ML20217N935
| ML20217N935 | |
| Person / Time | |
|---|---|
| Issue date: | 04/02/1998 |
| From: | NRC |
| To: | |
| References | |
| REF-10CFR9.7 ACRS-GENERAL, NUDOCS 9804090262 | |
| Download: ML20217N935 (64) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
Title:
MEETING WITH ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS)
PUBLIC MEETING Location: Rockville, Maryland Date: Thursday, April 2,1998 Pages: 1 - 61 OI r
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7 DISCLAIMER This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on April 2, 1998, in the Commission's office at one White Flint North,-Rockville, Maryland. The meeting was open to public attendance and observation. This transcript has not been reviewed, corrected or edited, and it may contain inaccuracies.
The transcript is intended solely for general informational purposes. As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed. Expressions of opinion in this transcript do not necessarily reflect final determination or beliefs. No pleading or other paper may be filed with the Commission in any proceeding as the result of, or addressed to, any statement or argument contained herein, except as the Commission may authorize.
1
- - 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 ***
4 MEETING WITH ADVISORY COMMITTEE
-5 ON REACTOR SAFEGUARDS (ACRS) 6 ***
7 PUBLIC MEETING 8 ***
9 10 Nuclear Regulatory Commission 11 One White Flint North, Room 1F-16 12- 11555 Rockville Pike l 13 Rockville, Maryland 14 15 Thursday, April 2, 1998 16 17 The Commission met in open session, pursuant to 18 notice, at 1:08 p.m., the Honorable SHIRLEY A. JACKSON, 19 Chairman of the Commission, presiding.
20 21 COMMISSIONERS PRESENT:
22 SHIRLEY A. JACKSON, Chairman of the Commission 23 NILS J. DIAZ, Member of the Commission 24 EDWARD McGAFFIGAN, JR., Member of the Commission 25 GRETA J. DICUS, Memb'er of the Commission ANN RILEY & ASSOCIATES, LTD.
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- 1' STAFF AND PRESENTERS SEATED AT THE COMMISSION TABLE:
2 DR. ROBERT L. SEALE, Chairman, ACRS 3 DR. DANA POWERS, Vice-Chairman, ACRS 4 DR. GRAHAM B. WALLIS,-Member, ACRS 5'- DR, GEORGE APOSTOLAKIS, Member, ACRS 6 MR. JOHN BARTON, Member, ACRS 7 DR. THOMAS S. KRESS, Member, ACRS 8 DR.-MARIO H. FONTANA, Member, ACRS 9
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1 PROCEEDINGS 2 [1:08 p.m.]
3 CHAIRMAN JACKSON: Good afternoon, ladies and 4 gentlemen. It's a pleasure to meet again with Dr. Seale and 5 the members of the NRC Advisory Committee on Reactor 6 Safeguards, who plan to discuss a number of' topics of 7 interest to the Commission at today's session.
8 But first, I would like to welcome, if he is here, 9 Dr.-Graham B. Wallis to the Commission's Advisory Committee 10 on Reactor Safeguards. We're pleased to have you on board.
11 The Commission is fortunate to be able to draw 12 upon views and experiences of this selected group of experts 13 as we try to solve and address various technical concerns in 14 licensing and regulation.
15 During today's. briefing, the Commission -- I'm 16 sorry -- the Committee will discuss the following topics.
17 First, improvements to the Senior Management 18 Meeting process; next proposed revisions to 10 CFR 50.59 and 19 related issues; third, risk-informed and performance-based 20 regulation, including the use of PRA in the regulatory
.21 decision-making process; fourth, status of the AP600 review; 22 fifth, shut-down and low-power operations; sixth, NRC safety 23- research programs; seventh, license renewal; and eighth, 24- fire protection rule-nsking.
25 Commissioner McGaffigan has>already made note of ANN RILEY & ASSOCIATES, LTD.
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4 1 the fact that our two Commission meetings this afternoon 2 have been scheduled for three hours but probably each 3 involve about five hours.
4 So, Dr. Seale, my colleagues and I welcome you to 5 this meeting and anticipate another candid and informative 6 session with the Committee, and I understand that copies of 7 the briefing material are available at the entrances to the 8 room.
9 Unless anyone has any opening comments, I think we 10 had better proceed.
11 DR. SEALE: Very good.
12 Well, good afternoon, Chairman Jackson, 13 Commissioner Dicus, Commissioner Diaz, and Commissioner 14 McGaffigan.
15 As always, the ACRS is pleased to have the 16 opportunity to meet with the Commission and exchange 17 information and for us to provide our views on items of 18 interest to you.
19 We have a very ambitious agenda today and would 20 not be offended if most or all of the discussion time were 21 consumed in the first four items or so, because --
22 CHAIRMAN JACKSON: It may come to that.
23 DR. SEALE: It may come to that. And as the last 24 four items are all work in progress and the view-graphs 25 summarize these items fairly succinctly, I don't think ANN RILEY & ASSOCIATES, LTD.
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- 1 there's a lot of pressure to necessarily pound the program 2 into the time.
3 Occasionally -- or additionally,, I'd like to 4 mention that we have submitted copies of the ACRS operating 5 plan, and this contains planned activities, priorities, and 6 metrics for assessing ACRS performance. Any comments you 7 may have on that plan we would very much appreciate. We 8 expect to update it quarterly -- that is, July being our 9 first update.
10 I think we'll get right into the program, and John 11 Barton, Plant Operations Subcommittee Chairman, will begin 12 with a discussion of the ACRS deliberations on the Senior 13 Management Meeting process.
14 John?
15 MR. BARTON: Thank you, Dr. Seale.
16 ACRS has been actively involved in the review of 17 the proposed improvements to the SMM process. In March 18 1997, the Committee reviewed the prepared Arthur Anderson 19 report and, since then, has had several meetings with the 20 staff and prepared two reports to the Commission.
21 In the September report to the Commisrion -- some 22 highlights of that report, 23 The Committee supported the goal of codifying the 24 SMM information-gathering and review process. However, the 25' basis for the top-level criteria contained in the template '
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6 1 was not clear to the Committee.
2 Furthermore, the process by which the template led 3 to formation -- formulation of decisions also was not 4 apparent to the Committee.
5 The Committee preferred to see a top-down 6 structure that starts with a point of decision, identified 7 the objectives of the decision, and then proceeded to define 8 the informational needs to support the decisions.
9 In a memorandum subsequent to the Committee report 10 --
it was a memo from the ACRS Executive Director --
11 fcrwarded comments from an ACRS member, Dr. Apostolakis, 12 which laid out for the staff an approach to the top-down 13 decision-making approach.
14 Also, another item in the September report, we 15 talked about the assurance of the needs of the new 16 performance standards to be objective and reduce reliance on 17 event-driven assessments, and we made the point that, 18 although progress had~been made improving information basis 19 of the senior management process, considerable work remained 20 in areas such as developing tocls for assessing management 21 and organizational effectiveness and testing their 22 implementation before being included in the SMM process.
23 Also, in our September report, with regards to 24 staff's integrated review of-the assessment process, we 25 noted the staff had not defined requirements, preferably ANN RILEY & ASSOCIATES, LTD.
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7 1 quantitative requirements, for an adequate program to assess 2 license performance.
3 It was not apparent to the Committee at that time 4 how well-designed recommendations could be formulated 5 without explicit definition of the requirements for an 6 assessment program that met the agency's needs.
7 It was also not clear how preferred opinions --
8 options could be selected absent these requirements, and we 9 recommend the NRC staff develop these requirements for an 10 adequate licensing performance assessment program.
11 Subsequent to that report, we had additional 12 meetings with the staff and issued a second report on the 13 subject in March of this year, and in that report, we 14 reviewed the draft Commission paper.
15 We looked at the overall objectives. We felt that 16 they were not sufficiently specific to allow evaluation of 17 the proposed assessment process. We recommended at that i
18 time the development of specific objectives and performance '
19 measures that could be applied directly to the process.
20 The assessment decision model, logic model, we ;
21 felt should show how the selected decision options noted in i
22 the draft paper would utilize the performance measures. )
I 23 CHAIRMAN JACKSON: Dr. Barton, I think '
24 Commissioner Dicus has a question.
25 COMMISSIONER DICUS: Yes. About the objectives i
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8 1 and the perfonaance measures, could you be a little more 2 specific on what sort of measures you think would be useful 2 to provide the claricy?
4 MR. BARTON: George?
5 Dr. Apostolakis led this thought, and I'd like him 6 to expand on that.
7 DR. APOSTOLAKIS: Well, the overall objective of a 8 process like the Senior Management Meeting is usually-9 something that is general, noble, but not operational. So, 10 as I. recall, it says something to the effect that we want to 11 make sure that the plants are safe.
12 Now, that doesn't mean anything. You have to tell 13 me what safe means.
14 For example, if you want this to be risk-informed, 15 would you like to prevent the occurrence of initiating 16 events?
17 Now, that's something specific, that's something I 18 understand, and that certain contributes to safety.
19 Would you like to make sure that the safety 20 functions have a certain reliability? Again, that's 21' operational.
22 Now, operational -- well, maybe that's an 23 exaggeration, but -- so, the second level, the second tier i
24 would be objectives of this type that elaborate on the top {
a 25 level.
