcommittee meeting and this meeting that we have held in-18 the last couple of days, t. hat you enjoy closer and greater i
19 support from the line organiuations than perhaps is 20 perceived at the Commission level.
The mere fact that Brian 21 Sheron was willing to take his time to show up to defend the 22 research program is a testimony to some support that maybe 23 is not perceived universally.
24 To quote the representative of AEOD from 25 Subcommittee meeting, AEOD can not do its job without ANN.RILEY & ASSOCIATES, LTD.
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research.
And that is pretty good support, I mean.
(N i
l' 2
MR. MORRIS:
Go on?
3 DR. POWERS:
Please.
4 MR. MORRIS:
So, again, as I say, we are going to 5
-- the objective is to talk about the deferred research, 6
but, again, the baseline here that we are talking about is 7
the FY '98 operating plan.
And one opportunity, or one
{
8 possibility for examining whether we should take on new work 9
is the possibility of either using unexpended funds, and 10 that is projects that didn't get initiated which we were 11 planning and for one reason or another, another office 12 wasn't able to do, or re-programming from what we would 13 consider, given the new information, now lower priority 14 work.
Ab 15 We have made a request for additional funds, and I 1
16 am going to talk about some of the items in that request in 17 the subsequent pages, but, I must tell you, the expectation 18 that the agency is going to be able to accommodate much of 19 that has to be realistically low.
20 One thing that we have to be sure that we are 21
-capable of doing is responding to a major crisis later in 22 the year, so you have to keep some money available.
And so 23' we want to guard -- the agency has to be guarded about that.
24 And as you go from one budget year to the next, there is 25 always the possibility that there might be some problem with ANN RILEY & ASSOCIATES, LTD.
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getting the_ budget approved.
For instance, if there were a
()
2 delay in approving the FY '99 budget for some reason, some l
3 of that funds is what we have available to allow the 4
continuation of the projects, and so we have to do that.
So 5.
we have to be careful about any use of these funds.
So it l
6 this is a very deliberate process.
7 CHAIRMAN SEALE:
Do you run into difficulty, 8
though, of losing funds that you hold for contingencies if 9
they bubble into the next year before they are committed?
10 MR. MORRIS:
There are ways that you can lose j
11 these.
Our agency has had in the past, and I wish someone i
12 here, and maybe someone can help me, has had in the past the 13 accommodation of allowing some carryover from year to year.
14 Other agencies might have more difficulty with that.
I l
r 15 don't know whether that is changing.
16 Anybody have any experience that they can relate?
17 Someone from the Chief Financial Office would have 18 to really give you the best answer to that.
I don't recall 19 a case where we -- we don't usually lose funds.
20 DR. POWERS:
I think there has been some changes 21 in the way the government does business that allows most 22 government agencies now to accommodate a certain amount of 23 carryover.
24 MR. HODGES:
We are allowed to carry over funds 25 from year to year.
Where it gets to be a problem is if you ANN RILEY & ASSOCIATES, LTD.
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1 don't spend it in one area, and you need to change it to
()
2 some other area, depending upon what budget category it is 3
in, you may lose it and then have to go back and fight for i
i 4
it again.
I mean we don't -- the agency keeps it, but I may 1
5 not be able to keep my money.
6 MR. MORRIS:
For some of those categories, there 7
is a process.
When you want to re-program, you can get 8
Congressional approval.
It's a fairly straightforward 9
process, 'as I understand it.
So you can make that step if 30 you want to.
It is easier to do it within program areas.
11 CHAIRMAN SEALE:
It is essentially approval of the 12 Chairman of the cognizant Committee or something.
13 MR. MORRIS:
Yeah, I think that's what it is.
l 14 That's it.
And we have done that.
O 15 Well, anyway, this is the framework for examining j
16 what we might do.
The other is that we are now going to 17 begin the development of the FY -- somewhere in the next 18-several months, we have got to begin developing the FY '99-19 operating plan.
That is the plan that has the detail 20 projects.
The start of a project, the completion of a 21 project and the deliverable.
And so that has got to be 22 done.
23 As we do that, there may be some latitude.
As the 24 budget has gone forward, there is some understanding of what 25 projects are included in that.
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has examined what they believe we are going to be doing.
2 But we could back and ask them for -- to make some 3
modification in detail.
4 The other thing that we can do is begin to 5
formulate the FY.2000 or 2001 budgets, and that is what is 6
going to be happening in the May time frame.
So there, yet,
.7 is another opportunity to initiate'a deferred project.
And 8
then we have the long-term where we have to look forward and i
9 say it is probably something we just have to recognize we 10 are going to have to wait a few years, given all the other 11 priorities, to initiate.
j l
12 And I think, ideally, what we would want is we i
13 would want our staff and the laboratories to be thinking 14 about, what is the long term, what should it be looking V
15 like?
And so we don't want to lose sight of that.
But, for 16 now, the items I am going to be talking about are more near 17 term items.
18 I did want to mention that in this procesa, I can 19 assure you, that we are going to continue to have close 20-interaction with the offices, figuring out what our 21 priorities are.
It means that we have got to understand 22 what their problems are, how they relate this and other 23 things, and so there is a lot of communication that is 24 needed.
25 And the other point, we do anticipate that -- it ANN RILEY & ASSOCIATES, LTD.
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is prudent, given that judgment is involved in making these
()
2 decisions, that we have a broad, even broader than the user 3
offices, range of input about the significance of some of 4
the projects.
Mel Knapp has. thought about this, and he is 5
envisioning, in terms of thinking about the longer term and 6
this issue of getting a broad range of input, that we have a 7
concerted effort to go reach out, to get the views of 8
industry, laboratories, universities, foreign entities, make 9
sure that we have got all the right information, and that we 10 have really understood the whole profile of technology 11 before we -- as we formulate, as we design these budgets.
12 And, of course, the bottom line is, whatever 13 assistance you can give to us in formulating this, would be 14 valuable.
I know you will be speaking to the Commission at is intervals and giving your advice in another form, but when 16 we have these dialogues and can understand what you are 17 thinking, I believe that helps us also.
So my impression is 18 that you are very much interected in these programs, so we 19 would stand ready to come in and talk to you, Subcommittees 20 as we formulate these ideas.
21 And what I have included in the subsequent pages 22 then is not intended to have any priorities established here 23 necessarily, I just tried to give a flavor for now of some 24 of the thinking of what might be coming.
And one thing I 25 wanted to do was just to go back, we have examined the
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letter you wrote, and we wanted to at least talk about some i
(G) 2 of those concerns you had expressed there about deferrals 3
and what might be happening.
And if you would like, I could
)
4 go through some of these and just give you a quick run-down 5
on what is happening here, and then turn to the other 6
subject of some of the other ideas we have.
So I'll proceed i
7 along that line.
8 DR. POWERS:
I have seen enough things on this 9
very familiar list that are of interest to the Committee.
10 Maybe if you could give us some idea of what is going along 11 in each of them, that would be --
12 MR. MORRIS:
Yeah, that's what I wanted to do.
13 Because as you have developed this concern, and expressed 14 these concerns, what has happened is, in a number of cases
(_,/
15 you are going to find, we have included in the FY '99 budget 16 some requests to do, to address some of these issues.
17 Now, I cannot say how successful we will ce in 18 getting the increments in what we have asked for without 19 also just, you know, maintaining a flat budget.
They might 20 say, yeah, do this, but, by the way, you only have so much 21 money to do it with.
22 CHAIRMAN SEALE:
Yeah.
23 MR. MORRIS:
So I don't want to have any higher 24 expectations about that.
But, you know, you have got to 25 have a squeaking wheel before it is going to be greased
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probably.
And so we have stated what we believe is our
()
2 concern, and you have stated it, too, in your letter.
Maybe 3
the two things'will have a synergistic effect and maybe 4
Congress will do something.
5 DR. POWERS:
Yes.
6 MR. MORRIS:
But, anyway, here is what we --
7 DR. POWERS:
Recognize, of course, that this list 8
was formulated in the context of these guys don't have 9
enough money to do all this stuff.
10 MR. MORRIS:
Yeah.
Right.
11 DR. POWERS:
And they should be because we saw a 12 societal advantage to doing it.
13 DR. UHRIG:
Is this list prioritized or is it just 14 O
15 DR. POWERS:
It is our list.
16 MR. MORRIS:
I'm not sure it is in the same order.
17 DR. UHRIG:
Okay.
IP MR. MORRIS:
I said take the letter and itemized 19 each of the items.
20 CHAIRMAN SEALE:
Screen it for --
21 MR. MORRIS:
We took a couple of the things out, 22 but I don't remember what they were.
You may want to ask 23.
about them, too.
