ML20217Q783
| ML20217Q783 | |
| Person / Time | |
|---|---|
| Issue date: | 04/02/1998 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-3032, NUDOCS 9804130164 | |
| Download: ML20217Q783 (249) | |
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DISCLAIMER UNITED STATES NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS I
APRIL 2, 1998 The contents of this transcript of the proceeding of the United States Nuclear Regulatory Commission Advisory Coinmittee on Reactor Safeguards, taken on April 2, 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.
J
1 1 UNITED STATES NUCLEAR REGULATORY COMMISSION A
2 i] ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 3 ***
4 451st ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS) 5 6 U.S. Nuclear Regulatory Commission 7 Two White Flint North 8 Conference Room 2B3 9 11545 Rockville Pike 10 Rockville, Maryland 11 Thursday, April 2, 1998 12 13 The subcommittee met, pursuant to notice, at 8:29 14 a.m.
15 MEMBERS PRESENT:
16 ROBERT SEALE, Chairman, ACRS 17 MARIO H. FONTANA, Member, ACRS 18 GEORGE APOSTOLAKIS, Member, ACRS l 19 JOHN BARTON, Member, ACRS l
l 20 THOMAS KRESS, Member, ACRS l
l I
21 DON MILLER, Member, ACRS 22 DANA POWERS, Member, ACRS 23 h!LLIAM SHACK, Member, ACRS 24 ROBERT UHRIG, Member, ACRS 25 DR. WALLIS, Member, ACRS
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2 1 PROCEEDINGS 2
[8:29 a.m.]
3 CHAIRMAN SEALE: Good morning. The meeting will )
4 now come to order.
5 This is the first day of the 451st meeting of the s
6 Advisory Committee on Reactor Safeguards.
7 During today's meeting the committee will consider l 8 the following: Performance-Based Regulation and Related 9 Matters: AP600 Design; Discussion of Items for Meeting with 10 the Commissioners; Updated Source Term for Operating Plants; 11 and Proposed Reports.
12 In addition, the committee will meet with the NRC l
13 Commissioners between 1:00 and 2:30'this afternoon in the 14 Commissioners Conference Room to discuss items of mutual O 15 interest.
l 16 This meeting is being conducted in accordance with 17 the provisions of the Federal Advisory Committee Act. Dr.
18 John T. Larkins is the Designated Federal Official for the 19 initial portions of this meeting.
20 We have received no written statements or requests 21 for time to make oral statements from members of the public 22 regarding today's sessions.
23 A transcript of portions of this meeting is being 24 kept and it is requested that speakers use one of the 25 microphones, identify themselves, and speak with sufficient ANN RILEY & ASSOCIATES, LTD. j Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 '
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3 1 clarity and volume so that they can be readily heard.
f'h
( ,) 2 I will begin with some items of current interest.
3 It may not be of interest of some of you, but I am 4 told that my allergies have already caused me to demonstrate 5 unstable tendencies. I hope I don't come completely apart 6 today --
7 [ Laughter.]
8 DR. KRESS: We haven't noticed any difference.
9 CHAIRMAN SEALE: It won't make any difference?
10 Okay. But I'll try to remain at least reasonably !
11 housebrcken during all of this.
12 DR. POWERS: This is to be different than most 13 meetings then?
14 CHAIRFmR SEALE: Yes, sure. I f
A IS There are five letters on the docket for this 16 meeting and three of them are of the A Category. There is 17 one of them that we will really have to make up our mind on, 13 but we do have p' tenty of work to do. These are not easy l 19 letters to worry with.
1 <
20 We will be meeting with the Commissioners again at l
21 1 o' clock and we have set aside a time from 11:00 to 12:00 22 for us to discuss the things we are going to talk to the 23 Commissioners about -- excuse me -- and hopefully we'll be 24 able to use a little bit of the lunch hour too, if we sort 25 of run down, get something to eat, and bring it back, to use ANN RILEY & ASSOCIATES, LTD.
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4 1 some of that time a little more effectively.
2 Among the list of items of interest there is a 3 pink sheet here -- or a pink folder. There is a speech from 4 the Chairman regarding issues associated with mixed oxide 5 fuel and I think that speech is interesting. It reveals a 6 large number of concerns, resolves relatively few of them at 7 this stage, but I think that is something we are going to 8 see on our plate a little more prominently as time goes on, 9 so it's not a bad time to sort of begin to think about what 10 those issues are and try to identify the impact that some of 11 those issues might have in various areas of our concern.
12 DR. POWERS: This is on mixed oxide fuels?
13 CHAIRMAN SEALE: Yes sir.x 14 DR. POWERS: We have a problem with that. The 15 mixed oxide fuels that has consistently been a part of the 16 agenda of the Reactor Fuel Subcommittee, but the Staff is 17 unable to support us in that area because they are under 18 restrictions imposed by Congress not to spend money on mixed 19 oxide fuels. I mean something has to give. You can't 20 doubly constrain everybody here.
21 CHAIRMAN SEALE: I appreciate that and I am 22 reminded that there have been other cases in the past where 1 23 issues have been unrecognized by order one day and suddenly 24 the burning issue in front of -- or that is high on 25 everybody's priority list the next day, and so I think that ANN RILEY & ASSOCIATES, LTD.
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5 1 the committee has a responsibility to keep nagging in this 2 area whether or not anybody is going to respond until they 3 get some changes. That's okay. We still have to make the 4 point that that is an issue that is significant and at some 5 point will be a concern for the industry and its suppliers, 6 and there are safety issues involved.
7 In this list of things on the pink sheet also 8 there's several fines delineated there which indicate a !
9 direction in which a lot of the concerns and time of the 10 Inspection Staff and so on are being focused these days.
11 The Staff put at your place a page out of the last 12 or a recent issue of Inside NRC, the March 30th issue. This 13 page has reports on a range of about five different things 14 that this committee considered at its last full meeting. I
\ 15 guess my only comment is we can't expect no to be noticed l l
16 and as long as they quote us rather than castigate us, I 17 guess we are doing some of the right things anyway and we 18 are largely quoted there -- so you'll want to interested in 19 where you or why you were quoted and the particularly 20 identified there.
21 There is one thing coming up -- the quadripartite l
22 meeting is now likely to be early in October and it will be l 23 right after the October meeting of tne committee and that 24 may require a slight change in the dates for the meeting, 25 since you lose a day going to Tokyo on the airplane, and so )
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6 1 that is kind of a notice to you that we may be changing the
() 2 official dates of the meeting.
3 Also, any of you who plan to take your wives to 4 Tokyo should let us know because we need to let our hosts 5 know what we might have along that line.
6 John, are there any other things that I should 7 mention?
8 DR..LARKINS: I think you pretty much covered
( 9 everything.
l l 10 on the quadripartite meeting, it is probably a l 11 good idea to start thinking about reservations if you can, 12 because things are getting books pretty quickly.
13 CHAIRMAN SEALE: Well, I almost forgot the most 14 important thing. My wife asked me to circulate to the l
15 members a note here. I initialed it for her. She suggests l
16 that any of the spouses that.would like to get together for 17 the May meeting, we should do that -- the May meeting starts 18 the 29th of April, so it is better organized than most of 19 'the things that we work with, and we'd like to know how many 20 of you think your wives might be able to make it.
21 DR. KRESS: It is interesting there you think 22 there's only two nice restaurants in the Washington area.
23 CRAIRMAN SEALE: I didn't say that. I thought 24 we'd only have a couple of times where we would have an 25 opportunity --
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1 7
1 DR. UHRIG: I notice Jed's Roadhouse is not one of 2 them.
\
3 [ Laughter.). j 4 CHAIRMAN SEALE: I war interested in that she felt 5 that ways to try to get better behavior by members of the 6 ACRS was one of the things on her agenda.
7 DR. KRESS: A lost cause.
8 CHAIRMAN SEALE: Yes. Okay. Our first 9 presentation today is on Performance-Based Regulation and i
l 10 Related Matters.
l 11 George, that is your subcommittee. Why don't I 12 let you take it from there. l
! 13 DR. APOSTOLAKIS: Thank you, Mr. Chairman.
l 14 We had a discussion with Mr. Murphy at one of the
-l 1
! 15 subcommittee meecings and now we see this paper from the 16 Executive Director of Operations to the Commissioners in l 17 draft form and I suppose Joe is here today to discuss that.
1 18 The floor is yours, Joe.
19 MR. MURPHY: Good morning.
20 DR. BARTON: Good morning.
l- 21 MR. MURPHY: This feels like it's one of a l
22 continuing saga'on the subject. It's a very short paper --
l 23 CHAIRMAN SEALE: Deja vu some more, huh?
l 24 MR. MURPHY: Yes. It's taking us forever to get 25 out of it. It's still in draft from. I think I can tell ANN RILEY & ASSOCIATES, LTD.
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I 8 1 you, I think I have about half the program office concurring 2 at this point.
3- We had a little problem with our Chief Financial 4 officer, who's concerned we have not been explicit enough 5 about the resources that will be required, and we're merrily 6 going down the pike. I think we are getting close.
7 The presentation I'll give today is one that is 8 geared more towards differences. We discussed this with the 9 subcommittee, as Dr. Apostolakis said, and because a number
! 10 of the members of the full committee were at the 11 subcommittee meeting, I have tried to organize the 12 presentation more along the line of what's changed since ,
4
- 13 then rather than go back to "GO" and describe the whole l 14 process. If that is enacceptable, I can easily go back to l5
( 15 "GO" and do the whole thing.
16 Basically, what we are talking about is that --
17 let me'say that in preparing the paper we tried to take into 18 consideration the discussion we had at the subcommittee 19 meeting. We found the committee's markup of the draft 20 Commission white paper very helpful to us. I think what we 21 have conforms to that. If it doesn't, the noncomformance 22 would be unintentional.
23 We of course are addressing a much smaller part of 24 the problem than what the committee addressed or the 25 Commission addressed, but clearly we are involved with the ANN RILEY & ASSOCIATES, LTD.
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9 1 white paper and as that white paper comes out, it may change 2 what we are doing.
3 Basically, in performance-based regulation our l 4 focus is on outcomes as opposed to specific features or l
l 5 programmatic elements of the regulatory activity.
l 6 Our attributes, which are in our paper towards the l
7 end, are the availability of measurable, calculable or 8 otherwise observable parameters. That's kind of a mouthful.
I 9 Calculable means something easy to calculate. A l
10 train reliability I would say was about as far as I would j 11 want to go into calculable. It does not in my mind extend l
i 12 to something like a core damage frequency. I l 13 Maybe it is easier to say that it is comething you 14 can do with hand calculator. The difference between l O' 15 measurable and observable would be something that is more I
16 qualitative like the ALARA concept.
17 As I said, next was your quantitative or 18 qualitative objective criteria set up in such a way that the 19 licensee has flexibility in meeting the performance criteria
! 20 and that performance criteria either directly or indirectly 21 provides some safety margin.
22 For reactor applications I think that should be 23 mostly directly. The indirectly is in there mainly to 24 accommodate things like repositories and materials licensing i 25 considerations.
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1
I 10 1 We believe that if we do it right, the flexibility
() 2 we give the licensee can lead to a win / win type situation.
3 Definitely the licensee has more flexibility and can figure 4 out the best way of doing it, may save money in the process, 5 but again if it is done correccly it may actually lead to an 6 improvement in safety and so both sides essentially have got I 7 those in both safety and economics can be positive.
8 DR. APOSTOLAKIS: I have a question.
9 MR. MURPHY: Yes.
10 DR. APOGTOLAKIS: Two questions. The document, 11 and that is the version I have, but I checked quickly and 12 the new version says the same thing, under " Definition" --
13 do you have the document with you?
14 MR. MURPHY: Yes. I have the new one, not the old
]
15 one.
le DR. APOSTOLAKIS: Well, under " Definition" --
17 MR. MURPHY: Would you give me a page?
18 DR. APOSTOLAKIS: Page 2. Is it there?
19 MR. MURPHY: Yes.
20 DR. APOSTOLAKIS: " General performance-based-21 regulatory approaches focus on the desired outcomes or 22 actual performance results of the regulated activity."
l 23 I guess that " desired outcomes" through me off a l l 24 little bit. Dc you mean the criteria, the objective 25 criteria that you are prejosing? Are these the desired l
()
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11 1 outcomes?
() 2 And if these are the desired outcomes, then 3 shouldn't that "or" be "and" on the desired outcomes and 4 actual performance?
1 5 MR. MURPHY: I believe you are correct. J 6 DR. APOSTOLAKIS: It should be "and"?
7 MR. MURPHY: I think it is. Let me check with the 8 author here.
9 DR. FELD: I would concur.
10 DR. MILLER: Sid, you need to identify yourself.
11 MR. MARKLEY: Would you identify yourself for the 12 reporter and use the mike.
13 DR '. FELD: Sid Feld.
14 [ Laughter.)
15 DR. APOSTOLAKIS: So the desired outcome then is 16 the objective performance criteria, okay. It would be nice 17 to explain that though, because nowhere in this document 18 does it say that the desired outcomes are the same as these.
19 There was another point. Oh -- and you just 20 mentioned it yourself. Well, on page 3 -- I hope it is on 21 the same page - "Each activity is likely to contain gray 22 areas and should provide flexibility where it is appropriate 23 and prescriptive direction where economy and human factors 24 would so justify."
25 What.does " prescriptive direction where economy h ANN RILEY & ASSOCIATES, LTD.
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12 1 and human factors would so justify" mean?
() 2 MR. MURPHY: What that is trying to say is that 3 there is probably no regulation that should be either 100 4 percent performance-based or 100 percent prescriptive, that 5 in certain situations you are going to run into conditions 6 where economics could drive you towards -- drive the 7 licensee towards basically favoring a prescriptive 8 formulation.
9 An example of that may be a radiography license.
10 A radiographer may prefer to have a prescriptive licensing 11 regime rather than having to develop a performance-based 12 thing that he can have. He doesn't have the economics to go 13 and develop that.
14 The same thing may be true if you want to go 15 performance-based with a university reactor where they have 16 tight budgets. They may not be able to invest the initial 17 money to come up with a performance plan for certain area, 18 .but even though they may find it philosophically appealing 19 to be performance-based they do not want to put the upfront 20 costs in that have to do it, so that is what is meant by 21 that phraseology.
22 DR. APOSTOLAKIS: Now continuing there it says, 23 "For example, many provisions of 10 CFR, Part 20 employ 24 performance-based features. These include concepts of as 25 low as is reasonably achievable, use of analysis to estimate
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131:
1 total effective dose' equivalent and so on."
2 I am a' bit. confused th're.
e The' concept of as low 3 as reasonably achievable is a performance-based feature?
4 MR. MURPHY: I think it.is performance-based. We !
l 5 don't tell you how to get as low.as reasonable assurance.
6 We tell you we want you to have a program that keeps your j 7 dose'to your operators.and to the public as low as l
8 reasonably assurance. We don't describe the programmatic I
! 9 requirements that you have to have.
{
10 Basically we say we set this general philosophical i
11 approach. Now it doesn't meet all the definitions we'have 12 here.
13 DR. APOSTOLAKIS: But is that consistent with your 14 G3cond attribute there -- quantitative or qualitative 15 objective performance criteria?
16 MR. MURPHY: Yes. I think this a qualitative.
17- DR. APOSTOLAKIS: And it's objective? And where 1
18 is the measurable, calculable or observable --
)
19 DR. WALLIS: I would like to support my neighbor.
20 I think that ALARA is the vaguest possible statement and 21 needs to be made as quantitative as possible. It is not
.22 quantitative in its present form.
23 MR. MURPHY: In general it is not quantitative.
24 There is guidance on how to make it quantitative in a Reg 25 Guide that is under discussion this month.before your ANN RILEY & ASSOCIATES, LTD.
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r 14 1 compatriots at ACNW in one of the Reg Guides that goes with
) 2 the regulatory criteria for -- I'm sorry, the radiological 3 criteria for decommissioning and there we have attempted to l 4 try to come up with a quantitative way of looking at ALARA.
5 But to me ALARA is a performance-based philosophy.
6 It does not meet all these attributes. It is qualitative
! 7 and while the objective is clear, I think -- it certainly is 8 not quantitative by any stretch of the imagination.
9 DR. POWERS: I guess I am surprised that you would i
10 pursue this tack on ALARA. It seems to me that it is 11 specific. It is a performance measure, and indeed it has 12 strong quantitative elements.
13 We have rather good capabilities of estimating the 14 likely dose for a worker performing a given operation. To 15 do so is part of ALARA engineering efforts, and measure it 16 after the work has been done.
17 I mean it seems like one of our better measures of 18 performance effectiveness here.
19 CHAIRMAN SEALE: And I think one of the reasons 20 that it is successfully both predictable and measurable is 21 the fact that it is an objective that has been out there for 22 everyone to see, admire, and strive to achieve for a ,
i 23 reasonably long period of time. I 1
24 DR. POWERS: At least 50 years.
I 25 CHAIRMAN SEALE: Yes, so we have had time to think l
I 1
' i I
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j
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15 1 about it and ask ourselves what we do to satisfy its 2 requirements.
3 DR. POWERS: One of the great attractions I think 4 of ALARA, and why I am an unabashed defender of it, is that 5 it has been ingrained in the engineering thinking when we 6 were doing radioactive work. It's a nicely linear system so 7 that it is easy to think about it. It is virtually routine 8 to think about ALARA considerations on every operation you 9 do, and like many of the speakers in the subcommittee I 10 meeting yesterday, I think I agree that not only has the 11 ALARA concept resulted in substantially lower and falling 12 worker doses, I think it results in a simplification of 13 operations, a. liability of operations on work that 14 otherwise would be difficult to achieve.
[~
\.~ 15 DR. APOSTOLAKIS: That is the value of ALARA. I 16 That is not the issue.
17 DR. POWERS: No, your issue is that you don't see 18 something like get your dose things down to "x" number of 19 rem.
20 DR. APOSTOLAKIS: Not "x" -- as low as reasonably l 21 achievable.
22 DR. POWERS: What you don't see is an "x" --
23 DR. APOSTOLAKIS: Yes.
24 DR. POWERS: The rule has as low as reasonably l 25 achievable and what I am arguing is that this system has ANN RILEY & ASSOCIATES, LTD.
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16 1 worked very well and satisfies all the requirements of
() 2 performance-based regulation and in fact has an enormous 3 amount of quantitative aspect to it.
4 The genius that exists in the NRC regulations is 5 in fact they have put a termination criteria in it for 6 public risk. They don't routinely use that termination 7 criteria in the operational effects within the plant because j 8 there are many things that don't appear in that termination 9 criterion that would be of interest to an owner operator, 10 but still there is this lovely termination criterion on when 11 good is good enough.
12 DR. BARTON: But Dana, there is a criteria for 13 termination of max limits on workers. It's in Part 20.
14 DR. POWERS: Oh, yes, but the operational
('3/
\d 15 engineer, the owner operator, may routinely violate that on 16 going even lower because there are other aspects that are of I 17 importance to him that do not appear in the regulatory 13 philosophy, but nevertheless there is a lovely termination 19 criterion.
20 Live in a system where that doesn't exist, for 21 instance in the DOE system where for years and years we did 22 not have that termination criterion, and you see how 23 valuable it is.
l 24 MR. MARKLEY: Beyond the regulation itself, most, 25 in fact all licensees have administrative limits on dose ANN RILEY & ASSOCIATES, LTD.
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17 1 that are much lower than the regulations.
I
((~')s 2 DR. POWERS: Sure.
3 CHAIRMAN SEALE: I think the other genius of ALARA 4 is that we haven't burdened the Staff with the problem of ,
5 trying to set lower limits for different kinds of operations 6 and yet I can from my own experience relate cases where in t 7 he operation of research reactor facilities and operations 8 with fixed sources and things of that sort as well as in 9 power reactor activities the ALARA concept has been both 10 useful and productive in guiding the allocation and use of 11 resources and in spurring innovative ideas to reduce 12 personnel exposure.
13 DR. POWERS: We only have to compare this ALARA 14 concept and the way it is implemented to things like fire O 15 protection to see how dramatically performance-based it is i
16 and that in fact it does elicit these innovations and )
17 creative thinki'gn that have been responsible for an awful 18 lot of things that have become routine in these planta I 19 nowadays.
20 If you go back and compare it to what you and I 21 are very familiar with in the research reactor community, we 22 can look at some of those more ancient facilities and see .
23 how much ALARA has brought us to a more modern setting.
24 There is no question in my mind, this is a 25 performance-based criterion by any standard and it is l
I)
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18 1 lovely. It has a lovely quantitative aspect to it.
() 2 DR. WALLIS: I don't want to get involved in too 3 long an internal discussion in the committee but it seems to 4 me that the genius that you refer to is being in the 5 implementation of ALARA, which superficially is a very 6 qualitative criterion, which maybe is a good way to start l 7 but eventually things have to be calculable in some way.
8 DR. POWERS: There is no question they are l
9 calculable. You can give me any operation involving nuclear 10 materials and I could give you a pretty accurate dose 11 assessment of that operation.
12 DR. WALLIS: But then the question is how much --
13 is it reasonable? Things like that have to be worked out in 14 some way. It cannot be left as vague as the initial 15 philosophy in order to be implemented.
16 DR. POWERS: And that is where we come in for 17 regulatory purposes -- there's this lovely termination 18 criterion. Understand, however, that when I am an owner 19 operator that I may have considerations that go well beyond 20 that termination criterion and I may well spend a great deal 21 more money. " Reasonably achievable" has a different i
22 definition if I am an owner operator than if I am a 23 regulator.
24 MR. MURPHY: In that regard I would really call to 25 your attention the draft Regulatory Guide that we have on I
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19 1 radiological criteria of decommissioning. Recognizing that
() 2 it is being reviewed by ACNW, we can get you copies.
3 What we have attempted to do there is to use a 4 principle of about $2000 a person-rem to help us go through 5 defining what does as low as reasonable assurance mean.
6 Now it's in a Reg Guide. It is not in a 7 regulation and it indicates one way that is acceptable to 8 the Staff.
9 For instance, when we get into decommissioning 10 sites, where we are talking about getting down to doses as 11 low as 25 millirem per year, when you go into competing 12 risks the risks associated with trucking the stuff offsite 13 might dominate the risk. j 14 The accidents that come from having a slew of 15 trucks loaded with dirt going to the appropriate landfill 16 can be the dominant thing from a risk perspective, so 17 there's some guidance there that we have tried to do, 18 because this is an unusual situation that is beyond the 19 normal reactor operation.
20 I think throughout all the years people who 21 operate reactors understand what ALARA means, but I guess 22 maybe we have a bit of a difference of cpinion, because to 23 my mind I don't have a problem with a qualitative criterion 1
24 of which I have an observable to match against it.
25 I don't want to give up -- I have to admit the
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1 r
20 i
1 only one I can think of right now is ALAPA, but I don't want l
, r~N
() 2 to give up that basic philosophical approach in terms of l
3 being performance-based.
l 4 DR. APOSTOLAKIS: Well, it is not a matter of 5 giving it up. It is a matter of what you want to emphasize 6 in the new approach or the move towards using more and more 7 performance-based approaches.
8 MR. MURPHY: The emphasis is on the quantitative.
9 DR. APOSTOLAKIS: Pardon?
10 MR. MURPHY: In my mind in our paper the emphasis 11 is on the quantitative but we don't want to eliminate the 12 qualitative.
13 DR. APOSTOLAKIS: Well, this paper will not
, 14 eliminate anything. If you leave it out, are you
( 15 eliminating it? No. It's just there. I mean it is being 16 used, but to say that you will have qualitative objective 17 performance criteria, I don't know, it seems to me it sounds 18 like an oxymoron.
19 How can a qualitative criterion be objective?
20 MR. MURPHY: I don't think ALARA is subjective.
21 DR. APOSTOLAKIS: I guess I have to learn more 22 about ALARA then.
23 DR. FOWERS: Well, it would clearly be very 24 valuable for you to take an ALARA training class because you 25 would see that -- I mean really what it ends up doing is you
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l 21 1 look at engineering alternatives to accomplish a mission and l
() 2 take the one that results in the lowest dose subject to a 3 constraint of reasonableness. I l.
4 I mean you quit doing it after awhile once you l 1 5 have got the doses down to the point that you are willing to l
l C live with them, and in a regulatory sense there is some 7 quantitative guidance for you, but in fact I think that the 3 alternatives you start off with are all typically well below 9 that termination sense, you are doing it for other kinds of i
10 reasons.
11 DR. APOSTOLAKIS: Why don't we then have a new l l 12 regulation that asks the licensees to demonstrate that their 13 . core damage frequency is as low as reasonably achievable and l-14 why wouldn't that be a performance-based regulation?
A
\- 15 They could consider alternative ways of doing it l
l 16 and then select the one that --
17 DR. POWERS: I think the biggest barrier that you 18 have and why we spend more time debating that than you do 19 with ALARA is with ALARA I have an excellent calculational 20 capability. l 21 Like I say, define for me a task, define for me 1
22 the operations, I could calculate the dose to the people l 23 doing that fairly accurately, plus after they are done I 24 could tell you what dose they have accumulated fairly l 25 accurately.
i
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i 22 l 1 I don't think you have that kind of calculational 2 capability either in a predictive sense or in a 3 post-activity observational sense for core damage frequency.
4 DR. APOSTOLAKIS: So what you are saying, Dana, is 5 that in that particular instance it is quite qualitative.
l 6 DR. POWERS: It strikes me that ALARA is a much l 7 more disciplined, quantitative thing than many of the things 8 that I can think of.
! 9 CHAIRMAN SEALE: But the quantitative aspect is in l
l 10 the detail, not in the concept, if you will. You don't 11 necessarily calculate the dose the same way or the expcsure 12 the same way for all kinds of operations.
13 It depends on the specificity of the process.
14 DR. APOSTOLAKIS: Let me put it this way, I am not 15 sure that citing ALARA twice, because you have this also on 16 page 6, helps this document. It is not just an observation.
