ML20248M096
| ML20248M096 | |
| Person / Time | |
|---|---|
| Issue date: | 06/04/1998 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-3041, NUDOCS 9806120380 | |
| Download: ML20248M096 (170) | |
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OFFICIAL TRANSCRIPT OF PROCEEDINGS LQ NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
(
Title:
453RD ADVISORY COMMITTEE ON l
REACTOR SAFEGUARDS Docket No.:
TEC4 ACRS R E~"JRN OR I G :.N A:.
T' Em"dH:TE M/S T-2E26 Work Order No.:
ASB-300-323 4:5-7: m THANKs:
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D LOCATION:
Rockville, Maryland DATE:
Thursday, June 4,1998 PAGES: 271 - 439 A01S Of EC05TETfY
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DISCLAIMER 1
~ UNITED. STATES NUCLEAR ~ REGULATORY COMMISSION'S 1
ADVISORY COMMITTEE ON REACTOR ~ SAFEGUARDS i
.1 i
l
. JUNE 4, 1998 i
The contents of this transcript of the proceeding of the United States Nuclear Regulatory Commission Advisory Commit' tee on Reactor Safeguards, taken on June 4, 1998, as reported herein, is'a record of the discussions recorded at j
I
.the meeting held on the above date.
This transcript had not been reviewed, corrected and edited and it may contain inaccuracies.
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-UNITED STATES NUCLEAR REGULATORY COMMISSION
- 2 ADVISORY COMMITTEE ON REACTOR' SAFEGUARDS 3
4' 453RD. ADVISORY COMMITTEE ON REACTOR SAFEGUARDS.
5 6
U.S. Nuclear Regulatory Commission 7-Conference Room 2B3 8
.Two White Flint North 9..
Rockville', Maryland
- 10 Thursday, June 4, 1998 11-l 12 The committee met, pursuant to. notice, at 8:30 13 a.m.
14-15 MEMBERS PRESENT:
16 ROBERT SEALE, Chairman, ACRS 17 MARIO.H. FONTANA, Member, ACRS 18-GEORGE APOSTOLAKIS, Member, ACRS 19 JOHN BARTON, Member, ACRS 20 THOMAS KRESS, Member, ACRS 21-DON MILLER, Member, ACRS
" 22.
' DANA POWERS, Member, ACRS 23.
WILLIAM SHACK, Member, ACRS 124 ROBERT.UHRIG,. Member, ACRS 25:
GRAHAM WALLIS, Member, ACRS
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1 P R O C E E D'I N G S (q-2
[8:30 a.m.]
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CHAIRMAN SEALE:
Good morning.
The meeting.will 4
now come to order.
5 This is the second day of the 453rd meeting of the 6
Advisory Committee on Reactor Safeguards.
During today's 7
meeting the committee will consider the following:
the 8
' agency-wide plan for high burnup fuel; operating plan from 9
the NRC technical training programs; status of Staff
- 10 activities associated with the proposed modifications to 10 11'
'CFR 50.59 -- changes, tests, and experiments; proposed final 12 standard review plan section in Regulatory Guide for 13 risk-informed, inservice inspection of piping; future ACRS 14 activities; reconciliation of ACRS comments and 15 recommendations; and proposed ACRS reports.
~
16 This meeting is being conducted in accordance with 17 the provisions of the Federal Advisory Committee Act.
Mr.
18 Sam Duraiswamy is the Designated Federal Official for the 19 initial portion 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 the meeting is being 24;
.kept'and.it--is requested that the speakers use one of the 25
-microphones, identifyfthemselves and speak with sufficient I
- rv
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- clarity and volumesso that they can:be-readily heard.
( )
.2 Today we have a full agenda.
Many of us are. going 3
to be involved in.the specific activities in that agenda, 4
and so our time.available to work on the research report to 5
the Commissioners is going to be quite limited today.
I 6~
would appreciate if you have any specific comments of 7-substantive content to make on the draft of the report that 8
'we discussed yesterday evening that you write those down'in 9-detail', identifying the page and line in.which you would 10 like to make or you would suggest changes, right them down 11 in an appropriate way so that they can be understood and 12 acted upon without a large amount of dialogue-back and
.13 forth.
14 I think we all have to recognize that the time
()
15.
available and the volume of the effort that is involved is 16-
- going to require that the decisions are on content or in 17 some cases going to have to be draconian and so let's worry 18 about things that are significant and keep our eyes focused 19 on the real issues.
20-Our first -- are there any other comments today, 21 l John, that I need to bring to anyone's attention?
22 DR. LARKINS:
No.
L 23 CHAIRMAN SEALE:
Any of the members have any other
'24 comments they would like to make?- Would you like to say
- 25 anything else,oDana?-
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DR. POWERS:
No, I think we'll move right along
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2 with the agenda.
3 CHAIRMAN SEALE:
Okay, fine.
4 Our first topic today is the agency-wide plan for 5
high burnup fuel.
We have a growing interest there, so I am 6
going to ask Dana, as chairman of that subcommittee, to tell 7
us what it is we are supposed to accomplish today and what 8
we are going to hear about and what the background is.
~
9 DR. POWERS:
Well, high burnup fuel of course is 10.
one of those issues that arises naturally because of 11 economic forces on the nuclear industry and taking fuel to 12 higher burnup has been a consistent trend over the last two 13 decades.
14 We were alerted by tests done in other countries
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(s) 15 that there may be a limit to where we can take burnup and 16 indeed we have arrived at that limit, and we are finding 17 that suspension of some of the agency's research in high 18 burnup fuels may catch us short as far as databases we have 19 available.
20 Today we are going to hear about attempts to catch 21 up in the area of high burnup reactor fuels.
The research 22-program in that area is asking us two questions that require 23 two distinct answers and distinct people.
They are going to 24 ask about our opinion on their overall research program.
25 They are also going to ask us about a specific involvement mj' ANN RILEY & ASSOCIATES, LTD.
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in a cooperative agreement abroad concerning the CABRI 2
reactor, so we are going to have to prepare two letters in 3
this regard.
I l
4 With that introduction, I guess I will turn to the 5
staff from Research and Ralph, are you going to lead off?
l_
6 I will introduce Ralph Meyer.
I think we have l
7 come to know him well -- and I will point out that there has 8
been a subcommittee meeting that went on for a couple of 9
days on this particular subject.
I think that most of the
~10 members who attended that subcommittee meeting came away 11 enthusiastic.
The subcommittee meeting did take quite a 12
.little time to cover this subject and we have constrained
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13 Mr. Meyer to a very limited amount of time to present that 14 two day's worth of material, so I think he is going to be (O) 15 terse in his presentations.
That hopefully doesn't detract 16 too much though.
Ralph, you have the floor.
17 MR. MEYER:
Thank you.
A little over a year ago 18 we briefed the Commission on several issues that had arisen i
19 regarding high burnup fuel and as a result of that briefing, 20 we were instructed to appoint a central coordinator in the 21 agency for high burnup fuel effects and that person was 22 Ashok Thadani and his first-action as the new High Burnup 2'3 Czar was to direct the Staff to prepare a program plan,
. :2,
cy'incy-wide program plan, to deal with the issues of high 4
.25-
.burnup fuel.
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So we did that, and for the most part the issues
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2 that we discussed with the Commission and that form the 3
scope of the program plan were issues that arose after the 4
NRC had given approval to the industry for burnups up to the 5
level of 62 gigawatt days per ton average for the peak rod, 6
so the major goal then of our work and as described in the 7
program plan was to provide some confirmatory assessment of 8
those approvals.
9 Even now, however, we are getting requests for 10 further burnup extensions and so one part of the plan then 11 was to try and define a strategy for dealing with further 12 burnup extensions, so the plan will also address a stre.cegy 13 for assessing these requests to go beyond the current limits 14 of about 62 gigawatt days per ton.
15 This slide now shows the issues that are covered 16 in the plan.
These were the ones discussed with the 17 Commission in.1997 and in the program plan we settled on a 18 format for discussing each of these issues, which provides 19 the following information.
20 First, we describe the nature of the issue.
Then 21 we give a brief risk perspective on this issue.
Following 22 that we say why it is okay in some cases to wait three to 23 five years to obtain new data so that we can finally resolve 24 the issue..We identify related NRC funded research and we
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251 indicate what'is needed for final resolution, so the report ANN RILEY & ASSOCIATES, LTD.
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- 1' is repetitive in this format.
For each of these nine 1 DL 2
issues,'you will see a discussion of'those' subjects.
V 3
'Now.the risk' perspective that we tried to bring 4
into this'was a serious effort, and'in one important area 5'
there was not information readily available from, say, the 6'
IPE studies.
This was in the area of the reactivity-7
' accidents, which generally are not high risk' accidents and
'8 so.you don't find them routinely addressed in PRAs, so we 9
asked Brookhaven, who had been involved in a lot of the risk 10 studies, tx) take a specific look at the reactivity
'11 accidents, specifically the rod ejection accident in a 12 pressurized water reactor and the rod drop accident in a 13 boiling: water reactor.
14'
'At the.same time they looked at a broader range of 1(
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- 15 reactivity accidents including power oscillations that 16 accompany a BWR ATWS, anticipated transient without scram.
L
'17 So the report by David Diamond in early spring of 18 this' year. covered the reactivity initiated accidents and a 19 range of other reactivity type accidents.
It also, by the
=20 way, mentioned some of the probability figures for loss of
-21 coolant accident in the report, which gives us a single 22 place to_look for the information that we have used in the 23 program plan on these risk perspectives.
24-DR.~ POWERS:
Ralph, earlier in the week the 25:
committee.has been listening to a protracted series of l
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presentations on power upgrades in a particular BWR.
Those
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have, analyses have-largely been done based on the existing (d
3 safety analysis report.
4 It seems to me that perhaps not at that particular 5
plant that we were hearing about but eventually at some 6
plant we are going to have the confluence of high burnup 7
fuel and power upgrades, and that comes into this question 8
of oscillations and anticipated transients without scram.
9 Have you looked at these two combined things in 10 any -- even just a qualitative sense to say is there a lul special issue we should be paying attention to here?
12 MR. MEYER:
Well, I thought about it briefly and 13 they seem to be relatively independent to me.
It is 14 important I believe that we straighten out our criteria and O
(_ )
15 requirements for high burnup fuel and once that is done the 16 power level will follow, so I don't see any complications --
17 DR. POWERS:
You don't see any synergistic effect 18 here that would -- I mean some of these power upgrades are 19 power upgrading one reactor to a power level that is well 20 below what others operate at, but you just don't see any 21 synergistic effect that we should worry about here?
22 MR. MEYER:
I don't offhand, no.
23 DR. POWERS:
Good.
24 DR. UHRIG:
What about the fact that most of this 25 upgrading is done by flattening the flux and bringing other i
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ffuel assemblies up.to the same exposure as the peak burnup l
2 level -- peak flux level as well as the burnup level?
'3 Do you think the existence of more fuel in there
~
4 with a higher burnup, but that is the overall average ~will 5
'be higher whereas the peak value may not be any higher than 26 62.
7 MR. MEYER:
The only thing that I think might l-8 result from this that has implications in the way that we 9
handle the high burnup issues is that as you design a. core 10 this way, you may use more and more burnable poisons to l
, 11 achieve uniform power levels for a longer period of time.
- 12 When you do tiiis, then you postpone the time or prolong the 13 time that fuel is operating at a high power level as it 14 progresses in burnup, and this tends to weaken arguments
~
~ 15 that you might make that old fuel is tired fuel and 16 therefore it is not limiting and we don't have to worry so.
i 17 much about it in terms of the regulatory limits.
18 But we have been pursuing all of the issues in a 19 manner where we attempt to define the regulatory limits for
-20
'the.high burnup fuel and then those considerations would all 21
. wash out in the analysis.
I mean-it is only when you say, 22
.. oh, I am not going to bother with this issue at high burnup
'23 fuel because the fuel has low reactivity and it won't be-24 anywhere~near its limiting power.
Then you would have to 25
-question ~whether thatLis a good assumption, and we are not N,O ANN RILEY &-ASSOCIATES, LTD2
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making that assumption by and large in shooting for final
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'2 resolution on these issues.
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DR. UHRIG:
I guess I-was thinking of the 4
' possibility that a little swelling within the one fuel 5
= assembly might be tolerated without binding the control 6
rods,.whereas a large number of them exposed at the same 7
level might have a overall effect.
8:
MR. MEYER:
I don't see a synergistic problem.
9 Okay.
Out of that list of issues, I am only going
-10 to focus on four of them, the three on criteria, criteria.
11 for the reactivity accidents, for the loss of coolant
-12 accidents and for the ATWS. power oscillations, and then the 13~
high burnup code.
There's a number of reasons for focusing 14' on those,.I am not going to dwell on this.
You can see that e
15-a couple of the issues are now resolved, a couple of them 16 are in the future.
And combining those realities with some
~
17 of the risk perspective, we end up drawing a bead on the 18 four in the middle and it's my intention now to talk about 19 those four.
20 And the first of those then, No. 3 on the list, is 21.
the criteria and the analysis for the reactivity accidents.
22 I think you are familiar with the background of this issue j
23 and also our. interim finding that there is no immediate 24 safety concern.
In fact, with regard to all of the issues 25 at high burnup, we have made, rather quickly, findings of no i
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immediate safety concern, and I think these are appropriate
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2 findings, even though we haven't fully resolved the issues
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and this distinction is discussed in the plan.
4 I am not going to go through all the details 5
because I think you are rather familiar with them but 1
6 there's one thing here on this slide that is relatively new 7
and I want to point it out to you, and that is, in the risk 8
perspective, that we have looked carefully at the boiling 9
water reactor, rod drop and the PWR rod ejection and we see 10 a difference.