24 But, anyway, on the issue of safety significant 25 human efforts, we full agree with the ACRS.
We do have an
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)
1 increase of about $400K in the FY '99,
$400,000 for the 3
(
)
2 human factors and organizational performance budget we have 1
3 sent forward.
I 4
On the issue of extending our ability to 5
understand risk to the shutdown low power area, we have j
6 included in the budget $1.5 million and that is included in 7
the request that has gone up.
8 Now, I must tell you that we have -- that is not 9
an increase over all other projects.
Okay.
There is a 10 refocusing here and an increase.
So that the budget, the 11 PRA -- if this, if you looked a the program area in the 12 budget, this area will increase from $3.5 to $4 million, but 13 a new emphasis will be placed on the low power and the 14 shutdown risk arena.
/'
15 MR. HODGES:
That will be several year project, it 16 won't be a one year.
17 CHAIRMAN SEALE:
Yeah.
I mean that is -- I think 18 was our -- we have argued in another forum for this 19 investigation and part and parcel with that argument was 20 that it was not something that could be accomplished in a 21 year, or even two years.
And, in fact, we said it should be 22 done deliberately rather than hastily.
23 MR. HODGES:
And in this year's budget what we are 24 doing is trying to see what else has been done by other 25 people so we can focus and do a better job.
MR. MORRIS:
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this one you also see at the next level another idea that we 2
have had, and that is to augment the accident sequence 3
precursor program to better assimilate information related 4
to this low power shutdown arena.
5 CHAIRMAN SEALE:
Very good.
6 MR. MORRIS:
That probably should follow on after 7
some time and effort to better understand the first phase, 8
but at least it is something we are thinking about doing.
9 The issue of proposals to extend the lifetime of 10 reactcr fuel, we have been making steady progress in this 11 arena and we have increased the budget there from $2 to $2.9 12 million, almost a million dollar increase.
13 I think that is targeted towards allowing work 14 in -- I think it is the Argonne hot cell to work on 15 irradiated material as opposed to un-irradiated material 16 that we have been limited to in the past and to improve _the 17 Halden fuels program.
Wayne can go into details.
18 DR. POWERS:
The committee has scheduled a review 19 of that particular activity for later in April.
I think you 20 will hear chapter and verse on that.
21 MR. MORRIS:
Okay.
22 CHAIRMAN SEALE:
Great.
23 DR. POWERS:
Now I will comment that the committee 24 did note and did highlight that while this work is going on 25 there has been a -- for the current, and I guess that would
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be -- I hesitate -- the fiscal year '98 or maybe it is
'99,
()
2 a zeroing of examination of source term issues associated 3
with these high burnup fuels.
4 We understood you correctly.
5 CRAIRMAN SEALE:
We understood your words 6
correctly.
We are not sure we understood the action.
7 MR. HODGES:
It's a matter of dollars and 8
priorities.
9 CHAIRMAN SEALE:
I understand that, but you 10 understand what we are saying, too.
11 MR. MORRIS:
On Item 5, on the program on severe 12 accidents, I think you heard that we incurred a reduction by 13 about 60 percent in the previous FY '97 program so in '98 we 14 are at, I guess we are at 40 percent of what we had 15 previously been at, and we have asked for funds to continue 16 at that level, not resumed to the old level, but to continue 17 at that level in '99.
18 CHAIRMAN SEALE:
You missed the mixed oxide.
I 19 was wondering --
20 MR. MORRIS:
Oh, I'm sorry, yes.
On mixed oxide 21 we are taking the position that the Commission has said that 22 we just are not ready yet to start a program in mixed oxide.
23 I think the point would be, and I am just trying to 24 formulate an expression of what probably was on the 25 Commission's mind is that they are just now starting up the ANN RILEY & ASSOCIATES, LTD.
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manufacturing-process for the mixed oxide fuels.
()
2 We are interested in the issues of the fuel 3
fabrication, the fuel production facilities that might be 4
involved in that.
The NMSS. side of the house is interested 5
in what ramifications there are for that, but at this time 6
we have just not been able to start up that program or do 7
anything on that and that is not in our planning horizon at 8
this point.
9 That doesn't say that it won't be at some time in 10 the future, hopefully at time where we could gear up and do 11 what is needed in time to be ready when mixed oxide fuel 12 would be used in the reactors.
13 CHAIRMAN SEALE:
Is that -- I am going to put 14 words in your mouth.
You probably won't let me.
I'll try.
15 Is that an implicit admission or a recognition I 16 guess is a better word that fundamentally the use of mixed 17 oxides is a reasonable and expectable -- it's an expectation 18 for the future, that the details however may require some 19 research support but you don't know exactly what those 20 details are yet and so it's not appropriate to begin to do 21 research at this time.
22 MR. MORRIS:
I probably would not say that that is 23 what the Commission has thought on this subject.
24 It is not an unreasonable point of view, but I 25 would have to beg off on trying to explain exactly what the
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basis was for this.
2 CHAIRMAN SEALE:
Well, I mean the bus is leaving, 3
you know, on mixed oxide.
4 DR. MILLER:
That was a Commission decision and 5
not a recommendation.
6 MR. MORRIS:
That's correct.
The Commissio'i has 7
made that as a policy decision at this time for whatever 8
reasons they have.
You reason is more of a technical reason 9
and I am not sure the Commission's reason was a technical 10 reason.
11 CHAIRMAN SEALE:
Yes, I appreciate there is a 12 little politics.
13 MR. MORRIS:
Yes.
So, let's see -- back to Number 14 6,
the safety and risk significance of fires.
15 We now expect to -- we are planning a program.
I 16 think the subcommittee may have. heard --
17 DR. POWERS:
The subcommittee really got caught 18 flat-footed on this one because we were left where the 19 subcommittee was -- that we were planning a program and they 20 weren't prepared to discuss those plans at the time and now 21 we find there is one, so the subcommittee is a little at a 22 loss on what that program, the length and breadth of that 23 program, even though it seems to be a pretty substantial 24 program.
25 MR. MORRIS:
Well, let me say that I thought that
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Nathan Siu had briefed you recently on that but I may 2
have --
3 DR. POWERS:
He briefed us on their efforts to 4
plan the research.
5 MR. MORRIS:
Okay.
6 DR. POWERS:
And we liked their efforts to plan 7
the research, but as far as what the program actually is, we 8
have never heard that.
9 MR. MORRIS:
Let me say that we have asked for it 10 in the FY '99 budget.
I would think it's got high priority 11 in our minds and what I think we need to do is come back and 12 talk to you more about the planning.
13 MR. HODGES:
But it is also true that we have been 14 doing the planning.
We have some resources set aside to do 15 the work but the work hasn't started.
16 DR. POWERS:
Okay.
Yes, I think we are going to 17 be -- make some crash effort to find out more about that, 18 because fire is emerging as an issue as we go through the 19 IPEEEs and I have been assured that next month I am going to 20 be peppered with questions by the Commission in that area, 21 so I better get educated.
22 DR. APOSTOLAKIS:
What is the driver here?
Why 23 are we having all this interest in fires?
24 DR. POWERS:
We have IPEEEs coming in with major 25 vulnerabilities in this area.
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381 1-DR. APOSTOLAKIS:
So is that the major driver?
()
2' MR. HODGES:
Well, that plus I think we feel we 3
need to go back and look at the method. the COMPBRN and try 4
to improve that 5
DR. APOSTOLAKIS:
Yes, but I mean why?
6 DR. POWERS:
George, in a greater --
7 DR. APOSTOLAKIS:
It must be the IPEEE.
8 MR. HODGES:
It's an important contributor, yes.
9 DR., POWERS:
Well, in a greater sense, understand 10 what fire regulation is.
Fire regulation has been injected 11 into Part 50 as a result of an incident that occurred some 12 time ago when the tools available for defining regulations 13 rested heavily on judgmental capabilities.
14 The community that you are certainly a prominent O
15 member has introduced a new tool that allows us the 16 opportunity to go back and revisit those judgmental and 17 perhaps overly conservative regulations and examine a 18 reapalysis.
19 At the same time, we have the IPEEE coming in 20 saying one of two things. Either the tools used for the 21 IPEEE were deficient or there were deficiencies in the 22 existing regulations.
23 It says one of the other.
I am not sure which one 24-it says,.but clearly we are having the confluence, a 25 technological development, and a discovery.
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~
1 DR. APOSTOLAKIS:
But it is really the discovery
(
2 that is driving the thing and of course we are always 3'
concerned about methodologies and so on.
4 DR. POWERS:
Sure, and I am sure that that creates 5
the biggest drive for an immediate response is a discovery.
1 1
6 DR. APOSTOLAKIS:
And we have been told by the 7
industry in the past that Appendix R is fine, and so on.