17 That is not what comes to people's minds when you 18 talk about performance-based regulations and Joe just said 19 this is the only example that you can think of right now 20 anyway that involves qualitative performance.
21 I think it dilutes what you are trying to do here.
22 Now obviously this is a minority opinion, so --
23 MR. MURPHY: I have to say the reason it is in 24 there is for just what you said. It is not what people 25 ordinarily think of when they think of performance-based and ANN RILEY & ASSOCIATES, LTD.
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i 23 1 what I was trying to do was expand the thought process that G
t s ,/ 2 goes with considering performance-based.
3 , It is much broader than the first thought of what 4 performance-based means.
5 DR. APOSTOLAKIS: Maybe you can drop it on page 3 6 and keep it on page 6, which would achieve what you want.
7 Now, let me tell you what page 6 is in your 8 handout. Okay. Yeah, on page 5, your page 5, feasibility, 9 second bullet, "Where objective criteria can not be 10 developed, EGLR, a qualitative specification of the safety 11 objective must be developed." I would be happy with that.
12 MR. MURPHY: Okay.
13 DR. APOSTOLAKIS: But not on page 3. I think it 14 too soon and you make too much of a big deal out of it.
O k_s 15 Page 3, now, let's see, it starts with "It must be 16 emphasized".
17 MR. MURPHY: Uh-huh.
I 18 DR. APOSTOLAKIS: Okay. Somewhere there in the !
19 middle --
20 MR. MURPHY: Yeah.
21 DR. APOSTOLAKIS: You know, again, you know, -- I 22 ' 'R . MURPHY: No , that's acceptable.
23 DR. APOSTOLAKIS: Yeah. Okay. Good. Good. That
.24 would make me happy.
25 How long is that course, Dana? l
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k 24 l 1 DR. POWERS: Oh, it depends on what -- what you
( 2 are going to do. If you are going to be a regular ALARA 3 engineer, it is a lifetime course. But the specific 4 training typically takes a couple of days. If you are going 5 to be a manager, they usually give you about an hour, and 6 about 10 exampleu and things like that on working it 7 through.
8 DR. APOSTOLAKIS: An hour sounds reasonable.
9 DR. POWERS: And a copy of the radiation 10 protection manual, and away you go.
11 DR. APOSTOLAKIS: I think an hour is reasonable.
12 What is --
I 13 DR. POWERS: Achievable.
{
l w
14 DR. APOSTOLAKIS: Yeah, right. l
\/ 15 DR. SHACK: There is a lot -- a lot of it is 16 reasonable.
17 (Laughter.)
18 CHAIRMAN SEALE: You got to tie it to the 19 attention span.
20 DR. APOSTOLAKIS: Okay. Now, regarding the 21 definitions, I think -- yeah, that's all I have for the 22 definitions.
23 MR. MURPHY: Okay. Going on to the next l 24 viewgraph.
l 25 DR. APOSTOLAKIS: To the next line.
l
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25 1 [ Laughter.]
(x
) 2 MR. MURPHY: These are the major changes that have 3 happened since our subcommittee meeting. We have tried to 4 get into the paper more recognition that the performance-5 based approaches are not the end all and the be all and that 6 you have to assess each particular application where you are 7 considering performance-based from a feasibility standpoint, 8 from a value impact standpoint. And that value impact 9 includes both the value and the impact on the licensee and 10 on the licensing organization itself.
11 The other thing we have done is we have linked 12 this effort strongly to the regulatory excellence plan that 13 I understand Mr. Thadani is discussing with you tomorrow.
14 And the ongoing portion of that plan is Strategy 5 and so we 15 have linked this very closely to Strategy 5, which is to 16 develop a process and identify candidate issues for 17 improving the effectiveness and efficiency of rules, 18 standards, regulatory guidance and their applications.
19 In that -- and you will see later in this 20 presentation, we are saying that as part of rulemaking 21 activities, we would require that everybody -- as part of 1
22 the normal process, people would investigate whether it 23 makes sense to have a performance-based rule.
24 DR. APOSTOLAKIS: Can you point me to the 25 paragraph in the white paper where you recognize that ANN RILEY & ASSOCIATES, LTD.
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26 1 performance-based approaches are not a panacea? Where is
() 2' it?
3 MR. MURPHY: I don't think that's in the white 4 paper.
5 DR. APOSTOLAKIS: Oh , it's not in the white paper.
6 But it will be?
7 MR. MURPHY: You have to ask the author of the 8 white paper?
9 DR. APOSTOLAKIS: Are you presenting something 10 different from the' white paper?
11 MR. MURPHY: The white paper, to my understanding, 12 is not out yet.
13 DR. APOSTOLAKIS: What is this, yellow?
14 MR. MURPHY: No, no. What are we --
15 [Imughter. ]
16 DR. APOSTOLAKIS: This is the plans to -- it's a 17 memo. Memo or a SECY, what is it? From the EDO to the 18 Commissions.
19 MR. MURPHY: No, no. You're talking about --
20 DR. APOSTOLAKIS: Yeah, that's not the white 21 paper.
22 MR. MURPHY: No, no. No. ;
23 DR. APOSTOLAKIS: What is that? Oh, the white i 24 pr.per of the Commissioners, you mean?
25 MR. MURPHY: I don't know what white paper you are
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27 1 Lalking about
() 2 DR. APOSTOLAKIS: Oh, what is this then?
3 MR. MURPHY: This, I would say is a paper from the 4 Commission -- responding to a Commission SRM on 5 performance-based regulation.
6 DR. APOSTOLAKIS: And that's what you are 7 addressing?
8 MR. MURPHY: That is what I am addressing.
9 DR. APOSTOLAKIS: Okay.
10 MR. MURPHY: And.the actual SRM that we are 11 responding to is at the top of page 2 of the new version.
12 When I use white paper, I mean the paper that is being 13 developed by the --
14 DR. APOSTOLAKIS: So is this statement then in 15 this document? The revision that you are talking about?
16 MR. MURPHY: Yeah. What I am saying is the 17 revisions that are on the slide have been made in the 18 document that was passed out to you today and differs from 19 the document that you had before it.
20 DR. APOSTOLAKIS: Now, where is it in the 21 document?
22 MR. MURPHY: What page?
23 DR. APOSTOLAKIS: Yeah.
i I
24 DR. FELD: The large paragraph on the top of page ;
25- 3, that sort of contains this information.
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28 1 DR. APOSTOLAKIS: Is that where it is?
() 2 DR. FELD: Yeah.
3 DR. APOSTOLAKIS: Okay. We'll find it there then.
4 That's where ALARA is. I guess that paragraph is --
5 MR. MURPHY: Yeah.
6 DR. APOSTOLAKIS: Okay.
7 MR. MURPHY: As I say, I consider that probably.
8 the strongest point that has been made is to tie to the 9 regulatory excellence plan.
10 Now, in terms of the good news and the bad news 11 regarding performance-based regulation, I think the good 12 news is that the licensing fitxibility really gives an 13 opportunity for a more efficient operation, more efficient 14 regulatory response, well, by the licensee at least, while
, / ~s 15 still be protective of the public health and safety, and it 16 recognizes the underlying principle that the licensee is l 17 responsible for the public health and safety.
18 DR. APOSTOLAKIS: Joe, just an observation here.
l 19 The big pro, it seems to me is that this is the real thing.
20 You really want good performance. Isn't that really what it 21 comes down to? I mean logically, this is the way it ought 22 to be. The reason why it is not is because you can not do 23 it in many cases.
24 MR. MURPHY: I won't disagree.
25 DR. APOSTOLAKIS: Why don't we start with that and
()
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29 1 say, you know, that this is the intellectually appealing
() 2 regulatory system,'a performance-based system. That is 3 where.we ought to be.
4 Now why aren't we there? Because of real life. I 5 mean there -- and then go to the more specific pros and talk 6 about flexibility and all that.
7 MR. MURPHY: I think that is a good suggestion.
8 DR. APOSTOLAKIS: Now the second point is the 9 memo -- the memo? -- well, this document does not address 10 something that in my opinion could be important and it has 11 to do with flexibility.
12 Now in other industries where they tell us that 13 they have this performance-based approach, like the fire ;
14 protection industry, they make it part of their rules that 15 the methods for demonstrating that you have met the criteria 16 must be acceptable. In other words, a priori we agree that 17 if you want to calculate this you can use A, B, C or D.
18 Now in our business I am not sure how realistic 19 that d.s and that is an issue in my mind and this document i 20 does not seem to address that issue. Was that deliberate?
21 MR. MURPHY: It is more or lese deliberate, but it 22 is mostly because we think at least in the reactor end that 23 what performance-based would mean in most caces is something 24 that is almost directly observable. ;
- 25. As long as it is observable, you really don't need A
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30 l
1 calculations that much to get you where you are going. I (N) 2 As I said at the beginning, I see about the most 3 sophisticated calculations that I would personally be happy 4 with -- more like calculational train on availability --
5 something very simple that requires taking some observance 6 and measures values and maybe doing a simple multiplication 7 or addition or division but not a very sophisticated l 8 calculation.
9 DR. APOSTOLAKIS: See, that is what is confusing 10 to me because I hear you say that but I remember in other l l'
11 instances -- maybe it was not you -- but there was a 12 statement made here that the core damage frequency itself is 13 a performance measure which it seems to me is inconsistent 14 with what you just said because the core damage frequency -- 4 15 MR. MURPHY: In my mind it is inconsistent. I 16 don't know whether the Staff would say that. I know Mr.
17 Christie feels that way.
18 DR. APOSTOLAKIS: So we have to go back and find 19 out who said it, but the core damage frequency then is not a 20 performance measure? In your opinion it is not?
21 MR. MURPHY: It is -- I guess you could call it a 22 performance measure but by the time you know whether you 23 performed or not it's kind of a bad place to be.
24 DR. APOSTOLAKIS: Well, yes, the fourth 1
25 requirement --
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1 l
31 1 CHAIRMAN SEALE: It's that other part of this
]
() 2 thing, and that is a useful performance measure ought to be 3 something that you don't -- that doesn't cost you an 4 inordinate amount.
5 DR. APOSTOLAKIS: Okay, so next time somebody says 6 it, I'll say --
7 MR. MURPHY: I can say to some extent if I go to 8 something like train availability I can back that out of 9 what is a reasonable target from what I have done in terms 10 of coming up with core damage frequency and what I think is 11 a reasonable target for those, so to that extent, but now I 12 have reduced it to the point where we have gotten a lot of 13 the uncertainty in the calculational process out of it and I 14 have set something that I can monitor.
f~'
S s\/
m 15 DR. APOSTOLAKIS: Now why wouldn't you go to the h
1 16 safety function availability?
17 MR. MURPHY: Safety function availability ,
i 18 personally? It depends on how well I can do common cause.
19 DR. APOSTOLAKIS: Yes?
20 MR. MURPHY: I'd go to my databases and all that.
21 I am not saying I wouldn't. I am saying it takes some 1
22 evaluation I haven't done yet before I would be wiling to go 23 there.
i 24 DR. APOSTOLAKIS: Okay. So the uncertainty is j 25 larger?
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i 32 l i
1 MR. MURPHY: The uncertainty is larger and each j 2 time I take another step where the calculation gets more 3 sophisticated, the uncertainty goes up and at some point I 4 have to say I have gone as far as I know and it may be based 5 on the calculated uncertainty or may be based on the fact 6 that I know there are elements that are not in the 7 uncertainty calculation that I really wish were, but I don't 8 know how to put them there.
9 DR. APOSTOLAKIS: So is it part of the plan then 1 i
10 that somebcay will investigate these issues at some point, '
11 how far we go?
12 MR. MURPHY: At this stage I wouldn't say it was 13 part of the plan, but it was definitely something that I 14 would see as an ongoing dialogue as we go through PRAs to 15 understand where the uncertainties are, what we can do to 16 better them, to the acquisition of databases and this sort 17 of thing.
18 Inevitably, as we use these things and as they are 19 used in the industry, as the data and stuff becomes 20 available, then I would expect more of us as an industry and 21 perhaps as a Staff initiative to push the limit on t.hese 22 things to where we are still comfortable, if our comfort 23 zone shifts.
24 DR. APOSTOLAKIS: Well, it is part of your 25 recommendations on your page 7 -- my page 7 too --
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33 1 Recommendation 5 refers to additional research. It seems to
() 2 me that we need to have someone think about these issues 3 .maybe for a year or so to decide where is it reasonable ^to 4 put the criteria, to place the criteria, the objective 5 criteria.
6 All this says is that, you know, there may be j 7 addi..lonal research so what I am saying is that this in my 8 mind is an important question that cannot be resolved by 9 meetings such as this one where people express opinions.
10 Somebody is supposed to sit down and think about 11 the pros and cons, what you mentioned and maybe other 12 issues, so that is why I asked whether there are any plans.
13 MR. MURPHY: There's not -- well, I will put it 14 this way. There are definitely plans for research in the O
l 15 PRA area. They are not right now directed toward this area, 16 toward chis specific question, j 1
17 DR. APOSTOLAKIS: But they could, 18 MR. MURPHY: But they could be and they are 19 directed, of course, to reducing uncertainty. l 20 They are not reducing, as to the next question, as 21 i to when the uncertainty gets reduced far enough you can move 22 into a performance-based regime, but that kind of thought 23 process is the natural thing that happens as you get a 24 research result.
25 I mean to my mind any time research turns out a
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e 34 1 product, we should be looking at what does it mean, what is
() 2 the overall message that it is giving in terms of how we 3 might be able *o change our regulatory posture either up or 4 down.
5 That I think is the normal process of our research 6 and if we are not doing that, then we --
7 DR. APOSTOLAKIS: But Joe, just to clarify 8 something, the recommendations are talking hbout looking at
! 9 specific cases, right, and gaining experience in doing 10 things. 1 11 Is it not worthwhile to have a research project --
l l 12 I don't know how long it will be -- a year, two years 1 13 maximum -- where we have some people really think seriously i
14 about performance-based regulation and the problems that are l 15 there and what solutions we can have, and at the same time l
i 16 have also special cases, case studies, and put the two i I
17 together and finally have something, because I think it is 18 very important to understand why we can set the criteria at 19 a certain level and not at another level.
20 On the one hand, it seems to me that in a truly 21- ideal performance-based system the objective criteria have 22 to be as high as possible. That means as close to the QHOs.
23 On the other hand, we all know that that is really out of 24 the question. I mean you can't go all the way up there, so 25 how far down do you go?
i I
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35 1 What are the criteria, what are the competing I
() 2 reasons here that you finally have to hit the optical and 3 what is the optimal? I think that would be a nice research 4 project.
4 5 MR. MURPHY: I would agree with you. I think it's 6 something that would be nice to do. It would remain 7 subjective. I don't think you could ever make the thing --
8 to some extent -- fully objective.
9 DR. APOSTOLAKIS: No.
10 MR. MURPHY: In all honesty in today's world it 11 will have to compete against a lot of other research effort.
12 You know, it will get caught into the prioritization of the 13 research process.
14 DR. APOSTOLAKIS: Yes.
f_/
s_
t 15 MR. MURPHY: And I don't know how high up on the 16 list it is going to come but I don't want to judge that 17 preemptively either.
18 DR. APOSTOLAKIS: Maybe it's only a six-month 19 program.
20 MR. MURPHY: But clearly it is a thinking process 21 that I think if we are serious about going into this that we 22 need to get involved with.
23 DR. APOSTOLAKIS: That's right, because this is 24 now, I don't know, the fourth or fifth time we are talking 25 about performance-based regulation in a committee meeting (O
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I l
36 l 1 with you and the other members of the Staff. We always 2 discuas this and is it always, you know, I think this and l 3 you think that -- where should it be.
4 Like today you said thac the unavailability of a 5 train seems to you to be --
6 MR. MURPHY: We have some research ongoing at the 7 moment that is almost done.
8 DR. APOSTOLAKIS: Yes. )
9 MR. MURPHY: That.is exploring the general area 10 but not at the level of depth that you are going into.
11 DR. APOSTOLAKIS: We will hear about it some time? l 12 MR. MURPHY: Sure.
13 DR. APOSTOLAKIS: Okay. I think you are going 14 very slowly over your slides, Joe.
15 (Laughter.)
16 DR. KRESS: Shame on you, Joe.
17 DR. APOSTOLAKIS: I just don't understand why he 18 goes so slow.
19 MR. MURPHY: Well, I have to remind you, I was 20 here once when the slide caught fire because it was on so 21 long, but that was one that was over an hour, i 22 The negative aspects of performance-based is the 23 increased licensing in NRC and costs associated with 24 developing and reviewing the responses. They come up with 25 setting up such a system and perhaps a very significant cost ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
37 1 to the NRC itself for inspection and enforcement, because 2 what it comes down to is instead of having a t
i 3 one-size-fits-all type of regulatory structure, you have the
! 4 appropriate size for each of your licensees, but that makes 5 the inspection and the enforcement of it much more 6 difficult. The amount of training you have to give an l 7 inspector may be quite different.
l 8 It makes it much more difficult to enforce from So there's mixed messages associated i
l 9 the legal standpoint.
10 with how good it is in terms of the overall regulatory ,
11 posture.
12 We are definitely aiming towards this, but we 13 recognize that there are costs associated with it that may 14 be rather significant, particularly in the inspection and i i
15 enforcement area.
16 DR. APOSTOLAKIS: Joe, the document says -- and I 17 think that is what you just addressed, that given that 18 performance-based approaches are likely to result in less 19 uniformity across licensees, one should anticipate increased 20 costs.
21 So the argument here is that in a prescriptive 22 system, you have uniformity. In a performance-based system, 23 part of that uniformity is sacrificed. I am not disputing 24 that, but is that what you are saying?
25 MR. MURPHY: I am saying that is the way it has ANN RILEY & ASSOCIATES, LTD.
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38 1 evolved with time. The regulatory posture that this agency
() 2 went through for a long period cf time was a one size fits 3 all.
4 And another way you might say is we regulated to 5 the least common denominator. You looked at what your 6 poorer performers were and you set a regulatory structure 7 that was designed to make sure that those plants were safe.
8 And the plants that traditionally operated in a much better 9 mode were more or less penalized by the sins of their 10 brethren.
11 We have tried to shift -- what this would do would i
12 make it very much oriented to each individual plant. The a 13 difficulty with that is that if you are an inspector on 14 plant A and you get transferred to plant B, you got a lot to O
k~l 15 learn. Where in the past, the basic regulatory structure 16 was the same. You had to learn a new facility, but the 17 regulatory structure in which it was licensed was the same, l 18 You know, the changes were basically changes in tech specs, 19 but beyond that, you had to learn the facility, but you 20 didn't have to have a whole new approach. In this case, in 21 a performance-based case, it is much more difficult.
22 The same thing for someone who wants to say you 23 violated our regulations. In a performance-based system, it l 24 is much difficult to do. And so the imposition on the l 25 enforcement people and the legal people is somewhat higher
/3 t
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39 1 than it is in the current environment.
2 But I don't think prescriptive has to be that way, 3 but it is, in fact, the way it has evolved over the last 40
)
4 years of regulation.
5 DR. WALLIS: I hate to go back, we ought to go 6 forward. But I just think you ought to clear up for someone 7 who is not so involved, you previous slide which starts off 8 saying the pros are a more efficient and cost effective 9 regulatory response and then the cons are increased costs, 10 increased costs for various things. I don't understand what 11 the n.essage is here.
12 Is it more cost effective or less cost effecti e?
13 MR. MURPHY: The answer is yes.
14 DR. WALLIS: Well, then you can bear these other
! 15 costs because you are saving somewhere else.
l 16 MR. MURPHY: No, I think the answer is for each 17 specific case, as you come down, you are looking at a given 18 element. But you are thinking of changing the regulation, 19 you have to ask yourself that question. There's no overall l 20 answer that says cost -- that performance-based is always 21 better than prescriptive or vice versa, j 22- For a radiographer, I think the answer -- licenses 23 dealing with radiography, you definitely are going to get an 24' answer. I think that this has to be prescriptive.
25 When you get to a university reactor, I can say i
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40 1 philosophically I may want to say a performance-based system
() 2 makes a lot of sense, they need a lot of flexibility. But 3 in the same token, .I also recognize that a lot of them are 4 operating on shoestrings. And so if I impose a regulatory 5 structure that has a one time cost of a few million dollars <
6 to establish a performance-based system, I may shut them 7 down.
8 DR. WALLIS: I don't want a long answer, I just 9 say that if the decision is going to be based on cost 10 effectiveness, then these -- there's got to be a conclusion 11 that A is more cost effective than B in some general sense, 12 and you can not sort of weasel with it --
13 MR. MURPHY: Okay. That is --
14 DR. WALLIS: -- and say it is most cost effective, 15 but on the other hand it is more expense. It doesn't sort 16 of make sense to me. So I just --
17 MR. MURPHY: I would say --
18 DR. WALLIS: I am just aiming for clarity not a 19 long explanation, that's all.
20 MR. MURPHY: Yeah. It can be either. l 21 CHAIRMAN SEALE: Could I ask you a question?
I 22 DR. FONTANA: It probably depends on where you are 23 coming from, because it certainly should be easier for a 24 regulator to have specific go/no-go criteria, whereas, you 25 give the licensee flexibility to do it in a most efficient
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I.
L-41 1 way, it.is probably better for him.
() 2 MR. MURPHY: Yeah.
3 DR. FONTANA:. You know, so it depends. Like you I 4 said, it depends.
5 MR. MURPHY: Well, ultimately, he pays the bill, 6 too, so. This is the reason the --
7 CHAIRMAN SEALE: Joe, could I ask you right quick?
8 MR. MURPHY: -- first element of the plan -- I'm l
9 sorry.
10 CHAIRMAN SEALE: Could I ask you one question i
11 right quick? In the one cost -- one size fits all 12 regulatory approach, are there specific regulations which 13 are very useful'in examining some facilities and really l
14 never-minds in examining other facilities?
( 15 MR. MURPHY: I am sure the answer to that is yes, l i
16 but I can't give you an example. l 4
17 CHAIRMAN SEALE: I think that's the real point.
l 18 MR. MURPHY: Yeah.
19 CHAIRMAN SEALE: Okay, 20 MR. MURPHY: One of the reasons for our plan that 21 we want to highlight is the stakeholder impact, it is just 22 the kind of discussion we are having here. The people who i j 23 know best where a performance-based system can he.1p them are l 24 not regulators but the operators of the facilities. So what 25 we p an to do is -- as part of the efforts going on on the
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42 1 strategic plan, as part of the efforts going on as part of 2 the Commission response to DSI-13, there will be stakeholder 3 meetings, hopefully, this spring or summer, I guess this l
4 summer, to discuss the involvement cf industry in the 5 licensing process.
l 6 Not as a specific part of those meetings, but i 7 piggybacked onto them, we plan to have meetings to ask where 8 we can be more performance-based in the industry's view.
9 And it is along the line that we have taken several times in 10 the past, that if they would propose something to us, we can 11 then work on that much more -- it makes much more sense that 12 us trying to come up with the areas ourselves.
13 DR. APOSTOLAKIS: *You are separating ,
I 14 performance-based regulation from risk-informed? You don't 15 mention risk information anywhere here, do you?
l l
16 MR. MURPHY: I have not mentioned risk information l i
17 in any way. My view of the world is as follows, picture a 18 VIN diagram. It has two circles that intei ~. and I think 19 I showed this to the Committee once some timo 2 I don't 20 have a pen that will write on this thing.
21 DR. APOSTOLAKIS: That's fine. We can imagine.
I 22 MR. MURPHY: You know, I have a risk-informed l 23 circle, I have a performance-based circle and they l
24- intercept, so the interception is the risk-informed, 25 performance-based. That's the way I see it.
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43 1 DR. APOSTOLAKIS: Now, again, if we go to Plato's
() 2 world, the two should coincide.
3 MR. MURPHY: Yes, and it may be that our goal in l 4 time is to make them do that, but I don't think they do that 5 in today's world.
i 1 6 DR. APOSTOLAKIS: But it is -- I mean the risk l
l 7 information, though, is very relevant to the question how 8 high do I set the performance criteria.
l 9 MR. MURPHY: Definitely. Definitely. And it 10 influences this to the extent that we can do it.
11 DR APOSTOLAKIS: In fact, that is the argument 12 you used when I said let's put it at the safety function 13 level. You said common cause failures.
1 14 MR. MURPHY: Yeah.
15 DR. APOSTOLAKIS: Well, that is risk information, 16 right?
17 MR. MURPHY: Yeah.
18 DR. APOSTOLAKIS: And I don't see how else you can i
'19 do it.
l 20 DR. KRESS: You can intuitively decide on what 21 might be risk important and set performance standards based 22 on that intuition, although you have no idea how to quantify
'2 3. it in terms --
l 24 DR. APOSTOLAKIS: Yeah. Well, I mean you can l 25 always do things. The question is the logic behind them. I l
l
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44 1 mean you can say my intuition is this. Well, fine, you
() 2 know, I can not -- my point is that the only rational way of 3 setting up the performance criteria is through risk 4 arguments of the type that Joe gave us. You know, I really 5 don't really want to go to the safety function, because I 6 know I have to include common cause failures and I know the 7 uncertainties are large, so I have a problem with that. I 8 think that is a technical argument that, you know, you have 9 to address.
10 DR. KRESS: If that were the case, I would call 11 that risk-based.
12 DR. APOSTOLAKIS: No. No. No, becaus that is 13 not the only argument. I learned the words now, it is a 14 . major argument but not the only argument. There are other 15 things that will come into the picture instead of the ,
16 criteria. In fact, he has already given us other things.
17 The four desiderata, you know, you have -- it has to be away I 18 from something major, I would like core damage frequencies 19 eliminated, it has to satisfy certain other things. So it 20 is not just risk information. So as long as it is not only 21 risk information, it is not risk-based.