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9 1 Then you might ask yourself, well, what does it 2 mean to assure the safety function, reliability? You go 3 down one further level.
4 Now you become more specific. Maybe you will say 5 I don't want such-and-such an event to happen, and you may 6 have to go down two or three or four levels until you reach 7 a point where you say, well, now, this I can measure, this'I 8 _can track, and then you have this hierarchy construction 9 that shows the rest of us why you selected certain things to 10 monitor and why you left certain other things out.
11 Right now, we have the top objective, and then we 12 jump way down to the six categories, what is called a 13 template, and the connection is not clear. I mean it's not 14 that there is no logic. I'm sure there is some logic 15 someplace, but it's not evident from reading the document 16 why, for example, I have to worry about human error, I mean 17 besides the general feeling that human error is important.
18 So, that was really the idea of requiring that.
19 COMMISSIONER DICUS: Okay. Thank you.
20 MR. BARTON: Also in our March report we made the 21 comment and recommendation regarding that the staff should 22 work-through at least one example that uses the actual 23 inspection reports.and demedstrate the implementation of the 24- new assessment decision logic.
25 We wanted to be sure that the new engineered ANN RILEY & ASSOCIATES, LTD.
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10 1 approach,'taken to an actual case and worked through, would
'2 lead you to the same decision that was arrived without this 3- approach. It was kind of a test of the new approach.
4 CHAIRMAN JACKSON: Now, my understanding is that 5 there has been some piloting of the process since the time 6 you had the discussions with the staff. Do you have any 7 updated coumentary?
8 MR. BARTON: No, we do not, not at this time. We 9- know that they.were going to try that process, but we 10 haven't had feedback as to how well that process worked.
11 We also recommended at that time that the 12 categories in the proposed templates -- the six categories 13 of the template be evaluated and see if they were at the 14 appropriate level'and whether there was any unnecessary 15- overlap.
16 We recommended the assessment process contain 17 provisions to ensure consistent results are obtained among 18 the regions. The new process really drives back to the 19 regions most of the work; decision-making is done at the 20 region level.
21 We wanted to assure that there would be 22 consistency, that in the new process would be enough built 23 into it that we could assure consistency among the regions 24 without having to rely on-headquarters people down at the 25' regions looking for the consistency.
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11 1 The' process itself should have built in reasonable 2 assurance of consistency among the regions. That was a 3 concern we had, and we didn't see how -- weren't sure how 4 that was in the model.
5 CHAIRMAN JACKSON: Commissioner Dicus.
6 COMMISSIONER DICUS: I want to dwell a little bit 7 just briefly on the consistency. issue, because I think it is 8 a problem.
9 Are you talking about consistency of 10 implementation of the process, or is there a greater problem 11 or another problem with regard to the consistency of plant 12 performance from a regional or a national basis?
13 MR. BARTON: We.were concerned with consistency in 14 the process. You know, no process is perfect. That's 15 probably the reason we're changing the. current process, to )
16 improve it, make it more scrutable, more objective.
17 We wanted to ensure that, in designing that new 18 process, that the same performance indicators that you were I
19 measuring in one region, you measured in another region and 20 gave you the same result. That's what we were looking at.
21 We also made a recommendation that the measured --
22 plant performance be measured at a more global level.
23 -We had some discussions with industry at one of
- 24. the Committee meetings, and we felt that the input to the 25 new process that.the staff was proposing was set a real low ANN RILEY & ASSOCIATES, LTD.
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12 l' . compliance enforcement level and saw some opportunity in 2 what the_ industry was proposing as performance indicators 3 that maybe the staff and industry might-get together and 14 raise the performance indicators and the input into the 5 process.
6 .CRAIRMAN JACKSON: Have you had discussions among 7 yourselves about the connectivity between the suggested 8 performance indicators from the industry to the kinds of 9 issues that Dr. Apostolakis raised?
- 10 I mean is there a migratory path? Are those --
11 have you looked at whether those would be the appropriate 12 performance indicators to achieve what he wants? Have you 13 agreed as a committee that you agree with what was in its 14 memo?
15 MR. BARTON: We have discussed this amongst 16 ourselves, and I think there is an agreement that -- based 17 on what Dr. Apostolakis mentioned before and where the 18 industry was coming from, I believe there's agreement in the 19 Committee -- if I'm not right in that, please, any member 20 speak up -- that there should be more attention paid at the 21' higher level.
22 Anybody want to comment on it?
23 DR. APOSTOLAKIS: I don't believe, Chairman 24 Jackson, that, as a Committee, we looked at that specific 25 aspect.of the NEI presentation, but that should be-ANN RILEY & ASSOCIATES, LTD.
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+ 1 relatively easy to check, because it's higher level, higher 2 level requirements.
3 But that is an issue that will keep coming back.
4 Where do you set the performance measures? We had a 5 presentation this morning on the new performance-based 6 initiative. Where do you do that? Do you use risk 7 information? Do you use something else?
8 Because ideally -- not ideally -- you would like 9 them to be as high as possible where the highest level is, 10 of course, the QHOs. Practically, you can't do that.
11 So, where is the optimum so that we will satisfy 12 that third feature, I believe, of performance-based 13 regulation, namely giving flexibility to the licensees. The 14 lower you go, the less flexibility they will have.
15 CHAIRMAN JACKSON: Right. But I'm really actually 16 turning back on you something that you said the staff needs 17 to ensure, and that has to do with consistency.
18 If you're going to talk, on the one hand, about l 19 the need to agree on performance indicators starting with 20 some that may have already been developed by the industry or 21 somewhere else and if you're going to make that 22 recommendation, then there has to be a connectivity between 23 that recommendation at whatever level these performance 24 indicators would come in, with a judgement as to (a) is that 25 the right level, (b) if it is, you know, what the connection
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-1 has to be to what the staff would, quote / unquote, actually 2- measure or look at, because in the end, it doesn't do -- you 3 have recommendations that go like this or like this, but at 4 any rate, you have to ensure that, if you're going to make 5 the recommendations on the one hand, in one area, that they 6 are consistent with the recommendations you make in the 7 other, 8 DR. SEALE: If I may make a comment, it strikes me 9 .that, realistically, what you have to do is to erect this 10 connective tissue between -- or lines between the low level 11- and the high level indicators, and once you've done that, 12 then the kind of gradation that occurs is deciding how you 13 tune to get blips on your radar screen.
14 One of the things you have to have is a scheme or
- 15. a system that gives you data that tells you what's going on 16 in the plant.
17 CHAIRMAN JACKSON: Well, I think that's where we 18 all want to get, obviously, and the issue is that, if you're 19 starting at the -- if you want a hierarchical scheme, right, 20 you have to have the connectivity all the way down.
21 However, what I'm saying is something slightly 22 different. I'm saying that, if you're talking about
- 23. imposing a set of performance indicators, that you've got 24 have a fundamental decision made as to whether they are the
' 25- right performance indicators for regulatory agency.
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1 DR. SEALE: Yes.
g 2 ' CHAIRMAN JACKSON: Okay. And then you're dealing 3 with in the context of this hierarchical or connected 4 . approach.
5 Yes,' Commissioner Diaz.
6 COMMISSIONER DIAZ: If I might build up on that, I 7 think, essentially, what we should be asking, also, is is 8 there a process of convergence between the different 9 opinions and if that convergence is naturally happening or 10 does it need to be a function, you know, that will make it 11 happen?
12 DR. POWERS: It strikes me that you need to be 13 careful not to misinterpret what the Committee was saying 14 when it made its recommendations.
15 It was saying that we feel there should be a 16 hierarchical structure, and in that hierarchical structure, 17 you will arrive at high-level performance indicators, higher 18 . level than perhaps what the staff is proposing, like what 19 the industry was saying.
20 We did not espouse the industry's indicators per 21 se but, rather, suggested that, when they created this 22 structure, they would encounter these higher level.and those 23 might be better to use than the lower-level indicators.
24 I don't think the Committee was saying adopt these 25 that the industry has proposed.
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16 1 DR. SEALE: 190, we did not come to that 2 ' conclusion.
3 DR. POWERS: Rather, these industry proposed 4 indicators looked to be higher'and you will arrive at them 5 in the course of your hierarchy.
6 CHAIRMAN JACKSON: But I would also argue that, 7 from an implementation point'of view, you've got to ask who 8- uses what when, and I assume this is implicit in what Dr.
9 Apostolakis is talking about, because you can talk about 10 having your higher-level indicators, but the issue is who's 11 making use of them and to what end?
12 Are they being used as a consistency check? Are 13 they being used in decision-making? Are they best used at a 14 very high senior management l'evel? That may be different
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15 than what the guy does in the field, and so, we have to be 16 very clear in that.
17 DR. POWERS: In a moment or two, Mr. Barton, we'll 18 get to the issue of requirements -- agency requirements for 19' the assessment process, and that will come up in spades.