Do 8
they still feel that way?
Are'they gaing to fight this?
9 MR. HODGES:
My guess is that they don't 10 particularly like Appendix R but they spent a lot of money i
11 to try to comply with it now and they would be reluctant to 12 change.
13 I can't put words in their mouth but that's --
14 DR. APOSTOLAKIS:
I know, but that is my 15 impression too.
16 CHAIRMAN SEALE:
It's the devil they know.
17 DR. APOSTOLAKIS:
They will not be too excited by 18 Item 6.
19 CHAIRMAN SEALE:
Well, how much money are you 20 talking about?
21 DR. POWERS:
No, I think that is an incorrect 22 description of the industry position.
23 The industry has been before us several times and 24 they have spoken directly to this issue.
j 25 They said they are very interested in the 1
/~N
(]
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development of risk-based methodologies for the evaluation 2
of fires and they have offered up as a test bed for some of 3
those methodologies the balance of plant that is not subject 4
to Appendix R regulation.
They think that is an excellent 5
place to try there things.
6 DR. APOSTOLAKIS:
But I thought they were against 7
revising Appendix R.
8 DR. POWERS:
They are --
9 DR. APOSTOLAKIS:
This is what Wayne mentioned.
10 DR. POWERS:
To correctly state their position is 11 they don't see a need at this point to revise the 12 regulation.
They do see a lot of information coming to the 13 fore in the next few months that may move one to rethink 14 that, and they cite specifically IPEEEs, the functional fire 15 inspections, and the NFPA effort.
16 DR. BARTON:
Nor did they want a new regulation 17 because they were used to working with Appendix R, as hard 18 as it is.
That was the other piece of it, I think, right?
19 DR. POWERS:
Yes.
I mean their position is one of 20 you think things are okay now.
More information is coming 21 to the fore and we are intrigued by these risk assersment 22 technologies and we just don't think they are sufficiently 23 mature.
24 DR. APOSTOLAKIS:
The problem with this is that if 25 there is any re]ief coming to the industry, it is really
()
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1 useless to them because they have already complied.
They
()
2 have already spent the money.
3 MR. MORRIS:
A few years ago we had a project and 4
we still are going forward with the project in an effort to l
5 try to identify places where we can make the regulations 6
more flexible and less burdensome at the same time.
h,
?
On the fire protection, there may be some who 8
would say that there may be even areas where there are as 9
yet safety concerns that need to be dealt with more 10 thoroughly in.the fire arena, but we had a program where we 11 asked, we tried to define and we involved ourselves with the 12 industry in trying to define some regulatory changes that 13 would have that effect.
l 14 F' ? 'reloped a draft rule and subsequently a Reg l
15 Guide thr' tPem ally said if you want to make a change in 1
l 16 the re.-
che petition process is available and we 17 suggested t'..at those that felt that they wanted to do that l
18 should come in with a petition and support it with a 19 substantial amount of information.
20 The industry brought in a petition to revise the 21 fire protection regulations with an Appendix S, and that 22 would have driven us in the direction to use more risk 23 information in the decision-making in the fire arena.
24 The Staff looked at that and I think I can l
25 characterize it as saying we were somewhat concerned that we I
l
)
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really weren't ready yet to begin to do that because we 2
hadn't got a level of comfort with the models, the equipment 3-fragilities and a number of issues that were still evolving, 4
and it is essentially tools for risk estimates in the fire 5
arena that we felt we were most lacking in,~and so we sort 6
of told the industry, well, if you are going to do this 7
there's a lot of homework that has got to be done.
8 Reg Guide 1.174 began to talk, to lay out a 9
framework for using more risk information in decision-making 10 on a site or plant-specific basis as opposed to, say, a 11 rule.
12 Because we perceived that gap in information and 13 risk insight and tools to make these decisions, I think that 14 is one reason we believe this program could be important, 15 that it would enable us in the future to -- if the industry 16 continues to believe that there may be important relief to 17 seek it out.
18 For the time being, however, after they have sent 19 in a petition and subsequently we started to wrestle with 20 how we would go forward and change the regulations, the 21 industry eventually decided I think that they would prefer 22 just to say with Appendix R as it is for now, but this 23 program is, I believe, intended to help us prepare for y
24 better decision-making in that arena.
25 Can we go on?
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i 386 1
DR. POWERS:
Please.
1 2
MR. MORRIS:
On the issue of validation of 3
industry standards in place of Government formulated 4
regulations, there is a strategic issue, Issue 13, on the 5
role of industry and actually the systematic and concerted j
l 6
effort to endorse industry standards is required by Federal 7
law.
I can't cite the law, but we have this effort.
John 8
Craig is leading this effort.
NRR is working closely with 9
us on developing a process to streamline the endorsement of 10 industry standards so we will cut down the time for doing 11 that and make that a more efficient process, 12 So we are not spending a lot of money on it.
It 13 is all Staff endeavor, but we are working in that area.
14-DR. MILLER:
Does that include where you have O-15 already endorsed the standard but you haven't endorsed the i
i 16 latest -- updated the standard?
Is this effort embc ded 1
17 within that?
t 18 MR. MORRIS:
That is an issue -- yes, as the
~
19 standards change we have to go back and re-evaluate and do a 20 rulemaking to change them or --
21 DR. MILLER:
No, that is not a rulemaking 22 necessarily.
This would just be where a Reg Guide is j
23 endorsing a standard and the standard has been updated, but 24 the Reg Guide hasn't been ungraded.
25 MR. MORRIS:
Whenever we write a Reg Guide and a
()
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rule we typically have written in them in terms of in most
()
2 cases a specific year -- you know, the standard is specified 3
for a specific year.
4 DR. MILLER:
The standard has been updated but the 5
Reg Guide has not?
6 MR. MORRIS:
Right.
7 DR. MILLER:
Is that embeddedness?
8 MR. MORRIS:
Let me point out --
9 DR. SHAO:
That's true.
10 MR. MORRIS:
-- we have both cases.
We have cases 11 where the rules explicitly name industry standards in the 12 regulations and then we have Reg Guides which name industry 13 standards, and this I think is both.
14 It is getting better able to endorse both and new 15 ones as well -- not only revisions but new ones as well.
16 DR. MILLER:
This is new ones and also --
17
' CHAIRMAN SEALE:
The housekeeping --
18 DR. MILLER:
-- because right now in the I&C area 19 we are way behind in that effort.
20 DR. SHAO:
In ASME we endorse by the rule 50.55.
21 In IEEE we endorse by Reg Guides.
22 DR. MILLER:
Right, with exceptions.
23 DR. SHAO:
Right.
24 MR. MORRIS:
On the high level waste area, this 25 work is done in NMSS now.
The FY '99 fundidg request has
()
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been -- we. ave asked for an increase from $15 million to f~
2
$18.5 so we are moving in the direction the ACRS wanted.
3 We believe that is probably going to help solve 4
the problem but we are not sure that it will come to pass.
5 Congress has cut that budget in the past and has 6
been pretty tough on it.
7 I think you had a briefing, a subcommittee, I 8
believe had a briefing on the Generic Issue Program.
9 CHAIRMAN SEALE:
I've got a question on that.
10 DR. SHAO:
What question do you have?
You had a 11 briefing last Monday, yes.
12 CHAIRMAN SEALE:
I have a question.
13 DR. SHAO:
Yes.
14 CHAIRMAN SEALE:
These are the residuum, I guess, b
15 of some 200 generic issues that were identified years ago 16 and have been worked off with varying success, and I won't 17 go into that.
18 What I will do is ask this.
There are 15 left.
19 Have you gone through and identified specific tasks that are 20 necessary to resolve the remaining issues on those Reg 21 Guides and then decided exactly which ones of those Reg 22 Guides will be served by whatever it takes in order to 23 resolve those outstanding issues in what year?
24 So that we can say that there are, for example, 25 five reg guides that are under active consideration at this ANN RILEY & ASSOCIATES, LTD.
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point.
There are ten of them that are not being worked
(')
2 right now.
But two years from now we'll start working on 3
these additional two.
And so at what point out there will 4
we finally have gotten ourselves to where we can declare 5
victory and state that these are all ancient history?
6 MR. MORRIS:
Well, one point to make is that the 7
generic issue identification resolution process is an 8
ongoing process.
9 CHAIRMAN SEALE:
That's right.
10 MR. MORRIS:
The 200 that might have been on the 11 plate many years ago, many have been resolved.
12 CHAIRMAN SEALE:
That's right.
13 MR. MORRIS:
But there are new ones that are 14 identified.
And through the years there has been a 15 continuing identification process.
So it's not as though we 16
'can just say -- declare victory and there will be no other 17 work in this arena.