What we find is that even conservative 11 assessments of the probability of occurrence of some sort of 12 unacceptable fuel damage from a rod drop accident is less 13 than 10 to the minus 7.
It is below the level that we would 14 give it consideration as a generic issue.
And I would say,
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15 just colloquially, that it seems to be so unlikely that we 16 don't need to worry about it.
17 That's not the case for the rod ejection accident l
18 in the PWR.
So from this point on, my discussion of the 19 RIA, the reactivity initiated accident, will be in regard to l
l 20 the pressurized water reactor event, the rod ejection 21 accident.
You will see in a minute though that the BWRs 22 aren't completely off the hook because we have the power 23 oscillations in the ATWS would come out with a fairly higher 24 probability and aren't negligible.
i 25 So what I would like to do now is to focus on our l
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plans for getting final resolution with the RIA, the l
(7-')
2 reactivity initiated accident, for the pressurized water
.v 3
reactor.
And this involves the water loop in the CABRI 4
reactor.
And I want to ask the question, Why does NRC need 5
more tests?
We need more tests because this issue is not 6
resolved.
And it seems to us that this is the only way that 7
we are going to get the issue resolved.
l 8
We have a Regulatory Guide 1.77 that gives the l
9 criteria for analyzing a rod ejection accident in a PWR and 10 after looking at those criteria, in contrast to all of the 11 data coming out of test programs in Japan and France with 12 high burnup fuel, they appear to be inadequate.
We have a 13 general design criteria and it specifically addresses this 14 accident, and so we need to provide some confirmation that ID (j
15 we are meeting the general design criteria.
16 We did do the best job that we could with the 17 existing data, that means the data out of the sodium loop in 18 the CABRI test reactor, and the low temperature capsule data 19 out of the nuclear safety research reactor in Japan.
The 20 Office of Research put together some proposed interim 21 criteria and, while I think these were useful, they were not 22 accepted as a means of bringing final resolution to the 23 issue, largely because there were big uncertainties in the 24 data.
And the test conditions, as we discussed in our 1
25
-subcommittee meetings and other places, left a lot to be n.
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desired and raised-questions about the adequacy of the O).
2 criteria.
G 3
We also had a major effort by the industry, 4
coordinated by NEI, and with technical work done by EPRI and 5
its' contractors:to bring to the NRC an analytical method L
6' that said we don't have a problem with this accident.
And 7
that was likewise rejected, largely on the basis of lack of 8
validation with test data.
Going beyond those, I could say that we looked 9
10 carefully at the plant calculations and at these data to see 11 what the apparent margin was between the energy deposition 12 level where you expect fuel damage and the capability of the 13 plant to deposit that energy, and, in fact, the margin 14 looked small.
This is quite a contrast to the situation a 7-t 15 few years ago before we had the high burnup data.
For.the 16 past 20 years, using Reg. Guide 1.77, and having some 17 knowledge of realistic plant calculations, the margin 18 between the capability of the plant to deposit energy during 19 this accident and the regulatory criteria looked absolutely 20 huge, and we didn't worry about the fine points of 21 irregularities in the criteria.
So --
22.
DR. POWERS:- Let me ask a question about 23 MR. MEYER:
Yeah.
24 DR. POWERS:
People have accepted and rejected 25 various things'here, and it hinges upon the data.
Data
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-involved segments of fuel'.
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MR. MEYER:
Yes.
Af 3;
.DR.
POWERS:.Maybe they are-like this.
4 MR. MEYER:
Right.
5 DR. POWERS:
And you go out and do and test --
'6-MR. MEYER:
Like this being about 15 inches-long.
7 DR. POWERS: '.Thank you.
And they get a result.
8 Sometimes that result indicates a very. low capacity for the-9 fuel to absorb energy, and that' fuel segmentLthat was used 10:
gets.then scrutinized and people say, oh, there was a flaw
-11 in that fuel segment for some reason.
12 I guess two questions come to mind.
How many 13 tests do I have to do in order to get a persuasive database?
14
-And when I find that I have flaws in my fuel specimen, why O(_)
15 is that significant?
Won't I have flaws in fuel rods of a 16 similar nature?
I mean these fuel segments are taken from 17 fuel rods.
18 MR. MEYER:
Yeah.
I'll make several comments.
19 There's really only one test that is highly contested over 20 the matter of a pre-existing flaw and that was the first 21' test in the sodium loop in CABRI, the. test we call REP NA1.
22 The people who conducted that test, to this day, adamantly 12 3 -
insist.that'there was.no' damage to that rod that was related
. 24 to-the' failures:during the. test.
Other people who have
. 25 examined the data still think there was.
There are repeats
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going on of.that test right now.
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I think with regard to how many tests that we
[J 3J need, I would say we don't need very many.
Maybe four or 4
,five for a cladding type, so that we get sv.te repeatability 5
and some variability with either burnup or oxidation level, 6
the principal variables.
7 What we have right now is a collection of data 8
that some'rather serious atypicalities with them which.
L 9
weren't understood to be so significant when the tests were 10 planned, but only become significant when you Jook back at 111 the test results.
In particular, the Japanese tests are all 12 run at room temperature, and we know that this accident will 13 only occur at a hot zero power condition.
So there's like a 250 degree centigrade difference in temperature of the
.14 -
O) 15 cladding just due to the test condition.
And because the
(,
16 cladding property that is important for failure is cladding 17.
ductility, this temperature is very important.
I 18' We have most of the tests performed to date on old 19
. style cladding, standard zircaloy'of years ago with a high H2O tin content, which is much more susceptible to oxidation 21-than the lower tin variance or the new niobium allows which 22 not.been tested at all.
.23 And then there's the matter of pulse width which 24 seems. to be: important, which is significantly different in
- 25 -
the test reactors.and the power reactors.
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' 1' So I think what we need is a short series of tests
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.under more typical conditions in those areas where we.found L3-the atypicalities to be a problem, and a' couple of group of L
l 4.
tests like-this for the major situations.
In fact, I have L
5 on the next slide what.I think would comprise a good base 6
program'and'I-believe it would provide 1 what we-needed.to get 7-fclosure on this. issue at the current approved range.
Juni 8
that would amount to testing two of the principal-cladding 9
-types, the low tin zircaloy 4 and niobium alloy.
10 DR. POWERS:
I mean you are very experienced, more 11; experienced than I, certainly in this area, and so your 12 judgment is very valuable.here.
But it would be more 13 persuasive-if we had some sort of -- some much'more 14
~ quantitative analysis on.how many data points are needed.
.15.
You_know, I am thinking in terms of-straight line 16 correlations, you can sit up good statistical criteria for 17 how many tests you need and. things like that.
18
- Is there any mechanism in this world, in.this 19 particular_ area that we can come up and say, okay, four 20-tests are going to ch3 it?
You know, I am going to get 21 enough data here'that I can.even persuade the doubters at
. 22 lEPRI, who~are~the ones that_ questioned the existing CABRI 23
' tests.
And can I confront'the contention that the power 24-pulse;used in:the tests is outs'ide-the range of reality for 25-
_a power plant?
I mean:is within'the. range of reality for a h-s iANN RILEY & ASSOCIATES, LTD.
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power plant.
()
2 MR. MEYER:
Well, I don't think thers's a big 31 problem in performing a test that is in the reality range 4
for a plant, now.that we understand the importance of some 5
'of the major variables.
There is, of course, a problem in 6
getting'a statistically significant database, and what we 7
are dealing with here is the art of the possible and a lot 8
of compromises.
There is no way that we can afford to 9
generate a large enough database for the kind of statistics 10 that are done en heat transfer correlations or some other 11 properties.
12 On the other hand, even though this event is -- in 13 probability space, is high enough to be considered, it'is 14 still a very unlikely event.
And so the amount of precision I
(,f 15 that is required in the answer probably is not so great.
16 DR. POWERS:
But I guess, I mean it really gets 17.
down to the heart of the argument, is that if we are limited 18 in the number of tests such that you can't do the kinds of 19 statistical correlations that you speak of for heat transfer 20 coefficients, then a low number of tests may simply be 12 1 -
-fooling us.
On the other hand, why can't we do, this is to 22 correlations, except instead of asking for a 95 percent 23 confidence intervals on things, you ask for 50 percent 24 confidence intervals?
25 I mean it seems to me that you can't ignore the f ')
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288 11 fact that these statistical analyses are meaningful, and 2
that it may be that getting a few extra, like four tests 3-with low tin zircaloy simply doesn't change your attitude 4
toward it when you do apply these statistical methods.
In 5
which case they are of zero cost impact.
6-MR. MEYER:
I don't really know how to answer you.
7 The f act is that we have always been living with suall
~
8 numbers of tests in this area because the tests are reactor 9
tests.
I mean,'you do one -- you occupy the whole reactor i
10 for one test, and you do them one at a time.
So they are 11 expensive, and you'll never have a lot of them.
12 We simply don't have tests that are devoid of 13 these major objections, and I think a -- I think a small 14 series of tests like this will give us -- I mean, I know
()
. hat the difficulties are that we had in trying to utilize a 15 w
16 criteria that was based on a relatively poor data base.
I 17 mean, it gave us some feeling for where the failure level 18 was, but the uncertainties were quite large.
And I'm fairly 19 sure that we can resolve that sitnation if we can get a 20 group of tests that don't have the major objections that 21 those do.
22 Now there is also the program in Japan that will 23 supplement this, but I think the water loop in Cabri is key 12 4 to the whole thing, because the NSRR reactor can't alter its 25-pulsewidth.
So it's destined to perform the remaining test (N-ANN RILEY & ASSOCIATES, LTD.
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that it will do with the narrowest of all pulses in all of-
\\
2-these test reactors, about 4-1/2. milliseconds.
The Cabri
[O 3
natural pulsewidth is a little under 10 milliseconds, twice l
4' that of the'NSR reactor.
And they have-the capability of L
5 broadening it with some artificial means.
6 MR. KING:
Let me add a couple things, Ralph, if I 7
could.
This is Tom King.
8 I don't think getting a statistically significant 9
data base is the primary issue here.
I think what you want 10 to establish.is the repeatability in the test, that when you 11 run the same thing --
12 DR. POWERS:
It's a statistical concept.
13 MR. KING:
It's a statistical concept, but to me 14 it's not one where you have to demonstrate, come up with
()
15 some limit'to some 95-percent confidence level or something 16 like that.
Once you can demonstrate repeatability, I think 17 there are enough other things that are uncertain in this 18 whole issue, things like how well do you know rod worth.
19 Little changes in rod worth can make a big difference in the 20 accident.
As the cores go to high burnup, you get changes 21 in reactor physics characteristics and so forth.
22 Those all add uncertainties to the calculation you 23 do, and I think once you can get some reasonable estimate of 24 what the cladding failure limit is, you have to step back 25-and say'okay, what's the analysis method and assumptions I'm D[
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f 290
-1 going to accept to account for all these uncertainties so
()
2 you can have some confidence that you've got some margin 3
between what you're calculating and what the real failure 4
rate-is.
5 I don't think it's. worth putting a lot of money-6 into doing a whole bunch of tests.
I think it's worth 7.
putting money'in to do enough that you can demonstrate l
8 repeatability so you've got some confidence that yes, I 9
understand the phenomena and those are really the ones that 10 are controlling things, and I've got a good ballpark idea of 11 where things fail and what's causing them to fail.
12 DR. POWERS:
You come down to the -- your answer 13 is the question, actually, that suppose -- we have one test 14 out there that gets' variously plotted as either 18 or 36 15 calories per gram, and there are contentions concerning that 16 particular test.
Suppose we tried to repeat that and we got 17 100 calories per gram.
Would our uncertainties concerning 18 the phenomenon be any reduced?
1 19 MR. MEYER:
Well, I think you may -- you may be 20 thinking too much about REP NA 1, the test with the spalled i
21 oxide.
That test was repeated in an approximate way in REP 1
22
.1U1 8, and it did get a higher failure level with indications 23 beginning around 24 calories per gram and with clear failure 24 occurring around 83 calories per gram.
There were some 25' uncertainties with that test as well, and another repeat ANN RILEY & ASSOCIATES, LTD.
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will be made in a few days in a test called REP NA 10.
2 But'-the thing that's different about these is 3
these are old-style cladding with heavy oxide that's 4
spalling.
This is not what we expect in the future.
There 5
is still some of this fuel out there, and this test is about 6
whether or-not the fuel -- the current old fuel with heavy 7
spalling oxide is a problem.
And this is a problem that's 8
going to disappear rather quickly because of changes.in fuel 9
design.
10 So that problem is one we expect to go away with 11-the current group of three tests and whatever decisions that 12' we make.
That question will not be included in the future 13 test series which will address cladding that presumably did 14
'not have heavy spalling oxide, and particularly the niobium
()
15 alloys will not have much oxide on them at all.
16 So that huge uncertainty that you see with the REP 17 NA 1 and REP NA 8 are really not typical of what we're 18 looking for with the new series of tests.
Those in my 19 estimation are values where you have fallen off of the 20 cliff, and they're values on the way down over the cliff.
21 What we really want to do is find out where the cliff is and 22 stay back from it.
1 23 DR.-POWERS:
And you want to find that out for 24.
. fuel that's actually. going to be used in the future --
25 MR. MEYER:
That's correct.
j
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DR.-POWERS:
Instead of fuels that
'2 MR. MEYER:
That's correct.
3 EDR. POWERS:
In the past.
4 MR. MEYER:
Now I don't know whether we've ever 5
mentioned the cost"of this program to you, but the cost to 6
the NRC for this program would be about $500,000 a year.
We 7
have discussed this program with EPRI.