20 CHAIRMAN JACKSON: All right. Well, then I better 21 let Mr. Barton proceed, then.
22 DR. APOSTOLAKIS: A forcing function in the form 23 of a delta function will be very welcome, by the way.
24 CHAIRMAN JACKSON: A delta function -- a forcing 25 function to you or a forcing function to the staff? Let's ANN RILEY & ASSOCIATES, LTD.
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C' 17 1 be clear on who we're forcing to do what.
2 COMMISSIONER DIAZ: If I may amend the record, the 3 Chairman who uses what when, also for what, and that goes 4 back to your performance measures.
5 DR. KRESS: That would call for different sets of 6 performance measures, one for the inspector and_another one 7 for the senior management and even a different one for you 8 guys.
9 CHAIRMAN JACKSON: Let Mr. Barton continue.
10 MR. BARTON: Dana, in our September report -- I 11 mentioned earlier -- this was a comment that we had made.
12 We had noted that we had not -- staff had not yet defined 13 the requirements for the program to assess licensee 14 performance. Would you like to expand on that? It was also 15 'in our September report.
16 DR. POWERS: Staff is now attempting to develop an 17 integrated assessment program, and what we saw was what I 18 would characterize as an assumed solution to that 1
19 assessment, to integrate together assessment that currently 1 20 takes place in three different areas into a single 21 assessment.
22 I call it assumed, because there did not appear to 23 us to have been an attempt to define what the agency needs 24 for-its own purposes as an assessment of plant performance, 25 what are the requirements that you had.
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1 Then, once you had those requirements, one could 2 presumably define a number of strategies for obtaining those
.3 assessments and compare them on'the basis of some ranking 4 system, some preferred alternatives, preferences that you
.5 had, how you would compare various strategies, all of which 6 . met the requirements the agency had but some of which may'be 7 preferred because they're less costly, less 8 manpower-intensive, more transparent to the public.
9 We had not seen that kind of structure in 10 developing this integrated assessment and found it very 11 difficult, then, to look at this integrated assessment and 12 say does it, in fact, meet all the agency needs,'as you 13 said, from the front line inspector, the eyes and the ears 14 of the agencies at the plant itself, to the top level 15 sitting at this table.
16 You need to have an assessment that meets all 17 those needs. It's difficult to judge if we don't know what 18' all those needs are.
19 COMMISSIONER McGAFFIGAN: My concern comes at it 20 from a slightly different direction.
21 The staff is going to talk to us -- I don't want 22 to spend a lot of time on this, but they're going to talk to 23 us in an hour-and-a-half about this stuff, and they have a 24- slide _of boundary conditions, which boundary conditions are 25 sort of like requirements,_and I'm not sure I agree with all ANN RILEY & ASSOCIATES, LTD.
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19 1 of them. I probably don't. And I've heard additional 2 requirements coming from you all this morning that aren't 3 among their boundary conditions, that this should be 4 risk-informed. That's not something that they're aspiring 5 to at the moment. They do aspire to line up better with 6 enforcement, which I'm hearing some criticism of and I have 7 concerns.
8 But I think there's a real danger in 9 over-constraining this problem so that there is zero 10 solutions. In fact, it may already been well past that 11 point, and when you try to design a single process to meet, 12 you know, a multiplicity of requirements and the 13 requirements keep growing, you know, if we aren't at the 14 point where there's zero solution, we'll certainly get there 15 rapidly.
16 DR. POWERS: The one thing you have to have in any 17 kind of design-making is to have an agreed-upon set of 18 requirements, and I forgot to say agreed.
19 COMMISSIONER McGAFFIGAN: Agreed-upon, right.
20 DR. POWERS: That's an essential step, and it is 21 not beyond the bounds of credulity to say that I can create 22 enough requirements that there is no solution, and then you 23 have to have an agreement upon reduction.in those 24 requirements.
25 I think it is better to do that, to follow that ANN RILEY & ASSOCIATES, LTD.
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, 20 1- tact, than to have a set of requirements created after you 2 have assumed the solution, and I think that's all we were 3 trying to communicate.
4 COMMISSIONER McGAFFIGAN: You think the staff has 5 this rock, as some people call it, and has the following 6 characteristics which they then say are the boundary 7 conditions for the rock.
8 DR. POWERS: I think there is a strong component 9 of that. I think that they, indeed, did see criticism of 10 having three or four, depending on how you count them, 11 different approaches to doing plant assessments, and they 12 said my requirement for this is to have one, and they took i 13 that.
14 CHAIRMAN JACKSON: I'm not here to be the defender 15 of the staff, but in fact, I think we all have to take 16 ownership, because I think, in fact, the staff was trying to 17 be responsive to what it thought it was hearing from the 18 Commission.
19 DR. POWERS: I have no doubt.
20 CHAIRMAN JACKSON: So, that defined at least part 21 of the rock.
22 DR. POWERS: I have no doubt that's true. You 23 have an excellent staff that's very responsive, and in this 24 particular case, you have a particularly ambitious fellow 25 leading this product that's anxious to produce a product ANN RILEY & ASSOCIATES, LTD.
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.. j 21 1 that everybody likes.
2 I mean he really is trying very hard, and we're 3 simply trying to hone his strategy a little bit here in our 4 comments.
5 COMMISSIONER McGAFFIGAN: He may have produced i
6 something that nobody likes. I 7 DR. POWERS: And he won't be the first.
8 COMMISSIONER McGAFFIGAN: Right.
9 CHAIRMAN JACKSON: Well, the real question I 10 really have in terms of an over-arching way, since I think 11 this is the last view-graph on this subject -- it's a 12 question but embodied in it is a comment, and that is how 13 much did you treat this as a work in progress and an 14 opportunity to help shape where it's going as opposed to 15 assuming that it is the product that needs to be accepted or o
16 rejected?
17 DR. POWERS: I' think we recognized exactly that it 18 was very much a work in progress. That's how it was 19 presented to us, if I can characterize it.
20 DR. FONTANA: Yes.
21 MR. BARTON: Yes. And tried to help the staff 22 develop the process as they went along.
i 23 COMMISSIONER McGAFFIGAN: Can I ask one other 24 question? One item you slipped over on the previous 25 view-graph was perform additional research prior to use of ANN RILEY & ASSOCIATES, LTD.
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T-I 22 1 economic indicators. I don't know whether that is a kind )
2 way of putting this off to the third millennium or later.
3 Is there any prospect that we're going to be able 4 to come up with something that's useful in economic (
5 indicators if we throw research dollars at it, or is that 6 something.that'we should just --
7 MR. BARTON: I'm not sure we were talking about 8 throwing a lot of research dollars at it. I think we were 9 coming at it from the perspective of can you really gain --
10 what can you really gain from some of the economic 11 indicators?
12 There's changes in how plants spend money that go 13 on for years before you see some performance-changes.
14 So, I think what we're really saying is be careful 15 how you use economic indicators. It may be a data point, 16 but we're not sure at this point that it should be a 17 decision point. I think that's where we are on the economic )
18 indicators.
19 DR. SEALE: But it's certainly an input to the j 20 product, and so, you should keep track of the economic 21 activity supporting the plant.
22 CHAIRMAN JACKSON: That's interesting. I mean the 23~ comments that the two of you have made actually have raised 24 a point of another clarification that perhaps needs to be in
- 25. .the process and that is making distinctions between what is ANN RILEY & ASSOCIATES, LTD Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
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23 1 input and knowing how that input is to be used versus the 2 decision point.
3 DR. SEALE: Yes.
4 CHAIRMAN JACKSON: Okay.
5 DR. SEALE: Well, you're back in the barrel again, 6 John, along with Tom on proposed revision to 50.59.
7 CHAIRMAN JACKSON: Proposed.
8 DR. SEALE: Proposed. We try to be careful with I
9 some of these words.
10 CHAIRMAN JACKSON: Okay.
11 MR. BARTON: Again, just some background.
j' 12 We provided the reports in April, October, and 13 December on the proposed 50.59 process change.
14 The first slide, which is the April report -- I l 15 won't go a lot into that. That's kind of -- it's history.
16 We proposed something and it went out for public comment.
17 So, skipping ahead till our October report, we i
18 proposed that the NRC should issue revision 1 to Generic 19 Letter 91-18. We felt that it did clarify the applicability 20 of 50.59 evaluations to address the degraded and 21 non-conforming conditions. Also, it addressed completeness j 22 and some inconsistency. l l
23 Also in that report, we recommended that there be l l
24 work continued to continue to develop the plan for a 50.59 25 process that's consistent with the risk-informed j l!
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O 24 1 performance-based regulation.
2 This is where Dr. Kress was driving-the Committee 3 to focus on the risk-informed piece of the regulation.
4 Tom, would you like to expand on that?
5 DR. KRESS: Certainly.
-6 I guess it would be easier to tell you what we 7 .didn't mean by that bullet rather than what we did mean.
8 We did not mean that the 50.59 process ought to be
- 9. done by means of a PRA looking at delta-CDF and delta-LERF 10 like the Reg. Guide 1.174, and in fact, we don't think 11 that's even possible.
12 The consistency part meant that any changes that 13 are proposed that have a direction of risk increase, even 14 though it's small or minimal, should not be inconsistent 15 with the values that are in here. They should be very 16 small.