That's going to depend on how rapidly 18 new issues --
19 CHAIRMAN SEALE:
But there's a certain sameness in 20 the list.
21 MR. SHAO:
For a long time.
22 MR. MORRIS:
Yes, many issues.
23 CHAIRMAN SEALE:
Things like fatigue.
24 MR. SRAO:
Yes.
25 MR. MORRIS:
Yes.
Remain far too long for our
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satisfaction.
(
2 MR. SHAO:
Let me make a comment.
Out of these 15 3
issues, you know, both NRR and Research are responsible --
4 depends on the issues.
Okay?
Some issues belong to my 5
division.
Some belong to Wayne Hodges' division.
And some 6
belong to NRR.
Okay?
For instance, like fatigue.
7 Fatigue -- we resolved the fatigue for 40 years.
8 But this is fatigue for 60 years and maybe for license 9
renewal.
Hopefully we have resolution this year on fatigue 10 for 60 years.
11 But EQ is a bigger issue.
EQ is going to take us 12 a couple years.
I think we will plan to do what you 13 suggested, for each of the 15 issues come out with a so-14 called strategy, how to resolve them, whether this year, I
\\
15 next year, and whatever.
Even for some belonging to other 16 divisions or other offices, we are going to ask them the 17 same question as you suggested.
And hopefully we have a 18 status of these fatigue issues.
19 CHAIRMAN SEALE:
Okay.
20 MR. MORRIS:
On the review of the effectiveness of 21 tile existing regulations, we have an initiative.
It's 22 called DSI-12, and we have an initiative called DSI-23.
23 DSI-12 is related to risk using risk information in the 24 decision making process, and a subtask of that is to 25 reexamine the effectiveness of certain regulations.
Station O)
(
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blackout, ATWS were two that-I recall.
I think maybe decay
()
2 heat removal was another one.
3
-So we are going to be looking at the effectiveness 4
of those regulations as the starting point for this process.
i
'S Under DSI-23, that's called regulatory excellence, and what i
6 we've got there is a what we call a strategy, and that 7
strategy is a systematic effort to identify areas for j
8 improving the Agency's regulatory framework.
And it goes 1
9 beyond the regulations.
It would go to regulatory guides, 10 anything that's impairing our effectiveness as an agency or 11 efficiency.
12 And this is a new process.
It's just being 13 designed and developed as a part of the regulatory 14 excellence program.
This initiative at this time involves a 15 few FTE to start with, and we're going to have to try it out 16 and see how effective we are, see whether that is a valid 17 and valuable process, but we are initiating this effort, and 18 it will be a formal process in the agency involving 19 recommendations to the Program Review Committee.
So we are 20 making that effort.
21 CHAIRMAN SEALE:
Yes, I think we have a 22 presentation coming up on this program very shortly.
23 MR. MORRIS:
On the issue of risk-informed 24 performance-based improvements, again DSI-12 involves a 25 concerted effort towards more risk-informed decision making.
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In addition to that, the Commission I think a week or so ago
()
2 Joe Murphy was in to talk to you, the Chairman has spoken to 3
you about the Chairman has an initiative to examine what we 4
can do in the area of performance-oriented regulation.
Joe i
5 spoke to you about that issue.
The staff is developing a 6
paper on this.
We have to do more planning, and we would 7
come back and tell you more about this as it evolves.
i 8
The Commission is deeply interested and involved l
9 in this, so I think we have to wait and see what they want 10 to do before we can get much farther along on this issue, 11 and so -- but we are focused on it.
It's not something that 12 we have asked for specific resources from Congress other l
13 than to implement DSI-12.
And I seem to have lost my note 14 on the -- on the digital technologies.
We have increased j
15 the budget in that FY '99 -- we've requested an additional i
16
$450,000.
17 DR. POWERS:
Digital technology is and software-18 driven systems and things like that is often mentioned when 19 the subject of new technologies comes up.
Is that the only 20 area where one could forecast new technologies being applied i
21 to our existing fleet of reactors?
22 One that comes immediately to mind is there 23 certainly are some developments in the area of clad on fuel, 24 which would have an impact on 50.26, or maybe it's 46, I'm 25 not sure which one it is, but --
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MR. HODGES:
50.46.
2 DR. POWERS:
And right now one of those, and it 3
must be 46, calls out specifically ZIRLO, and clearly people 4
are looking at alloy formulations that are n:t. ZIRLO, and 5
they're den.onstrating much higher corrosion resistance, 6
burnup resistance, and things like that.
I mean, that is an 1
emerging technology that's not just digital.
7 i 4
8 Are there others that don't spring into my mind
{
9 right away?
I 10 MR. HODGES:
You could probably say that almost 11 every area there's going to be some new improvements, 12 whether it's in analysis methods or whether it's something 13 like that on the fuel.
14 MR. MORRIS:
I think maybe what Wayne is saying, O
15 within any program there has to be an attention to any new e
l 16 developments in technological developments within this 17 program.
This is an area where a program is being largely l
18 driven by new technological developments.
They all would 19 encompass and be cognizant of those, but this is probably 20 unique in that regard.
1 21 MR. HODGES:
I mean, some of the things that we're 22 trying to do now even in the thermal hydraulics, the 23 experimental work there, in trying to formulate, do bett.er 24 formulations on the models, is driven by the fact there's 25 now better instrumentation so that you can go and do some ANN RILEY & ASSOCIATES, LTD.
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things that you couldn't do before.
So --
2 DR. POWERS:
Yes.
Dr. Eltawila acquainted us with 3
some of those things.
And certainly in that category one 4
has to include the accommodations that have been found for 5
new NDE techniques in steam generator tubes.
I mean, that's 6
new technology that we found some accommodation for via the 7
generic letter process since we couldn't do it by rule.
8 MR. MORRIS:
We're looking for a new technology, 9
remember, but I'm not sure how successful we'll be on MDE 10 for vessel irradiation.
But that's a search rather than --
11 DR. POWERS:
That's one where you may be leading 12 the parade.
What that general category referred to of 13 course were things that were emerging within the industry 14 that they might spring upon you, and the problem with 15 springing things on you is the time between revelation and 16 the time that you can accommodate it and the regulations 17 tends to be long --
18 MR. HODGES:
Right.
19 DR. POWERS:
And the only way to short-circuit 20 that I know of is get the research done before they spring 21 it on you.
22 MR. HODGES:
In the risk area we're kind of 23 developing new technology for treating errors of commission 24 and things like that so --
25 DR. POWERS:
Again there's an area where you're I
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leading the parade and you can unleash that on your
()
2 regulations at your leisure.
It's the ones that somebody 3
else unleashes on you that are the concerns here.
4 DR. SHACK:
Yes.
For example, they're making 5
changes in their water chemistry.
I mean, they're adding, 6
you know, zinc in PWRs, zinc in BWRs, noble metal additions.
7 DR. POWERS:
And that ought to be breathtaking 8
when that sort of thing happens.
9 DR. SHACK:
It's the sort of thing you want to 10 do -- one would think you'd do with a certain amount of 11 caution.
12 DR. POWERS:
A lot of caution.
13 MR. MORRIS:
I believe that covered most of the 14 items in the ACRS letter.
I think you were interested in 15 the user-need issue, and that was one of the things I 16 believe you had mentioned that in the letter.
I didn't put 17 it in the list.
We're engaged in a dialogue.
As I said 18 yesterday, eithe-1 or Mal or somebof from the office meets 19 with senior management at NRR all the time, every week. as a 20 scheduled meeting.
And we have other meetings as well.
And 21 we're trying to get on top of this issue of user needs and 22 their approach to user needs so that we have a very good 23 dialogue with them about when is the time to send one over, 24 when does it make sense.
As I told you, the technical 25 staffs work together on this issue of sharing information
()
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1 from the research staff to the NRR technical staff that
(-
2 sometimes results in user needs.
3 As we go through some of these issues we will talk 4
about some of the areas that have been pent-up user'needs 5
that we're trying to respond to, so maybe I can go on with 6
that, and we can come back to it if you want to, but I would 7
propose to move on through this and try to get back on 8
schedule here.
i 9
Let's see.
What we've done here is we asked the 10 divisions, Larry, Wayne -- Joe Murphy joined us, by the way; 11 he's over here -- to express to us what they think we should 12 be looking at for starts in the near term.
Remember, some 13 of these would be candidates for reprogramming in '98.
Some 14 would be candidates to be included in the FY '99 budget.
15 And some might have to be deferred until the year 2000 16 budgets.
And certainly your views on these issues either 17 today or at any time, you know, you might want to call us 18 back in and say we want to talk about that some more would 19 be just fine with us.
And even in fact the sooner the 20 better.