We have initial 8
indication of cooperation on this program.
These 9
arrangements have not been finalized.
We're in the process 10 of trying to cement them right now, and have imminent 11 meetings with the French and discussions with EPRI.
But for 12 us, you know, in the grand scheme of things, this is a 13 low-cost program -- a high-cost program with a low price tag 14 for us.
)
15 DR. SHACK:
The real answer to Tom and -- comments 16 is that -- I mean, you are working on the premise that you 17_
will get repeatability..
I mean, if these four tests come 18 ranging from 10 to 200, I think you'll have a problem.
19.
MR. MEYER:
We're certainly not expecting that.
20 DR. POWERS:
That would tell you we're looking at_
21 the wrong variables.
I mean, if they're all over the map, 22 something is wrong, and that's useful.
23 MR. MEYER:
We don't expect them to be all over 24 the map.
I mean, we think we know -- from what's been'done, 25 we'think we know what are the major _ variables.
l l
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I 293 1
DR. SHACK:
And you'll lcnow you. have a major l [)
2 problem --
V 3
DR. POWERS:
In that regard another question ~was 4
raised in the subcommittee meeting that we failed to pursue 5
further, and.not you but another speaker made a passing 6
comment that the way fuel is burned up makes a difference in 7
.its behavior.
And indeed we had a speaker describe two
~
8 general ways things were burned up, fast burnup and a slower 9;
approach to-high burnup.
10 That doesn't seem to figure as a variable in your 11 overall matrices either here or elsewhere in the program.
12 Do you have comments on why that is?
13 MR. MEYER:
Well, I think it would figure in in 14 the larger scope of work, but not in these tests.
These
(
15 tests would utilize fuel rods probably from a French PWR 16 with'high burnup on them, and whatever the power history was 17 is what we're going to be testing, and with the small number 18 of specimens for this we're not going to.be able to sample 19 lots of different power histories.
20 However, there are going on at the same time 21:
mechanical properties testing, which is a lot easier, a lot 22 cheaper, and you can cover these variables.
23 Now I would say that we're not far enough along 12 4 where we have worked that into our test matrix.
Certainly
.25 in the NRC program we are -- we don't have a large enough
([
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294 l-1 program to. work in all those variables.
But I would expect I~'\\
2 the industry would work then into their programs, and as you O
3 also recall from the subcommittee meeting that the industry 4
method -- analytical method that was not accepted by the NRC 5
was nevertheless a method that has merit and that will allow 6
us to do at least some interpolation to cover variables of 7
that type and also for example to cover variations of 8
cladding type like if we test on one niobium alloy, 9
hopefully by using measured mechanical properties for the
'10 appropriate alloys, that we could extrapolate those results
There are two or three varieties 13 of niobium alloys out there, and we're certainly not going 14 to test all of those in this integral program.
But we would ID
(_,/
15 address them with the mechanical properties test and have 16 the analytical means to interpret them.
17 DR. POWERS:
Is this matrix that you have up here 18 going to provide a sufficient basis to add substance to 19-that?
Hopefully you can extrapolate from one type to the 20 other.
21 MR. MEYER:
I think so.
I mean at this point all 22 we can do is use our judgment, but knowing where we have 23 come and how we have failed, I think this will give us the 24 resolution, the model validation that we need to do the
-25
. remaining interpolations.
(v)
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1 DR. POWERS:
I think we need to move on, but I 1
/-s l
[
2 would add that making that point, that in the end you're i
3 going to have to extrapolate or interpolate among various 4
types of alloys --
l 5
MR. MEYER:
Yes.
6 DR. POWERS:
And you need to validate that --
7 MR. MEYER:
Yes.
8 DR. POWERS:
Would be a potent argument in favor 9
of this test matrix.
10 MR. MEYER:
Yes.
-11 DR. POWERS:
Rather than just telling me I'm going 12 to do four tests.
13 MR. MEYER:
Yes.
14 DR. POWERS:
Tell me why -- not me, but tell your (n) 15 audience that I've got a problem in my overall strategy that 16 I need to validate my interpolation and extrapolation 17 techniques.
18 MR. MEYER:
This is pretty marked for the -- on 19 this slide I've got -- forget the MOX for a moment -- but 20 the ZIRC 4 and the niobium alloys.
We have seen results 21 from Russia on pulse tests with zirconium 1 percent niobium 22 alloy, and it behaved in a radically different fashion than 23 the Zircaloy did.
24 Now VVER 1-percent niobium is not the same as
.25 ZIRLO or the other varieties, but I would expect to see
.(O ANN RILEY & ASSOCIATES, LTD.
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significant differences in the failure behavior -- maybe 2
even the mode of failure might be different.~-- for the 3
niobium' alloys than for the Zircaloys.
4 So I think this gives us the two major variants 5
that we need, and then we should be able to work from those 6
for Zircaloys and for niobium alloys with mechanical 7
properties and analysis.
That's the plan.
8 CHAIRMAN SEALE:
Ralph, could I ask you a somewhat 9
different question?
10-MR. MEYER:
Yes.
11 CHAIRMAN SEALE:
Earlier you mentioned in your 12 slides that the industry had made a proposal and that NRR
'13 had rejected --
14 MR. MEYER:
Yes.
15 CHAIRMAN SEALE:
That proposal, and then just now 16 you made the comment -- referred back to that, I guess, i'
17 again.
18 MR. MEYER:
Yes.
19 CHAIRMAN SEALE:
Have you discussed this 20 statistically limited approach to testing of these 21 particular clad types with NRR to see whether or not you 22 have a viable set of results if your expectations are 23 verified by the tests?
I mean, are they going to buy what 24-
-you come up with, or what are their -- what will be their I
~
25' basis to make a buy / reject decision?
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fMR. MEYER:
Well, I think -- they are here and
(}
2 Tim, think of.your answer while I am stalling here --
3 (Laughter.)
l 4
MR. MEYER:
I think to a large extent NRR will 5
depend on Research for help in doing that and we will work 6
together on it.
7 Tim, can you comment on this?
8 MR. COLLINS:
-This is Tim Collins from Reactor 9
Systems.
10 We are es.ncerned about the limited number of tests 11 that are going to be done, but we are also taking into 12 consideration in the probability of the event it is hard for 13 us to -- in this regime of limited resources we have to make 14 a prioritization of where we want research dollars spent as O) 15 well.
(
16 CHAIRMAN SEALE:
Sure.
17 MR. COLLINS:
This program looks to us like it is 18' bargain, and it is going to provide good information in an 19_
area where we have some questions, okay, so we would like to 20 have that good information, that good data to provide us, if 21 nothing else, good insights as to judgments we may have to 22 make about these low probability events.
23 We are not expecting the results of these programs i
24 to lay out for us a statistically supported new set of 25 criteria in and of themselves, but we believe that the l
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298 1.
information that will be provided, a-lot of'it depends on
[V) 2 the outcome of the tests.
t 3'
CHAIRMAN SEALE:
I appreciate that.
4 MR. COLLINS:
Hopefully the' outcome of the tests.
5 Since it looks to us like a bargain, let's get the 6-information --' good information, accurate test data
' nformation is always good. 'So if we get it at a bargain-in i
7 8
this area where we think we need information, let's go get it.
' 10 CHAIRMAN SEALE:
So there is an NRR endorsement of 11-this program?
12 MR. COLLINS:
Oh, yes, yes, yes.
13 CHAIRMAN SEALE:
Okay.
14 DR. SHACK:
Ralph, you did mention that you have a 15 number of partners in this.
The French are also important.
16 Has the decision been made to go ahead with the water loop?
17 MR.'MEYER:
The decision has been made to go with 18 the water loop.
I am not sure about -- well, I can stop 19 there.
20 I have been informed in the last two weeks that 21 IPSN has made the decision to construct the water loop and 22 therefore the questions of ccnducting future tests _in either 23 a-water loop or a sodium loop are moot.
That's the same 24 price and besides, the sodium loop is going to be retired.
- 25 They are going to build a water loop.
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DR. SHACK:
That sort of settles that one.
V[
\\
2 MR. MEYER:
That one is settled, yes.
Can we go 3
on, Dana?
4 DR. POWERS:
Please.
5_
MR. MEYER:
The next iss'te, and I am watching the 6
clock so we will try and pick up speed here, is the matter 7
of the. loss of coolant accidents.
8 Again, I think you are familie.r with the issue and 9
its background where the embrittlement criteria in our 10 regulations and the ECCS models that we use are 11 theoretically affected by the things that happen at high 12 burnup.
13 To resolve this issue, we have initiated a program 14 in the hot cells at Argonne National Laboratory to test high O
(_,)
15 burnup fuel rods from both a BWR in the U.S.
and a PWR in 16 the U.S.
17 The purpose of this program is several-f'old.
18 First of all, and most importantly, it will be a 19 direct test of the embrittlement criteria from the 20 regulations.
These criteria are the 17 percent cladding 21 oxidation limit and the 2200 degree Fahrenheit peak 22 temperature limit.
23 In doing these tests we will also generate a 24 database that is needed for deriving ballooning and rupture.
25 models which are needed to carry out an Appendix K type or a b'
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best estimate type ECCS analysis.
/~')
2 There is a second'part of this program which will
. \\._/
3
. measure mechanical properties of cladding;from high_burnup 4
fuels under transient conditions and this is designed to 5'
give us a broader range of applicability.
That is, we'will 6
test under conditions that will give us data we can apply to l
l 7
-the reactivity accidents, the loss of coolant accidents and 8
the power oscillations.
l 9
The test plans are well developed for this program l
10 now and on this one we are working very closely with EPRI.
L 11 Let me just show a couple of diagrams here to 12-illustrate major features of the program and I am not going 13 to dwell on these, but this is a diagram of the apparatus 14 that is under construction right now.
That we'll use to m
jyj 15 search for the embrittlement thresholds.
16 All of the tests will be conducted at 2200 degrees 17
' Fahrenheit, the peak temperature limit that is built into 10 18 CFR 50.46, and we will vary the time of the hold at this 19 temperature, which will then vary the amount of oxidation 20 and it will be cooled and quenched in a rather typical 21 manner and we'll search for the fragmentation threshold, 22 which will give us the measure of the embrittlement 23 criteria.
24 There is a reasonable chance that the present 25
. criteria will work for high burnup fuel provided that we
't 9 -
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include'into the assessment the amount of oxidation that 2
takes place during normal operation prior to the occurrence of the transient, so all of those things will be looked at 4
in this program.
5 The mechanical properties tests -- there are 6
several varieties.
This is just one of them.
These are 7
ring-stretch tests, which will be done with the fuel removed 8-from the segments.
They will be done under several loading 9
conditions, but must prominently we'll be doing these under 10 plain strain loading conditions that are similar to the
'11 conditions that occur during the reactivity accidents.
12 This is a rather interesting and I would say 13 exciting part of the program right now, because we are 14 really at the state-of-the-art with this.
We have been e p) 15 looking carefully at the testing conditions, have run some
(,
16 round-robin measurements with laboratories in France and 17 Russia, and I think we are on the verge here of getting some 18 really interesting and useful data.
19 I know EPRI is excited about this program too, and
~
20 it seems to be. going quite well.
21.
There will also be some biaxial tube burst tests.
22 I haven't shown the diagram from that but there's a full 23 range of testing conditions and the specimens will be 24 matched up very closely with the specimens from the LOCA 25 criteria tests, so'we have very good material control during h
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302
(
1 this program.
A
' i i
- 2 The next issue then is the one of the power
%,J.
'3 oscillations during-the BWR ATWS.
Our risk-based L4 assessments'show'that'this was not negligible and so we.are l
5 trying to deal with iit.
6.
_This one presents us with'a problem, because we.
7 don't have a database for cladding behavior under these 1
L 8
conditions and the conservative use o,f RIA criteria doesn't
_9 seem.to be working any longer when we alter the RIA 10 criteria.
We don't have any margin left.
11:
I would say candidly that this is --
12 DR. POWERS:
I guess I don't understand what you 13 mean it doesn't work.
You say you altered the RIA criteria 14 and you have lost your margin.
I mean that seems like it's
,O
(,,).
15 worked just fine.
You have lost your margin.
16 MR. MEYER:
Well, the problem is that this 17 transient is different than an RIA transient.
18 The pulses are much broader and the loading on the 19 cladding will be quite different.
They occur in a different i
j 20 temperature regime.
These are at power.
They are
~21
-repetitive, so the -- it was believed that one could borrow j
22.
the criteria from the rod drop accident in the boiler and
~ 23 use that for these oscillations, and it was believed that 24 that was annar conservative because on one hand you have got 25-Ja very narrow prompt critical pulse and then here you have
. (
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__.w__.__m.... - _. _ _ _ _ _. _ _. _
303 Li~
-got'these broader oscillations, so the cladding -- the'
'( )
52;
. loading on the cladding will be different.
It should be
- 3
less severe 11n the power oscillations.
4; So I mean'you are kind of.a little bit lost'here.
5 You~ don't show the margin anymore.but on the other hand you 6L fbelieve you that those criteria that you were using were.
7.
Lvery conservative for this event.
You just don't have a 8
bead on it.
9 DR. POWERS:
So what you are saying is that you
.1(L think the criteria are just too conservative?
11 MR. MEYER:
I think the' criteria are too 12 conservative and I don't know what new criteria should be.
-13 This is the weak element in our plan right now.
14.
We don't really know how to attack this well.
()
15 What we are doing is'we are doing. calculations 16' with our transient fuel rod codes to.look at the loading on 17
.the cladding and the response of the cladding.
We are.also 18
. setting up to do more refined plant. transient calculations
'19 with our coupled, three dimensional neutron kinetics codes.