17 CHAIRMAN JACKSON: But to the extent that there 18 could be a direct comparison or could be cast --
19 DR. KRESS: If they could be.
20 Now, the other part of this is we take those 21 levels of risk change or outside the purview of PRA, that 22 PRA is just not good enough to quantify at those levels, so 23 that the challenge is going to be, for the staff, to 24 quantify both this word " minimal" or "small," as well as to 25 develop ways at which one could -- criteria or attributes ANN RILEY & ASSOCIATES, LTD.
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25
.1 that one could use for a licensee to be guided on what 2 qualifies for that kind of change.
3 Now, that's going to be a real challenge, and my 4 personal view is that you don't set up a set of criteria l l
5 that says, if the change meets these criteria, that it 6 qualifies. I think that's almost an infinite set.
7 I think what you do is set up criteria that, if 8 the change meets these things, then it does not qualify, and 9 clearly, one of these would be, .if it's a decrease in risk, 10 it automatically qualifies.
11 But some of the other things for increases in risk 12- are going to be much more difficult to come by, and they are 13 performance in nature because we have already said you can't 14 -quantify them with a PRA,- so you have to use intuition, 15 judgement, and I think there would be things like do they 16 impact defense-in-depth, is the change on some system or 17 component that's safety-important or safety-related.
18 I don't claim to know what these rules ought to 19 be, but I think that's where the challenge lies, and that's, 20 I think, how you make it risk-informed and consistent. That 21 was the intent of that bullet.
22 CHAIRMAN JACKSON: Can you look at it in terms of 23 -how it might affect design basis or FSAR accident frequency?
24 DR. KRESS: Yes, I think that would be one of the 25 criteria, ifLit affects the design basis.
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26 1- ' Another one would be, if you can -- if it's 2 obvious that you can use a PRA to quantify the change in 3 risk, then I don't think it's 50.59. I think that 4- automatically puts it in 1.174.
5 COMMISSIONER McGAFFIGAN: Can I ask a question?
6 CHAIRMAN JACKSON: Please.
7 COMMISSIONER McGAFFIGAN: The staff has shown you 8 a view-graph that isn't quite the one that's in Reg. Guide 9 1.174 at the moment.where 10 to the minus 7 core damage 10 frequency is described as negligible in terms of ,
11 risk-informed regulations, and presumably, things are going 12 to get handled very rapidly if somebody can convince the 13 staff that they're in that range, and there was at one point 14 a claim that 10 to the minus 7 was the limit of resolution 15 of PRA technology, and then that was clarified to say no, 16 there are lower levels of resolution that you all can deal 17 with, as low as 10 to the 10th, 10 minus 10, 10 minus 12.
18 DR. KRESS: I think the Committee disagrees.
19 COMMISSIONER McGAFFIGAN: Disagrees with that.
20 Okay.
21 That gets us maybe back to where we originally 22 were. If it's 10 to the minus 7 or below in core damage 23 frequency, is that a -- I know you're going to talk about 24 severe accident space versus design basis accident space, 25 but if it's that level, should-it be a 50.59 issue or should ANN RILEY & ASSOCIATES, LTD.
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, 27 1 it be an issue that comes to the Commission staff for review s 2 and approval?
3 DR. KRESS: I think the feeling of the Committee I o \
4 was we're not quite certain yet what that level ought to be, I l
5 ,because we're talking about cumulative risk over -- there 6 may be hundreds or even thousands at a given plant.
, j 7 , COMMISSIONER McGAFFIGAN: Right.
8 DR. KRESS: So, we're not quite sure that 10 to 9 the minus 7 is the correct level, but assuming there is some 10 level down there that's about there or even lower, we just 11 do not think that there is a good way to quantify that, and 12 you'll have to come up with a set of rules that you feel 13 qualifies a change to be in that level even though you can't 14 quantify it, and that's going to be a real challenge.
15 That's where we think the challenge is going to be.
16 CHAIRMAN JACKSON: But don't you think a point
.17 - that one has to keep in mind -- and that's the difference 18 between the intended use of the reg guide and the Standard 19 Review Plan, is that, in fact, the kinds of changes -- let's 20 leave aside the issue of whether you can put the kinds of 2 .' changes to the plant that would occur under 50.59 into this 22 space, but those lavels are determined within a context 23 that, by definition, the staff is going to be reviewing 24 those, whereas 50.59 is meant to be a screening rule that 25 relates to screening in terms of things that can happen ANN RILEY & ASSOCIATES, LTD.
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s 28 1 without coming to the staff, coming to NRC, so that one has 2 to keep in mind, if you're talking about numbers, that the 3 one has a set of numbers that's being used together with 4 other things but being used in the context of changes to the 5 licensing basis that, by definition, are being reviewed by 6 the staff.
7 The other is a screening set of criteria, and 8 that's a very different kind of thing.
9 DR. KRESS: Yes, I think that captures the essence 10 of it.
11 CHAIRMAN JACKSON: Let me just follow on for a 12 minute. If one wanted to do to risk-informed -- and I think 13 that's what you're really talking about, as opposed to 14 having performance-based per se approaches -- is it possible 15 to do something within design basis accident space, where 16 one can talk about a comparable kind of thing, like design 17 basis accident, frequency of probability in a quantifiable 18 way.
19 DR. KRESS: We have not discussed that, but I 20 pr anally don't think so. In fact, I don't think there is 21 a good connection now between risk and design basis space.
22 There is a connection. I don't think we have it well 23 ' quantified or well thought out.
24 CHAIRMAN JACKSON: Well, let's talk about it for a 25 second, because I'm trying to understand something. Isn't ANN RILEY & ASSOCIATES, LTD.
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- 1 what you would call a design basis accident something that, 2 at least for certain things, really what would be an 3 initiator in a PRA calculation?
I 4 DR. KRESS: Yes. It's generally an initiator, and 5 then there's stylized --
6 CHAIRMAN JACKSON: -- stylized sequences that 7 would lead to having you determine whether Part 100 limits 8 would be exceeded, right?
9 DR. KRESS: Yes.
10 CHAIRMAN JACKSON: So, is there a possibility of 11 starting with a design basis accident, as laid out within --
12 DR. KRESS: Well, certainly, because those were 13 selected --
14 CHAIRMAN JACKSON: Right. And then taking those 15 and going through -- is it possible to arrive at, going 16 through a sequence of things that could lead you to exceed i 17 Part 100, if you then were able to assign the same kinds of i 18 probabilities --
l 19 DR. KRESS: You certainly could do it that way --
20 CHAIRMAN JACKSON: -- and then arrive at some 21 probability of exceeding Part 100?
22 DR. KRESS: I think you could certainly do it that 23 way. I would not recommend that.
24 CHAIRMAN JACKSON: Okay.
25 DR. KRESS: Because I don't think that's true in ANN RILEY & ASSOCIATES, LTD.
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30 1 risk-informed.
2 CHAIRMAN JACKSON: Purity of risk-informed means 3 tied to severe accident analyses, but rick-informed, in many 4 people's mind, has come to mean tied to severe accident 5 consequences.
6 One could argue that you could hav'e a 7 risk-informed process that examines the probioilities of 8 some other consequence, of coming to some other consequence.
9 DR. KRESS: Oh, certainly.
10 CHAIRMAN JACKSON: And in that sense, I disagree 11 with your statement that you can risk-inform an analysis to 12 a different consequence.
13 DR. FONTANA: I can understand what you're saying.
14 I think, in the best of all worlds, there would be 15 a seamless spectrum from a severe accident all the way down 4 16 to --
17 CHAIRMAN JACKSON: Absolutely.
18 DR. FONTANA: -- and design basis would be a set 19 in those accidents. So, one ought to be able to do a risk 20 analysis with the lowest spectrum of accidents.
21 CHAIRMAN JACKSON: Right. j 22 DR. FONTANA: We're not there yet.
I 23 CHAIRMAN JACKSON: Well, all I'm saying is that my j 24 understanding is that, essentially, what you would call a 25 design basis accident, in many ways, is an initiator when l
1 I
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e 31 1 you do your typical PRA calculation, and so, you could have 2 a way, it strikes me, if it is an initiator, to put it into 1
3 the kind of methodology that 1.174 envisions, and you come 4 out with an answer, which in that case would be expressed in 5 terms of something like a core damage frequency or large 6 early release frequency, and that's one part of a screen if 7 there were some level set.
8 DR. KRESS: You could certainly put that on the 9 initiating frequency itself.
10 CHAIRMAN JACKSON: Right, exactly.
11 DR. KRESS: But once again, you're going to have a 12 great deal of difficult quantifying these types of changes 13 that will propagate through and end up at 10 to the minus 14 8-like levels.
15 CHAIRMAN JACKSON: All I'm trying to say is --
16 DR. KRESS: There certainly would be a way to do 17 it.
18 CHAIRMAN JACKSON: There are two pieces, because I 19 said that's one part of a screen. Okay? The other part of 20 a screen may be one that's rooted in, you know, the 21 defense-in-depth concepts, etcetera.