22 See, that is the kind of thing that I think that 23 research project I referred to should investigate, because ;
24 we always get warm in these meetings, we start talking about 25 these things and the time is up and then next time again, l
/*
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i l
l 45 1 CHAIRMAN SEALE: The passion dies.
I 2
! (A) DR. APOSTOLAKIS: Yeah, the passion -- well, for
! 3 some people.
4 Joe, let's go on.
5 MR. MURPHY: Okay. The remaining parts of the '
6 plan are to solicit the stakeholder input to acquire data on 7 those applications where we are already looking at t 8 performance-based. Many of those may well be risk-informed 9 applications. As I stated, they are ahead of the game.
10 Look to what the stakeholder input and our own 11 efforts say we should do in terms of screening regulatory 12 activities, and then conduct follow-on activities as needed, 13 which may lead to modifying the regulations.
14 Our recommendations on the next slide.
15 DR. APOSTOLAKIS: I still think that part of the 16 plan should be some sort of investigation of some of the key 17 issues, and I don't know where in these four bullets you 18 think that that will happen. I mean we have to think about 19 it, not just -- l 20 MR. MURPHY: I would agree we have to think about l 21 it. The reason I don't want to commit to it right now is 22 just strictly the resource applications. I 23 DR. APOSTOLAKIS: I understand.
24 MR. MURPHY: You know, what I don't know as to 25 what to tell you won't be done because I do this, and that's I
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! 46 1 the world we live it.
() 2 DR. APOSTOLAKIS: Could it be under analysis of 3 information? I mean you have analysis of information there, 4 so I don't know, that's not like the same thing though.
5 DR. WALLIS: Well, this will be done when there is 6 a reward for doing it.
7 DR. APOSTOLAKIS: The reward is?
l 8 DR. WALLIS: What is the reward?
9 MR. MURPHY: The reward, to my mind, in most cases 10 will be additional flexibility to the licensee.
11 DR. WALLIS: And if there is a real push from 12 somewhere, stakeholders or someone, to get this thing done, 13 --
14 MR. MURPHY: But I think --
15 DR. WALLIS: -- and there is a good reason given l
16 for why there is a reward, then mayba it will happen.
17 Otherwise, we could talk about it fcrever.
18 MR. MURPHY: I agree with you. Our l
19 recommendations are to have the stakeholder input, to l 20 participate in the workshops that are being tied to Strategy l 21 5 and tied to DSI-13. To collect the information that we l 22 can, and on the information identification phase of Strategy 23 5, which you will be hearing about tomorrow. The screening
! 24 process for candidate regulatory activities, again, that is 25 part of Strategy 5. It is something not too dissimilar from
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47 1 the Jereening process that is used in generic safety issue
() 2 pr'.oritization. And then coming out of that, we have will 3 h!.ve recommendations for additional agency action.
4 We will forward those recommendations to our 5 Program Review Committee and to the program offices and then 6 it falls into the normal prioritization process, with items 7 funded 50 the extent that there's resources available to do 8 them and they have been approved within the agency.
9 One recommendation we will make is that all 10 rulemaking activities that have been identified outside this 11 process that is associated with Strategy 5 also consider in 12 the rulemaking plans whether or not a performance-based '
13 approach makes sense and will modify the management 14 directive which describes the process for doing rulemaking, 15 to require that that kind of consideration be done in the 16 rulemaking plan.
17 The final bullet that all additional rulemakings 18 will be performed in accordance with the rulemaking 19 activities with the Management Directive 6.3 and tracked in 20 the rulemaking activity plan, isn't really a recommendation, 21 that is going to happen. I mean that is the way we operate.
22 Finally, there's the resource question. We are 23 going to rely basically on the resources that are currently 24 allocated within Research and within AEOD to start off this 25 process and this is the resources that are allocated for
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I 48 1 Strategy 5.
() 2 Now, what that includes right now is in-house 3 staff but no dollars. That makes it difficult for me to do 4 a research program outside. We are trying to see if there 5 is some way we can acquire those, but in terms of what is in 6 the budget right now, it is two FTE in Research and two FTE 7 in AEOD for the entire Strategy 5 process.
8 DR. WALLIS: Can I ask if you have some 9 articulated objectives and milestones and time scale and 10 things like that?
11 MR. MURPHY: We do not at the moment. We would 12 expect that to come out of our discussions with the 13 stakeholders where we have specific --
14 DR. WALLIS: But then you must have some planned 15 for when that is over and you start doing things. Just to 16 be sort of --
17 MR. MURPHY: Well, right now we are waiting for 18 the Commission SRM and DSI-13. Shortly after that, we will 19 set up and hold the stakeholders meetings, which they 20 haven't been set yet, I don't believe, but they will be this 21 summer. And shorcly after that, I think we have a plan of 22 action with dates associated with it. But I think that has 23 to happen first.
24 But once we make a recommendation for changes in 25 rulemaking as part of this process, then rulemaking has been
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49 1- transferred from the Office of Research to the Program 2 Office, so that recommendation will go to the Program 3 Office. And it will have to fit within their normal l 4 prioritization process.
5 DR. APOSTOLAKIS: Are there any plans to make the
(
6 q
maintenance rule performance-based? l l
1 7 MR. MURPHY: Well, there are people who believe 8 the maintenance rule is already performance-based.
9 DR. APOSTOLAKIS: No , it is not.
10 MR. MURPHY: And I would say it has --
l 11 DR. APOSTOLAKIS: It doesn't give flexibility to 12 the licensees. I mean no, we have not removed any of the 13 requirements, that is my understanding. It is not i
)
14 performance-based.
f 15 DR. FONTANA: The rule itself that is 10 CFR sure
)
16 looks performance-based. The implementation might be {
l 17 different.
l 18 DR. POWERS: George, I think most people concede t i
l 19 that the maintenance rule has a lot of performance-based l 20 characteristics in it.
l 21 DR. BARTON: But maybe it is not a complete 22 performance-based rule as we are describing 23 performance-based regulation, but it does have a lot of 24 attributes of performance-based.
25 DR. APOSTOLAKIS: What regulations were removed i
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t i
I 50 l
1 after the maintenance rule was instituted? I mean if it is (y 2 a performance-based thing, then we. removed something, right.
3 Because --
4 DR. FONTANA: I don't see what that follows.
l l 5 DR. BARTON: Does it have to be a one for one 6 correlation?
7 DR. APOSTOLAKIS: If it is in addition, then the 8 whole thing is a hoax. Anyway, that is my personal opinion.
l 9 It flies against --
10 MR. MURPHY: The performance-based rule -- the 11 performance rule -- maintenance rule, I'm sorry, is j 12 definitely an addition.
l 13 DR. APOSTOLAKIS: And is that consistent with the l 14 philosophy of performance-based regulation?
15 MR. MURPHY: It is not inconsistent with it.
l 16 DR. APOSTOLAKIS: Are you suggesting then, Joe, l
17 that everything you presented here will be additional 18 regulation?
19 MR. MURPHY: No. Not at all. What I am saying is i
) 20 that if, in the process of going through this, I find a gap 21 in the regulatory process --
l 22 DR. APOSTOLAKIS: Is it true --
l -23 MR. MURPHY: -- that I need to fill, I can fill it 24' with a performance-based rule, and it doesn't necessarily 25 have to take anything away. If I do not find a gap, and I
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l
51 1 find a'way of making the process more efficient, then, yes,
() 2 something may go away. It works both ways. , , .
3 DR. WALLIS: It occurs to me the' progress towards
! 4 making things more performance-based should itself be l
5 performance-based.
6 MR. MURPHY: I like that.
7 DR. APOSTOLAKIS: Isn't it true that the Office of 8 the Inspector General said that it was not l
l 9 performance-based?
l l 10 MR. MURPHY: I don't know the answer to that 11 question.
l 1 12 DR. APOSTOLAKIS: I read that report. It said it l 13 is not performance --
14 DR. BARTON: I think you may be right, George, I
,[
l j 15 think there's some words, 16 DR. APOSTOLAKIS: It is not performance-based.
- 17 And there is a lot of confusion about it. That's what it 18 said.
l 19 MR. MURPHY: You know, I --
I i
20 DR. APOSTOLAKIS: In the sense that no l 21 requirements were removed. I mean you are setting the l E
22 performance criteria, that is addition to everything else 23 ~ they'are doing.
l 24 MR. MURPHY: It is an addition, I will not argue 25 chat.
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52 1 DR. APOSTOLAKIS: Well, then --
l () 2 DR. SHACK: They could have added more 3 prescriptive rules, too.
4 CHAIRMAN SEALE: Let me amplify --
, 5 DR. APOSTOLAKIS: Well, I mean, yeah, and with a 6 PRA we can add new things, and that is why the industry is 7 so cool toward a PRA, because --
8 CHAIRMAN SEALE: If I may make one comment. Maybe i
9 no requirements were removed but, on the other hand, you 10 have seen what licensed renewal -- license renewal looked l
l 11 like before the maintenance rule came along.
12 DR. APOSTOLAKIS: Yeah l
l 13 CHAIRMAN SEALE: There were a lot of things that 14 were suggested to be in the license renewal package that i
15 were deleted when the general principle that if you 16 satisfied the maintenance rule, you were -- you had already 17 taken care of a lot of things that had been projected to be 18 put into that package.
19 DR. APOSTOLAKIS: Okay. So I start a new rule on 20 .something, maintenance, and that particular part gives 21 licensees flexibility how to calculate things, but they l.
l 22 still have to do everything else they were doing up until 23 today. Now, is that really a good definition of l 24 flexibility? I'm asking you to do something in addition to 25 what you've been doing, but now you're flexible when you're j
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L 53
-; 1 .doing this additional thing. Come on, guys.
'2 DR. POWERS: Well, I don't fathom your difficulty
.3 there.
4 DR. APOSTOLAKIS: Oh, I have great difficulty with 5- that. That's the whole point of this.
6 DR. POWERS: If I come along and I find that, 7 despite my best efforts in the past, that I have omitted a 8 particular aspect of an operation, feature of a system that 9 has the potential of leading to some hazard to the public 10 health and safety, and I say well, okay, I want people to
~
11 address this, and I need them to address that --
12 DR. APOSTOLAKIS: I have no problem with that. I 13 have no problem with that.
14 DR. POWERS: But you co, because --
15 DR. APOSTOLAKIS: No , I --
16 DR. POWERS: --
this is going to be in addition to 17 what I have required in the past, and now I say, well --
18 DR. APOSTOLAKIS: On the same thing.
'19 DR. POWERS: Yes, indeed, it can be on the same-20 thing. I have simply overlooked something, so I have some 21 additional requirement. I still have -- any additional 22 requirement has passed through the backfit rule, so that I 23 know it's cost-effective to do this, and if I require you to 24 do it in a performance-based sense, that's different than if 25 I laid down in Appendix S that prescribes things out in
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54 1 detail and exactly how you will do it. I guess I just don't
() 2 understand why you think that an increment in the regulatory 3 structure automatically is discounted from falling under the i category of performance based.
5 DR. APOSTOLAKIS: I didn't say any of that, Dana.
6 That's why you don't understand why I think it, because I 7 never said it.
8 DR. WALLIS: He's looking for a decrease or more 9 efficient means of getting to the same end with less fuss.
10 DR. POWERS: What you're focusing in it that you 11 would like to go through and change the regulations.
12 DR APOSTOLAKIS: Why not? Yes.
13 DR. POWERS: I'm asking the question. You're 14 focusing in on changing the regulations.
15 Now, if you change the regulations, of course, you 16 will have to pass through the backfit rule risk.
17 MR. MARKLEY: George, I would argue that what 18 you're talking about is more fitting for risk-informed where 19 you say something is not contributing to better safety 20 through risk, but performance-based in and of itself doesn't 21 mean deregulation. You're just talking about goals and 22 criteria and flexibility in how you meet a regulation.
23 DR. APOSTOLAKIS: When we are talking about 24 flexibility meeting the criteria, I thought we were talking 25 about the regulatory system where we have performance ANN RILEY & ASSOCIATES, LTD.
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55 1 measures and the licensee has flexibility. It never
() 2 occurred to me that we are talking about additional 3 regulation and we want this additional regulation to be 4 flexible. That's ridiculous.
5 DR. POWERS: I don't understand why -- that's the 6 step I never understand.
7 DR. APOSTOLAKIS: I never understand it, either.
8 So --
9 DR. POWERS: You come along and you --
10 DR. SHACK: If the additional regulation is 11 addressing an addition -- an issue that wasn't identified 12 before.
13 DR. WALLIS: No , but you seem to be believing in 14 the principle of the inevitable growth of bureaucracy. I 15 think what George --
16' DR. POWERS: I don't understand --
17 DR. WALLIS: There must be a way to make this 18 beast shrink, make it more agile and effective.
19 DR. POWERS: Go back and explain to me again why 20 it is that we believe in the inevitable growth of 21 bureaucracy.
22 DR. WALLIS: Because they see it. It's like the !
23 second law -- it has never been disproved yet.
24 DR. POWERS: I think I can find numerous cases 25 where the federal bureaucracy has, in fact, shrunk i
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56 1 dramatically.
() 2 DR. APOSTOLAKIS: Well, let me ask our guest, what 3 is the purpose of this initiative to move toward 4 performance-based regulation? What are we trying to do 5 here?
6 bUt. MURPHY: We are trying to install a better 7 regulatory system that provides flexibility tc the licensee 8 and still achieve safety.
9 DR. APOSTOLAKIS: Good. So better mean3 that we 10 have to change some parts of the existing system.
11 MR. MURPHY: I think in 90, perhaps more than 90 12 percent of the cases, we are talking about a system where we 13 substitute performance standards for prescriptive 14 regulation.
O k;/
% 15 DR. APOSTOLAKIS: Existing prescriptive 16 regulation.
17 MR. MURPHY: Existing prescriptive regulation. I 18 think in the vast majority, that is what we're talking 19 about.
20 DR. APOSTOLAKIS: Okay.
21 MR. MURPHY: But if in the process of doing the 22 search, we find, for want of a better word, I'll say a gap 23 in'the regulatory process that we feel needs filling under 24 the backfit rule, we will fill it.
l 25 DR. APOSTOLAKIS: And I don't have any problem l
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57 1 with that.
2 MR. MURPHY: And that may well be filled with a 3 performance-based rule if we can.
4 DR. APOSTOLAKIS: Right.
5 MR. MURPHY: So all I'm saying is it's not 6 definitely always one direction, but definitely the emphasis 7 is in the flexibility.
8 DR. APOSTOLAKIS: Right. I agree. So you said 9 that the intent is to take the existing structure and 10 replace it where we can by performance-based approach.
11 MR- MURPHY: Yes.
12 DR. APOSTOLAKIS: Now, does the maintenance rule 13 pass that criteria?
14 MR. MURPHY: The maintenance rule -- I guess I 15 don't understand the question. Now, if what you're asking 16 me is, should I go back and make the maintenance rule 17 performance based from what it is? Given that it's on the 18 books now, I go and change it to make it performance based?
19 Is that what you're asking me -- do I want to change the 20 existing rule?
21 DR. APOSTOLAKIS: All I'm asking you is you said 22 that you're going to -- the purpose of doing this is to have 23 a better regulatory system and remove perhaps some of the 24 existing requirements and replace them by a l 25 performance-based approach.
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r 1
58 1 Now, did the maintenance rule do that? !
2 MR. MURPHY: The maintenance rule does not meet l 3. all the requirements that I have identified in here as a 1 4 performance-based rule.
1 i
5 DR. APOSTOLAKIS: Okay. Exactly. i 6 i MR. MURPHY: But if you're asking me does that 7 mean I should then put the maintenance rule in the trash
\
l 8 can, -- !
9 DR. APOSTOLAKIS: No.
l 10 MR. MURPHY: -- I would say no. I 11 DR. POWERS: Remember, George seems to have an 12 affection for purity here.
13 DR. APOSTOLAKIS: I must say I thought I 1
14 understood this subject until two minutes ago, but I want to 15 finish on a happy note. I think you have a beautiful 16 sentence in its economy on page 5 under feasibility, the 17 last part of the first bullet: and the utility of a 18 calculated parameter diminishes as the uncertainty 19 associated with a calculation increases. I think the 20 thought is beautiful.
1 21 Now, what do you mean by the calculation, though? l 22 You mean model uncertainty or is it everyday English -- in 23 other words, the uncertainties involved?
24 MR. MURPHY: I mean the uncertainty involved.
25 DR. APOSTOLAKIS: Okay. But this is really good.
I l
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I 59 1 CHAIRMAN SEALE: Where was that sentence again?
() 2 MR. MURPHY: The first bullet under feasibility.
3 DR. SHACK: Page 5, the first bullet under 4 feasibility.
5 CHAIRMAN SEALE: Okay.
6 DR. APOSTOLAKIS: Well, I am done if you're done.
! 7 MR. MURPHY: I'm done.
8 DR. APOSTOLAKIS: Okay. Back to you, Mr.
9 Chairman.
10 DR. KRESS: We could have written that sentence in 11 at least five lines or more.
12 DR. APOSTOLAKIS: That's why the economy is really l 13 --
14 CHAIRMAN SEALE: Dr. Apostolakis is done. Are the l \_- 15 rest of the members of the committee done? Any other 16 comments on this subject?
17 Well, I think we should move along because we have 18 a tight schedule this morning. We will have a short recess 19 until five minutes after ten, and from then on until three 20 o' clock this afternoon, you're going to be in a dead run.
l 21 (Recess.] ]
I 22 CHAIRMAN SEALE: We are back in session and we're 23 going to hear about the AP600 ongoing review. That's Mr.
24 Barton's subcommittee, so I'll ask you to take over, John.
25 DR. BARTON: Thank you, Mr. Chairman. I won't l
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i 60 1 take my full five minutes. We spent the last day and a half
() 2 with the subcommittee on discussing Chapters 2, 9, 10, 12, 3 13, the security portion of Chapter 13, and Chapter 15.
4 Today, we ask Westinghouse to give us an overview of those 5 chapters that were discussed in some length the past day and 6 a half.
7 At this point, I will turn it over to Jim Winters, 8 or Brian, Brian McIntyre, who will lead the Westinghouse 9 discussion.
10 MR. McINTYRE: Okay. Thank you, Mr. Barton.
11 Jim and I are going to do a -- I guess I would 12 call it a fly-over of what we did in the last day and a 13 half. We've got about two slides per chapter just to cover 14 really the highlights, and Jim is going to talk about what i 15 he talked about and I'm going to talk about the rest of the 16 stuff.
17 In the interest of moving along -- Jim.
18 MR. WINTERS: Yes. My name is Jim Winters, 19 representing Westinghouse. We're going to go through the.
20 chapters just as Chairman Barton described except that 2 21 will be out of order; it will come after 12, 22 Chapter 9 is a chapter that includes all the 23 leftovers, auxiliary and secondary systems. We went over a 24 number of differences and features of these systems 25 yesterday. That included a discussion of our spent fuel 1
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l t
61 1 cooling system in an. accident condition, because our active
() 2 cooling. systems are non-safety, and also the fact that we 3 have graduated from having exemptions to 10 CFR 70.24, 4 Other interesting differences of AP600 from past 5 plants are that in all systems in Chapter 9, which includes 6 HVAC, water support systems and the like,.the only 7- safety-related functions'are containment isolation, reactor 8 coolant boundary isolation, and in the case of one HVAC 9 system, the boundary isolation of the main control room, and 10 that we have eliminated all of the safety-related functions 11 of our gas systems.
12 For any valve that is a gas-operated valve, the 13 removal of gas moves it to its safety position, or if moving 14 it to a safety position includes -- requires the stored 15 energy of pressurized gas, there is a bottle installed or a 16 chamber installed in the operator of the valve so that the 17 gas supply systems are not safety related.
18 We also discussed a number of features of our 19 -volume control system and purification system that are 20 simplified from past practice.
21 On your handout, please notice the change of the 22 third to the last bullet, that the word there is
- 23. purification, not participation.
24 The conclusion that we reached that the 33 25 auxiliary systems addressed in SSAR chapter 9 were adequate
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l 62 1 to support design certification -- there's really 34 -- fire l() 2 protection -- that was discussed in a different session 3 yesterday.
4 Going on to fire protection, we discussed that 1
5 l
[ AP600's adherence to Appendix R or BTP-9.5-1 is modified 6 slightly because of the passive systems. Our cold shutdown 7 is not achievable in a passive way. We need active systems 8 to get cold. However, our safety related story is based 9 upon what we call safe shutdown, which is -- lots of people i
1 10 call warm shutdown.
11 So the fire protection compliance story is also )
12 based upon warm shutdown, and in order to use that as a l 13 basis, there were three other caveats that we and the staff l
14 used for ensuring compliance with Appendix R. They are i
15 listed on this overhead, and we discussed them yesterday.
16 The conclusion was that the fire protection water i
l 17 supply system as well as the plant design features for fire l
18 protection are adequate to support design certification.
I 19 Chapter 10 is the st.eam and power conversion i i
20 system. That includes the turbine generator which supports 21 600-megawatt operation with proper over-speed protection, 22 main steam supply system, the condensate and feedwater i
23 systems, including the main and startup feedwater systems, l 4
24 main condenser and the support systems to operate the )
25 conversion system -- for example, aux steam and drains.
1 J
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63 1 On unique features, we discussed, in addition to
() .2 the turbine generator overspeed protection was that the main 3 steam system is qualified to leak before break. The 4 condensate and feedwater systems are non-safety in this 5 plant; however, we did discuss the features of the 6 connections of those systems to support cooldown and 7 shutdown operations if they're available. Main condenser is 8 a standard design. The support systems are standard 9 designs.
10 Again, the conclusion was that the AP600 steam and 11 power conversion systems are adequate to support design 12 certification.
13 DR. SHACK: What's the material of the main steam 14 supply system?
15 MR. WINTERS: That's a good question because 1 16 can't remember.
17 DR. SHACK: I'm just curious as to, if it's 18 qualified for leak before break, how you handled the problem j i
19 of flow-assisted corrosion.
20 MR. WINTERS: We did that by meeting industry 21 guidelines, and I'm not sure whether it's specified in a 22 standard or not, but industry guidelines on flow rates.
23 DR. SHACK: Oh.
24 MR. WINTERS: The main steam piping is large 1
25 enough to keep velocities down within the main steam piping.
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I 64 1 In addition, our blowdown piping is also designed for that
() 2 even though that's not leak before break. For the high 3 velocity systems, some of the high pressure drain systems 1
4 which have mixed flow, it doesn't have saturated steam but, 5 you know, has saturated steam and water droplets, they're 6 also designed for industry standard velocities.
7 We do have ---we specify -- we do specify a unique 8 material for the main steam system. We have, you know, i
9 standard carbon steel for most systems and the stainless i
10 steel for primary systems, and there is a unique steel l 11 specified for the main steam systems which is corrosion
'12 resistant; I just can't remember which type that is. It's 13 in the SSAR. So those two areas, we have selected a 14 materia:, a unique material for that system and the O 15 s
velocities.
l if Radiation protection. The context of chapter 12 17 in radiation protection is shielding basically direct 18 radiation. This isn't necessarily airborne radiation or 1
19 off-site affluence. There, we discuss'the bases. We ]
20 provided consideration for ALARA. For shielding, we use a 21 quarter percent filled fuel with conservative estimates on l
22 the transport of radioactive materials within the coolant i 23 that is taken outside of the main coolant for various 24 sampling and-purification reasons.
25 We are now using an unmodified NUREG-1465 for l
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65 1 accident sources, and any design features that need to be
() 2 included in the plant such as shield wall thicknesses or 3 times before access have been. included in the SSAR so that l 4 they will be covered by the certification process.
5 The results of that -- a summary of the results in 6 the three categories of particular interest for chapter 12 7 are shown on this slide. At the site boundary, there is no 8 noticeable -- or direct radiation is negligible at the plant j 9 site boundary. This is enhanced by our increased shielding i
10 within the reactor vessel as well as the numerous concrete l
11 shields that are between the reactor vessel and the public, l 12 There is a table here that describes the total l 13 operating man-rem per year, and that is well within the 14 requirements, and the last bullet discusses accident n/
N_ .15 operations. We have defined the operations required 16 following an accident, which for AP600 are few, but those 17 are defined in the chapter, and access paths and times for 1
18 those operations are defined, and we have shown that the 1
1 19 exposure to any individual following the recommendations 20 within the SSAR do not exceed the five rem total body or 75 21 rem to the extremities.
22 DR. BARTON: Again, this table represents a 23 refueling cycle year?
- 24 MR. WINTERS
- Yes, sir.
25 MR. BARTON: So an operating year --
1
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I 66 1 MR. WINTERS: An operating year with --
2 MR. BARTON: -- would be less. This is --
3 MR. WINTERS: Yes.
4 MR. BARTON: This is worst case.
5 MR. WINTERS: Right. Because it also includes 6 some in-service inspection, some shutdown --
7 MR. BARTON: But during refueling, you wouldn't be ;
8 --
9 MR. WINTERS: Right. Some shutdown inspections.
10 Right. I 11 MR. BARTON: Okay.
12 MR. WINTERS: Again, we came to the conclusion 13 that AP600 has radiation protection features adequate to 14 support design certification.
15 Now, that covers the plant aspects. Brian will 16 now go into the analysis aspects. If you have any questions 17 on the plant, we can discuss them now or wait until the end, 18 Chairman. It's up to you.
19 DR. BARTON: Well, you're going to be around, 20 right?
21 MR. WINTERS: I'll stay.
22 DR. BARTON: Okay. l 23 MR. WINTERS: Yes.
24 DR. BARTON: We'll hold the questions until the 1 25 end.
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I 1 67 1 MR. WINTERS: Okay.
2 I would like to turn the podium over to Mr. Brian 3 McIntyre. !
4 MR. McINTYRE: Chapter 2 are the site 5 characteristics, and basically what the site characteristics i l
6 amount to are the parameters that we use to design the
.7 AP600, and that the combined license applicant must meet 8 when they actually go to site the AP600.