But I realize that your schedule dictates a certain 21 rigidity with regard to what we can do here.
But let's go 22 on.
23 This issue of the potential for FWR sump blockage, 24 this is an area where NRR has sent over a user need, and we 25 have been discussing with them how to proceed on this issue.
I
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At one level, in fact the two first bullets, the PWR sump 2
blockage and the containment coating issue, could emerge as 3'
pretty big research programs in and of themselves.
And when 4
that happens, that is one of those areas where it's a 5
certain amount of disruption now occurs.
In the old days we 6
might have been able to accommodate a million or a $2 7
million program a lot easier than we're able to do today.
8 But when this comes over and we begin to look at it, we're 9
looking at, you know --
10 DR. UHRIG:
Was there a comparable program on the 11 BWRs, or did -- I thought industry pretty well bandled --
12 MR. MORRIS:
I think the BWR program has --
13 DR. BARTON:
ECCS suction strainer issues.
14 MR. SHAO:
Yes, blockage, we have a very sizable 15 research program.
We completed that program.
16 DR. UHRIG:
You completed the program, l
17 MR. SHAO:
Yes.
18 DR. UHRIG:
Sizable meaning half a million?
19 MR. SHAO:
Oh, the total's about 3 million.
20 DR. UHRIG:
About three million.
21 MR. SHAO:
We spent 3 million in the last three or 22 four years.
23 DR. POWERS:
Marshall came and reported to us.
24 MR. SHAO:
Yes.
Marshall's sitting right here.
25 DR. POWERS:
He got a round of applause for his ANN RILEY & ASSOCIATES, LTD.
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very good program.
()
2 MR. SHAO:
Actually I think we spoiled NRR on 3
this.
4 (Laughter. ]
5 MR. MORRIS:
So what we're doing now is we're 6
trying to work with NRR and Mike has been developing maybe a 7
phased-in approach.
8 DR. UHRIG:
Um-hum.
9 MR. MORRIS:
Where we do some initial evaluations 10 to see how big an issue this may be and then phase it up, 11 rather than say we're going to launch into a program that is 12 a $3 million program.
13 DR. UHRIG:
Are not some of the same solutions 14 that were for BWRs comparable here?
th(/
15 MR. SHAO:
Yes, the issues are the same, but' 16 mainly the debris transport is quite different, because 17 debris transport is the major issue, debris transport to the 18 sump.
And the coating issues is quite new.
19 DR. UHRIG:
That's a new one.
20 DR. POWERS:
Those two-phase thermal hydraulic y
1 21 types just cannot get it solved, can they?
22 MP. SHAO:
No.
I think they need some experi --
23 DR. UHP.1G :
The coating issue could also be 24 applicable to the BWR.
25 MR. SHAO:
Yes.
Coating can be to BWR and
()
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399 1-actually the BWk owners' group issued a coating -- and
()
2-they're working on coating issues too.
You're right.
3 MR. MORRIS:
So, again, this issue of the validity 4
of the accelerated aging process that's essentially included 5
in the regulations in IEEE.
I forget the number.
You know, 1
6 there's an IEEE standard that says you may use Arrhenius 7
aging, accelerated aging.
But there's questions about the 8
validity of that when you have synergisms between radiation 9
effects and thermal effects.
Does it really work?
10 So this question, we worked on it years ago,.had a 11 program at Sandia National Laboratory.
We were trying to 12 tackle that program.
I think it never was able to deal with 13 the issue.
We had to cut that program back considerably.
14 But this is now on our table again.
As the next issue is
\\
15 the one --
16 DR. MILLER:
What's putting it back on the table?
i 17 MR. MORRIS:
I remember looking at that some years 18 ago.
19 MR. SHAO:
Okay.
This is a very specific issue, 20 okay?
It will be called power upgrade.
Because of 21 potential power upgrade, they qualify for certain 22 temperatures for using Arrhenius, but power grade, the 23 temperature post-LOCA is higher than the temperature that i
24 qualified.
1 25 DR. MILLER:
So 323 wouldn't have --
I
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MR. SHAO:
Okay.
What they want to do is they've 2
got some local area, local time zone, post-LOCA is higher 3
than the temperature that qualifies for this cable.
But 4
licensees -- because a lot of other temperatures are lower.
5 So that if the licensee wants to use Arrhenius formula, say 6
even though they're locally higher, they're okay, because 7
consider lifetime spend, in general they're lower.
They 8
want to compensate the lower with the higher, 9
DR. MILLER:
Will radiation be higher also?
10 MR. SHAO:
Mainly right now they're worried about 11 temperature right now.
So there's a very specific issue for 12 this problem.
It's not the whole Arrhenius --
13 DR. MILLER:
It's the narrow use --
14 MR. SHAO:
Narrow use of Arrhenius.
15 DR. POWERS:
I think the answer on the radiation 16 is higher, but it's small factors higher, whereas the 17 temperature because of its exponential character --
18 MR. SEAO:
Correct.
19 DR. POWERS:
Has more impact.
But you still have 20 the synergism.
j 21 DR. MILLER:
Right.
22 DR. POWERS:
With the radiation.
I 23 MR. SHAO:
So that really tries to answer cer'.ain 24 problems related to power upgrade, when they increase the 25 power from let's say 100 percent to 120 percent.
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Okay.
We got a user request on this one too, but
()
2 we just don't have money to work on it.
And we requested 3
the chief financial officer for funding.
Hopefully we'll 4
get some money on this.
5 MR. MORRIS:
I think -- maybe you have questions 6
on the other issues, but those are all --
7 MR, SHAO:
The first five issues, right here, we 8
all have user requests.
The last one was anticipatory.
9 DR. BARTON:
And what's holding these up is 10 funding?
11 MR. SHAO:
Pardon?
12 DR. BARTON:
I missed why these are being 13 deferred.
14 CHAIRMAN SEALE:
No money.
15 MR. SHAO:
No money.
16-DR. BARTON:
Even though it could be a safety 17 issue, there's ru) funding.
18 MR. SHAO:
No money right now.
19 DR. MILLER:
On the upgrades, how are we going 20 to -- there'll be upgrade requests coming through --
21 MR. SHAO:
Yes.
22 DR MILLER:
What are we going to do if we don't 23 have this done then?
For approving the upgrade or --
24 DR. POWERS:
You make a conservative decision.
25 DR. MILLER:
Or make a conservative decision.
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MR. SHAO:
Decision.
Yes.
Or make a judgment (p s) 2 with Doug, and they confinn it af terwards.
I 3
DR MILLER:
So use judgment.
4 MR. SHAO:
Yes.
5 DR. MILLER:
And conservatism.
6 MR. SHAO:
Yes.
7 MR. MORRIS:
Well, the word " confirmatory" would 8
suggest that you may use judgment and then confirm the 9
validity of that judgment.
10 MR. SHAO:
Do you have that viewgraph?
I'll show 11 you the viewgraph.
Most likely everything's okay.
I'll 12 show you what the issue is.
13 You see in the shaded area they're C, but in 14 general they are under the C.
So they want to use just like 15 energy theory, you know, over the life they're still okay, 16 because they're locally increased.
17 MR. VORA:
For power upgrade and for license i
18 renewal the licensees have made some analyses for their EQ 19 requirement and they use the Arrhenius methodology, and they 20 are saying that as long as the overall time, temperature, 21 and integrated profile is still lower than the originally 22 qualifying EQ requirement they should be allowed to j
23 demonstrate that they'll be okay for the extended life or 24 for power upgrades.
25 DR. MILLER:
They use a basic energy argument.
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MR. SEAO:
Basic energy argument.
()
2 MR. VORA:
And the question comes about from 3
research perspective what are the other synergistic effects, 1
1 4
for instance, that when you go into post-LOCA conditions, do 5
you have the moisture and temperature combination effects 6
and can you just use the Arrhenius methodology to 7
extrapolate.
So that's a different issue that needs to be 8
addressed.
9 DR. MILLER:
Can't you do that partly by doing 10 some basic experiments?
11 MR. VORA:
This is correct.
12 MR. SHAO:
That's what we intend to do, yes.
It 13 costs about $200,000.
14 DR. MILLER:
200,000?
)
O)
(s, 15.
MR. SHAO:
Yes.
16 MR. MORRIS:
Before I take this off, those were i
I 17 the division engineering issues we're considering, and no j
i 18 other questions, I'll go on to the, let's see -- Joe j
19 Murphy's division, Division of Regulatory Applications.
20 We're looking at these issues.
Joe is here.
He can give me
{
21 any of the details.
22 The first one I believe you may be aware of, the i
23 significance of the application of the linear nonthreshhold 24 hypothesis for risk coefficients at low doses.
That can 25 have great financial implications.