^20 DR. POWERS:- This is the --
21 MR. MEYER:
Well, we have several of them.
We 22
'have RELAP and PARCS and we have TRAC and PARCS.
Both of 23;
.these couplings should be completed by fall and we should be 24
'doing.the. calculations later this year or early next year,
'25; so analytically we.are.trying to understand the plant r-P i
l' Lbl
.}
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transient and the cladding response better..
V)
(
2 At the same time, we are talking.with test reactor 3
people in Halden and a couple of other places to see if it-4 is feasible-to do any testing under these oscillating 5
conditions.
6 We are not very far along in resolving this issue, 7
and I would say at this moment don't see the light at the 8
.end of the tunnel.
9 CHAIRMAN SEALE:
You say the RIA criteria are 10 conservative.
'11 MR. MEYER:
We think they are.
12 CHAIRMAN SEALE:
Well, that may or may not be a 13 problem.
It is a problem if they don't give you enough 14 ultimately to cover the consequences of the BWR power (j
15 oscillations.
If they are conservative and you still can 16 handle all of the BWR power oscillations, then it seems to 17 me you are okay.
18 MR. MEYER:
But we canit.
19 CHAIRMAN SEALE:
But you can't cover them so that 20 is the real problem.
~21 MR. MEYER:
That's right.
I can be specific.
The 22 criterion that was being used was the 280 calorie per gram 23 limit.
24 CHAIRMAN SEALE:
Sure.
25 MR. MEYER:
In fact, the analysis that was done to b
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show~ adequacy had fuel enthalpies as high as 250 calories
/~b)/
2 per gram.
Well, 250 was less than 280.but 250 isn't less 3'
than 230 or 100.
We are not quite sure where this limit 4
should be brought down to for the high burnup fuel, but it 5
doesn't look good.
6 CHAIRMAN SEALE:
Fine.
7 So then the fourth area where we are putting our 8
resources and emphasis is on the codes.
I think you are 9-pretty much up to date on these codes.
We have a web site.
10 Just go ahead and show the web site address.
All of the-11 codes will be found here.
The FRAPCON-3 code is there right 12 now with all its documentation, the full nine yards is 13 online, and the FRAPCON-3 code is our single rod, steady 14 state fuel behavior code, which, as you know, has been (3
15 updated for high burnup app 3 ications, has been peer reviewed g,7 16 and' documented.
p 17 There are other codes on there right now, but the 18 coupled PARCS TRAC and PARCS RELAP are not on this side yet, 19 nor is our fuel rod transient code, FRAPTRAN, it is also 20 under development.
21 Let.me move on now to commenting on the licensing 22 strategy and then summarize.
23 DR. POWERS:
Before you leave the issue of codes, 24 we have indications from the industry that they would like
- 25.
to beyond the 62 megawatt -- gigawatt-day per ton.
.(\\
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MR. MEYER:
Yes.
2 DR. POWERS:
They would like to go as far they can v
3 but, presumably, even up to something like 75 gigawatt days.
4 Is the FRAPCON in the FRAP-T code predictive?
That is, you 5
are going to have a database for it.
Can you predict i
6 whatever the industry comes in and offer to you as to where l
7 they would like to go?
8 MR. MEYER:
What is the current range?
9' MR. SCOTT:
You go to 75, so we could go up, we 10 can calculate up to 75.
11 MR. MEYER:
Harold Scott has just reminded me that 12 the current code has a database that supports it up to 75 13 gigawatt days per ton, that's for FRAPCON-3.
14 I think the big issue for the higher burnups with 15 the codes is not going to be so much with the fuel rod codes 16 as it is with the neutron kinetics codes.
In order to 17 demonstrate that the plants are operating below the limits 18 that are emerging for high burnup fuel, you need to do a 19 better plant analysis, and, for that, you need the 20 three-dimensional capability, because both the rod ejection 21 accident in the PWR and the power oscillations in the BWR 22 are dimensional events.
You need a multi-dimensional code 23 in order to really calculate them precisely, J
'24 And we have seen from the early three-dimensional 25 calculations that'are being done for the reactivity h[
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accidents, for example, when you'do that, you get lower
~
- /~'Y
.2 Lenergy. depositions than you got with the more conservative V.
3 treatment of using a point kinetics model.
So I think -- I 4
think that's the direction, and that's going to be the 5
time-consuming activity for the NRC, because we will have to 6
review and approve industry codes, the three-dimensional 7
kinetics codes that we haven't reviewed before and that 8-always takes time.
9 DR. POWERS:
In the course of the subcommittee 10 meeting, I think Mr. Diamond presented quite an interesting 11 set'of viewgraphs on some of these neutronic codes.
And one 12' of the things that he pointed out was the width of the pulse 13 imparted to the fuel as calculated by the code depended, 14 apparently very significantly, on the delayed neutron
()
15 fraction.
Is that -- which then allowed as that delayed 16
' neutron fraction because it was averaged over some part of 17 the core, was relatively uncertain, and he didn't have a 18 feel for the magnitude of the uncertainties there.
Is that 19 being chase down in the --
20 MR. MEYER:
Yes.
Yes, it is.
Absolutely.
In 21 fact, we already see significant differences between the P's (22 and the B's.
And I don't think you have time to talk about 23 that.
David Ebert is here with us this morning, and he 24 could update you on what is going on.
But David Diamond at 25 Brookhaven is actively working on that.
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DR. POWERS:
I'think it is more important that'we 2
-understand:it is being worked on at this planning stage than 3-it is to understand what the results are.
4 MR. MEYER:
Okay.
The licensing and research 5
strategy involves some new and unique aspects.
And I can 6
say in a nutshell that the industry is just going to have to 7
shoulder most of this work for going beyond the current 8
limit of 62 gigawatt days per ton.
9 DR. POWERS:
Let me ask you a question about that.
10 Suppose I am sitting here with a reactor and then I have a 11 core-where I am approved to go to 52 right now.
12 MR. MEYER:
Say again.
13 DR. POWERS:
I am approved to go to 52 right now.
14 MR. MEYER:
Okay.
()
15 DR.-POWERS:
And so I am ready to reload my core.
16 Can I send a proposal in and get to 62?
17 MR. MEYER:
Yes.
18 DR. POWERS:
Okay.
I 19 MR. MEYER:
Is that the right answer, Tim?
i 20 MR. COLLINS:
That's correct.
21 MR. MEYER:
Yes.
Yes.
22 DR. POWERS:
I can go, regardless of where I am 23 right.now, I go clear up to 62?
24 MR. COLLINS:
Well, different vendors have 25 different approved limits.
Okay.
The highest approved 7 Y ANN RILEY & ASSOCIATES, LTD.
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limit for any vendor right now is 62, and we are willing to
[~}
2 entertain other vendors going up to 62 as well right now.
L 3
MR.'MEYER:
Beyond 62, we are going to shift 4
gears.
And we are going to literally shift the burden that 5
traditionally the NRC carried to the industry.
In the past 6
the NRC has always done its own research and developed its 7
own criteria.
l 8
In the subcommittee meeting we talked about the 1
9 criteria as being the speed limits and then about the 10 demonstration of compliance with the criteria as sort of 11 being the speedometer.
And the NRC had always established 12 the speed limits and put up the speed limit signs, and the 13
' industry had always had a speedometer in its car so that it 14 could tell that it was going below the speed limit.
What we O(,)
15 are saying here is the industry is going to.have to generate 16 a database and come in and tell us what they think the speed L
17 limit should be.
And if we agree with them, then we will l
l endorse those proposals with whatever modifications will be 19 made and adopt those as some sort of regulatory guidance, 20 probably in the form of regulatory guides.
21 So you see both a shift in the research area and 22 in the licensing area in this strategy.
The industry will 23 have to do the research and the industry will also have to 24
. develop the proposed guidance for going beyond.
25 DR. POWERS:
If I come_in with a proposal, take my 1.
l
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1
-fuel to 75 gigawatt days per ton, and I say I have done an
)
2 RIA test in the CABRI reactor and I got clad rupture and
]
.3 fuel dispersal.at 121 calories per gram, do you say very 4-good, or do you say, tell me how repeatable that was and
[
5 what your statistical confidence is in that number?
l l
6 MR. COLLINS:
Send us your application and we'll 7-give you the answer.
8-
[ Laughter.]
9 DR. POWERS:
What's good for the goose is good for 110 the gander here.
11 MR. MEYER:
What we are really looking for is that 12 the industry will make a concerted effort to come in with a 13 revision of Reg. Guide 1.77 and with a basis for it, so that 14 we have criteria that are applicable out to say 75.
That
()
i 15 they come in with -- and they have a database to support
.16 that, and they come in with a database and models and 17 criteria, or confirmation of criteria for loss of coolant 18 accident.
19 DR. POWERS:
What I am asking about is how good 20 does the database have to be that they come in with?
21~
MR. MEYER:
Well, I don't know how to answer the
~
22 question this far in advance.
23 DR. POWERS:
Don't we eventually have to be in a l
24-position-to answer that question?
25 MR.'MEYER:
Okay.
I think the best answer we I
'l T
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could give right now is that what we are doing to resolve r3 4
2 these issues in a confirmatory way for the current approved (w/
3 burnup limit of 62 gigawatt days per ton will provide an 4
example of how good a job they should do when they go beyond 5
it.
I would not expect anything less than we are doing.
6 DR. POWERS:
Would you expect anything greater?
7 Even more.
8 MR. MEYER:
I just don't know.
9 MR. COLLINS:
This is Tim Collins.
We are 10 starting to work with NEI to try to answer just these 11 questions.
What actually will have to be done to support 12 license extensions in the future.
We-just haven't worked it 13 out at this point.
But we recognize that that is a valid 14 question that we have got to answer, but we are going to rk,y
,/
15 have to work with NEI and see, you know, where it comes out.
16 We just don't know at this point.
17 DR. POWERS:
It might be useful to work with Ralph 18 to sort out how good the database has to be for 62 gigawatt 19 days per ton as well.
)
20 MR. MEYER:
I'm sorry?
21 DR. POWERS:
It might be good to work with you to 22 sort out how good the database has to be for 62 gigawatt.
23 MR. MEYER:
Well, they are working with us.
But I 24 think that by attempting -- by resolving these issues at the
)
25 current limit, that we will establish the model for how to l
l x
(
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()
~2.
DR. POWERS:
I.mean I agree'with that.
That it 3
was only your second statement, that you would expect 4
nothing less, that polluted that answer.
Quit while you are 5
ahead.
[6 CHAIRMAN SEALE:
And as you get closer to those
- 7 --
answers and so on, I am sure we would like to hear what you 8
are coming up with.
9 DR. POWERS:
I think you can count on an active 10.
ACRS interest in this program.
-11 CHAIRMAN SEALE:
Yeah.'
i 12 MR. MEYER:
Okay, then I can just summarize then 13.
by saying that the program plan addresses a range of issues 14 that were previously identified and discussed with the
(~
l I
15 Commission that for all of these issues we'were able to 16' provide a basis for concluding that there was no immediate 17
~ safety concern that would require some prompt plant action.
18 That confirmatory. work is under way for the issues 19 that are not fully resolved at the current burnup limit, 20 that the program plan provides a licensing and research L
21 strategy.for burnup extensions beyond.the current limit, and 22
.that this~ strategy involves a shift in responsibility to the 23' industry'for work that NRC traditionally has done to
-. establish regulatory criteria and guidelines, l
l
-25 DR.~ POWERS:.Let me summarize also to say that my ANN:RILEY & ASSOCIATES, LTD.
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313 1:
7 personal opinion-is that you have done an outstanding job in
(
.2
' organizing this research, and you have a very. fine.research
\\J
~
3 program that-you've outlined.
4-I. admire what ycu have done here for the limited
~
5
. resources that have been made available for this work.
I 6-worry that maybe it's too limited and that this anticipation 7
of what the industry is going to do is something we may not 8
_be prepared to handle right now.
It may be premature to tzar 9
to handle that because you've got to get -- obviously you're 10 still wrestling with things.
But certainly you've l
11'-
established,to my mind a very good foundation for handling
.12 ~
what we know is going to happen in the future.
l 13 Any of the other Members have questions they'd 14 like to pose on this particular topic?
q(,j 15 Thank you very much.
Appreciate you --
16 MR. COLLINS:
This is Tim Collins.
Could I just 17 make one additional comment?
/18 DR. POWERS:
You certainly can.
'19 MR. COLLINS:
On Ralph's slides there he talked 20
'about'a' couple issues being resolved, those being cladding 21 limits during normal' operation and control rod insertion.
22 Well, fully resolved I think is a little strong 23 terminology.
I mean, we're satisfied at this point with l'
12 4 -
what the industry is doing to address these issues at the 25
- current burnup levels.
These issues will need to be
plans for these programs, we did L
3 make a' recommendation that they be combined into a single 4
technical training program.
Then the strategic plan was l
5 rewritten, and as a result of that most recent rewrite of 6
the strategic plan, it just made more sense overall to 7
maintain the budget-oriented classifications of reactor 8
_ technical training and materials technical training. -So 9'
that's really why two different operating plans survive 10 today.
.11 Even'though there are two separate but very 12 related operating plans, they are maneged as a single 13 division program within the Technical Training Division.
So 1 44
' basically I plan to talk about both of the operating plans
()
15 at the same time, pointing out differences along the way.
16 I'd also like to provide you with some information 17 on a training review team that has been designated by the 18 NRC's Executive Council to perform a review and assessment 19 of the agency training processes and resources.
20 I am the program manager for the reactor and for 21 the materials technical training programs.
In case you're 22 not aware, the NRC is trying to move to a more 23
. program-oriented planning framework.
We've started in that 24 direction.