9 The parameters that we have picked are the ones i 10 that are defined in the ALWR utility requirements document, 11 and they envelope most of the potential sites in the United 12 States. It excludes, as we discussed, the West Coast. We 13 have a .3G acceleration for this plant.
14 The types of things that are in Chapter 2 --
15 that's the listing of things -- Noel had asked me to say 16 some words about the Chi over 2 because there was some 17 question as to whether or not that -- what exactly we had 18 done to look at local conditions since it was sort of an 19 average, and if you looked at the table that we had i [
j 20 presented as part of this when Richard presented it, there l
21 were two numbers. There was one that was a yearly average 22 and then there was the ten to the minus three number for the 23 worst two hours.
24 Basically what those are -- this gets back to how 25 the combined license applicant would actually utilize that ANN RILEY & ASSOCIATES, LTD.
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l 68 >
1 when they wanted to site the plant, and that would be up to (O,/ 2 the combined license applicant and the NRC to see how those 3 measurements and what sort of histories were looked at for a ;
4 very, very specific site.
5 DR. KRESS: Let me ask you a question.
6 MR. McINTYRE: Sure.
7 DR. KRESS: The Chi over Q, of course, is a 8 result. It's the dose over the source.
9 MR. McINTYRE: Yes.
10 DR. KRESS: And it leaves open as to how that can !
11 be calculated by the licensee. It says, because it's a 12 calculable parameter, you can never measure it.
1 13 MR. McINTYRE: Right. I 14 DR. KRESS: So what it's telling the licensee is 15 for the dose, we don't want your calculated value to be any 1
16 higher than this --
17 MR. McINTYRE: Yes.
18 DR. KRESS: -- for the worst two-hour periods --
19 MR. McINTYRE: Right.
20 DR. KRESS: -- and for a long-term average, we 21 don't want it to be any higher than this.
22 MR. McINTYRE: Any higher than that, yes.
23 DR. KRESS: And it leaves open how that 24 calculation is to be made and then it would be left to the 25 NRC to look at how the specific licensee at the COL stage 1
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69 1 makes that determination. So you're not saying use-
) 2 anything; it's-just that's how you backed your number out.
3 MR. McINTYRE: Yes.
4 DR. KRESS: And you say this ought to be the 5 number that's achievable by a lot of sites, maybe not all, 6 but a lot of them.
7 MR. McINTYRE: Yes, that's right.
8 DR. KRESS: And we'll leave the determination of 9 how that's done to the later stage for approval by NRC.
l 10 MR. McINTYRE: Yes. l 11 DR. KRESS: Is that --
12 MR. McINTYRE: Yes, that's fair.
13 DR. KRESS: Is that pretty fair?
14 MR. McINTYRE: Yes.
15 DR. KRESS: So that could be the nature of how we 16 write that up. It's really nothing to complain about; it's 17 just the criteria. The society is --
18 MR. McINTYRE: Right.
19 DR. KRESS: -- one that will allow you to utilize 20 a lot of sites.
21 MR. McINTYRE: Yes. As we said, it defines the 22 site-related parameters, and you're right, it's not -- and 23 unfortunately, on the analysis side, we always look at it as
! 24 an input. But you're right, it's not something you put your 25 Chi over Q meter out there and measure.
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70 l
1 DR. KRESS: Most people think of that as an input 2 because it's the other side of the equation.
3 MR. McINTYRE: Yes.
l 4 DR. KRESS: Really, it's an output --
5 MR. McINTYRE: Right.
6 DR. KRESS: -- when you do it as a criteria.
l 7 MR. McINTYRE: For a designer, it's an input.
8 For security, we had a closed session where we 9 discussed the AP600 security design. It was described by 10 Martin Green as being performance based, and what we had i
11 done is we had looked at where the vital equipment was and i 12 specifically what we needed to do to protect each of these 13 areas which resulted in these -- Martin's words were jail 14 cages around certain doors that the staff had a number of 15 comments or the committee had a number of comments on.
16 One advantage the AP600 has is with the passive 17 systems, we are -- we can reduce the size of the vital 18 areas. We don't have to protect diesel generators and 29 cooling towers and things like that. That reduced size gets l 20 it down to you don't need to have a lot of people with l 21 frequent access, so you can pretty much control the area to
, 22 the nuclear island and the auxiliary building, let people in 1
23 there and they can basically do the work that they need to 24 do.
25 We achieve our delay. Traditional plants have ANN RILEY & ASSOCIATES, LTD.
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71 1 fences quite a ways from the boundary and they achieve their 2 delay. By the time it's going to take someone to transit 3 that time period, we're achieving our delay in the AP600 4 because we're not protecting the fence by having hardened 5 doors and protected area enclosures so people really cannot 6 get in very readily. This design also allows -- the smaller 7 design also allows the AP600 to have pretty much a rapid-8 response from the security force. If you looked at the 9 vulnerability analysis, it was times measured in seconds, 10 The staff has reviewed this, and from a security standpoint, 11 they found this approach to be acceptable.
12 If you look at the figure, what we have done is 13 basically the things that are within the dark line are the i 14 areas that are within the security area and the rest of the 15 things will be protected by the traditional, I guess I would 16 describe it as industrial security through the fence. So 17 it's inside the line is the area that we're protecting.
18 For the accident analyses -- and again, we're 19 looking at this point at the results of the accident l I
20 analysis, not the verification and validation of the 21 computer codes. That's being done by the Thermohydraulics 22 Subcommittee. We looked at large break and small break and 23 how we comply with the requirements of'10 CFR 50.46. The 24 SSAR analysis used the passive safeguard systems. We assume 25 a single limited -- limiting single failure in these ANN RILEY & ASSOCIATES, LTD.
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l 72 1 calculations just like we do for the traditional plants. We 2 did not use non-safety related systems like the safety
( 3 injection pumps, so it's only the passive systems.
4 The results show for the large double-ended cold l S. leg break that the peak clad temperature, even including the 1 6 uncertainty, is 1676 degrees fahrenheit. For the small l
7 break LOCAs, for small breaks up through the largest size in 8 the core cooling system, that there is no core uncovery, so 9 that the core -- the peak clad temperature just continues to 10 decrease from the steady state operating temperature. !
11 It turns out that that is not limiting with 12 respect to the large break, so the large break is the 13 limiting case for this. And we take credit for the 14 automatic depressurization system functioning and allowing 15 you to achieve an I'../ST injection, which then cools the core l
16 in the long term.
17 Our conclusions are that the large breaks bound 18 the small breaks for the AP600 and that the AP600 passive '
19 safeguards systems are effective. We meet the requirements 20 of 10 CFR 50.46 and we do show for this plant that there is, 21 I think, significantly more margin than in current operating 22 PWRs.
23 DR. WALLIS: Are you going to answer my question 24 about the 1800 degreee internal clad temperature which stays 25 up and went off the end of the figure and never came down?
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i 73 l
1 MR. McINTYRE: No today. l (O,1 2 DR. WALLIS: Not today. But it will be answered.
3 DR. BARTON: That will be an open committee issue.
4 MR. McINTYRE: It's on the Dudley list.
5 For the non-LOCA cases, we have used the codes 6 LOFTRAN and LOFTR2 that we use on our currently operating 7 plants. We made modifications to those codes. We had to 8 add the PRHR heat exchanger, which is replacing the 9 auxiliary feed, which we do in current plants, and we had to 10 add a core make-up tank model, which was developed from the 11 testing that we had done at the Walts Mill site. There were 12 no changes for these codes to the central code numerics; we 13 simply made modules and inserted those in the codes and used I
. 14 them as appropriate.
s 15 The conclusion from that presentation was that 16 we've made the appropriate modifications, we have done the 17 verification and validation against test data, and we meet 18 the requirements that the NRC has for these types of 19 calculations. We know of no open issues in this area.
20 Radiological consequences has been an area of much 21 discussion between the staff and Westinghouse. We are now 22 using the NURFC 1465 source term as published instead of the l l 23 TID or the EPRI source term. We have also gone to using the 24 total effective dose equivalent, or TEDI, I understand we 25 have to have an exemption from the regulations to use that.
N
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1 74 1 Even though it's what we were told to use, that the staff f- 2 was going to come back and tell us we need an exemption.
3 We're also using the sliding two-hour window instead of the 4 worst or -- excuse me -- the first two hours of the !
5 calculation, i
6 The radiological consequences of the loss of ,
i l 7 coolant accident, we don't have safety-related sprays.
l 8 Another area that we had been discussing with the staff had l 9 been the appropriate Lamda to use for this time. We have i
10 reached closure with the staff on that. They have done i
i 11 their independent calculations, and we are using the l 12 Polestar Model that we have discussed in previous 13 subcommittee meetings.
14 If you look at the worst two-hour dose, it turns
.) 15 out that it's -- for the large break LOCA, it's from one to I
16 three hours. To meet the dose requirements, we had to i
17 reduce the containment leak rate from .12 percent down to .1 !
18 percent, and we found that if we do that, we do meet the l 19 regulations. This slide shows how we did, shows that we are 20 under the SSAR dose. This is what we report in the SSAR. l i
21 The dose limits are what the staff has in the regulations l 22 that we need to meet. So the good news is that we did meet i 23 al .1, the regulations for this and we think that these items 24 are now closed.
25 DR. KRESS: Pardon me. Those numbers are l
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75 1 calculated using the Chi over Q value.
l 2 MR. McINTYRE: Yes.
3- DR. KRESS: You could have gone two ways. You l 4 could have reduced your leak rate --
5 MR. McINTYRE: Yes.
6 DR. KRESS: -- or you could have changed those Chi 7 over Q values.
l 8 MR, McINTYRE: We chose to reduce the leak rate 9 because that was something that we were in control of, and 10 by doing that, we don't clamp down too far on the specific 11 sites.
12 DR. KRESS: You don't restrict the sites as much 13- that way.
-~. 14 MR. McINTYRE: Right. And when we selected the /
l \ms/ 15 .12 percent back six years ago, we thought we might.have to 16 clamp down a little more, so we made it as high as we 17 thought we could make it with the knowledge at that time 18 that we could reduce it down to .1 if we had to.
19 So it's what Westinghouse is in control of and 20 what the sites, and we thought we would rather restrict it 21 on this end rather than restrict it on the site end.
22 DR. POWERS: When you look at your numbers on that 23 table, many of them are substantially below the dose limit i 24 you have there, save for the Loss of Coolant Accident, which 25 is very close to the limit.
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76 1 I mean does that cause you pause or concern?
() 2 MR. McINTYRE: Concern? No.
3 DR. KRESS: I believe the limit already as margin 4 built into it.
5 MR. McINTYRE: Yes, j
6 DR. POWERS: There aren't modification to the 7 plant that are likely that would change those numbers any?
8 MR. McINTYRE: Not that come to mind. You mean l 9 that would further change the Loss of Coolant Accident or 10 change the other numbers?
11 DR. BARTON: Loss of Coolant Accident is the one 12 that is really close.
13 DR. POWERS: Yes. Coolant accident you've got no 14 margin there at all.,
15 MR. McINTYRE: The only things that we could j 16 change would be further changing the leak rate to get it 1 17 down, and since we were told what source term we were going (
18 to use, there's not a lot of room there or coming back, 19 because we still think we're right, that we can get a better 20 lambda if we really came back to argue about it.
21 There was one faction back home that wanted to 22 come down and make those arguments and we elected to not do 23 that.
24 So I don't think there's anything we would do to 25 the plant. What you would really have to do is almost
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f 1 1 1 I
77 I 1 something like put in a safety-related spray and we are O)
( 2 not --
3 DR. POWERS: Well, that sounds like a great idea
, 4 but --
I !
5 [ Laughter. ]
, 6' DR. POWERS: I wonder why nobody thought of that. )
l 7 MR. McINTYRE: It didn't take long to get to that.
8 DR. POWERS: What you are saying is this is i
! 9 physics. It's not --
}
i 10 MR. McINTYRE: Yes. What would you do to the {
l 11 plant? I mean the stuff is in the atmosphere. There is l
l l 12 nothing washing it out. It's settling out, and the only I i
13 thing we could fuss with would be the leak rate or a spray 14 syr4 tem or something active.
' \('
15 DR. POWERS: I mean the point is it's not 16 configuring a pump from this side to that side doesn't do 17 anything for you on this. You are stuck with the physics. ;
18 MR. McINTYRE: We are stuck with the physics.
19 DR. KRESS: Those numbers, calculating a maximum 20 pressure and holding it there for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> --
21 MR. McINTYRE: Yes. l 22 DR. KRESS: -- the flow is choked during that 23 entire period.
l 24 MR. McINTYRE: Yes. If you did a realistic 25 calculation -- that is a good point. If you were to go back j l
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)
p 78 1 and actually look at the way the containment pressure does
() 2 come down, you would get something less than that.
3 DR. KRESS: But that is the way it's always been )
l 4 done, so -- f 5 MR. McINTYRE: Right, it's a conservative 6 calculation.
7 DR. FONTANA: Is that leak rate likely to be {
(
8 difficult to attain?
I 9 MR. McINTYRE: No. We don't believe so. It's one )
l 10 real advantage of the AP600. We have done things like 11 reduce the number of penetrations. There's a lot of design 12 features that let us get there, and somebody from the Staff 13 said that -- I think Graham had asked the question of what 14 the typical leak rates were, and it was from some large
)
\ 15 number down to I think it was like 3 percent down to .1 l
16 percent, so we think this is readily achievable. l l
17 If it wasn't readily achievable. If it wasn't L 18 readily achievable, I can assure the utilities would have 19 screamed and we would have changed'the Chi over Q.
20 DR. KRESS: Let me ask you another question, just 21 for my curiosity. When you calculate choke flow, normally 22 you have a square root of KGRT type relationship for the 23 flow velocity.
24 What T do you use? Is that the T associated with 25 a sequence -- you know, the sequence talks about pressure
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79 1 but it never talks about the temperature.
() 2 Is that the maximum temperature in the containment 3 or --
4 MR. McINTYRE: I don't know.
5 CHAIRMAN SEALE: Saturation in the --
6 MR. McINTYRE: I don't know. That's a good 7 question.
8 DR. KRESS: Maybe you could put that on your list.
9 MR. McINTYRE: Jim just pointed out that the other 10 thing that this has in these calculations, it has the .25 11 percent failed fuel for some of the things down on the 12 bottom, and clearly that is another conservatism that is in 13 the calculation.
14 DR. KRESS: I am only concerned with the top one.
Og
\m) 15 MR. McINTYRE: The one that is close to the limit.
16 Our conclusion here is that we do meet the 17 requirements that are in the 50.34 and that was the good 18 news, and we can now -- we have been arguing about this for 19 several years. We can now get on and do some other things 20 here.
21 In summary, we have completed a number of chapters
- 22 over the past two days. The Staff has issued their draft 23 FSER sections. There are no known open items. I didn't l 24 know what " identified" meant after I'd typed the slide, but 25 there are no known open items.
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80 1 The Staff hann't brought anything up. I don't
() 2 think anything came up in the subcommittee meeting that 3 would really constitute a serious open item.
4 We have provided Revision 21 to the Staff to 5 support them writing their FSERs, which were the updates for 6 these five chapters.
7 Monday morning at 6:30 I will be down at the 8 loading dock with a pickup truck with SSAR Rev. 22. Noel 9 has asked for 10 copies to be sent to you guys so that you 10 can have your own copies.
1 11 We think that May 1st is still achievable of i 12 getting the FSER done and we look forward to meeting with 13 you. I think it's now on the 13th and 14th for this 14 subcommittee to go over those chapters that are listed down 15 there at the bottom and the PRA and something called 16 regulatory treatment of nonsafety systems.
17 If there are no more questions, we will see you in 18 May.
19 DR. BARTON: Just sit tight. Are there any more 20 committee questions or comments before we ask the Staff for 21 their --
22 DR. WALLIS: Can we have both groups, the Staff and these Westinghouse people, here for questions?
I l 23
! l i
24 DR. BARTON: Sure. l 25 DR. WALLIS: I think I have some points that ANN RILEY & ASSOCIATES, LTD.
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() 2 DR.-BARTON: Okay. Would you like to hear the 3 Staff comments first?
4 DR. WALLIS: Could I make my comments first?
5 DR. BARTON: No, I said would you like to hear 6 the --
7 DR. WALLIS: I would like to hear the Staff 8 comments first.
9 DR. BARTON: Tom Kenyon.
10 DR. POWERS: Before we go to Tom, I'd just comment 11 that we left the subcommittee meeting with plans to examine 12 more closely Chapter 9-A and the rod ejection accident.
i 13 The speaker was correct that no open items were 14 there. We just wanted to look at it more carefully. It 15 seems to me appropriate to come to some resolution on those l 16 matters at our May subcommittee meeting.
17 I don't think that people dedicated to those 18 chapters will need to appear before us at that time. I i
19 I mean we'll either have questions or not and get
- 2. 0 some resolution on that so it is out of the system.
21 MR. McINTYRE: Sure.
l 22 DR. BARTON: Tom?
l 23 MR. KENYON: My name is Tom Kenyon. I am the l
24 Senior Project Manager on the AP600 review.
25 I just wanted to reaffirm what Brian said. The l
l l
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82 1 Staff has performed its review of these topic areas, and
() 2 although there are a few documentation items that are still 3 outstanding we expect them to be resolved in Chapter 22 when 4 Brian brings it up.
5 We currently have no open issues in these topic 6 areas and the Staff has determined that the design either 7 meets the regulations or Westinghouse's proposal is an 8 acceptable alternative to meeting the regulations, so we 9 have just decided that the design is acceptable.
10 As Brian said, we do believe that May 1st is 11 doable and we expect to have the advanced final SER to the 12 committee on May 1st.
13 We do have one response to a question that was 14 asked at the subcommittee meeting, if I can turn this over 15 to Jim Lyons.
16 MR. LYONS: Hi, I am Jim Lyons from the Plant 17 Systems Branch. There is one issue that actually Jay 18 Carroll raised at the Subcommittee meeting, really, an old 19 ACRS issue on the Standard Review Plan for chilled water 20 systems. We end up doing our reviews in accordance with 21 Standard Review Plan 9.2.2, which is just reactor auxiliary 22 cooling water systems, and we don't really address the 23 chillers specifically.
24 As part of the Standard Review Plan update program 25 that was carried out in the past years, we provided comments
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83 ;
1 to the group that was doing that, that they should consider
() 2 adding a -- the Standard Review Plan -- at least addressing 3 the chillers specifically in the Standard Review Plan and 4 maybe considering a complete Standard Review Plan for the 5 chilled water systems themselves.
6 What I found, going back to the people that have 7 worked on it, some things have been picked up. For example, 8 the chilled water systems,.the emergency chilled water 9 systems that are now listed in SRP 3.2.2, which gives lists 10 of fl'uid systems important to safety for both PWR and BWR
< 11 plants, there's two tables in there. But that's about it.
12 The other issues of trying to increase the amount 13 of information about chilled water systems has been carried 14 by them. There's -- from what I can tell, and I haven't 15 found the exact list, but there's a list of Standard Review 16 Plan sections that were proposed, new Standard Review Plan 17 section that were proposed, but they were never -- nothing 18 ever really was done with them because the program ended up 19 running out of time and money. And so right now, it is kind 20 of on hold on whether or not there would be a new Standard 21 Review Plan section for chilled water systems.
22 DR. BARTON: Thank you.
23 Graham.
24 DR. WALLIS: Yes. You guys did a very good job 25 yesterday of getting us through on time and today you have
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84 1 done the same thing. And as you did yesterday, I had time i 2 to read this Chapter 16 again and to look at -- is it 15?
3 Chapter 15 again. And to look also at the Standard Review 4 Plan, which I didn't know existed before.
j 5 This document becomes a public document 6 eventually?
8 DR. WALLIS: Yes.
9 MR. McINTYRE: It is a public document right now.
1 10 DR. WALLIS: Right. So, I think my -- I see what 11 you have done is you have followed the Standard Review Plan, 12 which to me looks like filling out an IRS 1040, only it's a 13 thousand times as long.
14 MR. McINTYRE: That's fair.
15 DR. WALLIS: And so you have satisfied NRR.
16 MR. McINTYRE: Yes.
17 DR. WALLIS: And I think you have done a good job 18 .of satisfying NRR, but we don't know the d.etails of that.
19 And once you and NRR are satisfied, this document goes out 20 in the world. The world looks at it. So it has got to be 21 intelligible to the world, and you have something out there 22 which you don't retract, so you can't sort of improve it 23 once it is out there.
24 I think it is very important that it be 25 intelli3;ible to the world. So there are some minor things ANN RILEY & ASSOCIATES, LTD.
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85 1 like editorial details. There are figures 15.6.5A.1 to 51
\ 2 which have no label identifying what they are. It took me a 3 long time to discover that these were sensitivity studies on 4 the large break LOCA, which actually are put in the text 5 before the actual description of the large creak LOCA, so it 6 is very difficult to put them in perspective. This is just 7 an example of the king of editorial stuff which I think 8 someone should do before this goes out to the world.
9 I mean you have done a very good job between you 10 and NRR, but there is something else that remains to be 11 done, that's what I am saying. <
12 Now, the big message on the LOCA that you have is 13 that there is enough water made available rapidly enough to 14 cool'a core, and I think you have satisfied NRR on that 15 score. But the information you present is different in each 16 scenario, and it is impossible for the reader to make l
17' comparisons.
18 For instance, in the large break LOCA, the message 19 is that the core empties, or at least the level in the 20 . vessel goes down below the core, and then reflood occurs, 21 the collapse levels reaches around six fect. Now, you do 22 you have a collapsed liquid level plot? Someone has to i
23 -believe that six foot of water collapsed is enough to cool l i
24 the whole core, which has to be the result of two phase )
25 phenomena, --
1 i
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[ 86 1 MR. McINTYRE: Right.
I 2 DR. WALLIS: -- bubbling up, splashing up.
(_
3 It would help if you had somewhere described to 4 the reader that, in fact, the core is taller than that. How 5 tall it is, how does the water get up there, things which --
6 the key thing is not to have a collapsed level in the core, 7 but it is to somehow get the water up to the rest of the 8 core. Anyway, you give the collapsed level, it stays around 9 six feet, and apparently this is an important measure.
10 When I get to the 10 inch small brtik, there is no 11 level plot, there is no plot of collapsed liquid level.
12 There is something that is referred to which is minimum 13 reactor coolant system mass inventory. Now, I don't know
,_ 14 what this is. wnere is this water? You see, what is the
( )
\_/ 15 coolant -- coolant system, to me, is the whole thing. Where 16 is the water? It is not necessary in the core. You are 17 talking about coolant system mass inventory. Where is it?
18 Do you mean in the whole system, or in the core itself?
19 MR. McINTYRE: I think it's in the whole system.
l l
20 DR. WALLIS: So why it is a measure of cooling the i 21 core. It is focused on, it is emphasized, the whole I
i 22 conclusions speak to it. And today you spoke about no core l
23 uncovery. I can't make any connection between your 24 statement of no core uncovery and this 70,000 pounds of 25 water in the system, all right. And I know that the CMT O ANN RILEY & ASSOCIATES, LTD.
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87 1 hasn't injected yet, so are you counting that or not? I ,
2 mean there has got to be more-clarity about these measures 3 of success and how they are inter-related.
4 You show a downcomer level and a pressurizer 5 level, but never do you show this collapsed liquid level in 6 the core which was emphasized so much in the other break.
7 And if you go to the two inch break, you find other things 8 appear in the figures.
9 And so, yes, you probably have done a great job by t
10 our NRR standard, but there is no congruity between the
' i 11 descriptions of these various accidents so that someone I 12 coming from the outside who doesn't have a thousand hours to 13 read it all and figure out what it means, can dig into
, 14 chapters and find out what is the height of the core, what b
d 15 is the volunia occupied by the rods and all that stuff, can 15 make a translation between these different measures.
l 17 I mean you yourself used this no core uncovery 18 statement today, which is probably a good one, but there is 19 no translation made for the reader between this and this i 20 amount of water which is somewhere, and supposedly is enough )
I 21 to cool the core. I do see there is a downcomer level which j 22 is pretty high, so maybe all the water is in the downcomer.
l 23 I mean there is no indication that the core has the water in 24 it.
25 And there is something else called mixture level ANN RILEY & ASSOCIATES, LTD.
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l 88 1 in upper plenum and core. Well, how is that related to the
() 2 collapsed level you talked about before?
l 3 I think these -- the key things that matter should 4 be focused on, and a lot of emphasis should be given in the 5 final document to clarity of exposition so that the reader 6 understands how these key measures of performance are 7 inter-related and how to understand what is going on in 8 these -- the most important LOCA events. I don't think that 9 takes much effort.
10 I think too much effort is being put into 11 producing a huge amount of documentation and figures for NRR 12 and not putting it together in a way which makes the story 13 really good for the world.
A 14- I didn't really want to make a speech.
kms/ 15 [ Laughter.)
16 DR. WALLIS: But is there any hope that this can 17 happen?
18 MR. McINTYRE: Is there any hope?
19 DR. WALLIS: It is the time for you to do 20 something like this. We don't have to change any 21 conclusions. The conclusions are probably all right, but 22 the exposition, the way in which it is explained is very 23- important for public consumption. !
24 MR. McINTYRE: Certainly not in what I am going to 25 deliver at 6:30 on Monday morning. l l
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89 1 DR. WALLIS: No.
( 2 MR. McINTYRE: We will go back and look at that in 3 terms of how someone from --
4 DR. WALLIS: I am wondering if you and NRR can do, 5 if it doesn't need somebody -- maybe someone in Westinghouse 6 who hasn't been so involved can look at it and say -- Now, 7 what is the real message? What are you trying to say. And 8 say so that the key figures and the key statements, so that 9 they can be related to each other and not have four 10 different measures of success which cannot ae translated 11 into each other for different kinds of accicents and things 12 like that.