We have been forced, and i
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it's in concert with the national scientific community's 2
viewpoint that this is a conservative estimate of dose 3
effects at low dose, but they're extrapolating from high 4
dose-rate levels and making a judgment.
And if there's any.
5 way that we could bring science to bear to get a better 6
answer, we think it's important to do.
7 DR. POWERS:
Let me ask you a question.
8 MR. MORRIS:
This would be done in concert, EPA, 9
DOE, and funding a National Academy of Sciences study.
10 DR. POWERS:
Suppose that you came up with 11 incontrovertible proof, mathematical proof -- you're not 12 going to be able to do that, but let's just suppose that you 13 did -- that there indeed was a one-rem threshold, that 14 anything less than a rem, absolutely nothing.
What would 15 you change?
16 MR. MORRIS:
Well, we recently developed a rule 17 for license termination or decommissioning, and that rule i
18 has got in it the policy that at about a tenth of a rem --
{
19 100 millirem -- a tenth of a rem -- is the place where you 20 must protect against radiation levels above that.
And 21 that's consistent with international guidance and national 22 guidance from the scientific community.
We have said that 23 in order to assure against multiple exposures that might 24 exceed 100 millirem, we would find it acceptable if you 25 could reach 25 millirem.
There was a great controversy ANN RILEY & ASSOCIATES, LTD.
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about what level to pick.
But if we were able to show, as
()
2 you said, that there is no-risk at that level, why you would 3
revisit this.
4 We found as the doses go lower that you require 5
and you are searching for that the costs can go up 6
astronomically.
Eventually in = case where you are removing 7
soil from a site you eventually are forced to remove enough 3
soil that the truck accidents from removing the soil away 9
from the site override any risk benefits that you thought 10 you were getting from the radiation exposure savings, and 11 the cost can go up per --
12 DR. MILLER:
Exponentially.
13 MR. MORRIS:
Yes.
Per health effect averted 14 exponentially, and estimates, you know, the billions of O
15 dollars for health effects averted.
16 DR. MILLER:
EPA wanted you to go lower, right?
17 MR. MORRIS:
We have had a long discussion with
{
18 EPA about what the appropriate levels are, and they are 19 concerned that 25 -- they have the express concern that 15 20 may not even be protective.
21 DR. MILLER:
Right.
22 MR. MORRIS:
If what you propose were to be found 23 to be true, I think it would change this picture 24 dramatically and whatever costs may be incurred in going to 25 15 millirem could be avoided if there were no risk
()
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implications but that is an hypothesis.
()
2 You are not supposed to answer hypothetical 3
questions --
4 DR. POWERS:
No, but what I am trying to 5
understand is what the impact is.
6 MR. MORRIS:
We would probably -- you would 7
envision changing regulations that require cleanups to that 8
level -- low level waste, high level waste repositories --
9 the picture there wouJd change too.
10 That is the kind of ramification this would have.
11 DR. POWERS:
Would it have any impact on your 12 siting criteria?
13 MR. MORRIS:
Siting?
For reactors?
14 DR. POWERS:
Right, reactors.
15 MR. MORRIS:
The reactor siting criteria are well 16 above 1 rem and so I believe probably not.
17 DR. POWERS:
Probably not?
18 MR. MORRIS:
You know, I wouldn't I wouldn't 19 there may be some place that I can't think of.
Certainly 20 safety goals.
You would want to re-look at the implications 21 of the safety goals because at those safety goal levels, 22 remember -- I don't want to get too far afield here, but the 23 safety goal levels are about accidents and so the 24 ramification of an accident that pertains to this arena is 25 the residual radioactivity that would be left in the soil
.(
)
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from the deposition of airborne radioactivity as it was
()
2 deposited around, and so the cost of cleaning up an accident 3
would be changed if you felt you didn't have to clean up 4
except down to 1 rem.
5 DR. MILLER:
It would make a dramatic difference 6
on the land contamination issue.
7 MR. MORRIS:
Yes.
8 DR. POWERS:
Well, land contamination isn't 9
recognized in our consequence analysis.
It is recognized in 10 other areas.
11 DR. POWERS:
Okay.
Well, I have got a feel for 12 things now.
13 CHAIRMAN SEALE:
That's very good.
14 MR. MURPHY:
Dana, could I offer you an additional 15 thought on that?
16 It is important to recognize that in risk analysis 17 where we calculate person-rem that most of the person-rem j
i 18 tends to come beyond five miles, in the five to ten mile l
19 ratio, which means their dose is far less than a rem.
20 We make our decisions in a lot of rulemakings on 21 the basis of monetizing at $2000 per person-rem, and if you 22 eliminated the person-rem where the rem was below 1 rem you 23 might lower that by over an order of magnitude.
24 DR. MILLER:
Part of that is more on the effective 25 dose theory than on the linear, which is more ridiculous ANN RILEY & ASSOCIATES, LTD.
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than the linear.
()
2 MR. MORRIS:
These projects, we are unsure about 3
the' level of your interest versus the level of interest of 4
the ACNW on these issues.
5-We're perfectly happy to speak to you about any of 6
these in more detail at any time, but we probably also would 7
envision that the ACNW might be interested in some of these 8
areas because they do cover the area that they focus on.
9 DR. POWERS:
I'm sure they are.
I 10 I might comment to you that we have enlisted the i
11 aid of the ACNW in helping to prepare our report to the 1
12 Commission here.
j 13 MR. MORRIS:
I mentioned before that we are 14 looking at, in concert with the new emphasis on shutdown b
\\_s/
15 conditions and low power, we would look at the Accident 16 Sequence Precursor Program.
17 We also would look at expanding it to cover 18 external events.
19 You had mentioned in your letter that you were 20 concerned about doing a better job in human reliability and 21 human factors.
We believe that the second ATHEANA human 22 reliability analysis would be valuable.
23 The third bullet can be very important in terms of 24 getting a better handle on how to do a better job at risk-25 informed decision-making by following more closely a more ANN RILEY & ASSOCIATES, LTD.
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detailed technical review of the NEI full-scope PRAs that
()
2 are being planned and conducted.
We would certainly 3
envision trying to maintain a level of cognizance about what 4
is going on there even without additional funding, but if we 5
could get additional funding, we would be able to confirm 6
and follow in more detail the validity of those PRAs, 7
making -- facilitating the eventual use of that information 8
in decision-making.
9 The third one is a high priority item for us.
10 DR. WALLIS:
Are you going to move on?
11 MR. MORRIS:
I have two more --
12 DR. WALLIS:
I want to go address the last issue i
13 here.
14 MR. MORRIS:
I'm sorry?
O-15 DR. WALLIS:
I want to address your last bullet.
16 MR. MORRIS:
Okay.
17 DR. WALLIS:
I think a simplified thermal i
18 hydraulic code is not something you just have to explore the l
19 development of -- you could develop without too much trouble 20 today, and it would be useful, not just for real time 21 accident information but it is useful for sensitivity J
22 studies, for exploratory studies and particularly for 23 probability assessment.
24 Until you have a code which will run quicker than 25 this monster TRAC you cannot do a lot of sensitivity studies (f
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and probabilistic studies, but I am sure that you can 2
develop a thermal hydraulic code which doesn't have to be 3
necessarily all that simplified, which will run on a PC, and 4
will let you do these kind of studies which are very 5
necessary if you are going to bring in any kind of i
6 probabilistic problem into thermal hydraulics.
7 What you have also given up is the explorative 8
development.
There I think explorative development is 9
appropriate rather than actually develop -- explorative 10 development of a new modernized system code rather than 11 TRAC.
12 The decision has been made to go back to fixing up 13 TRAC and RELAP, the geriatric code, and give it another five 14 or ten years' life, rather than go to a new, young, robust OV 15 and vigorous code with all kinds of new features, and some 16 day that is going to happen.
You've obviously given up 17 doing it today.
18 MR. HODGES:
I agree with you on the use of the I
19 simplified code.
It needs to be done.
20 What we are doing with TRAC, it won't be the same 21 code.
Maybe it's not a start from scratch either, so it's 22 kind of a hybrid.
23 MR. MORRIS:
I want to finish up and then we want 24 to go to lunch.
So we have a couple of more items that we 25 are looking at and if you have questions, we can ann er
)
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them.
\\
2 But-what I wanted to do by this exploration and by q j 3
talking about these issues was to see if -- you know, 1
4 identify those areas where you might want to get more 5
information.
This was a very helpful observation Dr. Wallis 6
provided.
And at least let you see some of the thinking 7
that we are doing as we try to figure out just when and what i
8 rate do we initiate some of these new projects.
Some of j
l 9
these are smaller than others, I admit that, and each of I
10 these would essentially fit into one or more of the existing 11 programs.