We haven't really gotten there, because if you-25 look in detail at the budget process that's going on right
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now, certainly these are still office-based budgets, which
[
2 means that for any given office, the resources for one
(
~
'3 program may be in competition with the resources for a 4
different unrelated program within that office.
5 And that's certainly true for technical training 6
within AEOD.
But the agency is still striving to reach a 7
program-oriented planning framework which would generally 8
cause the lines that separate the divisions and the offices 9
of the agency to become much more blurred and to put more of
-10 a focus on the program rather than the specific 11 organizational locations of the comments -- of the contents.
12-As the program manager I'm responsible for 13 formulation and execution of both of these opereting plans.
14 As noted earlier, there are a lot of similarities.
So for 15 efficiency we'll be discussing them at the same time.
16 These bullets show the outline of the major 17 headings contained within the operating plan, and I'll be 18 providing you with an overview of each of these as they 19 apply to the technical training operating plans.
20 The first section is the description section, 21 which contains a few paragraphs that describe the program 22 and what the program entails.
23 In a nutshell, the reactor technical training 24 program supports the formal trairiing and qualification 25:
~ programs that are associated with the reactor program.
The
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-1 reactor program includes the staff within NRR and the
(
)
2 regions, and the reactor technical training program 3
primarily exists to support the technical training for 4
reactor program inspectors such'as resident inspectors, 5
operator licensing examiners, headquarters operations L
6-officers, and a few other selected technical groups.
7 The program itself consists of classroom and 8-simulator training, reactor technology training, which 9-covers the four U.S. vendor designs, as well as training in
'10 PRA, radiation protection, engineering support, and 11 regulatory skills.
12-The materials technical training program likewise 13
. supports the formal training and qualification programs for 14 the materials program staff within NMSS and the regions, as
/(f 15 well as for agreement State personnel.
16 Materials program staff and agreement State' 17 personnel attend courses that are covered by this materials 18 technical training program.
Generally the courses are still 19 classified in terms of PRA, radiation protection, 20 engineering support, and regulatory skills, which are all 21 part of the reactor technical training program, but in 22 addition to that there are material, medical, and fuel-cycle 23 courses that are covered specifically in the materials-24 technical training program and are not associated with the 25 reactor technical training program, b
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The Technical Training Division resources which
/~'
2 are budgeted to support these two programs have been b) 3 relatively stable.
They're both'shown for fiscal year '98 4
and '99 on this slide.
I would point out that the FTE 5
numbers that are shown on the slide reflect only direct FTE 6
and do not include overhead FTE, which includes whatever the 7
management structure is and whatever other nonsupervisory 8
overhead as might exist.
9 DR. MILLER:
Ken, do they include contractors, 10 also?
'll MR. RAGLIN:
No.
The contractors would be 12 included in this program support money up here, but it's 13 measured in what we pay as opposed to how many equivalent i
14 FTE we're buying for that money.
(~\\
l
(
)
15 DR. MILLER:
But the 20.4 includes contractor --
16 MR. RAGLIN:
No, that's just -- that's our staff.
17 DR. MILLER:
That's your staff.
18 MR. RAGLIN:
Direct staff.
So that's reactor 19 technology instructors, simulator engineers, senior health 20 physicists, technical training support assistance, technical 21 program managers.
22 DR. MILLER:
How many instructors?
23 MR. RAGLIN:
By position title there are ten.
By 24 current functional usage there are 12 reactor technology 25 instructors.
()
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There are'some differences depending on which part j
2 of the program'we're looking at.
For example, we have 3
reactor technology instructors who primarily instruct but 4
sometimes do project management activities.
We have other 5
people who primarily do project-management activities for l
6 contracted courses but occasionally instruct.
So there's no 7
crisp ~way to --
8 DR. MILLER:
And I'm certain some of your support 9
staff, engineers and so forth, do some instruction.
I 10 MR. RAGLIN:
Yes.
l 11 DR. MILLER:
Okay.
12 MR. RAGLIN:
So it's a combination of all of 13 those.
But it's 20.4 FTE.
Our total FTE budget for the' 14 Technical Training Division right now is 29 FTE, including "O)
(,
15 Steve and myself.
Of that.there are 22.4, 20.4 associated 16 with the reactor technical training program, and 2 17 associated with the materials training program.
We also 18 have another
.6 of an FTE in support of international 19 programs, primarily Lisbon Initiative technical assistance 20 to Russia and Ukraine.
That program is winding down.
21 So these resources that we're showing up here are 22 only those resources that are expended to conduct technical 23 training.
12 4 I mentioned that training review team earlier, and 25 I'll mention it again later, but the effort associated with p
1' Il
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1 that team will include quantifying the agency resources that
/~'i 2
are expended to provide and to attend training, not just V
3 technical training.
So I don't want to leave anybody with 4
the mistaken impression that these are the only resources l
5 that are applied to providing the agency training or even l
l 6
the agency technical training.
These are just simply the 7
resources within our division that are applied to that.
8 There are some other resources.
9 DR. MILLER:
And that's resources without 10 overhead; right?
These are.
11 MR. RAGLIN:
There are some other resources in 12 that from time to time we get support from program offices 13 in development, and in fact in presentation of certain 14 courses we get support from program offices and regions for (o) 15 source evaluation panel membership when we're putting in 16 place contracts for specialized courses.
There are other 17 technical training activities that are done independent of 18 us, and there are other nontechnical training activities 19 that are done independent of us.
20 Additionally the cost in -- the cost to the agency 21 to attend technical training is very considerable.
Based on 22 I think the '96 annual report that we did, the agency 23 expended something like 50 FTE worth of time attending the 24 formal training associated with these two programs.
25 So I'm just trying to keep it in perspective.
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1 Did you have a comment, Steve?
(')
2 MR. ARNDT:
Yes.
This is Steve Arndt.
s l
3 In reference to overhead, the FTE count does not 4
include overhead FTE, management and support.
The money, 5
however, does include overhead fees like rent, cost of 6
maintaining the simulators, and things like that.
All the 7
money-type overhead is included in the dollars figure that 8
you see.
I 9
DR. UHRIG:
So that's your total budget there.
10 MR. RAGLIN:
Yes.
That's the total budget that we 11 requested.
That may in fact not be the total budget that we 12 received.
13 DR. UHRIG:
But the '98 is the actual.
14 MR. RAGLIN:
Yes, that's what we actually have and r~g (j
15 are working with.
16 DR. MILLER:
Ken, you raised the issue of how much 17 the agency devoted to training.
Any idea of the total 18 dollar amount that would translate into?
19 MR. RAGLIN:
We don't really know the answer to j
20 that, and that's one of the reasons that this training
)
21 review team has been established.
We know very well what we 22 spent, and we can estimate very well what it takes to attend l
23 the training that we provide.
We know generally how much 24 money the Office of Human Resources has spent in developing 25 and providing the training that they provide.
We know less
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about how much effort actually goes into the training that's
(}
2 provided by the Incident Response Division of AEOD, for 3
example, for event responders.
We know a lot less about the 4
level of effort required by the regions, for example, to 5
actually qualify people.
l 6
We know in general that to qualify a resident 1
7 inspector the formal training that we provide represents 8
about 25 percent of the total effort that's required to 9
quality that inspector.
So from that we can infer that l
10
.there's a significant amount of effort that has to go on by-l 11 somebody in order to get that person qualified.
But trying 12 to wrap up the agency overall effort, we don't have a good 13 number, and that's one of the reasons the team --
14 DR. MILLER:
Yes.
s
(
15 MR. RAGLIN:
Has been formed.
16 DR. MILLER:
But it would be interesting when that 17 number comes out to compare it to what the agency spends on 18 training versus what the industry spends on training as far 19 as a fraction of.the total personnel budget.
20 MR. RAGLIN:
Yes, it would be.
l 21 DR. MILLER:
See if we're in a reasonable 22 ballpark.
23 MR. RAGLIN:
It would be.
24 DR. MILLER:
The nuclear industry as a whole, 25 including the agency, spends a lot of money on training.
l l-9(3 7
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CHAIRMAN SEALE:
Less now than they used to,
~ 2.
though.
4 3
I'm intrigued.
You say that the number for -- the 4!
number of FTEs involved in. supporting the recipients of the 5-training.is'around 50?
6 MR. RAGLIN:
Well, let me answer it this way.
For 7
each of the courses'that we provide -- they are formal 8-courses, first of all, and they have a fixed course length, 9
so it might be 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br /> for a given course -- we track the 10:
number of. students and we know the number'of hours, so we
-11 compute the number of instructional hours that were spent in 12 the classroom or simulator or whatever it is.
We sum all of 13 these things :up, and we get some number --
14 CHAIRMAN SEALE:
Which you divide by 2,000.
)
15 MR. RAGLIN:
Well, the number that you divide by 16 is arguable.
You divide the number of instructional hours 17 by something to convert it to FTE.
That something could 18 either be 2,080, 2,087, or maybe 1,800 if you back out the 19 time that's associated with leave --
20 CHAIRMAN SEALE:
Vacation.
i l
21 MR. RAGLIN:
And holidays and so forth.
22 CHAIRMAN SEALE:
Even so, a student-to-faculty 23-
' ratio of-2-1/2 is pretty rich on the faculty side.
'24 MR. RAGLIN:
That could be.
I don't think we 25
.have --
l
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CHAIRMAN SEALE:
I'm just telling you that, you
)
2 know, generally 20.to 1 is what most institutions talk 3
about.
So for those Commissioners who have academic 4
backgrounds, you might get yourself into some interesting 5
problems here, and I would only say yes, your courses are 6
much more technical in content, the amount of individual 7.
preparation in terms of' simulator exercises and so forth 8
that you have to prepare puts you much more often in a 9
one-on-one situation or a one-on-crew situation --
10 MR. RAGLIN:
Um-hum.
11 CHAIRMAN SEALE:
Rather than a one on a full 12 classroom situation.
And so you have a very different 13 profile of activities to defend yourself in that regard.
14 MR. RAGLIN:.Well, that's an excellent point, and
~(
15 it's particularly true for any simulator exercise.
We've 16 found empirically that if we get more than about six people 17 in a simulator course, many of the people don't get anything 18 out of it.
19 DR. MILLER:
Like a simulator is the same as 20 teaching laboratories in the engineering.
21~
CHAIRMAN SEALE:
Well, even --
22 DR. MILLER:
But of course you have a lot more 23 equipment.
24 CHAIRMAN SEALE:. Well, yes, but it's even more 25
. intense theris.
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'l MR. RAGLIN:
I would just make the point that as
~[d
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2.
we're all probably aware, there are many different budget 3
scenarios that are being discussed right now, and some of 4
the items that I will be covering as part of this 5
presentation which are items in our operating plan would 6
certainly be subject to change based on some of these 7
scenarios.
8 The next section is the budget plan 9
accomplishments.
This includes the major accomplishments 10 that are planned for the program, including a description of 11 the activity, the resources budgeted for the particular 12-activity, the milestones and the target goals for each of 13
.the milestones.
Both of the reactor and materials technical 14-training operating plans include needs analysis, design and 7s
(
)
15 developing, training program implementation and evaluation 16 of training.
17 One thing that we tried to do in this budget cycle 18 was to structure our budget along the lines of the classical 19 phases of the systems approach to training.
We ended up 20 combining two phases, design and development, into one 21 subcategory here.
Originally, we had these as separate
!22 phases and separate items within the budget structure but, 23 mechanically,.we were told that if we separate them out that 24 way, then we need to have the budget separated out that way 25 and it would be relatively difficult to move money from one ANN RILEY &-' ASSOCIATES, LTD.
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1 area to another.
So, for simplicity, we have dropped down l ()
2.
to a single line.. item-in the budget which has a bunch of 3~
subcategories-under it which cover this whole area.
4 The infrastructure, technical training center, 5
information technology infrastructure is included here.
6 That includes the simulators, the rental of space at the TTC 7
and the administrative support associated with operating a 8
remote facility.
Yes?
9 CHAIRMAN SEALE:
When you say the simulators, do 1-0 you mean -- does that include the technicians who are 11
. responsible for keeping the simulators in working order?
12 MR. RAGLIN:
Yes, it does.
Two ways.
Presently 13 we have five. simulators.
Presently we' have three simulator 14 engineers on staff.
Presently we have a hardware
)
15
. maintenance contract that provides four contracted 16 maintenance technicians -- hardware maintenance technicians 17 on-site all of the time.
So those are included within the 18 resources.
The FTE are counted in that 20.4 number and then 19 the money is in the other.
20-All of these costs in the budget are attributable 21
- to the reactor technical training program and it is just not 22 feasible to try to split out any fractional costs associated 23 with the materials technical training program.
- But,
.24-obviously,~all of the resources at the TTC support both the 25 reactor and the materials technical training program.
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CHAIRMAN SEALE:
Ken, before we get away from
)
2-that, can you crisply subdivide your FTEs into instructional p
3.
and support numbers?
I
'4 MR. RAGLIN:
Let me see.
I believe that we have 5
that.
I am not positive that I have it right here though.
l l
6 CHAIRMAN SEALE:
Well, I would urge you to have 7
that number handy so that when you get questioned on this, 8
if you will, student to faculty to ratio number, you are in 9
a position to make that distinction.
Because that would 110 ameliorate the -- or the high or the low number get, I guess
- 11 I should say, if you make that distinction.
i 12 MR. RAGLIN:
In the operating plan it addresses 13 the resources that are associated with each of these four 14 bullets.
Of course, the first one is where moat of the time
' (^)
g.
(
15 and money goes, that's where most of the FTE goes.
For 16 example, 17 FTE of the 20.4 are associated with that for --
17 CHAIRMAN SEALE:
But you just told me that you had 18 seven FTE involved in simulator engineers and simulator 19 people.