13 MR. McINTYRE: We can go back and look and see if 14 there is some -- I liked clarity of exposition. That's a 15 nice term, I like that. That's -- we can go back and look.
16 DR. WALLIS: Again, you know, if peak core clad 17 temperature is the real thing, which it probably is, then, 18 of course, you have got to solve this thing about -- this 19 strange one that goes off -- the figure with, still at some 20 rather high temperature.
21 MR. McINTYRE: That is not a LOCA.
22 DR. WALLIS: It's rod ejection actually.
23 MR. McINTYRE: Right.
24 DR. WALLIS: Right.
25 DR. BARTON: I think we just added the second
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90 1 Graham Wallis bullet to our letter. The first one being the 2 curve that doesn't --
3 DR. WALLIS: I thought it was a fusillade 4 actually.
5 [ Laughter.]
6 MR. McINTYRE: That is a hard thing to put down as 7 an action item. You know, 1800 degrees we can deal with.
8 Clarity of exposition is a little more --
9 DR. POWERS: It's much too qualitative and 10 subjective of a requirement to impose at this late date. We 11 need some sort of quantification, Graham.
1 12 DR. KRESS: We are reverting back to the previous 13 discussion, I can tell, i 14 DR. WALLIS: Now, let me say, a judge yesterday j 15 made a decision and it is very important that the judge, in q 16 making this decision, explained the position of the court in 17 a way that was understandable to the public so that justice 18 could be seen to be done.
19 DR. POWERS: But, I will comment --
20 DR. WALLIS: I would hope that the same thing 21 would be found in the case of this SSAR. It is not just a 22 question of a court agreeing with -- well, I don't quite 23 know how to describe it to Westinghouse, but --
24 There has to be a judgment which is appreciated by 25 the greater society and understood.
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\
91 1 DR. POWERS: I think you'll find that the legal
() 2 decisions that explain to the general public sufficient that 3 people can arrive at the conclusion justice has been done or 4 not always the norm.
5 DR. WALLIS: I want to thank you. I think you did 6 a good job.
7 MR. McINTYRE: I can assure you, Dr. Wallis, that 8 we have certainly followed the precedent in this cas+ .;.at 9 there are over 100 almost identical to that out there, but I 10 think that's a fair comment.
11 We can go back and see if there is something that 12 can be done with a simple stroke of a pen. We will probably 13 not reformat the entire thing, but there are some things 14 that we can --
15 DR. WALLIS: Well, certainly cross-references 16 between different parts showing how they are inter-related 17 and translating what appear to be different measures in 18 different places would help a lot. 4 19 MR. McINTYRE: But we will find out what minimum 1
20 inventory means. I am reasonably sure that is for the -- l 21 DR. WALLIS: What did you mean by no core uncovery 22 that you used today? That expression is not explicitly 23 explained in this document and yet you thought it was a 24 great measure of success today.
25 MR. Mc1NTYRE: It's intuitively obvious -- is that
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92 1 a -- it's one of those terms of art, let's call it that --
() 2~ that's 'aybe a better description.
3 DR. BARTON: Are there any other comments at this 4 time?
5 If not, the committee's action is to issue an 6 interim report. covering the chapters that were discussed in 7 detail yesterday and your review today.
8 At this time I will turn the meeting back over to 9 Dr. Seale.
10 CHAIRMAN SEALE: Any further comments from any of 11 the members? The audience?
12 Well, thank you very much and we'll move on to the 13 next item here.
14 DR. POWERS: Brian, I think that in another 15' context Professor Wallis has suggested that the 16 documentation available ought to be sufficient to be
- 17. persuasive to Shakespearean scholars.
18 LR. WALLIS: That's a different level. Are we on
, 19 the record now?
l 20 [ Laughter.)
21 DR. WALLIS: There are people who are 22 knowledgeable in the field, in the world, who want to know 23 what went on here and understand it, and I think that's a 24 different problem of addressing the larger, unsophisticated 25 public and those sophisticated in other areas, but ANN RILEY.& ASSOCIATES, LTD.
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1 93 1 eventually they vote.
2 CHAIRMAN SEALE: Actually, I think your 3 identification of a succinct statement of what the success.
4 criteria for each of these accidents is a very reasonable 5 and straightforward way to remedy a lot of these problems.
6 DR. WALLIS: And they should be congruent. They 7 should be sort of translatable between different accidents, 8 so you can see the whole picture.
9' CHAIRMAN SEALE: Yes, I think you have got a much 10 nore -- a meatier bone to chew on now, Brian, than you had 11 at some of the previous discussions.
12 DR. SHACK: How about a PDF document instead of 13 something that has to be delivered by pickup truck?
14 MR. McINTYRE: That I will talk about.
15 We will get to that point. It is --
16 DR. SHACK: You can burn CDs a lot cheaper than 17 you can cut down trees and print these suckers.
18 MR. McINTYRE: Oh, but what it takes to run. You 19 have got to look at the specific logistics. For these 9000 20 pages we have probably several hundred files, Jim? --
21 several hundred files in Wordperfect which then need to be 22 beat into the next form to be stuffed into Adobe Acrobat to J l 23 get that PDF out. We will produce that because we have to 24 produce it because it ends up having to be on a CD-Rom so we 25 can give it to the NIST so the NIST can supply it as part of 1
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94 1 the public record.
Oj t 2 We don't have that. We are working to get to that 3 point, probably in the next three or four months.
4 Particularly then it is non-updatable, and it's just a 5 horrendous logistics issues.
6 DR. WALLIS: Brian, I am here today and I should 7 be boiling down my maple syrup and the essence of boiling 8 ' down maple syrup is you start with 40 gallons and you make 9 one gallon, and you remove what you don't want and you come 10 up with an essence of the syrup and it is a hell of a lot l
11 sweeter when it is boiled down than when it's large volume.
12 MR. McINTYRE: We have a constraint, as I think 13 you found out, now that you understand what the SRP is, in 14 something called Reg Guide 170, Rev. 3, which says all of O 15 the stuff has to be in the SSAR.
16 DR. WALLIS: I understand all that but it seems to )
I 17 me that if ACRS can do anything it is they can point out ,
i 18 that there is a bigger responsibility you have than just 19 going through a requirement to satisfy -- it's very 20 important, which is the Standard Review Plan, et cetera, but 21 there is something beyond that which also should be done.
22 CHAIRMAN SEALE: Thank you again, Brian. We 23 appreciate your sense of humor.
24 Okay. Now we will try to prepare ourselves for 25 our meeting with the Commissioners at 1 o' clock.
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95 1 (Whereupon, at 10:52 a.m., the meeting was 2 recessed, to reconvene at 2:45 p.m., this same day.]
3 4
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96 l' AFTERNOON SESSION t f l
2 (2:52 p.m.]
l 3 DR. KRESS: This is a part of the Thermal 4 Hydraulics Severe Accident Subcommittee. The subject is new 5 source terms for operating plants. You guys know what 6 source terms are, that's the fission products and the j 7 aerosols going into containment -- not escaping from
{
8 containment.
9 DR. POWERS: This is that primitive technology 10 relative to thermal hydraulics, right? I I
11 DR. KRESS: That's right. l t
\
12 DR. POWERS: In that case, Mr. Chairman, I am l 13 going to have to recuse myself completely from this area. I 14 believe they are using Sandia Laboratories as a contractor d 15 on at least some portion of this work, and I actually 16 believe I actually know who the guys are that are doing 1 *, work.
18 DR. KRESS: You are so --
19 CHAIRMAN SEALE: Double jeopardy.
20 DR. KRESS: You may speak up and offer. advice in l 21 matters of fact.
l l 22 DR. POWERS: Anecdotes about personalities 23 involved and things like that?
24 CHAIRMAN SEALE: But you may not vote.
25 DR. POWERS: I shall do my best to remain mum.
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97 1 DR. KRESS: I guess the question is, given these ;
() 2 new source terms, what are they, and if an operating plant 3 voluntarily decides to use them, can they use all of them, 4 or part of them, or some parts, or what is the process 5 there? So with what as a really weak introduction, I'll 6 turn it over to Charlie Ader to give a better introduction 7 than that.
8 Is Charlie back there?
9 MR. ADER: Yeah, I am back here. This is Charles 10 Ader, the Office of Research. I'll try to keep my remarks 11 very brief. Charlie Tinkler and Rich Emch are going to fill 12 you in on the details of the rebaselining.
13 As I assume you are aware, Office of Research 14 picked up the task to do a rebaseline, what we call 15 rebaselining for the new source term in October. We have 16 been working on a pretty tight schedule. We owe the 17 Commission some information in June. So we wanted to give 18 kind of an overview of the plans and the progress of the 19 work today.
20 As Tom said, the source terms have been around a 21 while. 1465 was issued, the revised source term was issued 22 back in '95. At that time applicable future plants, but 23 there has been a lot of interest from current plants to use 24 the source term. We are trying to do an assessment of how 25 that will be implemented in the regulatory process.
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98
\
1 I hope that is short enough, Charlie, I will let 2 -- Tinkler, I will let you pick up.
l 3 MR. TINKLER: Is it okay if I sit, or would you?
4 DR. KRESS: Sit, please. You might tell us what 5 you mean by rebaselining first.
L 6 MR. TINKLER: Sure. I am Charlie Tinkler from the l
7 Accident Evaluation Branch, the Office of Research. The 8 purpose of my presentation is to brief the Committee on the 9 elements and status of the source term rebaselining 10 initiative.
l 11 Briefly stated, rebaselining is a comparison of
! 12 the off-site, control room and EQ doses that one would 13 calculate for design basis analysis using the TI --
the
- 14 original TID source term in comparison to the revised or 15 updated source term described in NUREG-1465.
16 So -- and it will become a little clearer as I go 17 through the elements of the program. We sought to compare 18 them on a number of distinct and different bases so there 19 would be a full understanding -- How would the results 20 compare if we did the calculation as the NRC has 21 traditionally done the calculation? How would the results j 22 change if we did the calculation as utilities have 23 traditionally done the calculation? So we could examine the i
24 different perspectives one might have when implementing the '
i 25 revised source term.
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99 l 1 In my presentation, I will briefly summarize the i
ll 2 background of this issue, outline the program we have 3 undertaken, provide a sampling of the results and the 4 findings we have drawn to date. And following my 5 presentation, Richard Emch from the Emergency Preparedness 6 and Radiation Protection Branch in NRR will address the 7 rulemaking plan the review of pilot plants.
8 Design basis analysis of reactors requires a 9 consideration of a substantial fission product release into 10 the containment called the source term. And it is based on 11 an accident which really involves substantial or 12 considerable melting of the core. It is considerable core 13 damage. It is traditionally coupled with the containment 14 integrity design basis accident for the c_iculation of the 15 off-site dose.
16 The original source term was published in TID in 17 1962 and that source term is further addressed by 18 supplemental guidance in Reg. Guides 1.3 and 1.4.
19 Over the past 30 years, substantial research and 20 experience, including lessons learned from TMI, have gone 21 into the generation of a new source term, described in 22 NUREG-1465, alternately called the updated source term or 23 revised source term.
24 About -- I guess it was almost two years ago or 25 so, a number of plants indicated an interest in implementing i
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100 1 thie new source term, and they have been indicated as pilot 2 plants and that provided a further interest in the staff's l
3 undertaking a comparison, an explicit comparison between 4 these source terms.
5 The NRC, by revision to 10 CFR Parts 50 and 100, l 6 the reactor siting criteria issued in 1996, revised dose 7 accepta.- Jriteria. These are the acceptance criteria one 8 must meet & fter performing the off-site dose calculation.
9 For new plants, a new EAB and LPZ dose limit of 25 rem total 10 effective dc M equivalent was established. The EAB dose 11 still applies -- or applies for any two hour period. The 12 LPZ dose still applies for a 30 day period.
13 By comparison, current plants have two different 14 requirements, one for a thyroid dose and another for a whole 15 body dose. Again, there is a dose acceptance criteria for 16 the EAB and the LPZ, as shown here. I think it is generally 17 true to say that in many cases in the past, the thyroid dose 18 has been limiting.
19 By a staff requirements memo dated February 12th, 20 1997, the Commission approved the implementation of the 21 revised source term to operating reactors. The staff was 22 directed to proceed with rulemaking after completion of the 23 rebaselining and, basically, it is an urging to fully 24 understand the impacts of the revised source term before 25 embarking on significant regulatory reviews. ;
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101 1- The staff was also directed to include the 25 rem
, 'O q ,/ 2 total effective dose equivalent and worst two hours to be 3 factored into this implementation.
4 This is a summary comparison of the differences I
5 and, in some cases, similarities between the NUREG-1465 l 6 source term. I.dve shown the corresponding values from 7 NUREG-1465 for a PWR. There are slightly different numbers l l
8 but they are essentially the same for boiling water 1
9 reactors, with some -- again, some slight differences. l 10 One of the first differences I have shown here is 11 the nature of the timing of the release. The TID release i 12 was assumed to an instantaneous release to the containment 13 atmosphere. Something corresponding almost, I guess, to an 14 instantaneous pipe break -- or perhaps not, but there's '
15 something of a parallel level.
16 The 1465 release takes place over roughly 1.8 17 hours for PWR and about two hours for a BWR. When you 18 consider the release limited to the gap and early-in vessel.
19 NUREG-1465 originally defined a fission product release 20 associated with a full core melt accident in which the core 21 melted, the reactor vessel failed, core concrete interaction j 22 took place, and long term revolitization out of the vessel l 23 also took place.
[ 24 For design basis accident analysis, it has been 25 adopted that the NUREG-1465 source term would be limited to
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102 1 the gap and early-in vessels phases. By doing that, we get A
() 2 a rough correspondence of the magnitudes of the fission 3 product release. Both have 100 percent noble gas release.
4 TID had a 50 percent iodine release. NUREG-1465, when 5 limited to the gap and early-in vessel, has a 40 percent 6 iodine release.
7 One of the bigger differences is the treatment of 8 solids. TID has a 1 perc.snt solids release. In the case of 9 .-
10 DR. WALLIS: Can I ask you a question for 11 clarification? I am new to this game, really, and I can 12 understand what you are saying here. But what is the basis 13 of the release itself? Is this something that is assumed or i
1 14 is it something derived from rational analysis?
!\ 15 MR. TINKLER: Well, --
l 16 DR. WALLIS: You were talking about a complete
! 17 core meltdown and stuff like that. Is that -- that is just 18 the worst that you could possible imagine or --
19 MR. TINKLER: Well, it was -- it is not the worst 20 that you could possibly imagine, but it is a substantial 21 release of the fission product inventory of the core.
l l 22 DR. WALLIS: That's not what you are doing now, is l 23 it?
l 24 MR. TINKLER: Yes, we are --
25 DR. WALLIS: You're still doing that?
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103 1 MR. TINKLER: We are still -- we still -- you can
'/~N
'i
, ) 2 look at some of these magnitudes.
3 DR. WALLIS: So all these other analyses showing 4 it can't happen are irrelevant for this purpose.
5 MR. TINKLER: For this, for the design basis 6 analysis, we still retain an assumption of a substantial 7 release of fission products associated with it.
8 DR. WALLIS: What does substantial mean?
9 MR. TINKLER: Well, in this case we have 40 l
10 percent.
11 DR. WALLIS: You have to say how much.
I 12 DR. POWERS: If I can inject a comment, because I }
13 I know some context for this question. This 1465 source term '
14 was devised from -- taken from a variety of analyses of
\ 15 severe accidents done with fairly mechanistic descriptions 16 of both core degradation and fission product release. It is 17 not the most bounding of those, but it is in the higher 18 range.
19 DR. WALLIS: It has nothing to do with the LOCA 20 analyses, for instance, that we heard about?
21 DR. POWERS: No, these are more risk pertinent 22 reactions, our accidents that were analyzed. I believe that i
23 most of the 1465 accidents that were examined in creating j l
t 24 this were in fact risk dominant accidents. ;
25 DR. FONTANA: Historically, if you go back to TID
(
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104 1 14844, the question was there were some small experiments
() 2 that were done in Oak Ridge years and years and years ago.
3 They were melting down small bits of fuel entirely and the 4 information that you see here in the left-hand column is 5 kind of a rough summary of that. All noble gases come out.
6 A lot of iodine comes out and not too many solids comes out.
7 DR. WALLIS: I believe all that but the question 8 is how much -- percent of what.
9 MR. TINKLER: Percent of the total core inventory 1
10 of radionuclides.
11 DR. WALLIS: So you might as well do no LOCA 12 analysis shatsoever.
13 MR. TINKLER: This is a source term that by orders 14 of magnitude exceeds a source term you would get from an 15 ECCS analysis.
16 DR. WALLIS: The total is equivalent to, say, the 17 total reactivity in all of the nuclear tests ever performed.
18 Is that --
19 DR. POWERS: Nuclear tests?
20 DR. WALLIS: Yes. Total core inventory, let's 21 say.
22 DR. POWERS: The nuc' lear test produces 23 substantially different spectrum.
24 DR. WALLIS: I mean just say this is something 25 which is so out of all proportion.
1 I
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'1 105 1 DR. POWERS: All proportion to what?
() 2 MR. TINKLER: This is the release associated with 3 a severe accident, basically.
4 DR. WALLIS: There is a disconnect in my mind 1
5 between doing all this stuff to show it can never happen and 6 then suddenly assuming it does.
7 MR. TINKLER: That is true. That is true -- for 8 the purpose --
9 DR. WALLIS: There is no logical sequence 10 whatsoever.
11 DR. POWERS: Let me inject here. No , there is a 12 logic.
13 What you are seeing here is the manifestation of 14 the concept of defense-in-depth, that you do calculations to 15 assure you that the plant will never enter into an accident.
16 You do calculations such that if the plant does enter into 17 an accident the ECCS will get it out of that accident, and 18 now you are doing calculations to say all of that fails, ,
i 19 that now how well does the containment as your last barrier 20 prot.est you?
21 DR. WALLIS: Now I think I understand.
22 DR. KRESS: This is the insult the containment has 23 to withstand from the standpoint of radioactive --
24 DR. MILLER: Even though the probability of this
.25 release is virtually nonexistent --
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i l
l 106 1 DR. KRESS: No, this lack of risk dominant 2 accident has these kind of levels. The probability and the 3 consequences is risk dominant.
l 4 DR. POWERS: This would be your 10 to the minus 5 5th LERF. This is the kind of release to the containment 6 you would get in a 10 to the minus 5th --
l 7 DR. WALLIS: Has it ever came up energetically 8 enough to challenge the containment, hydrogen explosion or 9 anything?
10 DR. FONTANA: Graham, there's inconsistencies all 11 over the place here.
12 DR. WALLIS: Right.
13 DR. FONTANA: Yes. The containment physically has 14 to be designed to withstand a double-ended pipe break, steam 15 pressure, blah-blah-blah.
16 The radioactivity release that you calculate 17 somebody standing on a site boundary comes from these 18 numbers here.
19 DR. WALLIS: There is nothing else that insults 20 the containment like a hydrogen burn?
21 DR. KRESS: They do have to require a certain 22 amount of hydrogen.
23 DR. WALLIS: That is also in there?
24 MR. TINKLER: Well, for the offsite doses there is 25 quite little. I mean there is some but it's generally ANN RILEY & ASSOCIATES, LTD.
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l
\ 107 1 not --
() 2 DR. KRESS: He is talking about the pressure l 3 design basis. accident.
4 MR' TINKLER:
. Yes. The containment integrity l 5 design basis accident includes a substantial mass and energy j 6 release to the containment that the containment must be 7 capable of withstanding.
8 DR. WALLIS: Including hydrogen burn?
I 9 MR. TINKLER: No. (
l 10 DR. WALLIS: Something which while you have I 11 assumed the worst, you haven't quite got the worst.
12 MR. ADER: Charlie, I was going to say if I can i
13 add, the regulations require a postulation of a source term 14 that involves a substantial meltdown for the design base 3
\ 15 calculations. I 16 The TID is what is currently being used. It is 17 there. It is 100 percent of noble gases.
18 What we did in 1465 was to look at the risk 19 dominant scenarios from 1150 using the then-current best i 20 estimate codes. At that time a lot of that was based on the 21 source term code package but there was some MELCOR analysis l
22 to look at'the range of releases for these risk dominant 23 scenarios, and then took a mean -- a little ,
I l 24 oversimplification -- but we took a mean of the ranges of 25 releases from the fuel and then the releases from the
(
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.108 1
1 reactor coolant system into containment and this is a source
() 2 term that is put into containment for judging fission 3 product removal systems.
4 That is where you come up with the numbers, the 5 100 percent, the 40 percent, 30 percent cesium, et cetera.
6 As Dana said, it is not a bounding. It was not 7 the worst scenario but it is based on scenarios that have 8 station blackout. You don't have ECCS. So again it's 9 'trying to come up with a conservative source term for 10 purposes of judging containment features and removal spray 11 systems, et cetera.
12 DR. FONTANA: Of course, in the best of all worlds 13 you would look at each sequence individually, calculate the 14' source terms and indicate the response of the containment 15- and the systems that are in it -- first principles.
16 MR. ADER: In risk assessment, severe accident 17 analysis you do a more realistic best estimate.
18 MR. TINKLER: But this is a deterministic 19- calculation.
20 DR. KRESS: I think it is important to stress what
'21 Charlie said, that this is used to judge the containment.
22 MR. TINKLER: The inconsistencies are intentional i 23 and are intended to provide defense-in-depth, as Dana said.
24 MR. EMCH: This is Rich Emch, Chief of the I 25 Radiation Protection Section, NRR. l l
l 1
()
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109 1 There was a question earlier about the connection t
(_j\ 2 of all this to what you have heard over the last couple of 3 days. There is a connection, okay? The list on the 4 right-hand side here, NUREG-1465, is the source term that
)
5 was used to do the design bariis accident dose assessment for j 6 the AP600, the discussions we have had over the last few 7 days 1 l
8 Dr. Kress, when I promised you an opportunity to I
(
9 see it -- here it is.
10 MR. TINKLER: One of the points I wanted to make 11 here is if there is any doubt that we no longer consider a 12 substantial release of fission products in the revised 13 source term, this shoald persuade you otherwise.
1 14 (Laughter.] l
[ )
(/ 15 MR. TINKLER: This is a large release of fission .
16 products -- 30 percent of the iodines.
1 17 Before we ascumed 1 percent of the cesium. We now 18 assume 30 percent of the cesium.
19 This is on a more consistent basis between the 20 various radionuclides, but it is indeed a large source term.
21 You do see a substantial change in the chemical 22 form of the iodine released to the containment. The TID 23 source term assumed 91 percent, inorganic vapor -- often 24 termed elemental iodine -- whether it was elemental or HIs 25 is not really consequential -- but it is inorganic vapor, 4 f3
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110 1 percent organic vapor, and 5 percent aerosol.
() 2 An abundance of data calculations suggests that it 3 really is the crter way around. It is virtually all 4 aerosol, mostly in the form of cesium iodide. There is some 5 inorganic vapor and a very small quantity of organic vapor.
6 That chemical form of iodine presumes --
7 DR. KRESS: For the record, I have to declare that 8 I am conflicted on those numbers also.
9 MR. TINKLER: But you have not necessarily a 10 conflict with those numbers?
11 DR. KRESS: I am conflicted only because basically 12 I developed those particular percentages at Oak Ridge.
13 DR. POWERS: And so now you are dissociating 14 yourself from any involvement with these, right?
15 DR. KRESS: That's right.
16 DR. POWERS: Yes -- you keep away from those 17 numbers.
18 [ Laughter.)
19 DR. WALLIS: Like the AP600, this is a homogeneous 20 mixture in this vessel?
21 MR. TINKLER: Yes.
22 DR. WALLIS: In this containment.
23 MR. TINKLER: In this containment -- oh, let me 24 just clarity one thing.
25 The particular dose calculations may divide the ANN RILEY & ASSOCIATES, LTD.
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111 1 containment up into various regions for the purpose of the
() 2 dose calculation. If a containment has a spray, contains a 3 spray for example, they mado divide the containment up into 4 sprayed and unsprayed regions based on line of sight 5 considerations and compartmentalization, so that you 6 wouldn't get the same fission product scrubbing from the
~7 sprays in some regions of the containment from others, but 8 that is not based on a C of D calculation, of mixing between 9 the sprayed and unsprayed regions.
10 It is based on empirical flows judged to occur 11 between sprayed and unsprayed regions.
12 Normally the solids were ignored for the offsite 13 dose calculation.
14 They were considered and are considered for the 15 equipment qualification dose calculation. For NUREG-1465 16 the solids are treated as an aerosol release.
17 DR. POWERS: Let me make sure, Graham, you 18 understand that the right-hand source term is not 19 instantaneously put into the containment and sitting there 20 as a homogeneous mass in that containment.
21 It is put in there over a period of time.
22 DR. WALLIS: Linear fashion.
23 MR. TINKLER: Linear.
24 DR. POWERS: Yes, it's a constant fashion.
25 DR. WALLIS: It is still 40 percent of all the i ANN RILEY & ASSOCIATES, LTD.
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112 1 iodines in the core?
() 2 MR. TINKLER: Yes.
3- DR. WALLIS: Okay. Maybe it's just so 4 mind-boggling --
51 DR. POWERS: If you want to be boggled, turn those
)
6 numbers into curies and you will see that you are talking 7 about a ferocious --
8 DR. WALLIS: Nuclear weapons --
9 DR. POWERS: I wouldn't compare them because the 10 source spectrum is so vastly different --
11 DR. WALLIS: In terms of curies you can do it.
12 DR. POWERS: These actually have some lifetime to 13 them.
' 14 DR. WALLIS: There are no actinides involved.
15 DR. POWERS: Oh, yes, there are.
16 MR TINKLER: Yes. Yes, I have others here but 17 this includes refractory radionuclides, plutonium --
18 DR. WALLIS: It includes them as well?
- 19. MR. TINKLER: Yes. Now those fractions get 20 smaller but they are still in there.