22 DR. SEALE: Yes.
23 DR. KRESS: Yes.
24 CHAIRMAN JACKSON: And so, since we're talking 25 ' screens, we're talking gates.
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32 1 DR. KRESS: yes.
2 CHAIRMAN JACKSON: Okay. And so, maybe you have 3 an "and" gate that you have "and, and," that'you have a 4 screen or a gate that's related to your defense-in-depth 5' pieces but you also do a consistency check.
6 DR. KRESS: That is, in fact, what I meant by 7 these sets of rules.
8 CHAIRMAN JACKSON: Right.
9 DR. KRESS: They would be that sort of "and" gate.
10 CHAIRMAN JACKSON: Commissioner McGaffigan.
11 COMMISSIONER McGAFFIGAN: My understanding was --
12 and you can correct me, because I haven't. looked at the 13 documents, but I thought the staff, in the follow-on reg 14 guides for in-service testing, in-service inspection, 15 etcetera -- that they were struggling with exactly these 16 issues, because some of -- they're going to be looking at 17 license amendments in the context of design basis 18 evaluations.and yet have to make risk-informed judgements.
19 So, I hope they're ahead of us in this discussion, 20 but you all probably have looked at these later reg guides, 21 and how are they doing in the more issue-specific reg guides 22 in trying to make this translation from severe accident 23 space to design basis accident space and back?
24 DR. SEALE: Of course, they're change tech specs, 25 so there's no doubt they have to go through a 1.174.
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a 4
33 1- CHAIRMAN JACKSON: I think his point 1--
2 DR. SEALE: I agree.
3- CHAIRMAN JACKSON: --
that you're talking about 4' changes the things that fall within design basis.
5 DR. SEALE: That's an interesting template, if you 6 will,.or connection.
-7 COMMISSIONER McGAFFIGAN: We just know they're 8 struggling. I don't know whether they're succeeding, but I 97 know that they're working on it.
10 CHAIRMAN JACKSON: Is there struggling, Gary?
11 MR. HOLOHAN: Gary Holohan, Staff.
12 I'd like to think the staff is succeeding.
13 CHAIRMAN JACKSON: Thank you so much.
14 All right. Let's go on.
c.
15 MR. BARTON: The other recommendations in our 16 December report have been overcome by events. You've issued 17- directicas to the staff, and essentially we agree. ,
1 18 CHAIRMAN JACKSON: Well, in fact, I think the
, 19 direction agrees with -- I mean it resolves essentially all 20 of the kinds of issues --
21 MR. BARTON: Yes, it does.
22 CHAIRMAN-JACKSON: -- that you had raised.
23 MR. BARTON: Yes.
=24 DR. SEALE: Okay. Are we through with that one
. 25 now?-
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34-I 1 MR. BARTON: Yes.
2 DR. SEALE: Okay. Fine.
.3 The next'one is on, risk-informed performance-based 4 regulation, including use of PRA in the regulatory 5 decision-making process, and if this sounds like deja vu all 6 over again, it's because it is.
7 George?
8 DR. APOSTOLAKIS: Thank you, Bob.
9 The first slide is just some of the activities of
-10 the Committee the last several months, so we can skip that.
-11 The next one, on ISI, we are, in fact, meeting 12 with the staff tomorrow morning to discuss the new version 13 of the guide, so I don't have anything to say right now.
14 What we said last July still stands, but I think, in the 15 next few weeks, you will see a letter from us on this guide.
16 The next one is the major recommendations that'the 17 Committee made on Regulatory Guide 1.174 and associated 18 Standard Review Plan. Obviously, we agree with what the 19 staff did there. We think they are succeeding. There's no 20 reason to read what's here.
21 We have a figure later which will give me an 22 opportunity to talk about some of these things.
23 Now, the other guides on IST, GQA, and technical' 24 specifications.-- we also recommended that they be approved.
25; We were not too excited by.the GQA guide, 1.176, ANN RILEY & ASSOCIATES, LTD.
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35 1- as.you'probably have guessed already from the. letter.
2~ We-felt that this version of a guide was a 3 significant improvement over the first one that we had seen, 14 - which I believe we had called timid, but still, it doesn't 5 go far enough, even if one accepts the fact, which is true, 6 that the lack.of a model for assessing the quantitative 7 impact of QA requirements is really a major problem here.
8 CHAIRMAN JACKSON: Does that imply that you think
.9 we have a difficulty or no way of assessing the benefits of 10 our QA program, period?
11 DR. APOSTOLAKIS: I think the benefits of the'QA 12 requirements are grossly exaggerated.
13 CHAIRMAN JACKSON: This is a Committee point of 14 view?
15 MR. BARTON: There are some members that agree 16 with Dr. Apostolakis.
17 CHAIRMAN JACKSON: Let's take a poll.
18 DR. KRESS: I agree.
19 CHAIRMAN JACKSON: Do you agree?
20 DR. SEALE: I think so.
21 CHAIRMAN JACKSON: Do you agree?
22 DR. POWERS: I think we have to be very careful
.23 about saying we have no way of assessing the benefits of our 24" QA program'~ period.
, I think we definitely do have ways of 2
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36 l 1 -benefits grossly exaggerated? In the minds of whom?
2- What I think the.more pertinent issue here is, do 3 we have a way to quantitatively describe those benefits and 4 to translate them into a reduction in risk? We do not now, 5 and so, when you ask us to do a risk-informed gradation of 6 QA, we quickly get very handicapped.
7 What we can do is a risk-informed grada. ion of 8 systems and components and structures in this system, and 9 then we can assert that surely there must be some gradation 10 in the QA. associated with them accordingly.
11 The problem is how do you judge that?
12 CHAIRMAN JACKSON: So, it has to do with 13 quantitative modeling.
14 DR. POWERS: It's the quantitative modeling here. ,
15 I don't think we ought to get into the subjective and 16 cometimes pejorative statements concerning the QA and QC L 17 programs that exist.
18 There's no question that there's a benefit, and 19 there's no question in people's mind that, even without 20 quantification, for those items that deal with very i 21 risk-significant systems, I think everyone, licensee and 22 regulator alike, would just as soon err on the conservative 23 side to assure we have QA.
24 It is in the lower regions that I think that we i 25' worry that too much work is expended, too much work and cost p
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37 1 is expended on assuring the QA of particularly procurement 2 on items that are probably adequately reliable off the shelf 3 rather than having a QA back to the mine in which the metal 4 came from.
5 Our concern as a Committee, a Committee position, 6 has been the first steps here were timid, that it was 7 possible to take bolder steps.
8 Our view on the current version of this is a 9 bolder step has been taken, and we understand the 10 inhibitions to going yet farther, and that's why we caveat 11 our endorsement of this by suggesting it be revisited both 12 after experience and additional research.
13 CHAIRMAN JACKSON: Okay.
14 DR. POWERS: I think there's room for more here.
15 COMMISSIONER DIAZ: If I try to extrapolate from 16 what you said, will it be fair to say that a graded QA focus 17 resources on a matter that there are safety.
18 DR. POWERS: That's right.
19 Now, a licensee might well find it in his own 20 interest to grade his QA on reliability and economic impact 21 and loss of time and things like that, but as a regulatory 22 institution, we would want to focus on safety, 23 CHAIRMAN JACKSON: But nonetheless, you're saying 24 that, in the graded QA area, that the reg guides and the 25 associated SRP sections ought to be issued for use because ANN RILEY & ASSOCIATES, LTD.
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38 1 you think that out of that will come --
2 DR. POWERS: We think that experience and comfort 3 -- and in fact, if one looks at this whole business of the 4 quantification of risk since 1974 -- I think that was when 5 it first became very apparent to the community at large --
6 you find that there is a substantial component of becoming 7 comfortable, to see that it does not immediately result.in 8 the madmen running wild on the plants, that in fact this is 9 not a license to kill, it's a license to focus, and so, it 10 takes some comfort, especially as you move in these 11 non-traditional areas.
12 My own experience within the application of PRA 13 within the Department of Energy was that, before it became 14 at all tolerable to people in maintenance, the PRA people 15 had to learn to speak maintenance-ese instead of PRA-ese, 16 and I think that's -- the graded QA may be a classic example 17 of where we need to develop that language out of the 18 quantification of PRA that the QA/QC professionals in the 19 organization can understand in their context, and then we 20 can take these bolder steps with comfort and assurance.
21 CHAIRMAN JACKSON: Okay.
22 DR. FONTANA: I take it we don't have to answer.
23 CHAIRMAN JACKSON: I'm letting you off the hook, 24 let the record show.
25 DR.-APOSTOLAKIS: Well, when I say they were ANN RILEY & ASSOCIATES, LTD.
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39
+
1 grossly exaggerated, I didn't mean that -- we have to be 2 precise here. I'm not saying that we should throw out of 3 the window all the requirements.
4 What has been grossly exaggerated is the 5 significance of the difference between the current 6 requirements and some form of relaxation.
7 CHAIRMAN JACKSON: I think we understood that.
8 DR. APOSTOLAKIS: Okay.
9 CHAIRMAN JACKSON: And to the extent that your 10 recommendation relates to that, then that's the point you 11 want to make to us. Is that correct?