20 MR. RAGLIN:
Four of those are contracted.
21 CHAIRMAN SEALE:
Okay.
You said they were --
22 MR. RAGLIN:
Three are covered right here in this 23 information technology infrastructure.
24 CHAIRMAN SEALE:
Okay.
Okay.
25 MR. RAGLIN:
One thing that is misleading about
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331 1-all of this is that we are only allowed by the process to I'T 2
. include direct FTE, and'it almost presumes that some of the
, Q i
-3' things that we have to do are free.
Well, they are not.
4-free,' they are being done by non-direct FTE.
In'particular, 5
needs analysis and evaluation are principally things that l
l 6
are done by non-direct FTE.
7 I can also tell you that of the SAT phases up 8
here,' design and -- well, implementation is clearly where we 9
spend most of the staff resources.
The next largest is 10 development, and then there's really very little spent in 111 terms of needs analysis and really very little spent in 12 terms-of evaluation.
l 13.
DR. MILLER:
What is your ratio on implementation, 14 which I assume really is instructional time, and DQ 15 development?
16 MR. RAGLIN:
I am not sure whether we have the 17 number exactly, but it's about 3 or 4 to 1.
18 DR. MILLER:
Development?
19 MR.'RAGLIN:
Development.
That's an interesting 20 point because the budget process seeks for everybody to very 21 precise about how many FTE, how many dollars they use, and 22.
then we are all faced with making choices and we are all 23 faced at looking at what discretion we have within our 24 program when something changes.
'25 Typically, :the discretional that I have comes both L/
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.1 '
from. implementation and from development.
Implementation, I YY
.2 can extend somewhat the interval between certain courses b
l-
-3
-that are required for qualification programs.
In terms of 4
development, I can extend the time, I can defer some l
5 development that we plan to do in order to do some other 6
things.
But that's really about all of the discretion we 7
have since we are essentially baseloaded right now to cover 8
the qualification and training programs for the agency, the 9
ones that have been identified in a formal way.
10 DR. MILLER:
A question on development.
I would
- 11-assume a number of the courses you offer are repetitive, you 12 offer the same thing over and over and over.
Is that true?
13 MR. RAGLIN:
That is true.
14 DR. MILLER:
I guess I am now questioning how are
()
15 the high development ratio versus instructional ratio?
16 MR. RAGLIN:
The courses have to be kept current.
17 At one time I used to believe that we could have reactor l
l 18 technology courses that would remain stable and would not 19 require a significant amount of development.
I have since 20 changed my mind because things keep changing.
L 21 For example, the development that we are trying to I
22 accomplish right now within the reactor technical training 23-program is to incorporate the new standard technical 24 specifications and the latest Owner's Group emergency 25 operating procedures, EOPs, into our program.
That is time
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2
'otherwise be teaching, that is necessary in order to keep 3
the program up to date.
4 The only discretion we have -- well, I guess we 5
could not do it, but we don't think that's a very good idea.
6 So if we can't do it now, we will try to do it later.
But 7
there is a constant amount of effort that is required in 8
terms of-life cycle maintenance for the courses that exist, 9
and that is necessary in order to continue to give courses 10 with predictable results, predictable consistency and so 11 forth.
That's kind of in the baseload as I see it.
=12 Then we have to try to carve out time for the 1
i 13 staff to do new things that are required for development.
I 14 might also mention that development is particularly heavy
()
15 when we are asked to bring online a course that does not 16 exist.
Then you have a huge up-front.
17 DR. MILLER:
I understand you have three different 18 categories.
You have categories where you are offering the 19-same course with very little maintenance.
You have 20 categories where you are upgrading a course on an annual 21 basis to keep up, and then the brand new course, that 22 development has to be far more than 3 to 1.
23 MR. RAGLIN:
I might also mention that included in 24 development, for example, is project management.
There are 25
.many courses where we have contracts for outside companies
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to provide technical training.
These contracts are of fixed j )
2 duration, sometimes they are three years, four, up to five.
3 Usually, it is whatever the' maximum our Division of 4
LContracts will let us get away with.
But, in any event, 5
when the contract runs out, we have to go through another 6
competitive procurement cycle which requires work which we 7
classify as development because it is not implementation.
8 So there's --
9 DR. MILLER:
Everything -- basically, you are 10 saying everything that is not classroom instruction is in 11 the development pot, so to speak.
12 MR. RAGLIN:
Yeah.
Unless it happens to.be needs 13 analysis or evaluation.
14 As I noted, these are some things that we would
~%
15 like to do within the reactor technical training program.
16 Another one on the list there is conversion of courses 17 within the fuel cycle curriculum to a directef self-study 18 format.
19 We think that is particularly important right now.
20 We have spent relatively quite a bit of money over the last 21 few years developing some courses for fuel cycle curriculum 22 and getting the target audience through those courses.
Now 23 we are faced with a target audience that is very small --
24 three or four people may need this, that or the other and so 25-we are having these' courses directed to a' directed tb ANN RILEY & ASSOCIATES, LTD.
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335 1-self-study. format which involves the use of an administrator
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2.
or subject' matter expert in addition to the person who is b}
3 proceeding through the program.
4 DR. MILLER:
What method are you going to use for 5
the self-study, computer-based or something?
6 MR. RAGLIN:
No, it's paper-based.
We.really 7
don't have the resources to develop computer-based for many 8
things.
We only have a couple of pilot applications.
9 We have paid money and had a contractor develop 1
'10 certain parts of the fuel cycle self-study program and we 11 are just kicking this off, but we are very high on it in 12 terms of cost effectiveness, and we consider it remarkably 13 different from some of the other self-study activities that 14 are indigenous to the qualification program for inspectors,
/G
( /
15 who are basically "here it is, read it, sign it off when you 16 are done" or something.like that.
17 This is much more structured than that.
18 CHAIRMAN SEALE:
Ken, I am going throw you a curve 19_
ball.
I am going to ask you a question and then I am going 20 to remind you that we have a tough schedule today, but my 21 curve ball is this.
22' In some of the things that we have been hearing 23
.from utilities lately, there has been a large number of 24 applications for changes that have come in that employ
.25:
something called an-expert panel.
Now this is a utility-I ANN RILEY & ASSOCIATES, LTD.
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1 creature, not a Commission creature, and I am sure the l ()
2 utilities are going to have to worry about training
\\_/
3
. people -- well, deciding what the elements are of an expert 4
panel and getting people to understand what their I
5 responsibilities, how they preserve their independence and 6
that kind of thing.
7 It would seem to me that it would be helpful for 8
you as training professionals to be -- let's say to look l
9 into that process to the extent that you could determine (a) 10 whether or not there is a need for the Commission to be 11 concerned with the inspection people knowing something about 12 what expert panels ought to be; and (b) be aware of what one 13 would expect from an expert panel so that you could, your 14 people could independently assess whether or not those
()
15 panels are acting in a way that fulfills the requirements 16 for those expert panels, so it's kind of a new one that is 17 coming up over the horizon here and it is something you l
l 18 mig.it want to think about.
19 DR. BARTON:
That was more of a knuckle ball than 20 a cureed one.
21 (Laughter.]
22 MR. RAGLIN:
That sounds like a good suggestion.
23 I am afraid I know nothing about it.
24 DR. BARTON:
That's why I called it a knuckle 25 ball.
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CHAIRMAN SEALE:
You can get c:ught cold, and I 2-don't think you want to be, so you might want to --
3 DR. MILLER:
We can talk to the Human Factors 4
' people and people in Research, of which I know a few.
5 MR. RAGLIN:
Well, let me move on then, in the 6
interests of time.
.7 The operating plan includes a section on support l
8 office activities.
Over the years,-we have had some l
9 difficulty in receiving direct feedback from the line 10 organization regarding accurate needs, regarding desired 11 input for course' content, and regarding accurate projections 12 of the number of people that would attend certain courses.
13 All of these things become more important as the 14 budget _ shrinks.
Support offices for the technical training f~)
(j 15 operating plans include NRR, the regions, Research, AEOD and 16 HR for the reactor one, and NMSS, the regions, Research, 17 AEOD, state programs, and HR for the materials program.
18 Now it may seem like a strange concept, support 19 offices for training, which is pretty much a support 20 function, the concept being that in order to have a 21-competent program input from the line organization must take 22
' place -- must take place on the front end.
We need to know 23 if we are doing the right thing.
We need to know if we are 24 doing-the_right thing well.enough that it is achieving some 25 objectives.-
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So we have listed a number of things in the
}
2 operating plan.
These are our expectations for these-3 support offices in support of the reactor and materials 4
technical training programs.
l 5
Human Resources is covered mainly because we have 6'
to use the classrooms that are up here for a. number of the 7_
courses, which requires coordination.
8 DR. MILLER:
What fraction of the courses are 9
offered at headquarters versus --
' 10 MR. RAGLIN:
For FY '97 43 percent of the courses 11 were provided'at the technical training center; 23 percent 12 were provided at contractor facilities where the equipment-13 was there; and what does that leave? -- 30-some percent were 14 provided up here.
L.()
15 CHAIRMAN SEALE:
You don't do training at the 16 regions?
17 MR. RAGLIN:
Yes.
I should qualify that -- up 18 here or in the regions.
19 CHAIRMAN SEALE:
Oh, okay.
20 MR. RAGLIN:
We do a significant portion of
- ;21 training wherever the students are and if there is no
- 22 compelling reason for it to be at the training center 23 because of specific equipment or at a contractor's facility
- 24 because of specific equipment, we try to give it wherever 25L
-the students are in order to minimize the overall costs.
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339 1-CHAIRMAN SEALE:
And that is another thing that
[~
2 makes your faculty-to-student ratio much higher, fewer
- L 3
students per faculty member.
4 MR. RACLIN:
Right.
5 CHAIRMAN SEALE:
So you want to keep that one in 6
mind too.
7 MR. RAGLIN:
Output measures are also a part of 8
it.
As you are probably all aware, we were. required to 9
develop some metrics for the operating plans and these are 10 the ones that have been selected so far -- quantity -- what 11 we are trying to do is provide the numbers and types of 12 courses that. meet 90 percent of the cumulative needs 13 identified by the offices in the regions.
14 We would like to meet 100 percent.
We would have 15
-to'have some number against which we can be measured.
16 In terms of timeliness, our metric is course 17 development and implementation milestones are met 80 percent 18 of the time.
19 In terms of efficiency, the average total r
)
20 enrollment for the courses is above 50 percent is the normal 21 maximum enrollment.
This one is a tough one.
It depends on 22 the overall needs of the agency and there are some 1
23
. categories of courses where the target audience is p
24 relatively small.- On the.other hand, the impact of the 25 training'isLrelativelyfhigh;and so in some cases it is worth
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i 340 i -
-1
'it to the agency'to inefficiently give the course for
[~'
2
'relatively.few people, because those relatively few people
\\
3 need it badly, 4
In terms of quality, we_are-measuring the student
'5.
' perspectives on the course at the time the course ends,'with' 6
- 90. percent of the evaluation ratings.as satisfactory or 7
.better and in terms of effectiveness,'we are evaluating 8
student knowledge of the subject matter at the end of the 9
_ course, as indicated by.the exam score.
l 10 This slide shows,the assumptions'that are made for 11-the reactor technical training program and one of our.
12 assumptions is that'for the planning period the current 13 qualification development and training programs will 14' continue at'at least their.present levels through FY 1999.
()
15 Of course, large budget swings could have a significant
' mpact on the validity of that assumption.
i 16 17 We have also taken into account plans that have 18 been announced or implemented within NRR regarding PRA 19 training for different categories of reactor' program 20 personnel and other courses that have been added as 21 qualification requirements.
22 There are no budgeted resources for anything that
-23 we might eventually have to do associated with DOE 24 regulation.
There is simply nothing in the budget and too 25-much is unknown.
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341 1.-
I guess that would cover this one right here.
I
.(
2
' don't think we need to say anything more, except on this one 3
we are still assuming that the current Commission policy 4
concerning training of agreement state personnel remains'the 5
same.
6
-DR. MILLER:
What is that policy and how many 7
participate amongst the agreement states?
8 MR. RAGLIN:
The number of agreement state 9
personnel versus NRC personnel for some of the materials courses 's very high, a.high ratio -- maybe four to one, i
10
- 11-agreement state.versus NRC~ Staff.
12' The policy that used to be in place was that we 1
13-provided'the training.
It was free to agreement states.
i 14 The Commission now wishes for agreement states to pay their
)
15 own way, to. factor it into their budget. cycles within the 16 states, and to reimburse NRC for training that they 17 provided.
18 What we are doing right now, based on Commission 19 guidance is scheduling courses that are necessary for qualification and training of NRC personnel.
Given that 21 there are certain courses that exist that have open slots, 22 we are allowing agreement state personnel to' attend those 23
- courses, g
l
-24 If the states can pay, then they are reimbursing 1
25 for. courses ~that have, contracted costs associated with them.
i :
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.For. states-that can't pay,.there are some exceptions.
(-)
L2 DR. MILLER:
Do you have any idea of the level of 3
. participation -- l'et's put it this way.
If you have so many 4
agreement states and you have so many Staff, what fraction 5-of that' Staff are participating in the training programs?
6 Any idea on.that?
7 MR. RAGLIN:
That is a difficult question.
8
-Agreement state training has been ongoing for many, many 9
. years and over the years the number of agreement state
- 10-personnel have gone to training that was sponsored by NRC.
11 If money were no object, we would be flooded with 12 agreement state personnel and attending these courses.
They 13 are metered in right now and the input to us is pretty well i
14 controlled by the Office of State Programs but we are
()
15 continually advised that there is a long waitino list to get 16 into these courses.