21 DR. POWERS: A core meltdown event is a traumatic 22 .high temperature event and you get -- if you were to look at 23 the materials that were actually physically vaporized from 24 the core, all those numbers go up a substantial amount.
25 There is a large amount of margin between the ANN RILEY & ASSOCIATES, LTD.
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113 1 releases from the core and that that actually reaches the
() 2 containment because of the deposition in the piping system, 3 and that is why mechanistic models had to be used to 4 calculate that.
5 DR. WALLIS: Why the others are so small a 6 percent.
7 DR. POWERS: Some of that is low vaporization and l 8 a lot of it deposits that does get vaporized on a fractional 9 basis, I think, what 90 percent of the other refractories l
10 drop out in the piping system typically?'
\
11 CHAIRMAN SEALE: There are lot of cold surfaces t
I 12 there.
i 1
l l 13 MR. TINKLER: But limiting it to the early 14 invessel, it also restricts some of those low volatile A
) 15 radionuclides anyway.
16 DR. POWERS: Sure, but those restrictions are not i
17 capricious and arbitrary. Those are based on a vast number 18 of experiments done in no small part by the gentleman to l
19 your immediate left.
20 MR. TINKLER: An integral test underway currently 21 basically confirmed that at least in the case of the iodine I i
l 22 release these chemical forms are generally appropriate and 23 may actually be conservative still -- more than likely.
I 24 DR. POWERS: A leap that I am not willing to make 25 right now.
t l
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114 1 DR. KRESS: I think there is disagreement on that.
)
2 DR. POWERS: I would like Charlie's words 3 generally confirmed rather than demonstrably conservative.
4 MR. TINKLER: We are still in the throes of some 5 of those programs so, you know, you k=ve got to expect some 6 of that.
7 DR. KRESS: PHOEBUS results look a little funny.
8 DR. POWERS: Well, they're French, you know.
9 [ Laughter.]
10 MR. TINKLER: I included this to illustrate what 11 you might see as a result of implementing the revised source l 12 term for one particular plant, because it has a somewhat 13 unique characteristic, but not so unique in that it doesn't 14 represent an occurrence which is prevalent for a lot of l
15 plants.
16 Because the old TID was an instantaneous source 17 term, systems that were designed to mitigate the offsite 18 dose had to be actuated very promptly, almost instantly 19 because if the dose is released to the containment 20 instantly, in order to mitigate the two hour dose you have 21 to have a system that turns on quickly.
22 In the case of Surry, which is a subatmospheric 23 containment, the design concept is to bring the containment 24 atmosphere to a subatmospheric condition within one hour.
25 Therefore, after one hour the containment will not
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115 1 leak, and there will be no incremental dose -- so all the e-(T j 2 dose you get is the. dose you get from that first hour.
3 Well, if you released the dose instantaneously you l
4 can see that you get 50 percent of the iodines with 50 l 5 percent playout, 25 percent of the iodines released j 6 instantly available to the containment.
7 If you go to the revised source term, over the 8 first hour you have only released maybe a third -- you could 9 look at the area under that curve is roughly -- so you get 10 an immediate benefit by going to a time-dependent release.
11 DR. FONTANA: If you did a sequence by sequence 12 probabilistic assessment you'd probably even do better as 13 far as which equipment has to work within a certain amount 14 of time and so on -- maybe.
15 MR. TINKLER: Well, you are asking to consider 16 both what is required for a severe accident and what is 17 required to meet Part 100 dose acceptance criteria, and that 18 becomes a little tricky, but the timing of the release as 19 Charlie Ader indicated was based on a consideration of a i 20 number of sequences from 1150.
21 If you look at some sequences, the onset of 22 fission product release would be even more delayed than 1465 23 dictates and the release would be slower.
24 DR. FONTANA: That is one of the biggest benefits i
25 that you get is more time allowed to get equipment -- .
i I
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i 116 1 MR. TINKLER: That is a significant benefit, the
() 2 timing of the release.
3 DR. KRESS: Mario, speaking of that, if you did it 4 sequence by sequence, if you gave this thing the Reg Guide 5 1.174 treatment to see what the effect of the new source 6 term would have on risk of delta CDF and delta LERF, I doubt 7 it you would see it.
8 DR. FONTANA: You wouldn't see it because those 9 sequences are --
10 DR. KRESS: And in fact it may be a negative 11 change in risk with the new source term if you did it 12 properly. I doubt if you would see it in PRA space. 'i l
13 MR. TINKLER: Timing is a significant difference. '
14 The organic contribution of iodine is also of significance, 15 and you have heard discussions about charcoal filters 16 because of low organic releases now.
17 DR. FONTANA: No, you don't need charcoal filters 18 anymore.
19 MR. TINKLER: Well, if you think you have to 20 control organic iodine, then you can reassess those issues.
1 21 Whether or not you need them is another broader issue. l l
22 DR. POWERS: What you have to remember is that he 1
23 is speaking of the source term to the containment. ;
24 MR. TINKLER: Right.
25 DR. POWERS: Now the marvel of iodine is that it
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117 1 does other things in the containment and so your assessment 2 is convoluted by that marvel of chemistry that takes place 3 in the containment, whereas there is a growing database -- I 4 hesitate to say that we are axiomatically predictive in 5 this -- in how that iodine changes while it is in the 6 ~ containment.
7 MR. TINKLER: I think I have already gone over 8 these points.
9 Basically the rebaselining was to compare tne 10 doses for an individual received dose, the equipment 11 qualification dose.
! 12 Part of the rebaselining is intended to address 13 the effect of potential plant modifications including those 14 plant modifications' impact on severe accident risk.
l 15 Some of the pilot plants have indicated a desire 16 to make some changes to safety systems. Changes to those
(
l 17 safety systems may still allow them to meet Part 100, but 18 part of this project is to assess where those changes to 19 those safety systems will in any way impact the severe 20 accident risk.
21 DR. KRESS: I would give it the Reg Guide 1.174 22 treatment.
23 MR. TINKLER: So that was one of the objectives of 24 this project.
25 DR. WALLIS: Would you educate me some more? I'm ANN RILEY & ASSOCIATES, LTD.
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118 1 sorry, where is this individual who is receiving the dose?
1
() 2 MR. TINKLER: This is an individual at either the 3 EAB. distance, the exclusionary boundary --
4 DR. WALLIS: Is he downwind or she downwind?
5 MR. TINKLER: In this case they are downwind in j 6 the path of the plume.
7 DR. WALLIS: Is the plume coming out, oozing out 8 from every pore of this containment or is it oozing out of 9 one hole in it?
10 MR. TINKLER: It is generally one release path.
11 DR. WALLIS: So there is one point source from l
12 this containment other than --
13 MR. TINKLER: You usually assume ground release.
14 DR. KRESS: You assume that the release is at O 15 ground level.
}
16 DR. POWERS: And at a distance of A or B it really 17 matters not whether you are oozing out of every pore or you 18 have a single point release. It behaves like a single point 19 release at that distance.
l 20 DR. WALLIS: Thank you.
21 MR. TINKLER: And the individual stays there and 22 breathes deeply.
23 [ Laughter.)
24 DR. POWERS: And for a long time.
25 DR. KRESS: Part of the specification has to be
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F l
119 1 some sort of energy associated with that release so as you
() 2 can make a downwind calculation -- somehow get that out of 3 your large break LOCA.
4 MR. TINKLER: For the purpose of managing this 1
5 effort and, basically, to divide up the work into !
t 6 discernible and distinguishable tasks, we broke this down 1 l \
7 into four phases.
8 In Phase I we repeat TID and 1465 dose ,
9 calculations, off-site dose calculations, using the models l 10 and assumptions that were described in the SERs for the l
11 representative plants chosen.
12 CDR . KRESS: Use MACCS for that?
p 13 MR. TINKLER: No, we used, in this case we used l
L 14 RADTRAD and/or HABIT, okay, which is the design basis, the 15 design basis models. MACCS has the probabalistic 16 meteorology.
17 DR. KRESS: Right.
l
! 18 MR. TINKLER: In Phase II, we repeated these same l 19 calculations using the models and assumptions employed by.
l 20 the utilities when they do these calculations in an FSAR to I' 21 see what kind of differences they might see when they go to 22 the new model.
l l 23 DR. UHRIG: So it is not plant-specific, that is a 24 generic?
25 MR. TINKLER: Actually, these were plant specific. j i
l
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120 1 DR. UHRIG: They were.
2 MR. TINKLER: These were -- these are.
3 DR. UHRIG: For the particular plants.
4 MR. TINKLER: For the particular plants chosen.
I 5 DR. UHRIG: Thank you. l 6 MR. TINKLER: In the rebaselining, so far we.have b
7 focused on the Grand Gulf, Surry and Zion plants to give a 8 representation of the different classes of reactors.
9 in Phase III we are focused solely on the 10 NUREG-1465 revised source term, and in this case we have 11 repeated calculations using the current SRP assumptions for 12 treatment of firsion product removal with reviaed and 13 updated models that were developed at Sandia, that were done 14 in parallel with the development of the revised source term.
15 This was work that was done to reevaluate fission product 16 scrubbing due to the cperation of containment sprays, 17 suppression pool scrubbing, natural removal mechanisms.
18 DR. KRESS: I might add to that, that that was a 19 pretty good piece of work. I don't know who at Sandia did 20 that, but it was an awfully good piece of work.
21 [Laug/1ter. ]
22 DR. POWERS: And I will get that money to you 23 l tomorrow afternoon, Tom, if that is okay, i 24 [ Laughter.]
25 MR. TINKLER: One of the other issues we wanted to I
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121 1 look at in this phase is, dare I say it, the consistency in 2 some of the thermal hydraulic assumptions between 1465 and I 3 the design basis LOCA for containment integrity.
4 And, basically, one of the principal issues 5 identified was, in the case of a boiling water reactor, when 6 you release the fission products over'an extended period of {
7 time, it is not clear that you should assume those fission 8 products are swept through the suppression pool as you might I 9 normally do in these calculations, because the fission
(
10 products are actually released after the initial blowdown of '
11 the stored energy of the reactor coolant system.
1 12 So you don't have that same driving force to push 13 fission products through the suppression pool. So we wanted 14 to look at these issues of suppression pool bypass and O 15 fission product. scrubbing as part of this.
l 16 We also included in'this phase some fully 17 consistent severe accident calculations using the MELCOR l 18 code. And in this case, we just -- we picked some scenarios j 19 that have some correspondence to the design basis accident j 1
20 in terms of looking at pipe breaks. But we wanted to do the 21 calculation in a fully consistent matter, that is, calculate 22 the fission -- the generation and release of fission 23 products, the thermal hydraulic boundary conditions inside 24 the containment as well as containment leakage, because as 25 containment pressure decreases you would expect a decrease I
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122 1 in containment leakage, instantaneously, as opposed to the es i
(,) 2 way the design basis calculation is done, which assumes a !
3 constant containment leakage rate for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and then is I l
4 reduced.
l 5 We also, under this phase, have looked at the pH '
6 and dispersion factors. The chemical forms of iodine 7 assumed in NUREG-1465 assume that the containment sump or 8 suppression pool is buffered and is maintained in an 9 alkaline condition, so that that there isn't a large 10 revolitization of iodine. We are doing calculations to 11 examine the pH conditions in a typical BWR.
12 Under Phase IV, we are looking at the impact of l 13 proposed plant changes, or candidate plant changes, what 14 those changes may reveal for the DBA dose. We are also looking again at the risk impacts of those changes and at
\_- 15 16 non-dose effects that timing might allow, changes in purge 17 valve isolation enclosure, things like that, because it 18 could have an impact on other calculations like ECCS 19 backpressure.
20 I have already described what, basically, was the 21 intention of Phase I. Again, we looked at -- these 22 calculations in Phase I, we were restricted to Surry and 23 Grand Gulf. We did analyze the off-site dose for the LOCA, 24 the fuel handling, main steamline break accidents, as well 25 as the rod drop accidents. The calculations were performed
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123 1 for the EAB, the LPZ and the control room dose.
2 In Phase II, again, we looked at 1465 versus the 3 TID source term using the FSAR assumptions and models. And 4 in this phase, we included the equipment qualification --
5 the calculation of equipment qualification dose. In this 6 phase we added calculations for Zion because we wanted to --
7 .we wanted to capture something which is a little more 8 mundane, a simple volume that has a spray system and a 9 constant, near constant release that is unmitigated by 10 enclosure buildings and other more complicated systems.
11 We have done quite a few calculations. It is well 12 beyond the time we have in this meeting to talk about the 13 overwhelming majority of them. So I have included in here a 14 sample of some of the calculations to address the 15 ' differences between the TID source term and 1465, from Phase 16 II, specifically, the Grand Gulf LOCA.
17 Basically, you can see that overall, 1465 will 18 generally allow for the calculation of a lower dose. In the 19 case of the EAB thyroid dose, -- again, let me point out, 20 also, that what I have shown here is the -- unless otherwise 21 indicated, the dose results from the first two hours. In 22 parentheses, we have when the worst -- when the worst two 23 hour dose is something other than the first two hours, so it 24 gives you an indication.
25 In the case of the EAB thyroid, for example, 23.1 i ANN RILEY & ASSOCIATES, LTD.
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l 124 1 is the worst two hour dose and it is the first two hours.
() 2 In the case of NUREG-1465, the first two hour dose is 12.6 3 rem. The worst two hour dose is 24.2 and it begins at 1.4 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
5 Now, some of this comes because some of these 6 plants have enclosure buildings so the containment doesn't 7 leak to the environs directly, it leaks to the enclosure 8 building, and then the enclosure building leaks to the 9 environs. So the source term doesn't appear for some time 10 in the enclosure building. You have to reach a new 11 equilibrium and you leak at that point out to the environs.
12 In the case of the thyroid dose, the dose I
13 reduction from the delayed release, the timing of the new !
i 14 source term, is all set because of increased pool bypass.
15 And what I am getting at here is, in the case -- we used the 16 FSAR assumptions. So in the FSAR, there's a large release, 17 a large steam release to the drywell, which purges the 18 source term through the suppression pool in the case of TID.
19 But because we now release our source term after the 20 blowdown, we get very little suppression pool scrubbing with 21 NUREG-1465.
22 In fact, most of the dose, as calculated by the 23 utility, bypasses the suppression pool, but it is then 24 captured by the containment sprays in the case of Grand 25 Gulf. So even though it bypasses the suppression pool, the
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125 1 ' sprays catch it.
() 2 Another feature of Grand Gulf is they have an 3 enclosure building which is drawn down in two minutes.
4 After two minutes, everything that leaks into the enclosure 5 building goes through a filter with 99 percent efficiency.
6 So in the case of TID, virtually all the dose 7 occurs -- well, not all, but a significant fraction of the 8 dose occurs in the first two minutes. And some of that is 9 --
some of that is offset by the timing here in NUREG-1465.
10 DR. KRESS: Is it the practice to allow mitigation 11 in the enclosed surrounding buildings for the 10 CFR 100 12 dose calculation?
13 MR. TINKLER: Typically, all we give them credit 14 for is dilution.
15 DR. KRESS: Just by the volume.
16 MR. TINKLER: By the volume. We generally do --
17 there is no additional played out on surfaces in the 18 enclosure building.
19 DR. KRESS: This --
20 MR. TINKLER: Well, you will see -- the timing 21 reveals some of the effects of dilution. But, like I say, 22 in this case, most of the dose comes from that first two 23 minutes in the case of TID. And there is -- there is a 24 substantial difference to some degree between the first two 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> and worst two hours. You can see that when you push ANN RILEY & ASSOCIATES, LTD.
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1 126 1 the start of the worst two hours out, you get about the same 2 dose. But it is a pretty small dose in the case of the 3 thyroid.
4 The LPZ thyroid dose is reduced for different i 5 kinds of reasons. Principally, because the -- again, that 6 is'the 30 day dose. The organic iodine is a much smaller 7 contributor to the off-site dose, and the ECCS leakage plays 8 a more significant role in this particular plant. Remember, {
9 everything that goes in the enclosure building gets 10 filtered, so the only way to get a dose off-site is you got I 4
11 to look for other paths, and the ECCS leakage path is one of 12 them in this particular instance.
13 DR. FONTANA: EAB thyroid dose, is that somebody 14 is standing there for two hours?
15 MR. TINKLER: Yes.
16 DR. WALLIS: Or running around the track 17 equi-distant.
18 DR. FONTANA: And breathing hard. l 19 MR. TINKLER: Well, if he moves, the plume follows 20 him.
21 CHAIRMAN SEALE: And he drinks a lot of milk.
22 DR. POWERS: Not for the thyroid dose.
l 23 [ Laughter.]
i i l 24 CHAIRMAN SEALE: I was teasing. I 25 DR. WALLIS: That comes later. You have to milk ANN RILEY & ASSOCIATES, LTD.
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127 1 the cows first, and they have to eat the grass.
(O,/ 2 MR. TINKLER: .The higher level conclusiond --
i 3 actually, we finished Phase I, we finished Phase II. We are 4 somewhere between 50 and -- or 75 percent of the way through 5 Phase III. I haven't shown any of the Phase III
,6 calculations where we compared the SRP numbers versus the 7 more mechanistic removal mechanisms. But we see comparable 8 changes in that the overall impact of 1465 versus is TID it 9 to generally produce lower calculated doses.
10 It might be from timing, it might be from some 11 nuances associated with the magnitude of the release of the 12 organic iodines, for example. The extent of the reduction j
13 is influenced by the influence of the plant-specific safety j 14 features, which are timing sensitive, standby gas treatment O4 15 systems, sub-atmospheric design features.
l 16 They are also affected by SER and FSAR calculation !
17 assumptions. Some of these old calculations havn unusual 18 assumptions, either very high or very low fission product 19 reraoval decontamination factors, Lambdas is the term given.
l 20 So when you go from one calculation to another, the original 21 calculation may have assumed a very reasonable removal 22 coefficient for elemental iodine and a very small j 23 coefficient for a particulate. So then when we go to 1465, 24 we see the trend going the wrong direction. But you just 25 have to be aware of those kinds of things.
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128 1 The differences in the source terms, the magnitude l
( 2 and the chemical form is also changing some of these 3 results. The original calcu,..-lons in many cases used old, 4 what we call radionuclide data, older dose conversion 5 factors that change curies into rem. Adoption of NUREG-1465 6 is accompanied by new dose conversion factors and, 7 generally, they will produce lower calculated doses.
8 Especially, if it is from the very early -- ICRP2 dose 9 conversion factors.
10 And it it; true that the use of the worse two hours 11 does negate some of the benefits of the revised source term, 12 because you lose some of the benefits of the delayed 13 release.
14 DR. POWERS: )
I guess I don't understand, when you 15 say benefits, you are talking benefits to the licensee?
16 MR. TINKLER: Well, I am talking about if you kept 17 the calculation on a first two hour basis, you would expect 18 a dose which uses a source term which is released over the 19 .two hours interval to produce a lower dose. Now, when you 20 go to that worst two hour window, you will see a reduction 21 in the.-- a reduction in the reduction of the dose.
22 DR. POWERS: What you are saying is that when you 23 use the worst two hours, the doses calculated at the site l
l 24 boundaries are' closer to what you got under the TID?
l l 25 MR. TINKLER: Closer, yes.
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1 129 l 1 DR. POWERS: I wasn't sure who benefited.
' /~T
( ,) 2 DR. WALLIS: The person standing at this --
3 whoever it is -- this location sucking up this dose is l
4 benefitting too, isn't he?
l 5 MR. TINKLER: Yes, he's benefitting also.
6 As part of this re-baselining, as I said, we 7 looked at the equipment qualification dose. This is a 8 repeat of the Surry calculation for the equipment 9 qualification dose, basically the gamma dose calculated in 10 the containment atmosphere at the center of the containment 11 and the gamma dose calculated for the sump. This --
12 DR. WALLIS: Say that again? Someone's standing I
13 in the middle of the containment?
14 < MR. TINKLER: Well, this is pieces of equipment --
/~N,
\ssl 15 DR. WALLIS: Oh.
16 MR. TINKLER: -- in the middle of the containment, 17 or a piece of equipment in the sump, and that's why we --
18 that's why -- we did a calculation for both gamn.a and beta, 19 but beta is not real important for equipment. And 20 typically, or what we see here, NUREG 1465 actually 21 calculates a little lower dose. ,
l 22 DR. KRESS: Is equipment supposed to be qualified 23 for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />?
24 MR. TINKLER: Equipment can be qualified for much
)
25 longer periods of time -- three months, six months, even j i
1 1 rN '
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130 1 longer.
1 2 DR. KRESS: So the fact that this is a lot lower 3 during the first day --
4 MR. TINKLER: Well, actually, these are ten to the l
5 fourth hours. These are --
6 DR. KRESS: Yes, but at one point, it catches up, 1 7 so there's no difference.
8 MR. TINKLER: In the case of the sump dose, it 9 catches up after 20 days in this particular calculation. In 10 the case of Surry, it caught up after 30 days. But you also 11 have to compare this dose with the dose received during l 12 normal operation, and in some cases, this may or may not be 13 --
l 14 DR. KRESS: Yes. May not --
\
15 MR. TINKLER: Right. And as part of i
16 re-baselining, we will look at the total dose seen by 17 equipment, not just the accident dose. And basically, this l
1 l
18 is all due to the 30 percent cesium versus one percent l l
19 cesium assumption between TID and 1465, and that we repeated
'20 the calculation and we took cesium out, and you can see we i
)
21 never reached TID in that case. So that provided the 22 confident that that was what was actually making the l 23 difference. And I think I've said all this.
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r l
131 1 associated with the implementation of the revised source 2 term basically to develop the technical foundation for the 3 development of a reg guide, to understand how we should go l 4 about, you know, working out the devil which is in the 5 details for implementing this revised source term and also 6- to give a measure for the regulatory analysis.
l '7 As we indicated, we repeated some of these 8 calculations using the severe accident codes done in a fully i 9 consistent fashion, and we think that will give some measure 10 of the conservatism that's seen in these licensing !
11 approaches. ,
12 We are going to perform the dose calculations for 13 Surry, Grand Gulf and Zion, and we will use the SRP and the 14 updated removal mechanism models described in these NUREGs, l 15 NUREG CR 5966 for sprays, 6153 for the suppression pools, 16 and there's another accompanying NUREG for natural removal 1
17 mechanisms.
18 DR. KRESS: Question on that. Do you also include 19 -- you know, I just see sprays and suppression. Do you also 20 include nacural attenuation processes or just sprays?
21 MR. TINKLER: Normally for operating reactors that 22 have sprays and these -- natural removal mechanisms are a 23 small player. Now, that doesn't mean that some utilities in 24 certain regions may not want to take some credit for natural 25 removal mechanisms, for example in the drywell where they l ANN RILEY & ASSOCIATES, LTD.
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132 1 had no sprays. The staff hasn't reached a position on
() 2 consideration of those issues. The dominant mechanisms are 3 sprays and suppression pools, okay?
4 DR. KRESS: When you did the spray, the removal 5 mechanisms due to spray are numerous. They are impaction, 6 diffusion, condensation. Do those spray models include 7 condensation of steam onto the droplets?
8 MR. TINKLER: The models that we are proposing to 9- use for design basis analysis would not include 10 hygroscopicity or the growth of droplets due to absorption 11 of water.
12 DR. KRESS: How about diffusiophoresis?
13 MR. TINKLER: Diffusiophoresis? In the natural 14 removal mechanisms, it doesn't.
15 DR. KRESS: I mean with sprays.
16 MR. TINKLER: Just sprays?
17 DR. POWERS: They don't.
18 MR. TINKLER: I think it's a collision efficiency 19 primarily driven'--
20 DR. POWERS: The models in that particular 21 document you're referring to there leaves out the transient 22 that occurs initially on absorption of steam. It's a pretty 23 short period of time. And it also leaves out the 24 evaporation from the droplets during the thermal transient, 25 which is another short period of time.
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133 1 .
DR. KRESS: All I can say is congratulations, b\
'g 2 [ Laughter.]
3 DR. POWERS: I know you don't believe in those )
4 mechanisms. They're almost impossible to calculate. i J
5 3R. KRESS: I believe in the mechanisms.
l 6 DR. POWERS: Well, you just don't believe in using (
7 them. There is a difficulty here, and it's a real 8 interesting problem. When you first put the spray on in a {
l 9 steam-filled environment, it absolutely collapses the spray. '
10 There's a transient period. It's very short. And on the j 11 scale of what they're doing, the calculations, it doesn't 12 even show up as a blip.
13 Then you get into an evaporation situation where 14 you're not evaporating anything in particular; you're 15 evaporating from droplet to droplet, and its little ones are 16 evaporating into big ones and --
1 17 MR. TINKLER: The little ones disappear. '
18 DR. POWERS: Yes. And it's the -- it's a 19 nightmare to calculate. Fortunately, it wouldn't show up, l 20 but another little blip in your thing.
21 There is a very late time diffusiophoresis, very 22 late in time, and we did try to analyze that for system 23 80-plus, and it's like a ten percent effect and it shows up 24 one day and it's now where you're getting evaporation out of 25 the sump coming onto the spray, because you've got a heat (O
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l 134 t i source down in this spray. It's a ten percent effect; it's 2 not included in here. It's not huge, and in fact, the 3 System 80-Plus, they recognized it, but they didn't ask for l 4 credit for it.
5 MR. TINKLER: Also under phase 3, we're going to 6 do some, as I said, some best estimate calculations using 7- MELCOR for Surry, Grand Gulf and Zion to assess some of the 8 margins which will still exist in the DBA analysis.
9 DR. KRESS: You will do that for a defined break? 4 10 MR. TINKLER: Well, we're going to do that for a 11 large break LOCA and a small break LOCA. We want to look at ;
12 a high pressure and low pressure sequence basically, and we 13 can do the calculation using both the consistently {
14 calculated fission product release as well as kind of a 15 combination calculation where we let MELCOR calculate core j
- 16 damage and thermohydraulic boundary conditions, but over the '
17 same time interval input, the 1465 source term, just to see 18 if there are any differences associated with that.