12 DR. A?OSTOLAKIS: Yes.
13 CHAIRMAN JACKSON: I think you should go on.
14 DR. APOSTOLAKIS: Risk-informed regulation -- this 15 was an attempt to -- which I thought was successful -- to 16 show that PRA -- that this is an evolutionary process. We 17 are not about to drop defense-in-depth and safety margins.
18 We do want to proceed in a cautious way. Therefore, changes 19 should be small, and of course, they should be monitored 20 using some strategy.
21 So, I think these five principles -- the 22 formulation of these principles was a significant step 23 forward.
-24 The next slide shows one of the figures -- one
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4 40 1 think I should make a few comments here.
2 First of all, the lines between Region I and the 3 other regions should not have been so bright, but I think 4 it's a problem of software. It should have been a smoother 5 transition to send a message that there are uncertainties in 6 PRA, there are imprecisions.
7 We are not going to maKe a decision based on 8 whether a number is 10 to the minus 5 or 1.1 10 to the minus 9 5. So, the transition should have been smoother.
10 I think the text makes it very clear, but I think 11 it's worth mentioning that.
12 Second, the issue of -- well, it doesn't show very 13 well there, but as you see in the actual figures in the 14 guide, we have this shade of gray that becomes darker and 15 darker as we approach areas that we don't like, and it's 16 explained in the footnote that this means we'll pay more 17 attention, we'll scrutinize what you're doing more, and I 18 think that's very important because recognizing explicitly 19 again that there are some issues with PRA, but we are aware 20 of them, we're willing to spend the appropriate time to 21 understand what you're proposing if you are in that region.
~
22 So, I think that there is an adequate message 23 that's being sent by these two figures, and of course, the 24 text elaborates on these.
25 Sometimes, you know, trying, again, to be as ANN RILEY & ASSOCIATES, LTD.
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41 1 complete as we can, maybe we turn people off, because 2 somebody who does not intend to do a complete PRA picks it 3 up and sees all this discussion on model uncertainty and 4 parameter uncertainty and say, my God, I can't do this. But 5 again, it's trying to satisfy many requirements in one 6 document.
7 But I think it was the right thing to do.
8 CHAIRMAN JACKSON: Yes, Commissioner McGaf#igan.
9 COMMISSIONER McGAFFIGAN: When you all saw this 10 view-graph last fall, it had that 10 to the minus 7 and 11 negligible category in it. Should it have been retained?
12 It basically had one ore -- it had Region IV, I guess.
13 DR. APOSTOLAKIS: I don't remember that.
14 COMMISSIONER McGAFFIGAN: You don't remember that.
15 DR. APOSTOLAKIS: I remember that Region III was 16 not going to the right as far as it goes now. No , Region 17 III did not exist at all. That's why I'm confused.
18 COMMISSIONER McGAFFIGAN: Region III didn't exist?
19 I have seen a view-graph where there is a 10 to the minus 7 1 20 and below -- it would imply that the degree of review would 21 be quite modest for things down in that category, and I was 22 wondering whether you had any views on retaining that 23 category or not.
24 DR. APOSTOLAKIS: My personal view is that it 25 would not really serve any purpose to add it there, but ANN RILEY & ASSOCIATES, LTD.
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'l 'that's personal'.- The Committee hasn't discussed this.
2 COMMISSIONER McGAFFIGAN: You talked about the 3 - words, you'think, make up~for the fact that the lines look C4' sort of bright on the view-graph. I'm not absolutely
- 5. convinced of that. I think proof 1will be when somebody r
6^ comes in at the margins of one of these' bright lines and 7; asks something where no changes are allowed.
8 If I'm not .9 times 10 to the minus 5 today and'I 9 propose something that's going to be 1.1 times 10 to the 10 minus 5 and, therefore, is in the region where no changes 11 are allowed, then I'd still be a 2, which is a factor of 5 12 better than this goal that we don't have of 10 to the minus 13 4. Should I not be considered at that point, or should I be 14 considered?
15 I take your remarks to mean that maybe I should 16- get considered even though -- if there's a good reason for 17 it. If I'm going to save large amounts of money and I'm 18 still well within any regulatory requirement, maybe I should 19 be considered.
1 20 I'm r_ct sure the words in the reg guide reflect 21 that, but you all are saying put it out and let's get some
-22 practice and maybe we'll get some hard cases at that point.
- 23. DR. POWERS: I definitely think practice is 24 essential here, but you raised the question of review,-how
-25 much-review is required, a very minimal-amount of review.
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4 43 1 I think we ought not forget there is a big tough 2 nut to crack when.you come into this risk-informed 3 regulation, and that is the review on your PRA that you're 4 basing this on.
5 That is a non-trivial review that tne staff is 6 going to have to undertake, and it's compounded by the fact 7 that, in many cases, the total quantification of risk is 8 going to involve some estimations.
9 Those estimations become more pandemic once you go
'10 to any kind of WARF number. This is a non-trivial burden 11 for a licensee to approach even if he's coming in with one 12 of his 10 to the minus 7th sort of things.
13 Now, I think he gets over that once -- once he's 14 done one, it becomes a lot easier after that, because 15 staff's not going to go back to ground zero on every review 16 for every licensee, I'm sure, but there is a tough issue we 17 face here for -- in thinking about where your resources --
18 your manpower resources are going to go in regards to this 19 risk-based regulation.
20 You've got a front-end cost on this that's 21 non-trivial, and I assure you, the licensees are concerned 22 about_that cost. They are not interested in getting 23 involved in something where they will, to quote them, be run l 24 ragged chasing thousands of our requests for additional 25 'information.
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44 1- They need some confidence and some standardization 2 here to approach -- whenever we get to talk about fire 3 protection, we'll get into that iscue more realistically, 4 because it is a barrier there.
5 DR. SEALE: I would add, I think Ohe prompt 6 -attention to Reg. Guide 1.174-type requests and pilot 7 ~ studies and so forth is probably the single most important 8 aspect of encouraging licensees to be responsive to.tne 9 offer of risk-informed regulation.
10 DR. APOSTOLAKIS: Okay.
11 The next topic is the. report we sent in December 12 on uncertainties versus point values, and again, this 13 summarizes the recommendations.
14 I would like to say a few words about the first 15 bullet, which sounds like a trivial thought, you know, to 16 what degrees are confidence of the PRA results and insights 17 will improve on the existing regulatory system.
18 I submit to you that is a question that is never 19 asked. The question that is always asked is, is PRA perfect 20 to be applied to this new area and not whether PRA can
-21 contribute to doing things better.
22 So, we. thought it was important to put that there 23- even though it doesn't really relate to uncertainties and 24 . point-values.
'25 COMMISSIONER DIAZ: What is the answer to the ANN RILEY~& ASSOCIATES, LTD.
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45 1 question?
2 DR. APOSTOLAKIS: What question?
3 CHAIRMAN JACKSON: The question posed here.
4 DR. APOSTOLAKIS: It's situation-specific. We had 5 the presentation of higher perfection the other day, and the 6 discussion was all on the limitations of higher PRA. Nobody 7 told me anything about the limitations of the existing 8 regulations regarding fires.
9 I would like to see two columns. The existing 10 regulation has these problems and it does certain things 11 well. PRA has these problems, but it also does certain 12 things well, and when you put the two together, you have a 13 better system.
14 CHAIRMAN JACKSON: I think that I would warn 15 against statements that go too far to the pejorative, 16 because I think, in fact, the kinds of questions the 17 Commission was asking in the fire protection briefing, in 18 fact, were exploring just that issue in terms of what the 19 limitations are of the current situation vice where we might 20 go in a risk-informed approach, and the Commission has not 21 made a decision on that yet, and so, I think we should leave 22 it at that.
23 DR. APOSTOLAKIS:
)
I was not referring to that.
24 DR. SEALE: We get the language from other places, l 25 as well. 1 I'
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46 1 DR. APOSTOLAKIS: It was a theme.that was coming 2 back when we were discussing the regulatory guides and so 3- on. It was always how good is PRA, PRA doesn't do this, PRA 4 doesn't do that, and what we're saying here that's only one 5 part of the question.
6 CRAIRMAN JACKSON: I think what you're doing is --
7 I think we're moving down this track, so let's keep moving 8 down the track.
9 DR. APOSTOLAKIS: Now, plant-specific application 10 of safety goals -- Dr. Kress will say a few words about 11 that.
12 CHAIRMAN JACKSON: Slide 23.
13 DR. APO3TOLAKIS: Twenty-three.
14 DR. KRESS: The question arose, of course, because 15 the safety goal policy statement specifically says not to do 16 this, and then we come up against what's here called 17 DG-1061, which is now Reg. Guide 1.174, which goes right 18 ahead and does that in the context of requests for changes 19 to licensing basis, and it came to us as a question as to 20 whether that was appropriate or not, and we came down on the 21 side that it certainly was; in fact, there was no other way 22 to do 1.174.
23 Then the question broadened itself to the whole 24 subject of risk-informed regulations in general, not just in 25 the context of changes to the licensing basis, and it was
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47 1 our feeling that, in order to have a coherent system like 2 that, you have to do it on a plant-specific basis, and that 3 if you're going to use the safety goals as your top-level 4 criteria, that they have to be applied on a plant-specific 5 basis. It was just apparent to us. So, there was nothing 6 very deep there.