-17 I know that didn't exactly answer your question.
18 DR. MILLER:
No, I asked a question.
I knew you 19 didn't have the answer to it.
I just wanted to get a feel 20 for it.
21 MR. RAGLIN:
Okay.
Now I would like to just 22-mention this training review team effort again.
In March of l
23 1998 the Executive Council assigned Jack Roe, who is 24 presently.the Acting Director, Division of Reactor Program 25-Management, within NRR, and a team under his leadership the yy
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task of reviewing the agency's training activities.
2 Really what is driving this is the concept of the 3
cumulative effect of training.
There'is training that we 4
provide.
There is training that is separately provided by 5
the inservice response division within AEOD.
There'is 6
-training that is provided by the Office of Human Resources.
7 There is now training that is provided by the CIO, training 8
that is provided by the CFO, training that is provided by 9
the OGC, training that is provided by a number of others, 10 training that is provided by program offices, training that 11 is provided by the regions.
12 There is a lot of training and we really don't 13 know how much it costs to the agency to provide and attend 14 this training.
What we do know is that there is a fairly 15 large disconnect between the real number and many of the 16 training budget assumptions -- for example, five percent of 17 Staff time -- so there is a team that has membership that l
18 generally, specifically does not involve the technical 19 training division within AEOD and does not involve the 20 Office of Human Resources, and the team is doing a number of 21 things -- collecting data, trying to determine the costs 22 that are. associated with the training that is being given 23
.and.looking toward making some recommendations in terms of 24' overall effectiveness and efficiency from an agency 25-standpoint.
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1 344 1
They will be interviewing a number of agency I ' I')
2 managers and other staff over the next few months.
They' s
s_-
3 will-have a draft report of their findings to the Executive 4
Council in August, and they are expected to issue some sort.
5 of a final' report in October.
6 The reason I am mentioning this is that the 7
results of this study may very well have some impact on what 8
is done in terms of the reactor and materials technical i
9 training programs as well as all other training that is done 10 within the agency, so in summary, the two operating plans il document the activities, schedules, milestones and resources
-12 planned for the next two years based on certain planning 13 assumptions.
14 They include performance measures, generally to
( )
15 try to determine how well we met the agency's training 16 needs,'and we anticipate that there may very well be some 17 implications for us when this training review team has 18 completed its work, 19 DR. UHRIG:
Do you even have the remotest idea of 20-what that might be, what those implications might be?
21 MR. RAGLIN:
Well, some of them could be
'22 organizational.
23 DR. UHRIG:
Are you likely to have an additional 24
. load on you?
25 MR. RAGLIN:
I don't know how it is going to come f[ 7 ANN RILEY & ASSOCIATES, LTD.
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out.
I mean there might be many different ways to address
(
2
'what are determined to be the problems.
3
.An. organizational structure that is responsible 4
for all of training might be'one of the recommendations.
5 Whether that is adopted or not,. I don't know.
6 There-may be some other recommendations about 7
relative priorities that would cause some changes in the way 8.
things are being done.
l 9
Certainly right now the agency managers feel.that 10 everybody is just lobbing on the table new training 11 ~
. requirements without any regard for the overall impact on 12 Staff time and without any regard for what already exists.
13 There is a great frustration on the part of agency 14 managers and I share that frustration because I see the same (O
15 thing myself and there's many things that are in competition
,j 16
.for the same resources, and there's not enough time for the 17.
. people to attend all of this training, at least not in the 18 next two years.
19 DR. BARTON:
The industry I think faces the same 20 thing.
Any time you need to do something, well, obviously l
.21 it is a training -- lack of training.
We ought to do more 22
. training, more training -- so develop me a training 23-
. course -- so -- you hear this on both sides of the fence, I 24 think.
j 25 HMR. RAGLIN:
What the line management would like
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-to see is'if this goes in, what is coming out l
.2 CHAIRMAN SEALE:
Well, in that. regard, have you --
3-certainly one of the large and high profile efforts that you 4
have had in the last two to three years has been the PRA 5
training program that you have implemented.
Have you gotten 6
any feedback from the people in, well, let's say what use --
7 well, the appropriate people who are in fact working PRA in 8
the agency on the value of that training in bringing Staff 9
up to speed to meet their needs?
10 MR. ARNDT:
In particular areas we have gotten 11 very specific feedback.
In terms of the tech managers' 12 course for managers, we have gotten very positive feedback, i
13 In areas -- some of.our more specialized courses on how to 14
.use the tools and things like that, we have generally gotten
()
15
'very good feedback.
On some of the other courses, we have 16 gotten -- in most cases.no feedback as opposed to negative 17 feedback.
18 CHAIRMAN SEALE:
The reason I asked the question 19 is that we have had some recent conversations with the 20_
people who are trying to process risk-informed applications 21 of one sort and another, and quite frankly they-are what.I 22
'will characterize as brains versus bodies limited.
The 23;
. people they need need certain specialized talents.
24 Now clearly a person can't go through that course 25 and immediately be prepared to be a senior manager to make l
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highly informed, senior manager level type decisions of
(\\
2 overall approval, but on the other hand, the input that they j
3 get from other people in the agency can be a much better l
4 quality and much more directed to PRA-type concerns and l
5 issues if that course has been successful.
l 6
So it would seem to me that it would be very 7
worthwhile for you to try to gain that kind of feedbeck and 8
to structure it in such a way that you can answer these 9
kinds of questions because you don't have to be too smart to 10 recognize that this could turn into a hunting license where 11 you would wind up being the deer, and you don't want that to 12 happen, you know?
13 DR. BARTON:
A turkey shoot.
14 CHAIRMAN SEALE:
Guest of honor at a turkey shoot.
A()
15 DR. MILLER:
Can I follow up?
Bob has asked the 16 first important question.
That is, what has the feedback 17 been?
The second important one, have we made a major impact 18 as far as numbers of Staff who have been through the 19 program, do they have good feedback and also able to 20 implement this fairly dramatic change in agency direction?
21 MR. RAGLIN:
We are making progress.
There's been 22 a great deal of program office support in terms of 23 identifying, making it very clear that certain categories of 24 personnel are required to do certain things.
25 Many of the offices have mandated the technical
[
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1 managers' course for~PRA as' required training for managers
(/I 2.
despite all'of this.other stuff that is also required'for s_
3 the managers.
4 I am quite sure that NRR would like.to have sent L
5 its staff to'a number of the PRA courses, but'there'is a 6
trade-off in terms of-training and getting other work down 7
and so they have limited it to what they feel that they can 8
swallow right now, but they have mandated training for 9
Headquarters personnel in PRA.
They have mandated training 10 for resident inspectors in a new PRA course that we have.
11
.These are all well on-track now.
We will have 12 trained over two-thirds of the' agency's technical managers-13 in that technical managers' course by the end of this fiscal 14 year and we will_ pick up the remainder next fiscal year.
()
15 By the end of FY '99 all of the resident 16 inspectors will have been through the PRA training for them 17 and the goal is to have one resident from each site through 18 that training by the end of this fiscal year.
Those all 19 have very'significant resource implications for the reactor 20 program.
21 Despite that, there is a commitment on the part of-22-the program office to make it happen and it is in progress 23 and it is tracking toward completion.
24 Steve?
i 25 MR. ARNDT:
Let'me say one more thing, as an
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anecdotal-answer to both Bob'and Don's issue.
v};
2 As some of you will know, at the regulatory 3
information conference one of our resident inspectors. spent 4
his entire time saying how effective from a regulatory point 5
of. view the senior reactor analyst program had been in his 6
region and that is, as you know, a combined effort to' bring 7
people with inspection experience up to speed, to provide 8
PRA risk-informed perspectives, and it is based on our 9
training experience by rotational assignments into Research 10 and NRR's PSA branches and work in the field, so for at 11 least that specific example, we are getting very positive 12 feedback.
13 DR. MILLER:
Do all of the regions now have a 14
. senior reactor analyst of really high quality as far as PRA A-q) 15 expertise or are some still in progress?
+
16 MR. RAGLIN:
Region III's are still in progress in 17 terms of the rotational assignments.
18 DR. MILLER:
I was really impressed with what I 19 have heard -- I think it was Region II 20 DR. BARTON:
IV was one --
21 DR. MILLER:
IV was one that really seemed to 22' be --
23 DR. BARTON:
Yes.
They had their stuff together 24 last year.
25 DR.-MILLER:
We are going to visit Region II in
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2 DR. BARTON:
III doesn't have any.--
.3 MR. RAGLIN:
Th'ey don't'have any that are in place because the program includes the rotational assignments.
.T 4
5 he two that are in the pipeline have completed the formal 6
training portion.of the overall program.
7 MR. ARNDT:
The reason that they are not in place 8
a significant time after the program started was that the
(
9 two that were originally selected for that program in Region
'10 III, while they were qualifying, were such good candidates 11 they got promoted -- out of the program.
12 DR MILLER:
I think it's important that 13 two-thirds of the managers.or more have been through -- of 14 equal or more importance is you have at least a cadre at OQ 15 each location of very high quality people who are very good 16 at it.
That is probably equally important and two-thirds is 17 a good number and that is a very good program, by the way.
18 That three-day course is a good course.
That gets a lot of 19_
people up to speed.
20 DR..BARTON:
Are the training simulators to Year 21-2000 compliant?
l 22 MR. RAGLIN:
Yes, with a little caveat.
L 23 DR. BARTON:
Okay.
1
~ 24:
MR. RAGLIN:
Time for simulation, the only thing 25 that matters is relative time, so there are some pretty l
((^')
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1 strict definitions of Year 2000 compliant that our CIO has
[/)
2 put out and some of those things just don't apply to the w
l 3
simulation.
1 I
4 For a couple of them, we will be setting the boot 5
time back to 1990 rather than spending millions of dollars 6
to fix something that may not work when we are done, but we 7
are Y2K compliant right now with respect to the CFO 8
guidelines given the waiver for the simulators based on l
9 unique circumstances.
10 DR. BARTON:
Thank you.
11 DR. MILLER:
Just one more comment.
You may or 12 may not note that this committee has reorganized our 13 subcommittees.
In doing that, we will not have a training 14 subcommittee next year.
r
(
15 Is that true, Bob?
16 CHAIRMAN SEALE:
I believe that is the case.
17 DR. MILLER:
But that does not in any way reflect 18 our interest in and our commitment to high training.
The 19 concept is to have each subcommittee take training on as 20 their issue, rather than having a separate committee.
It's 21 a one-year trial basis, so I didn't want you to -- we didn't 22 want you to get the idea that we don't think training is 23 important because we really do.
24 MR. RAGLIN:
Okay.
25 CHAIRMAN SEALE:
And furthermore, any time you n
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have any input that you feel that's important for the ACRS
'N (b
2 to hear about and you don't know which subcommittee it might l
3 be involved with, don't let that slow you down.
Come see 4
the Staff and we will figure out where it goes, and we 5
certainly want to hear frcm you.
6 MR. RAGLIN:
Okay.
We appreciate the effort.
7 DR. MILLER:
Well, with that, I am three minutes 8
late, Mr. Chairman, but I will turn it back --
9 CHAIRMAN SEALE:
Three?
What clock are you 10 looking at?
11
[ Laughter.]
12 Okay.
Our next topic is proposed modification to 13 10 CFR 50.59.
Before we get into that, I want to remind you 14 later this afternoon we're going to be reconciling comments m
.f' _,)
(
15 and that material has been passed out and I would ask the 16 cognizant committee members to be ready to respond to those 17 questions when we get to that.
18 John, you're the cognizant subcommittee chairman I
l 19 on the 50.59 issue.
Would you introduce our speakers?
20 MR. BARTON:
Yes, thank you, Bob.
21 The purpose of this session is to discuss the 22 status of staff activities associated with the proposed 23 modifications to 50.59, Changes, Tests, and Experiments.
24 Our last, I guess, correspondence or meetings with the staff 25 on this were late in
'97.
We did issue a report in December
(
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'97 with some recommendations regarding some directions for-2 50'59.
Subsequently the Commission issued an SRM to the 3
staff in March of '98 which, if you'll recall our letter,.
4
-the SRM basicallyLhad most of the points that were in our 5
letter except for the long-term, risk-informed approach to 6
50.59, the other items were addressed in the SRM.
And I do 7
.believe we do have a subcommittee meeting coming up June 8
19th to discuss with the staff the details of the 9
rulemaking, and I believe today we're going to hear from 10 Eileen McKenna on the status of where you are with respect
' 11 to'the SRM.
I 12 MS. McKENNA:
Thank you.
My name, as mentioned, 13 is Eileen McKenna in the Office of NRR.
Also with me at the j
14 table are Tom Essig who is the acting branch chief for 15 generic issues environmental projects branch and Frank 16 Akstulewicz who is the section leader in that branch for
- 17 regulatory improvements and they may participate in the 18 discussion as the briefing goes on.
19 As Mr. Barton mentioned, this is intended to be by 20 way of a status -- oops -- that's a different button.
And 21 part of the reason that it is status is~as my second bullet 22 indicated is that we are in the process of receiving 23 comments from members of other offices and other parts of
- 2 4 -~
NRR'on the rule that we put together so far, and that's the j
I 25.
package that we sent to the committee in parallel with these
-l t
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- other. individuals.
Also, there are some issues that weLare 2
still under discussion with the Commission on.
3 As you may be aware, there is a' Commission meeting l
'4 this' afternoon that was requested by the Nuclear Energy 5
Institute and the staff is also going to participate that 6
will speak to topics such as the guidance that the staff has 7
proposed on FSAR updating and some issues on 50.59 8
rulemaking that I will talk about shortly.