19 DR. KRESS: That will give you a consistency for l
20 your source term.
21 MR..TINKLER: That will give us the consistency 22 between the source term and the removal mechanism modelling 23 in the DBA.
l 24 DR. WALLIS: There is no reality check of any of 25 this, is there, in terms of a real core which is really
{
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135 l 1 dispersed and really -- real sprays in the real atmosphere?
2 MR. TINKLER: Well, we have TMI. I mean, that's 1
j 3 --
i 4 DR. WALLIS: We have TMI.
6 DR. WALLIS: That's the only one you have, isn't 7 it?
9 DR. WALLIS: Chernobyl did not --
l 10 MR. TINKLER: Well, ycu know, I was trying to 11 respond to reactor when you said reactor. In the case of --
12 well, there are an abundance of fuel damage tests where they )
13 measure fission product releases from --
14 DR. WALLIS: I may be completely wrong here.
15 You've all got much more experience than you. You have a 16 whole lot of mechanisms postulated, guessed at, with some l
l 17 evidence about some of them and then there's some j 1
1
! 18 predictions made, but the predictions are all subject to l
.19 uncertainties --
l l
20 MR. TINKLER: Yes.
21 DR. WALLIS: -- especially if you're looking at 22 some containment of a different scale, different i 23 characteristics, in something that we have some experience l
l 24 with like TMI, and yet you're looking at changes in numbers 25 which work out to three decimal places or something like l
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136 1 that and you say this one is smaller than that, therefore
() 2 it's better, and it-just bothers me in terms of a sense of 3 proportion that you feel you can do this when everything is ,
4 subject to so much uncertainty, i
5 MR. TINKLER: Well, I plead guilty to showing some !
6 decimal places there. I'll agree to that. Although I would !
7 say that in -- the purpose of this was to assess the 8 differences you would see implementing one source term' l l
9 versus another using the same methods. So if there are 10 uncertainties in the methods, the best --
I guess my best 11 defense is I used the same methods in both cases because I
- 12. was really interested in the -- I would like to think I have 13 a consistent uncertainty. I can't say I can prove that per 14 se. But the purpose of this is to evaluate the differences, 15 and as I said, I believe that we will show that a best 16 estimate calculation will reveal lower doses than what we 17 calculate for the DBA.
i l 18 DR. KRESS: Which is what you would hope it --
1 l 19 MR. TINKLER: Which we would fully expect.
20 DR. WALLIS: I admire your courage in preparing to l 21 do this. I understand you've got to be consistent and I ;
1 22 think it's valuable. But I'm so bothered by -- l l 23 MR. TINKLER: Well, like I said, there are other 24 reasons --
25 DR. WALLIS: -- all these uncertainties that ANN RILEY & ASSOCIATES, LTD.
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l 137 1 probably are there. For regulatory purposes, yes, you do I
(O ,j 2 this kind of thing, but it still seems a somewhat fantastic l 3 --
4 MR. TINKLER: Well, I would have to say, though, ,
5 that the uncertainties in traditional design basis analyses 6 are generally on the " conservative" side. I mean, we 7 acknowledge there are uncertainties, but where we understand 8 it, we bias them to produce more bounding numbers.
9 DR. POWERS: It also might be worth pointing out 10 in some of the suppression or mitigation thing documents 11 that were cited here were deliberate attempts to assess the 12 magnitude of those uncertainties.
13 MR. TINKLER: Yes.
14 DR. POWERS: And, in fact, numbers and whatnot are 15 reported that reflect uncertainties on just about everything i 16 that the author could think of that might affect these. And 17 I think actually, you -- I know at least one reader of those 18 that came away thinking that they're not as big as I thought 19 they were.
20 DR. KRESS: With respect to what you're talking l 21 about, I think the biggest concern about uncertainties here 22 is when you compare a MELCOR actual calculation of a couple 23 of sequences to the result you might get using the stylized 24 source term, is there is a big uncertainty in the source 1
25 term you will get from MELCOR. So what you would be touting r
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138 1 that or would be, I presume, a sort of a best-estimate 2 source term for those particular sequences, but you could 3 very well do an uncertainty analysis on that and compare the 4 whole uncertainty distribution to what you get. But, you 5 know, I don't think -- you don't really need to go that far, 6 I don't think --
7 MR. TINKLER: That is not the intent.
8 DR. KRESS: No. For purposes that you wanted, to 9 find out the consistency and the direction of changes and 10 stuff, I think this is a pretty good way to do it.
11 DR. MILLER: Tom, when yo't say big uncertainty, 12 what --
13 DR. KRESS: In the magnitude of the releases that
., 14 you would calculate --
k- 15 DR. MILLER: What do you mean by big? Five 16 percent? Ten percent? A factor of ten.
17 DR. KRESS: It's nuclide specific. For example, 18 there's not that big of an uncertainty in the Noble gases, 19 but there might be a big uncertainty in the Tellurium for 20 example. Instead of five percent, you might get 50 percent.
21 It's that kind of thing.
22 MR. TINKLER: But you have to distinguish between 23 the releases from the fuel and the releases to the 24 containment. because this is a dose to the containment 25 itself.
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i 139 1 DR. KRESS: Absolutely.
() 2 DR. POWERS: I mean, it's a really important 3 point, because you have this wonderfully exponential process 4 taking place that gives rise to'the release where small 5 changes in your calculated temperatures give huge changes in 6 the integral release, and then you run into the equivalent 7 of a filter, and suddenly those uncertainties in the release 8 don't make any difference. It doesn't matter whether I 9 released it in the first hour or in the second hour of core 11 0 degradation; it is still being deposited largely in the 11 piping system. So what comes out the piping system as an 12 integral quantity is not nearly as uncertain as what was 13 released from the fuel. It's really an interesting 14 uncertainty analysis in that respect, because you have these O
\m / 15 things that are uncertainty dampers, and the more you j 16 integrated in time, like when you get out to the 30-day i l
17 dose, you've had so much damping that actually those 1
18 numbers, you can hardly change them.
19 DR. MILLER: You're saying in 30 days, the 20 uncertainty is -- you've got all these other things 21 happening.
22 DR. POWERS: It sill exists. Don't get me wrong.
23 It still exists. But you've had a lot of uncertainty 24 dampers. So you might be uncertain in the release of iodine 25 by two orders of magnitude. It's a release rate, may be
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140 1 uncertain by two orders of magnitude, and you'll see an O
g j 2 uncertainty of ten percent out in the 30-day dose because 3 you have these uncertainty dampers integration functions 4 that integrate over time.
5 DR. MILLER: You need to explain what an 6 uncertainty damper is.
7 DR. POWERS: It is things like, I'm very uncertain 8 about the release rate from the fuel.
9 DR. MILLER: Right.
10 DR. POWERS: But I run that through the piping 11 system, which acts like a filter, and --
12 DR. MILLER: You're uncertain --
13 DR. POWERS: -- and now, if the number I'm wanting 14 is the integral of what comes out, that uncertainty doesn't 15 propagate through --
16 DR. WALLIS: So what comes out is not roughly 17 proportional to what goes in?
18 DR. POWERS: No. What is the integral that comes 19 out is not proportional to the rate of release from the 20 fuel.
21 DR. WALLIS: But then the -- the story he was I 22 telling about stuff being released into this containment and 23 mixing up and being sprayed and so on, I don't see any j 24 uncertainty dampers in there at a.l.
25 DR. POWERS: I didn't hear a word you said.
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141 1 DR. WALLIS: I thought there was a picture -- I
() 2 have a picture of stuff being released into a containment, 3 and then maybe there's a spray, maybe there isn't a spray, 4 maybe it goes to the suppression pool, maybe it doesn't, and 5 then it's hypothesized that it squirts out through a hole 6 and this plume goes off and someone is standing in the way.
7 I don't see uncertainty dampers in that scenario at all.
8 DR. POWERS: There really are because you're ,
i 9 integrating -- for instance, if I integrate over two hours, 10 there's a damper there because I think the speaker pointed 11 out that for TID, all the dose comes in the first two 12 minutes. I can shift that critical two minutes around a lot 13 and I still get the same number for two hours. That's what 14 happens to you in the uncertainty analysis.
15 They will all propagate through is the only point 16 I am making.
17 DR. MILLER: I don't quite understand why they 18 don't.
19 DR. FONTANA: Well, a good example would be --
20 DR. POWERS: Because you integrate.
21 DR. FONTANA: For example, if your spray system 22 works then it's going to wash off.
23 DR. MILLER: Oh, I see. You add more 24 uncertainties on removal.
25 DR. FONTANA: What?
i
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i l 142 i
i 1 DR. MILLER: You add more uncertainties on the 2 removal?
3 DR. FONTANA: Yes, but those uncertainties are 4 small compared to the uncertainties you start with.
l 5 DR. POWERS: Spray is a good example. Spray wipes 6 out all your uncertainties on timing and the release because
! 7 it kills everything.
8 DR. MILLER: Basically it doesn't matter how much 9 you release if your sprays work.
10 DR. KRESS: That's almost right.
11 DR. MILLER: Almost right. But there is an 12 uncertainty on whether your spray is going to work or not, t
{
l 13 DR. FONTANA: Yes.
14 DR. MILLER. If your spray doesn't work you still 15 have big uncertainties then. j l 16 DR. FONTANA: You trend toward thermal dynamic 17 equilibrium of some kind or other. i 18 DR. MILLER: We are getting to a curve that I want 19 to look at. 1 20 DR. KRESS: But in design basis space you assume 21 the sprays work. You don't assign an uncertainty.
22 CHAIRMAN SEALE: Okay.
23 MR. TINKLER: Lastly, under Phase III we are 24 performing TRENDS analysis of the sump pH to examine pH 25 control for Grand Gulf and Surry to evaluate the evolution ANN RILEY & ASSOCIATES, LTD.
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143 1 of iodine.
() 2 DR. KRESS: You might point out that trends 3 analysis doesn't mean you are tracking the trends, that you 4 are using some esoteric code called TRENDS -- which I will 5 also have to plead conflict of interest on.
6 DR. MILLER: What does TRENDS mean?
7 DR. KRESS: God --
8 MR. TINKLER: That's a good one. I don't know if 9 I can get a correlation --
10 DR. SHACK: Transient --
11 MR. TINKLER: Transient Radiciodine Evolution --
12 DR. KRESS: Dominant Sequences is the DS.
13 DR. POWERS: Let me defend the speaker's in their 14 inability to report this.
15 To my knowledge the acronym has been defined only 16 in a set of handwritten notes attributed to the Grand Guru 17 in an informal presentation in Oak Ridge is the only time I 18 have seen the acronym translated.
19 DR. KRESS: That was correct at one time. I am 20 not sure --
21 DR. MILLER: If we can find those handwritten 22 notes.
23 CHAIRMAN SEALE: And the "T" stands for Tom's --
24 [ Laughter.)
l 25 DR. POWERS: Tom's Ridiculous Enterprise -- with ANN RILEY & ASSOCIATES, LTD.
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144 1 nothing to do with the source term.
() 2 DR. MILLER: More important, what does TRENDS do?
3 Oh, you are going to tell us, I guess.
4 DR. KRESS: It calculates iodine behavior in 5 containment --
chemistry and mass transport.
6 DR. MILLER: I thought EPRI did comething like 7 that.
8 DR. KRESS: Oh, there are a number of codes that 9 do this.
10 DR. POWERS: I don't think EPRI --
11 DR. KRESS: EPRI doesn't have one. There's a 12 couple of foreign codes.
13 DR. POWERS: The best ones right now, the 14 state-of-the-art codes in this field for accident analysis I 15 believe would be the IODE and IMPAIR, which are identical 16 essentially, and LIRIC,. which really is tough to use in a.7 17 accident analysis other than a CANDU , and then there is 18 INSPECT which really isn't good for accident calculations.
19 It is more specialized.
20 DR. WALLIS: Well, these codes, are they tested in 21 the same way that thermal hydraulic codes are supposed to be 22 tested with lots of scale models of different scales and 23 lots of scenarios and lots of comparisons between data and 24 prediction, or is it assumed that because you put together a 25 code that it works?
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145 1 DR. KRESS: It's harder to do that with these
() 2 codes that it is --
3 DR. WALLIS: So they are much less certain thermal 4 hydraulic codes --
5 DR. MILLER: I want to hear the answer to that 6 one -- much less certain than thermal hydraulics.
7 DR. POWERS: The test data for an instance that is 8 being used to validate the IODE/ IMPAIR and LIRIC codes I 9 don't know whether TRENDS is involved because I don't know 10 what the status of trends is right now, but that test data 11 consists of experiments, about 100, at what you would call 12 the bench scale, about 8 at what you would call the 13 intermediate scale -- that is about the size of a 55 gallon 14 drum, and then tests at what you would call a large scale, 15 which is basically 10 cubic meter containment with 100 liter 16 sump, which are large-scale tests.
17 The challenge.you face in this is you are working j i
18 with radioactive iodine. I 19 DR. WALLIS: These are tests with well-specified 20 initial and boundary conditions and things that you know 21 about?
22 DR. POWERS: They are better controlled of course
- 23 at the bench scale than as you get up in larger and larger 24 scale you get -- and more prototypic things get a little 25 floppier --
()
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1 l
146 1 DR. WALLIS: Represent them by dials -- in other
() 2 words, twiddle-able dials where you change constants until 3 you tune the code to fit the data?
4 DR. KRESS: There is some tuning in TRENDS and it 5 involves the rich iodine chemistry in the aqueous phase, l 6 which may involve up to -- I have seen up to 500 or 600 in l 7 kinetic equations.
8 DR. POWERS: LIRIC right now is running at 1000.
9 DR. KRESS: 1000? s 10 DR. WALLIS: No -- stop. It's getting fantastic.
11 DR. KRESS: But there is some tuning of TRENDS to i
t 12 that rich chemistry..
13 DR. WALLIS: You don't have 1000 kinetic constants l
14 in your trend, no way. Absolutely no way.
15 DR. KRESS: It's tuned to be basically an
' i 16 empirical correlation of data.
17 DR. POWERS: Now if we turn to LIRIC, which is not l
18 an empirical correlation, it definitely does have 1000 19 kinetic parameters in it. It is not hard to generate 1000 l
20 kinetic parameters in these codes.
I 21 DR. WALLIS: Well, that's nuts. l 22 DR. POWERS: Why is that nuts?
23 DR. WALLIS: Anything with 1000 parameters --
24 DR. POWERS: Oh, no, no, no. They are not fitting 25 parameters. They are kinetic rate expression. Most of. them l
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147 1 have been derived from a huge number of experiments 2 involving anything from a pulse radiologist experiments, 3 stop flow experiments and what-not.
)
4 The trend in the modeling has been to go from '
5 TRENDS which took, what, 38 sets of experimental data, and 6 generated eight to 15 -- It depends on which version.
7 DR. KRESS: It's about 8 because it's every <
8 ionization state of iodine.
9 DR. POWERS: About 8 empirical kinetic 10 coefficients -- that's TRENDS -- to the LIRIC and INSPECT 11 models, which I don't think they Lave an empirical l 12 coefficient in them.
13 I think it's a pay your mone.y, take your chances l
14 type code.
O l 15 It is quite unlike this really peculiar thing that 16 goes on in thermal hydraulic where they just, t.5ese Von 17 Carmen constants or something like that based on experiments 18 that have nothing to do with anything, i
19 CHAIRMAN SEALE: All right. Let's quit baiting 20 each other back and forth, l 21 [ Laughter.)
l 22 DR. KRESS: I can tell you are enjoying this, 23 Charlie.
24 MR. TINKLER: Let me st op --
25 DR. WALLIS: I admire your patience certainly.
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148 1 All I am trying to do is put this in some sort of
() :2 perspective and maybe.this committee has it all in great 3 perspective already.
4 MR. TINKLER: Let me go on to the next point here.
5 I think a year or so ago the committee heard a 6 discussion of the meteorological models that go into some of 7
our DBA dose calculations and I think the committee had a 1
8 number of comments about them as well --
9 DR. WALLIS: The New York Times reporter would 1
10 say, you mean you are modeling the weather?
i 11 MR. TINKLER: Yes. Yes.
12 DR. WALLIS: And is that what the public. thinks 13 about that.
14 DR. KRESS: We don't predict the weather. We !
15 use --
16 MR. TINKLER: We use the 95th percentile worst 17 weather --
18 DR. KRESS: That's right.
19 MR. TINKLER: There'is not much weather that is 10 worse than the weather that we use.
21 DR. KRESS: For dispersion.
22 , MR. TINKLER: For dispersion of this dose o' 4 fsite.
23 So it is true that we model the weather but we 29 don't get much credit for it.
25 DR. POWERS: You have to be 'rery careful when you
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149 1 talk about 95 percentile weather.
2 DR. KRESS: It doesn't include rain-out. )
- 3. DR. POWERS: Well, I mean the problem you run into 4 is when you say the 95 percentile worst is it is not that 5 one day of the year when things turn out bad. You can have 6 your 95 percentile weather every single day of'the year for 7 5 percent of the time.
8 This is a different concept. You have to be very 9 careful about it.
10 DR. KRESS: Five percent of that time, because it 11; is done on an hourly basis, 12 DR. POWERS: That's right.
I 13 DR. MILLER: So there is some uncertainty there. )
14 CHAIRMAN SEALE: Okay.
15 MR. TINKLER: Phase IV, as I indicated, was the 16 phase where we in addition to looking at the effects of
.27 candidate plant changes, we looked at the risk impacts from 18 implementation of the revised source term.
'19 We actually did this work a couple years back in 20 anticipation of implementation of the revised source term. '
y, 21 DR. KRESS: Phase IV was done before Phase III?
y G
22- MR. TINKLER: No. This particular aspect of Phase l '\
l 23 IV. We haven't looked at the DVA dose calculations but the 1 24 risk impacts of potential changes, and we looked over a wide i
25 range of issues for plant changes, far beyond what had been ANN RILEY & ASSOCIATES, LTD.
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150 i proposed in the pilot plants, actually.
2 Acjain we looked at this to see if changing any of 3 these ESFs or their operation, while it would allow the 4 plants to-meet Part 100 requirements -- by decree it must 5 meet Part 100 -- would that have any impact on the severe 6 accident risk?
7 This study is documented in draft NUREG-6418.and 8 basically we considered quantitatively the impact of those 9 changes.
10 The approach was to modify the PRAs to assess the t
potential change in component performance for the various 11 12 -features including containment leakage rates, containment 13 spray operation, reactor building drawdown time, the 14 subatmospheric aspect of containment designs, and filtration 15 systems.
( 16 DR. KRESS: Did you use independent, one at a 17 time, or combination? l j 18 MR. TINKLER: These were done primarily 1 19 independently. We did I.think -- I am hard-pressed to 20 recall exactly which ones we looked in combination. !
21 I think we looked at a couple combinations but l
.22 primarily these were looked at independently.
23 We looked at this for the NUREG-1150 plants --
24 Peach Bottom, Grand Gulf, Surry, Sequoyah and Zion and 25 Lasalle -- and the 1150 methodology was used in that i
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4
{.
i 151 1 accident progression event trees were modified to reflect
() 2 the change and the event trees were requantified. Source l 3 terms were_ developed as needed.and the offsite consequences i '
4 were recalculated.
1 5 In the case of containment leak rate, this was i
i 6 clearly demonstrated to be small over a wide range of 7 containment leak rates, which isn't surprising to anyone l
8 that looks at severe accident analysis, since leakage is a 9 very -- normal design basis leakage is a very, very small 10 leak.
11 DR. KRESS: Now for the benefit ~of Professor
! 12 Wallis, do you want to put sort of a number on small -- like 13 it didn't even show up in PRA space or --
l 14 MR. TINKLER: Actually, I would like to draw -- I !
15 need to draw a picture. That's the hole.
16 DR. MILLER: That is the hole that is leaking out 17 at us.
18 MR. TINKLER: Actually the' design basis leak hole 19 is a little bigger because it is blown up on the viewgraph.
- 20 It's actually about the size on here.
l 21 DR. MILLER: That is the size of the hole in the 22 containment --
l 23 DR. KRESS: But actually when you say this --
24 MR. TINKLER: That is the cumulative leakage area 25 for design basis.
I
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152 1 DR. KRESS: When you say the change in plant risk
() 2 is small -- this is what I wanted a number on -- that means 3 you could hardly measure it, right?
4 MR, TINKLER: Right. I mean risk -- by definition 5 risk dominant sequences involve containment failure where 6 you assume a gaping hole in the containment very early on --
7 hundreds and hundreds of --
8 DR. WALLIS: That is another one of these --
9 DR. KRESS: It is not an assumption. It has 10 criteria for determining when and those things. It's got 11 lots of uncertainly.
l 12 DR. WALLIS: That is part of this great portfolio 13 of scenarios is where you assume bigger holes than that?
14 MR. TINKLER: No. In the case of -- when one does ,
i 15 a severe accident analysis and calculates the containment )
16 pressure exceeds the ultimate capacity of the containment 17 then it generally is assumed at that point that it is a if ,
l 18 not catastrophic -- serious, i
I 19 DR. WALLIS: Nothing really for a steel vessel l
20 between this sort of a hole and a pop?
l 21 MR. TINKLER: For steel. For reinforced concrete, 22 penetrations tear -- but for the sake of severe accident l
23 analysis, it's assumed a near catastrophic failure. !
I 24 DR. WALLIS: I think you are on good grounds for 25 number one, because this is a measurable quantity and has ANN RILEY & ASSOCIATES, LTD.
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1 153 1 been measured.
() 2 MR. TINKLER: Yes.
3 DR. WALLIS: And so that's --
4 MR. TINKLER: Yes, we know what the design basis 5 leak rate is. It's tested and measured, but when we vary 6 that leak rate in severe accident analysis, over a wide 7 range, it does not change --
8 DR. KRESS: You don't see it on LERF, for example.
9 You just won't see it.
10 DR. WALLIS: One other question I'd have there on 11 that one is how much does it fluctuate? Is the leak rate 12 small because people patch up the holes before it is 13 measured or is it consistently small or do people, don't pay 14 attention to some developing cause of a leak or there must l
15 be some continual checking --
16 MR. TINKLER: People are required to on specified 17 intervals leak test their containment and demonstrate its 18 leakage, i
19 DR. WALLIS: What is the history? Does it stay )
20 about the same over a period -- from test to test? I l )
l L 21 MR. TINKLER: It has been a long time since I 22 worked in that area, but, you know, if the design basis 23 leakage is .1 or .2 percent per day, they may exceed the 24 design basis leakage by a small amount.
25 It's not like people leave doors open.
1
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154 l
1 DR. WALLIS: So we are on good grounds. I 2 DR. KRESS: Once in awhile they will find a valve l l
l 3 left open and a big, big exceed but the frequency of that l
l 4 is --
5 DR. POWERS: By the way, the PRA does attempt to 6 estimate the frequencies with which that is done and it l 7 actually is a fairly -- it is a nontrivial number -- about j l
8 the human error rate. J l
9 DR. WALLIS: You are asked to assume tha'c all of 10 this stuff gets out and then that no one leaves the valve I
11 open -- you could equally well assume that 1 percent gets l 12 out and the person does leave the valve open - -
i 13 MR. TINKLER: Actually, the probability that the l l 14 containment is not isolated is routinely addressed in severe j 15 accident analysis and a probability is assigned to that i 16 eventuality.
l 17 DR. WALLIS: That is one of the better ones.
l 18 DR. KRESS: What changes were postulated to the l
i 19 containment spray operation as a result of the new source !
l 20 term?
l 21 MR. TINKLER: What changes -- I I 22 DR. KRESS: You are assessing the effect of that
'23 change in the containment.
24 MR. TINKLER: I am not aware that anyone has 25 actually come in and proposed a significant change.
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l' l <
155 1 DR. SHACK: What change did you use here?
2 MR. TINKLER: In this case we turned sprays off.
3 DR. SHACK: Okay.
4 MR. TINKLER: Or delayed the actuation.
E DR. KRESS: That is what I would have thought, 6 delayed.
7 MR. TINKLER: Some of these when we got to the l 8 point in the event tree after reactor vessel failure, if the i
1 9 sprays were operating we turned them off.
10 DR. KRESS: You do that in severe accident specs.
L1 MR. TINKLER: Well, understood. But in those 12 locations in the event trees where the sprays were assumed 13 to have a probability of operating, we assumed they were no 14 longer operating, and then requantified the event trees.
15 MR. ADER: In this case, in this NUREG, if I can 16 add, they were -- it was a delayed spray. There were some 17 other studies where they looked at not having sprays or the 18 contribution to the overall containment failure sequences 19 with not having sprays, but in the draft NUREG, as I 20 remember it, I believe it was just a delayed sprayed 21 operation. l 22 DR. KRESS: So as long as your delay was not 23 sufficient to overlap with containment failure with respect 24 with small --
25 MR. ADER: Some of these assessments were more of l
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s.
156 1 a qualitative. Some people familiar with 1150 would look at I_ 2 the event trees and what was in the event trees, in some l '
~
l- 3 cases things were not modeled.
i 4 MR. TINKLER: In some cases, a matter of pushing 5 early containment failure out to a later containment 1
6 failure.
7 DR. KRESS: Basically, these things shows --
< 8 MR. TINKLER: Basically, what this shows is that 9 you make -- if you change these systems in a way that still 10 allows you to meet Part 100, --
11 DR. KRESS: But you don't see --
12 MR. TINKLER: -- you are not likely to affect your l l
13 severe accident risk profile. In some cases -- a common ;
i 14 them is, in the dominant risk sequences, these probably I
-15 aren't working, so changes to them aren't likely to affect 16- risk.
17 DR. KRESS: Which is a commentary to Professor 18' Wallis on the design basis accident versus reality.
19 MR. TINKLER: Which means, in general, for the 20' severe accidents, the robustness of the containment itself 21 is the principal protection.