7 The question then got down to the surrogates, the 8 LERF and the CDF, to the QHOs, and is it possible to use 9 those on a plant-specific basis when the OHOs actually 10 involve site characteristics and population and so forth, 11 and our final conclusion was, yes, there's not that much 12 variability in the effects of the site, that you can 13 actually use those and they will focus your attention on the 14 things that we can best deal with in a regulatory agency, 15 and that's the meaning of the other two bullets.
16 CHAIRMAN JACKSON: Okay.
17 DR. KRESS: We also did note on this last bullet 18 that there probably ought to be more attention to developing 19 -- if we revisit the safety goal policy statement, there 20 ought to be more attention given to developing a societal 21 risk measure, because the ones we have now intend to do 22 that, but in practice, they focus on individual risk, and we 23 felt one risk -- societal risk was total early fatalities as 24 opposed to individual, was a rather robust one.
25 It's not the only one. One should think about ANN RILEY & ASSOCIATES,'LTD.
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'48 1 . land interdiction and other things, but we think that would-2 be a' good listing to-the safety goals if, indeed, they are 3 revisited.
4- CHAIRMAN JACKSON: Okay.
5 DR. APOSTOLAKIS: The final subject is elevation-6_ of CDF for fundamental safety goal and possible revision of 7 safety goal policy.
8 As you see here, we have very carefully listed' 9 only_ facts. We're still debating the issue. There is a 10 meeting tomorrow with the staff to discuss certain things, 11 and we felt it was:important to schedule a subcommittee 12 meeting two weeks from today to go more deeply into these 13 issues. So, maybe we should leave it at that today.
14 COMMISSIONER DIAZ: I just wanted to look at the 15 entire presentation, and like Chairman Jackson said, we 16 already engaged the staff on this.
17 If you look at your presentation, the presentation
-18 was really on risk-informed regulation. Yet, the title says 19 risk-informed performance-based, and I think we are trying 20 to make the point that these issues should be separated, and 21 when they are_together, that's fine. They're together, they 22- mean something different, because the process is much more 23 complex than if you look at each one of them by themselves.
24 And if I might go as bold as going to when I asked 25- what is the answer, I think it.would be important if the ANN RILEY & ASSOCIATES, LTD.
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49 1 Commission would get some sense from the Committee in that, 2 when applied properly, cases in which PRA have definitely 3 improved the regulatory system, because asking a question is 4 great, but if we could have at least some specific answers, 5 like you said, that are area-specific, then that will 6 certainly help us to get a better idea.
7 DR. APOSTOLAKIS: Did you ask where PRA can or 8 has? I didn't catch the verb.
9 COMMISSIONER DIAZ: I think both.
10 DR. APOSTOLAKIS: Okay.
11 COMMISSIONER DIAZ: It will be an important 12 contribution to our body of knowledge.
13 DR. APOSTOLAKIS: Regarding the title, I think we 14 sort of routinely, since day one, have been using 15 risk-informed performance-based regulation, you are right, 16 this was on risk-informed part only. From now on we should 17 be more careful.
18 We did have a discussion today on 19 performance-based regulation, by the way, so we are 20 following that, but you're absolutely right, this was not 21 part of it.
22 CHAIRMAN JACKSON: That is not a statement, 23 because you have performance-based regulation without 24 risk-informed.
25 DR. APOSTOLAKIS: Exactly.
i l
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50 1 CHAIRMAN JACKSON: And vice versa or both.
2 DR. APOSTOLAKIS: That's right.
3 CHAIRMAN JACKSON: That's the point.
4 DR. APOSTOLAKIS: But this presentation did not 5 address performance-based regulation at all.
6 CHAIRMAN JACKSON: Well, in some ways one could 7 argue that this presentation was PRA regulation.
8 DR. APOSTOLAKIS: As it should be.
9 DR. SEALE: Is that all, George?
10 CHAIRMAN JACKSON: I think so.
11 DR. APOSTOLAKIS: Yes.
12 DR. SEALE: Next we'll discuss --
13 CHAIRMAN JACKSON: Because I'm chairing this 14 meeting, that's all.
l 15 DR. SEALE: We'll discuss the AP600 review.
16 MR. BARTON: AP600 -- it seems that the meetings 17 have been going on forever, since 1991, the Subcommittee 18 first met with Westinghouse and the staff. We seem to be 19 able to see the light at the end of the tunnel. There have l 20 been no recent contentious issues such as in-containment 21 spray system, but I think the process is moving. We've had 22 meetings with Westinghouse this week. Six more chapters
( 23 were reviewed -- SAR plus draft SERs -- and questions are 24 getting closed out raised by the staff and also by the j 25 Subcommittee and the full Committee.
l L
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51 1 The major hard spots between -- we see between now 2 and the schedule and issuance of the final report are the 3 issues that the thermal hydraulics subcommittee has had with 4 the test analysis program, and Dr. Kress has a few comments 5 on those issues and where he sees their resolution.
6 DR. KRESS: I don't know that most of these issues 7 arise, thermal hydraulics, because thermal hydraulics is so 8 important or because of personalities. I get different 9 views from the Committee on that.
10 It does seem that most of the bones of contention 11 have been in that area.
12 I would like to say that the test analysis program 13 that Westinghouse has done to demonstrate that their plant 14 meets the requirements and that their codes are valid has 15 been very impressive and, I think, a very good set of 16 programs, and we think, as a Committee, that the -- we've 17 listed a number of issues that have come up in the thermal 18 hydraulics subcommittee. We put them, in I think, in our 19 interim AP600 letter -- I forget the date. They were 20 divided between the RCS and the containment in terms of 21 issues.
22 I don't really see any show-stoppers in either of 23 those. These have been -- the staff has been very 24 responsive in putting these together as requests for 1 25 additional information from Westinghouse. We are looking ANN RILEY & ASSOCIATES, LTD.
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9 52 1 for responses back to those.
2 I think there are legitimate good answers to all j 3 of them, particularly with the RCS.
4 The one area that I see may still be a problem has j 5 to do with the containment, and the problem is hard to put l I
6 into words, because I think, if you look at the codes they 1 J
'I 7 use, which, in particular, GOTHIC is one of them, it's a '
8 lump-parameter code, and in order for the thermal hydraulics 9 part and the fission product behavior part of those to be 10 appropriate for AP600, you have to demonstrate that AP600 is 11 a well-mixed containment, and they have not come forth with 12 an appropriate demonstration to us to convince us that they 13 do, sure enough, have a well-mixed and handle the 14 stratification problem well.
15 CHAIRMAN JACKSON: Was this the first time these 16 issues had been raised?
17 DR. KRESS: I think we raised them -- it's a 18 question of how much emphasis is actually put on them, 19 because sometimes you raise an issue in a meeting, a 20 subcommittee meeting, and it gets on the minutes and not 21 much more gets done about it sometimes. But they have been 22 raised.
23 DR. POWERS: These issues have been focuses of 24 attention -- foci of attention since the AP600 design was 25 first advanced as a passive plant with natural circulation.
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53 1 _ COMMISSIONER DIAZ: If I might go to'that first 2 bullet, I think this is a matter that even I am confused at 3 times. Lack of adequate justification'for' level of 4 conservatism. I understand lack of adequate justification,
.5 but as to level of conservatism, is it too high, adequate, 6 .or too low? It doesn't tell me there which way you're 7 pointing.
8 And then, in relation to the Chairman's question, 9 there's an enormous laundry list of issues that came very 10 late.
11 DR. KRESS: Those didn't come very late. They 12 were just consolidated from various lists that existed up to 13 then. We wanted to get them all on one plate.
14 This one bullet -- number one, I don't think there 15 is a regulatory requirement for level of conservatism.
16 We're talking about peak clad temperature here in design 17 basis space. This is the RCS.
18 The regulatory requirement says that, when making 19_ the analysis to determine what your peak clad temperature is 20 for the various design basis accidents, that you use a 21 conservative analysis.
222 They haven't demonstrated yet-to us that the 12 3 conservatisms they have claimed for the analysis are really 24 conservatisms that add up to a conservatism that one would 25 be comfortable with.
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54 l' But I have to'say, personally, I think the RCS is 2 not a_ problem, that they have good ECCS systems. The 3 analysis codes, why they have a lot of difficulties dealing 4 withi these low-pressure flows and stuff -- the test and 5 analysis program.is very robust and has demonstrated to me 6 that they really do not have a problem. They're a much 7 better system than standard plants.
8 COMMISSIONER DIAZ: So you would say the level of 9 conservatism in the proposed design based on the calculation 10 is adequate.
-11 DR. KRESS: Not based on the calculation, based on 12 the test and analysis program. But the calculations still 13 need to be -- some issues still need to be -- I do not think 14 they will -- when their issues are finally ironed and the 15 questions are answered, I don't think the answer will be 16 yes, we are in bad shape and the conservatisms aren't there.