So these are projects that would fit into one of i
12 the existing programs.
And so these guys have to plan their I
13 budget program, they have got to figure out what they want 14 to come forward with.
And, of course, the office will be
-r T k_)
15 looking at it, and the Program Review Committee will be l
1 16 looking at it.
17 DR. POWERS:
I don't know whether.I am happy or 18 disappointed that Professor Apostolakis is not here because 19 he would be saluting and doing all kinds of things over your 20 last one.
21 DR. WALLIS:
I have an overview question here.
I 22 think it is very useful, what you have gone through today.
23 What you have not mentioned is the things that you might do 24 if you really had the opportunity to do them.
I think that 25 you can talk about what you are doing, and what you can't
[#)
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do, what you would like to do and sort of deferred.
r l
2 But there is another level of thinking where, if 3
you really had free rein and you were not constricted by, 4
not just budget, but other things, what would you really 5
like to do?
At so?e time it would be nice to hear that, 6
because I think one gets sort of mired in the details of 7
what is possible all the time, and doesn't -- I think you 8
ought to think about what you would like to do if you could.
9 MR. MORRIS:
I think -- what we did was, as you 10 see, a limited effort.
I recognize and I felt that I would 11 have preferred -- I would have liked to have been able to 12 give you that flavor.
But I think we would have to step 13 back -- I think we would need to do some what is called "out 14 of the box" thinking to come up with that and get a better 15 picture of some of those items.
But we could come back and 16 do that at some time in the future.
I would like some time 17 to mull that over before I try --
18 DR. WALLIS:
I ask because I think part of the job 19 of the ACRS, as I gather from what I have heard around here, 20 is to try to think out of the box and get other people to 21 think out of the box.
22 DR. POWERS:
If I were to offer a pe"sonal l
23 opinion, I sense that among many of the programs there is so 24 much pressure to find ways to cut the budget, to squeeze 25 what you would like to do down, and to make it finite, ANN RILEY & ASSOCIATES, LTD.
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saleable and whatnot, that many of your -- not you 2-gentlen2n, but maybe your subordinates immediately below 3
you, have inadequate opportunity to define what they really 4
would like, think the agency needs, as opposed to what'they 5
can get this budget cycle.
6 And so we see things like, to remove it stri ct.ly 7
from research, I mean we don't feel anything personal here, 8
is you see the ASP Program coming in and asking for updates J
9 to the codes they have eith some frequency -- I mean there 10 is a Version 1 and a Version 1 Prime, and a Version 1 Double 11 Prime -- and they have not had the opportunity to say what j
12 is the kind of code I would really like to have and can I --
13 once you knew that, once you could set down exactly what you 14 wanted, maybe you could get all these updates leading to 15 that, rather than just putting a new layer of paint on a 16 structure.
I mean I am very sympathetic to what their 17 problem is.
My heart bleeds for them, in fact, because I 18 know what kind of pressures they are under.
19 And to the extent that se can give those people 20 the time to think about it, I think you might find some 21 efficiencies in there.
It is -- as I say, I don't mean this 22 as a criticism, it is simply an observation of the
]
23 environment that they are forced to live in.
l 24 MR. HODGES:
The ASP I think is an interesting 25 example.
As far as the technology, and how fast you can run ANN RILEY & ASSOCIATES, LTD.
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the calculations and this type of things, the SAPHIRE code, (Oj 2
which, it is going to be much more detailed, would be a 3
great tool for doing that.
The problem is when you go that 4
-- you are using essentially the same code, basically, 5
that's what it is.
It is the detail and the modeling for 6
each plant that you go to.
And so, if I had my druthers, 7
yes, I would have a detail model for every plant, so when 8
something happens --
9 DR. POWERS:
Yes.
10 MR. HODGES:
-- then I would do what we do in ASP, 11 which is a more simplified model using the same basic tool.
12 But, again, practicalities get in the way, and so you use a 13 more simplified model.
14 CHAIRMAN SEALE:
There is one other bit of 33 information I think would be useful for you, and for us in 16 the longer run, and that is, as I go through this list, you 17 have been very faithful to the identification language that 18 we used in our list and to the language that is used within 19 your staff discussions to identify problem -- program areas.
20 That does not necessarily always make the relevant 21 core technologies that are involved transparently obvious.
22 And it would strike me that it might be very worthwhile to 23 ask yourself where the effort in these things are with 24 respect to core technologies.
And that might help you then 25 get a better handle on what the levels are that these kinds ANN RILEY & ASSOCIATES, LTD.
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of questions would demand.
It might help you in scheduling
()
2 things out a ways.
3 It would also help, I think, in areas like the ASP 4
Program, for example, to recognize that having codes that do 5
the thermal-hydraulics is not the whole story in doing
(
6 something like ASP because, as you say, not all plants are 7
alike.
You have to have the competence to recognize what 8
the differences are and to see where adjustments are 9
necessary in order to properly take into account those 10 differences.
11 So I think going through these things and relating 12 them back to core technologies might be useful in seeing 13 what the personnel implications of these kinds of efforts 14 would be.
15 MR. MORRIS:
I think we are to some extent doing 16 that.
Remember the presentation for core capabilities 17 yesterday?
18 CHAIRMAN SEALE:
Yes.
19 MR. MORRIS:
After this meeting, we are going to 20 be meeting again to revisit the effort to refine our concept 21 of what core capabilities we need.
So we will take that 22 advice in hand as we do that.
Thank you very much.
23 The other point -- one other thing, in terms of 24 the long-range view, I did put a bullet up early on that we 25 need to keep track of the long range, think about this out
()
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of the box thinking.
And I mentioned that we are going to 2
undertake an effort tc get a broad range of views.
I think 3
you have said our staff needs to do that.
We are going to 4
go out and see the views of others as we do that.
So, in 5
that context, it will be helpful, and we will try to see if 6
we can start that out of that dialogue along the lines of 7
let's make sure that we are stepping back from these detail 8
programs and looking at the big picture.
9 DR. WALLIS:
I think that would help the sort of 10 enthusiasm and morale of the staff.
I think they already 11 are doing a very good job, but if they can sort of think 12 about something exciting coming along that they can be part 13 of, and it would also help in that regard.
14 MR. MORRIS:
Good point.
Thank you.
Yes.
15 DR. POWERS:
Let's see, I want to pursue, just for 16 my own understanding, and briefly, some more about the user 17 need request.
I think I understand that there is a fairly 18 careful discussion that goes on between NRR and RES before a 19 user need is acted upon.
What I would like to understand is 20-
-- Is there somewhere in the agency a pot of user needs that 21 don't get elevated up?
I mean they sit there and wait.
And 22 maybe it is in the Director of NRR's safe or something like 23 that.
User needs that exist but haven't been elevated up to 24 the point of discussion with RES.
25 MR. MORRIS:
I think, as I have talked to Brian ANN RILEY & ASSOCIATES, LTD.
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Sheron on this, he has mentioned he has a few things that he
()
2 is considering, and he mentioned those, but I can't remember 3
right offhand what they were.
4 MR. SHAO:
Okay.
I 5
MR. MORRIS:
And that he is considering, and that 6
have been developed by the staff.
But as far as a backlog, 7
a large backlog, I am not aware of any such backlog.
- Now, 8
there may be some ideas and concepts brewing as the Research 9
technical staff talks to the NRR technical staff, but they haven't yet emerged as a document that I 'think has been put 5
10 11 on Brian Sheron's table or Sam Collins' table.
12 Larry.
13 MR. SHAO:
Okay.
I think, I mean I want to 14 reinforce just what Billy said, there is not a big backlog, 15 only two I am aware.
It is very recent.
Okay.
There are 16 two user needs and my staff and their staff work together 17 and they are ready to come and will stop by Brian Sh.eron 18 because they -- he think that we don't have money to work on 19 it.
Okay.
The two user needs, one is on seismic 20 qualifications.
The other one on MOV DC motors, beer use we s
21 found a problem with MOV AC motors.
Only two I am aware of.
22 I don't know about Wayne there, but in my area, only two.
23 So there is not a big backlog.
24 DR. MILLER:
Can I follow-up on that?
I have a 25 question on that same kind of area.
Would you judge the
()
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interaction of the staff and NRR and Research as uniform i
2 across the different disciplines or areas, or would you say 3
there is some lack of uniformity?
Or there could be 4
backlogs that you don't know about in certain areas and 5
certain areas, not?
}
6 MR. SHAO:
I cannot speak for Wayne's area, but in
)
7 my area, I think it is pretty uniform and has been very good 8
so far.
9 I don't know, Wayne, do you want to say something?
10 MR. HODGES:
It is not completely uniform, but I s
11 think we, both we and they are making an effort to try t 12 talk more and be open.