22 DR. WALLIS: The thing that has bothered me along 23 is the assumptions that you made like this have so much more 24 far reaching effect than all the tremendous effort that is l 25 put into analysis. Isn't that -- or am I wrong?
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157 1 You can make some assumption which is tremendous
() 2 -- has a tremendous influence on the answer, and write it 3 into law, and then have people spend millions of man hours 4 using hat and very carefully working out whether some number 5 is under some other number.
6 MR. TINKLER: But it is also --
7 DR. WALLIS: And it seems a fantastic thing to 8 require when the sort of -- the guesswork that went into the 9 assumptions were so human and prone to errors.
10 MR. TINKLER: In defense, though, it is the 11 margins that have been built into design basis analysis that 12 have allowed us to withstand the assault from severe 13 accidents in many cases.
14 DR. WALLIS: How many of those have there been?
15 MR. TINKLER: Well, there haven't been, 16 thankfully, a great many, but the calculations -- I would !
17 still say that, while these other requirements may not 18 necessarily show their benefit clearly in severe accident 19 analysis, it is the margins that have been accumulated or 20 derived, or implicitly built into the plant through those 21 requirements.
22 DR. POWERS: I mean I think Charlie is absolutely 23 correct. What 1400 showed, and what NUREG-1150 confirmed, 24 was that the reactor systems we created based on a 25 deterministic, subjective view on the design basis f')
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1 158 1 philosophy, when subjected to the best consistent
() 2 probabalistic analysis we could do, yielded what is 3 vulnerable to these accidents involving multiple failures, 4 only to the extent of what, at typically around 10 to the 5 minus 4, maybe as much as 10 to the minus 3 per year.
6 Even though they had not been designed for 7 multiple failures, they were -- because of defense in-depth, 8 and a general robust design that comes out of the design 9 basis, these machines can stand up to an awful lot of insult 10 before they give you a catastrophic failure.
11 DR. FONTANA: Well, TMI is a pretty good test of 12 that. If you asked us before it happened, if TMI could 13 withstand what happened to it, most experts would say no.
14 But it did.
15 CHAIRMAN SEALE: Okay.
16 DR. MILLER: I thought -- was told that it did 17 what it was designed to do. Containment worked.
18 DR. KRESS: But it still points up a -- it points 19 up a prejudice or a bias I have had for a long time, and 20 that is source terms aren' t very important in risk-based.
21 Design basis source terms aren't very important in 22 risk-based. What is important is the containment integrity 23 source term, and that is important in risk-based. And there 24 is not as much as uncertainty in that, I don't think, as 25 there is in source terms, though there is quite a bit of ANN RILEY & ASSOCIATES, LTD.
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159 l 1 uncertainty in that.
) 2 DR. MILLER: I have a question.
3 DR. KRESS: Yeah, questions are welcome.
l 4 DR. MILLER: Back on -- and I am going to forget 5 about all these uncertainties. You said the objectives of 6 ~doing this were to better understand the effect on 7 individual doses, effect on equipment qualification and 8 effect on plant modification. Can you summarize quickly J
9 what this study has done as far as those three objectives?
10 I mean it is kind of embedded in your talk.
11 MR. TINKLER: Yeah. The effect on the calculation j
12 of the individual received dose, there is a general trend 13 for 1465 to produce lower doses. The exact amount.of the j
, 14 reduction in the individual received dose is more difficult to identify generically because it is often influenced by.
15 16 the impact of certain features, plant-specific features, or 17 the assumptions in the analysis.
18 When you go to the worst two hours, the thyroid 19 dose, or the thyroid dose reduction is perhaps not too 20 great.
21 DR. MILLER: How much is too great?
22 MR. TINKLER: Well, in some cases, you know, 30 23 percent, something like that.
24 DR. MILLER: Is that within the uncertainties of 25 these two -- I am comparing two numbers. You say 30 I
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160 1 percent. Now, is that a real comparison, or is the 2 uncertainty big enough it is washed out?
3 MR. TINKLER: Well, the differential between the 4 two, I think would be preserved. I am really cautious about 5 citing a number here, because we see -- I see, you know, we 6 have seen different trends depending on the plant.
7 We haven't seen -- you know, part of this was to 8 see, was to -- after going through these calculations, is 9 there something we hadn't imagined? Was there some cliff?
10 Was there some unforeseen effect in going to 1465? And,-
11 frankly, we don't see that.
12 DR. MILLER: You'didn't see that.
13 MR. TINKLER: We don't see that.
14 DR. MILLER: Okay.
15 MR. TINKLER: We see differences which are 16 explainable. Generally, they are lower doses. I want to 17 withdraw my 30 percent.
18 DR. MILLER: Maybe that is the more important 19 consequence of this study than trying to answer these 20 questions.
21 DR. KRESS: The only consequence that probably has 22 is that it would allow a licensee to loosen up on his 23 leakage rate.
24 MR. TINKLER: Right. And I mean it's --
25 DR. KRESS: Which is no big deal, really.
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161 1 ~ MR. TINKLER: You know, if you are getting --
2 before, you were getting 60 percent of your dose in-the two 3 minutes because you had an instantaneous dose assumed.
4 DR. MILLER: Well, that is because you included an 5 instantaneous --
6 MR. TINKLER: Well, now that you no longer have an 7 instantaneous dose, maybe you don't need to turn on a system 8- in 30 seconds or a minute.
9 DR. MILLER: Well, that's true, but your original 10 assumption in the TID was -- everybody knew it was totally 11 unrealistic. You are not going to instantaneously --
12 CHAIRMAN SEALE: Yeah, but they still have to j 13 start the -- in 30 seconds.
14 DR. MILLER: So that's the consequence, not the 15 total, total dose.
16 MR. TINKLER: Well, that's true, but we are seeing 17 some reductions now. Some cases, as I said, it because the 18 original dose has a high organic component to the iodine, 19 which is very difficult to filter, you know, it requires 20 charcoal filters. The new dose has a very small organic 21 component to the iodine release. That may allow for certain 22 changes. It definitely allows for a reduced dose for plants 23 that don't have charcoal filters anyway. Because before 24 they couldn't -- they couldn't scrub it, and now it is 25 smaller because the revised source term dose is smaller, so ANN RILEY & ASSOCIATES, LTD.
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162 {
l' they get a lower dose.
2 .But the difference between the two calculations 3 for a plant that had charcoal filters won't be as great in 1
4 that case, i
'5 DR MILLER: Let's go to equipment qualification.
6 MR. TINKLER: We are seeing very similar doses.
7 We see a slightly higher dose in the long term, 20 days, 30 8 days, longer. At this point, it does not --
9 DR. MILLER: How much -- how much would that be?
10 Slightly --
11 MR. TINKLER: It does not appear to be a 12 significant effect. We need to do a little more in that 13 area, but it is --
14 DR. MILLER: So we don't need to go back and 15 rewrite the qualifications.
16 MR. TINKLER: No. No, there's nothing that we 17 have learned so far that would lead you to believe that.
18 DR. FONTANA: It seems one of the biggest benefits 19 is things like valve closure times and things like --
20 MR. TINKLER: Timing issues come up.
21 CHAIRMAN SEALE: Yeah. Emergency closing.
22 MR. TINKLER: Things like that.
23 CHAIRMAN SEALE: Let me ask you a question. It's i 24 related but it is not specifically on this presentation. Is 25 that fair?
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l 163 l
l 1 DR. KRESS: Yeah. l
\ (~h l g 2 CHAIRMAN SEALE: Some of our more radical members 3 have been touting the importance of looking at other things, 4 something called shutdown risk and fuel storage risk and 5 things like that. Have you guys schmoozed around a big 6 about what you would do to the source term for the kinds of 7 low temperature, lighter, particularly for the spent fuel 8 storage, but essentially, the different physical conditions '
l 9 you would have for shutdown or spent fuel pool risks?
10 DR. KRESS: Do you want to know what the effect is l
]
11 on the source term?
! 12 CHAIRMAN SEALE: Yeah.
13 DR. KRESS: Or risk?
14 CHAIRMAN SEALE: Well, first --
's / 15 DR. KRESS: Are you asking these guys?
16 CHAIRMAN SEALE: Yeah, I mean they are the 17 experts.
18 MR. ADER: I don't know if you remember, Charlie, 19 I think there has been some look, I don't remember what came 20 out of it, it has been a while back, and I guess I would I 21 hesitate now to try to start remembering because I am sure I 22 would deviate from reality pretty quickly.
'23 DR. KRESS: I'll tell you what you would expect.
24 Would that help?
25 CHAIRMAN SEALE: Well, I don't whether your ANN RILEY & ASSOCIATES, LTD.
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l 164 l
1 expectations are the same as mine.
) 2 DR. KRESS: The first place, in order to get a 3 source term, you have to go into core damage, core uncovery.
4 So you have to -- in shutdown, that is likely to occur later 5 in time when the decay heat is much lower.
G CHAIRMAN SEALE: That's right.
7 DR. KRESS: This means the timing will be markedly i
l 8 different.
l 9 CHAIRMAN SEALE: Uh-huh.
t L ,
10 DR. KRESS: It also may mean, if you do go into l 11 core uncovery, heat up and melt, that your fission product l.
l 12 releases are likely to be about the same. And I'll tell you
! 13 why that is. You get a slower heat-up rate initially l
14 because the decay heat level is lower, but you will l 15 eventually reach a temperature that lights out a zyrc steam I
16 reaction.
l l 17 CHAIRMAN SEALE: Right. Exactly.
18 DR. KRESS: And the heat-up rates there are 19 probably going to be about the same. And it is the heat-up p 20 rate that drives off the fission products.
l~
l 21 Now, you may have lost some of your iodine, but )
i I l
t 22 not much, because seven days doesn't give you much decay i 23 time. So you are going to end up with about the same source )
24 term. But the timing is going to be considerably different.
25 CHAIRMAN SEALE: I agree. Exactly.
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165 1 DR. KRESS: And the conditions of the containment 2 may be considerably different.
3 DR. POWERS: I think there is another issue with 4 shutdown that is more interesting than that. I think I 5 agree with you. If you go to a full core melt and I 6 integrate over 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> in a full core melt sequence, I am 3 7 not going to be able to tell whether it is a shutdown 8 accident or an accident of power. l 9 More interesting to me is that, suppose you go i
10 into core uncovery in a shutdown situation, and a guy says, I 11' oh, I really don't want to be -- uncover my core, I have got 12 good access to my containment, so I will run this fire hose 13 in here and I'll quench this puppy. And he does, and he I 14 fractures the fuel, as you know he will. And that fuel will 15 start leaching your beloved iodine into solution.
16 You haven't stopped the accident. You are now 17 having this partitioning, probably coming out of an acid 18 solution, of iodine coming out.
19 The other thing, of course, that makes shutdown 20 interesting for both of them, --
21 DR. KRESS: Is the potential for the air ingress.
22' DR. POWERS: Well, you have an air ingress, but I 23 personally believe you have an air ingress even in the 24 regular accidents.
25 DR. KRESS: Regular accidents, yeah.
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166 1 DR. POWERS: But there's another feature of it
() 2 that is real interesting, is you don't have pressurized 3 release. And you get this -- this drift release, and 4 suddenly those auxiliary buildings that Charlie here has 5 been giving a DF of 2, suddenly start giving you DFs of 20 6 and 30.
7 On the other hand, you have a real high site 8 population. Now, are those site workers, who are 9 transients, part of the public or part of the site force?
10 You got some interesting questions come up that are not 11 transparently handled by the existing codes. Though, like 12 you say, if you go through a classic core meltdown, I think 13 on source term, the actual release, you stand back for 10 14 hours and integrate, I defy you to tell that from an at 15 power accident.
16 CHAIRMAN SEALE: On the hand, it seems to me that 17 it would be poor -- it would be rather indefensible to stand 18 back and be in a position where, after someone has decided 19 to reflood an uncovered core, tell him, well, any fool ought 20 to have known not to do that.
21 DR. KRESS: That will do it.
22 CHAIRMAN SEALE: Yeah, I know they would want to, 23 but I wonder if that is not a case that ought to be 24 considered in some kind -- some way which is (a) defensible, 25 and (b) publicizable, so that people are aware of the ANN RILEY & ASSOCIATES, LTD.
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167 1 difficulties that you can get into under those
()
gs 2 circumstances.
3 DR. WALLIS: If he didn't reflood, he'd probably 4 get arrested.
5 CHAIRMAN SEALE: See, that's what the Governor can 6 do for you. I mean that is typically the kind of thing the 7 Governor might tell you to do and so --
8 DR. KRESS: We don't have the database L. decide 9 whether it is better to reflood at a particular time or not 10 to. I certainly think I would reflood.
11 DR. POWERS: Well, there is no question that you 12 would reflood, but the point is you have not terminated the 13 accident.
14 DR. KRESS: It's still going on.
O
\~ / 15 DR. WALLIS: What is this Governor doing?
16 CHAIRMAN SEALE: Telling you to reflood. ,
17 DR. WALLIS: The Governor of Vermont is an MD. Is 18 he going to be able to diagnose what is going on at Vermont 19 Yankee or --
20 DR. POWERS: I don't know anything about 21 Governors --
22 MR. EMCH: Would you guys like to hear about 23 rebaselining in the pilot plant plants?
24 [ Laughter.)
25 DR. KRESS: Yes, we would. I declare this debate l
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168 1 overwith. Let's hear about the pilot plants.
2 DR. BARTON: Are we finished with Charlie? .
3 CHAIRMAN SEALE: I'm glad you knew how to put a t 4 cork in this.
5 ~ MR. TINKLER: I'd add a quick note while Rich is l I
6 walking up up there. That risk study -- Charlie mentioned '
7 it was done several years ago.
8 If my memory serves me right, I think it was a 9 comment that you made, Tom, at a meeting that said maybe we 10 ought to be looking at risk ahead of time here instead of 11 waiting to be asked, so for good or bad --
12 DR. KRESS: Well, you really just confirmed what I 13 thought you would find out anyway, that the risk is going to )
14 be small.
\ 15 DR. MILLER: But that ds an important conclusion. )
16 DR. KRESS: Absolutely.
17 MR. EMCH: I am Rich Emch. I am the Chief of the 18 Radiation Protection Section, NRR.
19 What Charlie has described to you is the analyses 20 that have been done to try to help the Staff get an 21 understanding of what the impact of the revised source term 22 might be when the rubber meets the road, when licensees l 23 start saying okay, I am going to implement it for my 24 plant -- I am going to use this as my design basis analysis 25 tool and because of that I am going to use it to make ANN RILEY & ASSOCIATES, LTD.
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169 1 certain changes in my design that may make -- give me
() 2 operational flexibility, may save me money, may enhance 3 safety. There's lots of different reasons why licensees 4 would want to do that.
5 What I am going to talk about is the rulemaking ;
l 6- plan. We have determined that we do need to do a rulemaking, 7 and I am also going to talk a little bit about the pilot i
8 plants.
9 The first slide -- you can see that we are on the 10 hook to present a rulemaking plan to the Commission on June 11 30th and we are on course to meet that date. Since it is a 12 plan the Commission of course will be examining it and they 13 may tell us to do things slightly different or whatever.
(~N 14 There is also the chance that as Charlie finishes the other
"\ l 15 phases of this rebaselining analyses that there will be 1
16 other insights that pop up that might affect how we would 17 want to do the rulemaking plan or how we would want to build 18 the revisions to the rule.
19 This is quite preliminary but we would expect in l 20 this rulemaking plan to tell the Commission that we will do 21 the proposed rule by July 30th of '99 and complete the final 22 rule by February of the year 2000.
23 Principally the rulemaking is going to make 24 changes to Part 100, simply put, to put in the TEDE dose 25 guidelines -- the 25 rem TEDE guidelines -- and it will also ANN RIL3Y & ASSOCIATES, LTD.
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170 1 point out that it j *be most limiting with any two hour
()
l 2 exposure.
3 This will be in place for -- these acceptance 4 criteria will be in place for anybody who wants to use the 5 revised source term, wants to implement the revised source 6 term in their design basis analyses.
7 You probably remember that when we went through a 8 similar change for new plants we actually took the dose part 9 of this out of Part 100 and put it into Part 50. I think l 10 you probably saw that earlier when we were talking about the 11 AP600.
12 For a number of reasons that had to do with the 13 fact that Part 100 has been the rule of the land that all 14 these plants were' licensed to and because some number of 15- those plants might not ever want to actually change to the 16 TEDE methodology with a revised source term, there's a 17 number of reasons why we felt it would cause less confusion 10 if we'd go ahead and make the change in Part 100 instead of 19 following the method that was used for the advanced plants.
20 One of the things that we either forgot to do, ran 21 out of time or resources to do was to actually go into Part 22 50 and change the acceptance criteria, the dose acceptance 23 criteria for control room operators.
'24 That still says 5 rem, whole body, or the 25 equivalent to any organ and one of the things that we are
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171 l
1 going to do here is we are going to go in and change that to 2 5 rem TEDE in a manner consistent with what we were doing on 3 the offsite doses.
4 Then there is a whole handful or two handfulo, 5 maybe even more than that, of conforming changes. Most of 6 you would probably know that the references to the source j 7 term and to the acceptance criteria and that sort of 8 thing -- there are several places throughout the regulations 9 where this is included, and we are going to have to go l 10 looking -- we have found them all. l Now we have to figure 11 out what to do with each one of them.
i 12 There will be a lot of, as you can probably deduce l 13 from Charlie's presentation earlier, there are some insights 14 that go along with the revised source term and some changes 15 in approach, changes in calculational approach, and so we 16 believe that it is going to be necessary to draft a new 17 Regulatory Guide that talks nbout how one uses the revised 18 source term if you choose to implement the revised source 19 term.
20 It is important to point out that it is a 21 voluntary situation. The rules will be written so that it 22 is voluntary if somebody wants to use the revised source 23 term. We are not going to force it on any licensee. !
24 DR. KRESS: Does that 1-10-97 capture all but one 1
25 plant?
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172 1 MR. EMCH: There's been a little bit of a question
() 2 in our mind. I guess theoretically it should capture 3 everything -- I am not sure if it captures everything. It 4 doesn't capture the AP600 or any plants like that because 5 that is a different rule.
6 DR. KRESS: I don't think it captures Watts Barr 7 either.
8 MR. EMCH: I am not sure. Plus there's a couple 9 of plants that still have cps and never -- and we are not 10 quite sure what it means for them, so we will have to look 11 at that also, i 12 DR. WALLIS: Why do you need a prior to at all?
13 Why don't you just say anybody who wishes to voluntarily --
,, 14 MR. EMCH: Why the date at all? Is that what you
\~s/ 15 said?
1 16 DR. WALLIS: Presumably if they have a license, l
17 they got it some time and if they want to voluntarily amend 18 it, why do you need a cutoff date of one -- of anything?
19 MR. EMCM: Steve, can you help me with that, 20 please?
l 21 MR. LA VIE: The way the regulations are currently l 22 drafted, for licensees who are going after their operating l
23 license after 1-10-97, they must follow subpart (b) of Part i 24 100 and the requirements in 50.34.
25 MR. BOEENERT: Would you identify yourself for the ANN RILEY & ASSOCIATES, LTD.
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173 1 record?
() 2 MR. LA VIE: I'm sorry. Steve LaVie, Radiation 3 Protection Branch.
4 DR. KRESS: So it is not voluntary for those?
5 MR. EMCH: That is correct.
6 DR. WALLIS: Oh , they must now.
7 MR. EMCH: Okay. This is the pilot plants.
8 There's five of them -- Browns Ferry -- and what we have 9 done here is try to list for you some of the main things 10 that the pilot plants intend to do with.these -- as part of 11 their use of the revised source term.
12 Browns Ferry wants to increase the allowable MSIV 13 leakage and they want to delete the filtration systems on 14 the standby gas treatment system in the control room.
15 DR. POWERS: I will remind members that we do plan 16 to be visiting Browns Ferry in July, so if you are 17 interested in this particular area, you will have an 18 opportunity to ask.
19 MR. EMCH: Perry, Unit 1, they want to remove the 20 MSIV leakage control system and increase the allowable 21 leakage rate.
22 Indian Point 2, they want to remove the chemical 23 additives from the spray system, I believe it is. And they 24 also want to remove their in-containment filtration system.
25 You may have heard it referred to as kidney filters in the (O) ANN RILEY & ASSOCIATES, LTD.
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E ,
I l
l l 174 .
I 1 olden days.
() 2 Oyster Creek is a little bit different situation.
i 3 They have had a problem with their evaluation of control l 4 room habitability, proving to us that they meet GDC-19, for l
l 5 some time, and they don't want to make any changes to the i
6 plant. As a matter of fact, they want to use this to prove 7 that they are okay so they don't have to make any changes to l 8 the plant.
i ,
I 9 Grar:d Gulf wants to remove the MSIV leakage J 10 control system and increase allowable leakage.
11 CHAIRMAN SEALE: Could I ask, is anyone using this 12 to request a delay in availability of emergency diesels?
l 13 MR. EMCH: None of the pilot plants have suggested 14 this. At one time Haddam Neck, I believe, was -- wanted to 15 be, before they got more important things on their plate, 16 they wanted to be -- or tiillstone, I think it was, Millstone t
l 17 wanted to be a pilot plant, and several of the changes they l I l' I 18 wanted to make were very directly related to the timing auch
(
! 19 as what you are talking about. I I
20 Our expectation is that people, that some plants )
i
{
l 21 will want to take advantage of that. And, in fact, not '
22 solid on this, but we have given some consideration to --
23 some of the things that just really make a great deal of 24 sense from a timing standpoint, we might not even need to 25 actually do dose calculations and check them, we just say,
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1 175 l 1 yeah, that is okay, you know.
() 2 pandemic.
CHAIRMAN SEALE: Erpecially where it is kind of 3 Where everybody could get some help.
4 MR. EMCH: In one particular instance, I think 5 Millstone was having trouble with their -- how fast they )
6 cou;d drawdown secondary containment, and that was a change 7 they wanted to make.
8 I would mention at this point that there is a 9 generic framework document that was put out by NEI that 10 said, here's the kinds of -- here's the principles we want 1 11 to use to do this, and here's the kinds of things we want --
12 that we think our plants will want to use it for, and what i 13 you are talking about was one of the broad categories. It 14 doesn't happen to show up in the current pilot plants.
Q 15 CHAIRitAN SEALE: Thank you.
16 MR. EMCH: The Commission told us, essentially, 17 they naid, okay, ga do the rebaselining analyses and when 18 you are fairly comfortable with what the. insights of those 19 rebaselining analyses are, when you think you understand the 20 impact, then begin rulamaking and go ahead and do the review i
! 21 of the pilot plants. 1 I l 22 It is worth noting, we expect to have issue !
23 exemptions for the pilot p.lants for the same reasons that we 24 are talking about having to do rulemaking. So we have got 25 technical -- just about got technical assistance contracts ;
i
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176 l 1 in place with Sandia, Oak Ridge, and Pacific Northwest to do
() 2 various kinds of r.hings that those labs do quite well for 3 us, to help us. T1.e usual suspects, is that what you said?
4 Okay.
5 We have assigned technical reviewers in my group 6 and a lead technical reviewer, and they have started having 7 some brainstorming sessions to determine how we are' going to 8 approach some of these things. And they are doing 9 preliminary reviews to make sure that we -- if there are 10 major pieces of information missing, that we can get that 11 word out to the pilot plants quickly. So to speak, we are 12 kind of leaning forward in the trenches, getting ready to 13 start in earnest as soon as the - as soon as we get the 14 go-ahead.
15 And here is the last bullet, it is the one that 16 most people are really interested in. How fast are we going 17 to do this? Broadly speaking, we hope to complete the pilot 18 plant reviews by the end of 1998. ,
19 DR. KRESS: Any comments or questions from the 20 Committee?
21 (No response.]
22 CHAIRMAN SEALE: Very good. Pretty good.
23 DR. KRESS: I must say, I think you guys are 24 marching off in the right direction. Your stuff looks 25 pretty good. I reiterate that the rubber meets the road in
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)
177 1 Delta risk and I think you ought to give these pilot plants j
() 2 the 1~.174 treatment at-some point to see what the effect is 3 on the Delta LERF and Delta CDF, because that is what is
- 4. going to be asked. That is where the rubber meets the road. i 5 CHAIRMAN SEALE: I don't know. I think the rubber ;
6 meets.the road in reality.
7 DR. KRESS: It is -- reality is Delta CDF. ,
8 CHAlRMAN SEALE: Well, the reality is also the 9 possibility of being able to delay a start-up of the diesels 10 to, say, five minutes, if that is feasible, to make sure 11 they really start.
12 DR. BARTON: Save the diesels.
13 CHAIRMAN SPALE: Is that it?
14 DR. KRESS: That's it, I'll turn it back to you, O 15 Mr. Chairman.
16 CHAIRMAN SEALE: Thank you. Well, again, like I 17 say, I find this a very interesting presentation. It was l 18 obviously our interest that made us sit here a little bit i
19 longer, but we are glad you are willing to sit here with us, )
20 share you work with us. :
21 I think -- anybody from industry want to make any 22 comments or anything?
23 N response.]
[.o 24 CHAIRMAN SEALE: Okay. I think we have done it 25 for today as far as the record is concerned. So we will
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178 1 close the record.
()
O 2 [Whereupon, at 4:41 p.m., the meeting was recessed, to reconvene at 8:30 a.m., Friday, April 3, 1998.]
3 4
5 6
7 3
9 10 11 12 13 14 15 16 17 18' 19 20 ,
21 22 23 j 24 25 4
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REPORTER'S CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of:
l l NAME OF PROCEEDING: 451st ADVISORY COMMITTEE ON l
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PLACE OF PROCEEDING: Rockville, MD t
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 l typewriting by me or under the direction of the court i
l reporting company, and that the transcript is a true and i
accurate record of the foregoing proceedings.
-)u wn J n Hundley l Official Reporter ,
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