17 I think the answer will be it's okay, we've proven it for 18 the RCS.
19 It's a little different with the containment. The 20 containment -- what I see there is a code that is a 21- lump-parameter. It has known errors in it that we pointed 22 out. The calculations -- the conservatisms they claim in 23 the calculations haven't been demonstrated at all and are,
- 24. indeed,.somewhat small.
25 The calculated peak pressure with respect to ANN RILEY & ASSOCIATES, LTD.
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55 1 design pressure requires you to take credit for all the heat 2 transfer mechanisms, to the thermo-dynamics of mixing with 3 the atmosphere, heat transfer to the walls, heat transfer to 4 the structures, plus the passive containment cooling system, 5 and then you barely peak at the peak pressure, and this is 6 coupled with the fact that they haven't demonstrated it's 7 well-mixed, and if it's not well-mixed, this is not 8 conservative.
9 Plus they have an aerosol calculation that 10 involves using the lambda, the decay factor, that invokes 11 diffusiophoresis, diffusion, sedimentation, agglomeration, 12 as well as thermophoresis, and basically that's 13 unprecedented in our regulations, we have never allowed that 14 before, and to me, they haven't demonstrated that they've 15 conservatively chosen those values, and with this 16 combination, you end up just barely meeting 10 CFR 100 17 guidelines, just barely, and what we have is a containment 18 that's basically a volume like a standard plant.
19 It's relatively weak in pressure, like 45 psi 20 design pressure. That's pretty strong, but -- compared to a 21 BWR, but compared to a large dry -- and it's a thin shell, 22 which we've had little experience with, and think shells 23 tend to fail catastrophically as opposed to leaking like a 24 containment, and you barely meet the design basis criteria 25 and you don't have a spray.
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56 1 The aerosols stay in there a long time, the-2 pressures stay in there a long time, and although you meet 3 what appears to be all the regulatory requirements, it 4 doesn't leave us with a warm feeling.
5 -COMMISSIONER DIAZ: It might be worthwhile if you-
! 6 would bound your real concerns in this area so the staff 7 'O A have an area.which they can' point and focus on.
8 DR. KRESS: I think we.have, and I think it 9 involves looking at the answers to the requests for 10 additional.information and seeing what the revised scaling 11 . analysis, what the revised code results give us, and then we 12 could make a better assessment.
13 CHAIRMAN JACKSON: Let me ask you two questions.
14 You know, the staff has stated that ITAAC will be 15 open still on May 1st on their FSER submittal to you, but 16 they hope to close it out shortly thereafter. Does that 17 pose a problem for you?
18 MR. BARTON: The information they gave us at the 19 ' Subcommittee, if they meet the commitment, that will not be 20 a problem. The Final SER by May 1 is the only question-mark 21' at this' point, whether-they can support that date.
22 COMMISSIONER McGAFFIGAN: Sort of following on 23 Commissioner Diaz, as I understand this issue --
24 CHAIRMAN' JACKSON: Actually, I wasn't done.
25 COMMISSIONER McGAFFIGAN: I'm sorry.
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' 1 CHAIRMAN JACKSON: The second question -- the 2 staff reduced the open items from about 500 to 7 over the 3 last couple of months, and I understand that you were 4 briefed on one of these open items, fire protection, this 5 week. Do you have some initial assessment of the staff's 6 position in this area?
7 DR. POWERS: We have an initial assessment that 8 we're going to look at it more carefully. We've asked for 9 that through a fire protection subcommittee activity.
10 My assessment is that we will find the staff 11 position in their SER and the Westinghouse position in their 12 application supportable, that it's essentially taking an 13 Appendix R position.
14 We just want to look at it a little more closely, 15 and we have some concerns about feedwater supply and things 16 of detail like that that we just need to look at a little 17 more closely than we were able to do in our grander 18 subcommittee meeting.
19 MR. BARTON: We will re-look at those in the May 20 subcommittee meeting.
21 DR. POWERS: We are committed to close that out 22 for Mr. Barton and his work for the may subcommittee 23 meeting, and I would not want to leave you feeling that we 24 have identified some red-flag issue. We just want'to walk 25 through the details fairly carefully on this.
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58 1 This is one of those lovely prescriptive 2 regulations that you can go through check-lists, and we're 3 going through the check-list.
4 CHAIRMAN JACKSON: Commissioner McGaffigan.
5 COMMISSIONER McGAFFIGAN: I just want to 6 understand the issue that you're talking about with 7 containment.
8 The staff isn't here, but I understand the staff 9 doesn't share the same concerns that you all have with the
-10 use of the codes, and I'm just trying to understand how we 11 are going to -- whether that is a resolvable matter in the 12 next month.
13 DR. KRESS: I think it's resolvable. I think the 14 staff has asked for requests for additional information that 15 reflect the concerns that we have on containment, and we're 16 awaiting these answers to come back, and so is the staff. I 17 don't know whether they actually --
18 COMMISSIONER McGAFFIGAN: When I listen to you, 19 just to try to -- theoretically, one could construe you as 20 saying they have to come up with a new code --
21 DR. KRESS: Oh, no.
22 COMMISSIONER McGAFFIGAN: -- invent it as they go 23 along.
24 DR. KRESS: No.
25- COMMISSIONER McGAFFIGAN: No?
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1 DR. KRESS: No. In fact, a demonstration by other 2 means that the AP600 is well mixed would certainly go a long 3 way in my mind to saying that the GOTHIC code is an 4 appropriate way to treat the analysis for AP600. No, 5 there's definitely not a need for a new code.
6 DR. POWERS: I think that, when the examination of 7 AP600 began, it certainly became clear that it would sure be 8 nice to have a code that solved the momentum equation 9 instead of lump-parameter codes, but a stride that has been 10 made over the last few years has been to recognize, indeed, 11 with appropriate calibration against experiments, it is 12 possible to justify the use of a lump-parameter code.
13 There's no question in our mind that, if we'd had 14 a fast-running CDF-type code -- competition fluid dynamics 15 code, I'm sorry -- that could apply to this containment, 16 things might have gone more smoothly, but we don't, and we 17 have to rely on a lump-parameter code.
18 That means you have to have an excellent 19 calibration against experiments and scale properly to the 20 actual plant, and it's those details that you go through, 21 and it's a grinding sort of thing to go through, because you 22 are doing an approximation to the Navier-Stokes equation, 23 and those approximations need to be justified, and there's a 24 rigorous, precise science associated with that. That's all 25 we're doing.
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1 9
60 1 MR. BARTON: That's it for AP600.
2 CHAIRMAN JACKSON: I actually think I'm going to 3 allow the Commissioners to ask any final questions. We're 4 actually going to end the meeting on this subject.
5 COMMISSIONER DICUS: To reiterate, you said 6 there's no red flags so far. You should know by now if 7 there are. 'You don't anticipate any?
8 DR. SEALE: Well, certainly, if we can get a 9 satisfactory word on this mixing problem in the containment, 10 that's the one area where I see an issue that could give all 11 of us pause.
12 COMMISSIONER DICUS: Okay. But given that, you 13 think this September date is meetable?
14 DR. SEALE: Yes. We certainly plan to meet our 15 schedule.
16 MR. BARTON: Which is a July report to the 17 Commission.
18 DR. SEALE: That's right. Yes.
19 CHAIRMAN JACKSON: Very good. Thank you.
20 I think this has been a very healthy discussion --
21 DR. SEALE: Thank you.
22 CHAIRMAN JACKSON: -- and your views are critical 23 in our evaluation of a number of difficulty and, frankly, I 24- think very forward-looking stances and issues that the 25 Commission is dealing with, and I, therefore, encourage you ANN RILEY &. ASSOCIATES, LTD.
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61 1
i) 1 to continue to be forward-looking in bringing issues to our
{
i 2 attention, and we'll cull through the remaining list and see l i
l l
3 which ones might be appropriate for our next discussion.
4 DR. SEALE: Let me make one statement.
5 CHAIRMAN JACKSON: Please.
l 6 DR. SEALE: It's a real pleasure for us to get I
7 again a demonstration that, when we make our
)
8 recommendations, they are not recommendations that are --
9 well, they receive scrutiny --
10 CHAIRMAN JACKSON: Yes.
11 DR. SEALE: -- receive critical thought on your 12 part, and that's the only way we can possibly have an 13 impact, is if they do, and we appreciate it very much.
14 CHAIRMAN JACKSON: Well, that's the game in town.
15 We' re adjourned.
16 [Whereupon, at 2:35 p.m., the public meeting was 17 concluded.)
18 19 20 21 22 23 3 24 25 i
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s ~
- ?' CERTIFICATE This is to certify that the attached description of a meeting of the'U.S. Nuclear Regulatory Commission entitled:
' TITLE OF MEETING: MEETING WITH ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS)
PUBLIC MEETING PLACE OF MEETING: Rockville, Maryland DATE OF MEETING: Thursday, April 2,.1998 was. held as herein appears,'is a true and accurate record of .
the meeting, and that this is the original transcript thereof
-taken stenographically by me, thereafter reduced to typewriting by me or under the direction of the court reporting company w
Transcriber: I C( A Reporter: Mark Mahonev
% _