I think I would say over the last 13 couple of years there has been some good, considerable 14 improvements in that.
15 And also, bear in mind,NRR is not the only source 16 of user needs.
We also get them from AEOD and NMSS.
17 DR. MILLER:
Right, I know.
18 DR. POWERS:
Yeah.
It's just an example, 19 Well, do the members have any other questions they 20 would like to pose?
21
[No response.]
22 DR. POWERS:
If not, I guess I will let you 23 gentlemen go get lunch and I thank you for an impressive set 24 of presentations, both today and yesterday.
I think you 25 have filled the objectives of the agenda far better than I ANN RILEY & ASSOCIATES, LTD.
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thought it could be fulfilled.
2 I appreciate very much you taking the time and 3
interest in this activity, and remind you again that our 4
report to the Commission on the Research Program will take 5
us a couple of months to put together, so there is j
6 opportunity, if there are things that come to mind over the 7
next couple of months, that you think that we need to be q
8 aware of, or you think that we have succeeded in getting i
9 ourselves confused on and you would need to straighten us 1
10 out on it, please feel free to try to interject in our 11 agenda, or to work informally with us.
12 MR. SHAO:
Okay.
{
13 DR. POWERS:
I'll return it to you, Mr. Chairman.
14 CHAIRMAN SEALE:
Okay.
I would like to add my r
15 observations.
I think this is probably less painful --
16 DR. POWERS:
It didn't look like it right then.
17 CHAIRMAN SEALE:
Yeah, I know.
This is something 18
-- this is a different problem.
Last night's pizza or 19 something.
I don't know.
20 But this is less painful than I think any of us -
21
- well, all of us recognize that it might be, and I think 22 that is because you have been very well prepared.
You have, 23 obviously, taken some time t.v put together not only lists, 24 but also to think about the lists and so forth, and we do 25 appreciate that.
We hope we will be able to do justice to ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W.,
Suite 300 Washington,.D.C. 20005 (202) 842-0034
I
~
]
420 1
1 the effort that you have put forth and come up with a (A,)
2 process that will be mutually beneficial to everyone.
3 With that, why don't we come back at 1:30.
4 DR. POWERS:
I was going to suggest a quarter of 5
2:00, 6
DR. BARTON:
I have got a problem with that.
Dana 7
has got the Committee basically tied up on research agenda 8
from 1:00 to 5:00.
We are losing one of our constituents 9
here, mid-afternoon, who is an important player in a letter 10 that we have not yet read before the Committee.
And so I 11 think somehow we need to take a break in Dana's, with his 12 permission, somehow in his agenda this afternoon, and get 13 that senior management meeting letter read before we lose 14 George.
p_
15 At quarter to 2:00, I think we are really going to 16 be pressed for time.
So that is something we need to figure 17 out.
18 DR. POWERS:
In that case, why don't we plan to 19 come back at 1:30 and work immediately on letters, because I 20 do have Saturday morning scheduled as well.
21 CHAIRMAN SEALE:
Okay.
Fine.
22 DR. POWERS:
And I will defer the plaus till 23 Saturday morning.
24 CHAIRMAN SEALE:
Okay.
1:30 then.
25
[Whereupon, at 12:22 p.m.,
the meeting was
()
ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W.,
Suite 300 Washington, D.C.
20005 (202) 842-0034
.m 421 1
concluded.]
2 3
4 5
6 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W.,
Suite 300 Washington, D.C.
20005 (202) 842-0034
REPORTER'S CERTIFICATE This is to certify that the attached proceedings
(
before the United States Nuclear Regulatory Commission in the matter oi:
NAME OF PROCEEDIE:
450TH ADVISORY COMMITTEE ON REACTOR SAFEGUARDS DOCKET 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.
1
< xa twd Hundley Official Reporter Ann Riley & Associates, Ltd.
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7
i FUEL BEHAVIOR i
Definition of research area This area is concemed with the development of the technical basis for NRC regulatory criteria and review capabilities to ensure the safe operation of nuclear fuel assemblies. The primary type of work to be performed in this area encompasses 1) the performance of experimental programs to provide a data base for regulatory criteria, the understanding of related phenomena, and analytical modeling for safety analysis; and 2) the development and maintenance of state-of-the-art fuel behavior analysis tools (FRAPCON for steady-state calculdtions and FRAPTRAN for transient calculations). Fuel-related regulatory criteria are used to ensure that anticipated events and postulated accidents do not evolve into severe accidents with unacceptable consequences to the public health and safety. Fuel related criteria
- . that are used to prevent the loss of coolable geometry following postulated accidents are required by 10CFR 50.46. and those used to ensure fuel integrity during notmal operation and arridosted operational occurrences are required by 10CFR 50, Appendix A. Other related crRoa are found in Regulatory Guides and the Standard Review Plan. The analysis tools provide the NRC with the abi;ity to perform independent analyses to assure that the regulatory criteria are met during reactor operation and postulated accidents.
Assumptions Requests from the nuclear industry to modify operating licenses (e.g., power upgrades) and improve operational performance (e.g., longer operating cycles, new fuel designs) will continue
'O to a < c iv o o-iii reaeir iooea ooent Iv i av ta i <r. oa < tiee i
- i=veivio2 cladding and fuel damage will continue to occur with regularity (domestically and intomationally), and these will require independent assessment and analysis by the staff to determine if they are precursors to safety problems. Fuel behavior research will continue intomationally (e.g., France, Japan, Norway). New data might alter our present understanding and could require reevaluation of safety margins.
State of technologv/ knowledge Fuel damage criteria were developed for normal cperation, anticipated transients, reactivity-initiated accidents, loss-of-coolant accidents, and several other postulated accidents. When most of these criteria and related analytical tools were being established in the 1970s, it was 1
thought that fuel bumup in commercial plants would not exceed about 40 GWd/t. The data base that supported the criteria and analytical tools included specimens with bumup to that
)
level. However, the industry has extended fuel bumup to much higher levels'(as high as 62 GWd/t) in recent years and has introduced new fuel designs with advanced cladding materia:s.
This has required a reevaluation of NRC regulatory criteria and mor"' ration of related analytical tools. While there is a basic understending of the behavior of Zire voy clad oxide fuel, a fundamental understanding and quantification of factors related to "igher bumup and to new feel designs and materials is needed to ensure the safe behador of auclear fuel assemblies.
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Rii
I FUEL DESIGN AND' BEHAVIOR What portion of the core capability if any, can be obtained from other than NRC funded sources, and if so can it be obtained in a timely manner and with j
independence?
Tnere is no practical non-NRC source for fuel rod analysis (codes). All such codes in the U.S. have been developed by the vendors or EPRI. They are proprietary and would not give NRC a capability that is independent of the regulated industry. A few foreign government codes might be made available.
but they are generally not open for public scrutiny.
Experimental data needed for code development and regulatory criteria can be obtained. In part, from foreign government programs for a price, in general safety-related research
" (i.e.. investigations of transients and accidents) is not performed by the
~
industry, so data available from industry sources would be limited to basic steady-state information.
What are the different disciplines that need to be supported? Which of these disciplines should be at NRC and which,should be at contractor organizations?
Which would disappear if not supported by the NRC?
Two different disciplines are needed:
(1) materials science, covering zirconium metallurgy, ceramic engineering. and including experimental procedures and (2) analytical modeling. Including code running skills.
Some O
of each is required at NRC to define needed work and apply the results.
Experimental programs require the use of contractors, in principle. the analytical work could be done entirely at NRC: however the present contractor arrangement provides a larger group of skilled personnel.
While international efforts in this area would likely continue: domestically, the materials science discipline. as applied to transients and accidents woulc be diminished without NRC support. The analytical modeling discipline would be maintained by the industry, which we regulate. but NRC's independent capability would be lost if not supported by the NRC.
What facilities are needed, in any? Why should they be supported? Will they be used frequently enough to justify their expense? If the facility was abandoned, would the cost to reassemble or construct the facility, if needed, be prohibitive?
Provided that major foreign programs continue to operate key test reactors and cooperate with the NRC. we can probably meet our needs by maintaining the good analytical hot cells at ANL.
In these cells, we can examine irradiated fuel from U.S. power reactors measure cladding properties, and simulate some transients and accidents.
~.
1 O
aeavletorv eltere814ve 1f there wes eo core reseerro reoe6414tv:
Traditionally. NRC has developed its own fuel damage regulatory criteria Dased
/ bent an experimental program. staff would have to rely on its own research.
decisions on largely conservative criteria to make licensing decisions e.g.Without the ability to dev related to new designs for hig" burnup fuel.
analytical models and to perform calculations for accident analyses. the NRC would lose most of its technical capability. and thus its independence in this area.
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