So we may have l
l 9
some additional interactions with the Commission on some of 10 these issues.
11 And as was mentioned, we do have a subcommittee 12 meeting on the 19th at which point we hope to have some 13 feedback from within the Agency, the different offices and 14 you can discuss the comments we have and where we might be 15 going as a result of the comments.
16 The next slide I tried to outline some of the key 17 elements from the Commission SRM of March 24th as they bear 1
18 on the 50.59 rulemaking activity that we have underway.
19 The first item is to prepare a proposed rulemaking 20 package, the date the Commission selected was July 10th 21 which has been a very ambitious schedule from the beginning.
22 We are striving to try to meet that as best we can.
And 23 they asked us to provide, quote, "a little bit from the 24 SRM"; make changes under the rule without prior approval to 25, el'iminate the de facto zero increase and allow minimal tO ANN RILEY & ASSOCIATES, LTD.
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~ increase in the probability of. occurrence or consequences of
(
2 an accident or malfunction of equipment and minimal 3
reduction in margin of safety.
4 Later on in the SRM they asked the staff to define 5
" minimal" in a clear and practical manner consistent with 6
the intent that minimal is larger than negligible,-and 7
substantially smaller than significant, and that in this 8
development the staff should consider its efforts on the 9
standard review plan for review of an application of NUREG 10 800. and also its standard review plan and regulatory l
11 guidance on risk-informed regulation.
12 A couple of other items in the SRM, they asked us 13 to continue our interactions with NEI on areas of 14' disagreement on their guidance document, 96.07.
They asked
()
15 us to evaluate certain other chan5es to the rule that I will 16 elaborate upon in the next slide in a moment.
They asked 17-the staff to consider the appropriateness of making changes 18 to other regulations that have similar language to 50.59 and 19 I'll speak to that further in a moment as well.
And then 20 they also asked the staff to come back in February '99 with 21 a status report on progress on certain ongoing initiatives 22 which would include, for instance, the FSAR updating, and a 231
. recommendation as to whether there should be'any change to 24'
.the scope of 50.59 from what it presently is, that is, 25 facility and procedures as described in the safety analysis ANN RILEY-& ASSOCIATES,-LTD.
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So that'was the direction we received in March that L
1
. report.
1
['
.2
' t \\~c) we'have been working to' respond to.
.3 As I mentioned, the Commission asked us to L
4 consider.certain -- whoops,l['m not.sure what happened to 5
that~ overhead.
I apologize, it seems to have gotten 6
smeared.
I'll ask you to consult your copies.
7 In particular the Commission asked a couple of 8-specific questions.
One, they asked the staff to evaluate 9
'for Commission consideration the advisability of revising
'10 50.59 to allow proposed changes that result in the creation l
11 of an accident of a different. type with minimal safety 12 impact or malfunction of equipment with minimal safety 13 impact.
And they asked the staff to do that evaluation, as 14 I stated, expeditiously that should the Commission decide A(_,)
15 they wished to pursue that option, it could be done in this 16-proposed rulemaking package.
17 The staff has responded to that issue and some 18 others'in a memo that was recently issued on May 27th.
I 19 don't know whether the copies reached you and were 20 distributed in time for the meeting --
21 CHAIRMAN SEALE:
We got it yesterday.
22 MS. McKENNA:
Okay.
Good.
And that has been 23 released to the PDR and we will have some discussion on that 24 at this afternoon's Commission meeting.
25 The other issues that they also would ask us to i
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reconsider our position with respect to acceptance limits on I[~'
2 consequences, and that issue was also discussed in that May.
l/\\
L 3'
27th memo.
l 4
On this-slide -- the slide that-you have in front 5
.of you, are how we_dispositioned those different issues 6'
based upon the response we provided to the Commission.
So 7
the draft rule package that we circulated for comment 8
' includes the direction from the Commission to allow minimal 9
increases.in-probability or consequences.
We are proposing
' 10 an approach with respect to margin of safety for using 11 acceptance limits to determine whether there has been a 12 reduction in margin of safety.
13 In lieu of the language of malfunction of a 14' different type with minimal safety impact we are proposing
-(Oj to adopt a recommendation that came from NEI to change from 15 16 malfunction with a different type to malfunction with a 17 different result.
We felt this was. responsive to the 18 concern of the Commission that malfunction of a different 19 type may.not have any impact in terms of safety, but by the 20 rule would require review whereas considering a different 21 result, if it wasn't something already evaluated and bounded 22 in the analysis, then maybe the is worthy of review.
23 Indicated here, the draft we circulated includes 24 changes to Part 72 NRR preliminary discussions with Office 25 of'NMSS.
They felt that that was the most likely candidate
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to be done in parallel considering the nature of the
/
2 facilities, the fact that the licensees are typically.the h~-
3 Part 50 licensees, so we are -- the package as drafted has 4-changes to Part 72 in it.
It's not final as to whether they 5
will proceed together or maybe be on some different 6
schedule.
We need to get further discussion going on that.
7 As I mentioned, we responded to the Commission 8
that we did not recommend adoption of certain aspects that 9-they had proposed on their SRM and these are listed down 10 here.
For instance, the first one was that,we did not 11 recommend changing of criteria to accommodate accident of a 12 different type with minimal safety impact.
We felt that it 13 was really difficult to come up with a criteria that would 14 be workable and would still ensure that the staff was (O) 15 involved when it was appropriate.
And we also were not sure 16 how it would fit with our established regulatory process for 17 handling amendments as significant hazards.
There's no 18 significant hazards.
So the recommendation was to not make 19 a change to the rule in that area.
20 CHAIRMAN SEALE:
There's a hook in 50.59 which I i
21 think everyone -- at least my experience is that everyone 22 was always very sensitive to, and that was the 23 characterization of the requirement to-review those things 24-that constituted an unreviewed safety question.
It seems to
- 25
- me that the accident of a different type clearly is an (O)
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unreviewed safety question.
/ '\\
2 MS. McKENNA:
I think-that was our view and that Q
3' it 4
~ CHAIRMAN SEALE:
And I don't recall that anybody 5
ever suggested that that was a candidate for this mir.imal 6
thing here.
7 MS. McKENNA:
Well, as I say, the only suggestion 8
was the request in the SRM for'the staff to_ evaluate that.
9 CHAIRMAN SEALE:
Okay.
So the Commission was 10' being a little bit more expansive, I guess, than the rest of 11'
.us?
12 MS. McKENNA:
Yes.
We are trying to respond to 13 the issues that they asked us to address.
14 CHAIRMAN SEALE:
Fine.
j'%
_ ( J-15_
MR. BARTON:
Didn't they ask to look at -- you to 16 provide some way to allow minimal increases in the 17 probability of' occurrence or consequences of an accident or
-18 malfunction, and minimal reduction to margin of safety and 19 ask you to define what-minimal safety impact was?
20' MS. McKENNA:
They asked us to define what 21
" minimal" was.
22 MR. BARTON:
Right.
23 MS. McKENNA:
We were looking at that as minimal
)
i 24
.in the context of what's the minimal increase in I
25 probability, what's the minimal-increase in consequences, if Il ID i
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we're going to do it, what's the minimal reduction in margin fT 2
ofJsafety.
]
- \\ms/
l
- 3' CHAIRMAN SEALE:.But the same kind of accident-j 4'
'that'had already been identified?
5 MR. BARTON:
Right.
6~
MS. McKENNA:
Yes, those are with respect to.the-7 accidents previously evaluated.
8-MR. BARTON:
Right.
9' MS. McKENNA:
This was creation of a different
-10 type from any previously evaluated.
11 MR. BARTON:
Were you successful in defining 12
- " minimal"?
-13 MS. McKENNA:
Well, I think that's yet to be 14 judged.
We attempted to provide in the write-up, I guess I A(
J-15 will call it, a qualitative view that minimal is really 16-small enough that it would not have impacted upon the 17 regulatory decision that was being made.
Then we also, as 18 we'll talk about a little further, tried to offer kind of 19.
where we thought it would no longer be minimal to give some 20.
bounds on that.
I mean, qualitative is nice, but eventually 21 you have to reach a point where people.have to make a 22 decision one way or the other.
So we tried to say, this 23 far,'if you go beyond this point we would say it's no more 24 than minimal.
So that was the approach we took was to.try 25 to say qualitatively what we thought it meant, but to give J.,O
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- some. guidance so that we could hopefully have more
[)
2 commonality on issues than having people to say, well, I L'
3 Edon't think-it's minimal.
4 It's a difficult thing to do when you're --
5 MR. BARTON:
It's a fuzzy line as Dr. Apostolakis 6
would say.
7
[ Laughter.]
8 MR. APOSTOLAKIS:
And the change has to be minimal 9
in both probability and consequences?
10 MS, McKENNA:
That's correct.
That's correct.
11 MR. APOSTOLAKISr Not the product?
12 MS. McKENNA:
That's correct.
13 MR. APOSTOLAKIS:
Why is that?
14 MS. McKENNA:
We're keeping pretty much with the
/')
15 structure of the rule and the way that -- you know,
(
16 accidents were looked at originally, as I think we had u.
17 proposed in our earlier papers to do, we call it a two-step l
L 18 process or whatever, to keep within the criteria we l
19 basically had with some minor adjustments and we weren't 20 ready to make a bigger leap to a product or risk kind of l
21 criteria at this point in time.
22 MR. APOSTOLAKIS:
But I still don't understand it.
23 I mean, why -- I mean, you are being asked by the Commission i
l 24' to evaluate these options.
Why not evaluate the option of 12 5.
_the product being minimally changed?
i 4
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CHAIRMAN SEALE:
George, I guess I want to know
()
2 how you're going to get the numbers before.I decide I'm 3
worried about what you're going to do with them after you 4
get them.
I think most of the things we're talking about 5
don't even come up on the PRA screen.
6 MR. APOSTOLAKIS:
That's right.
But --
l 7
CHAIRMAN SEALE:
How are you going to getLa number 8
to multiply?
9 MR. APOSTOLAKIS:
-- it may be that it will be 10 easier to evaluate the product of an individual.
11 MR. KRESS:
I agree with you, George.
The 12 individuals in my mind -- the individual changes may end up 13 in the product.
The change may affect only one of them.
14 But I agree with you, it makes more sense to get the
(
15-product, but I wanted to jump in and second Bob's motion.
I 16 think you're asking for nothing but trouble if you're trying 17 to quantify changes that are minimal and don't show up on 18 the screen of PRA.
You're just asking for an impossibility.
19 And you're getting yourself into a problem that just is 20 going to be continually arguments about the meaning of the 21 quantification and how it's done, and I think you're much 22 better of -- you're much better off getting off that tack 23 than defining " minimal" in other terms.
12 <4 MR. MILLER.:
Not quantitative.
25' MR. KRESS:
Not quantitative in terms of the
,O -
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attributes --
5 / ')
2 MS. McKENNA:
Well, we tried to do that --
t 3
MR. KRESS:
-- of the change itself --
4 MS. McKENNA:
-- to a certain degree, but I think 5-as, you know, mentioned in previous meetings, there's'a 6
number of different types of changes that may be 7_
contemplated and having attributes for each of those changes 8
that are clear that one would -- that you could get 9
agreement that it was or was not minimal is also a difficult 10 task.
'11 HMR. KRESS:
That's an extremely difficult task.
I 12 think you're better off going that way and you will have 13 less trouble in the long run.
14 CHAIRMAN SEALE:
You're setting the staff up to be
)
.(q,/.
15 unresponsive.
And that's not a good posture to present in 16 today's climate, because, as Tom says, you're just -- you
)
17 don't know where to go.
And so numbers as such, certainly 18-not PRA-type numbers, don't really enter in here.
19 MS. McKENNA:
No, I agree.
We're not really --
20
~we're not talking PRA numbers in the sense that people --
l 21 CHAIRMAN SEALE:
We're prejudging, maybe we ought 22 to let you talk.
23 MS. McKENNA:
-- really talk about.
I think, as I 24 mentioned, we were trying to focus on the minimal increase l
12 5 and probability of the accident, previously evaluated
-(<-~)
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minimal increase in the consequences of the accident f~)
2 previously evaluated.
And the ones that happen to be G
3 impacted by the change that's being considered, but, you 4
know, recognize any time you have numbers you will have 5
questions about how you got the numbers.
Yes.
6 Back on the acceptance of the consequences was the i
7 other -- the second item that we, at this point were not 8
proposing to change.
We addressed the reasons in the memo 9
that because of the way the changes have been reviewed in 10 the past, and by allowing in acceptance limits that may be a 11 Part 100 limit we felt that that maybe was too large a leap 12 to be taking and also reviewed that as being inconsistent 13 with a criteria of minimal increases and consequences that 14 you kind of either need to do one or the other.
/~~'
( )%
15 If you're looking at a minimal increase, you're 16 looking at some delta from where you were.
If you're 17 looking at use of acceptance limits you are giving yourself 18 a limit that you can't exceed and you can't put the two 19 pieces together.
And that's also the reason why we -- on 20 the last bullet, on the minimal reductions in margin of 21 safety we saw the same way that if you are saying, take your 22 reduction by determining whether you've satisfied the j
23 acceptance limits that you would not want to go beyond that 24 even in a minimal manner.
25 MR. APOSTOLAKIS:
The minimal increase is in the
(~s (V}-
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frequency, I guess, not'the probability.
That has to be
' f~J')
2 minimal -- which frequency _are we' talking about; the change-3-
itself?
4
- MS. McKENNA:
The minimal increase is what --
5 MR. APOSTOLAKIS:
In what?
In the core damage 6
. frequency?
7.
MS. McKENNA:
In the probability of the accident.
8 MR. KRESS:
What accident?
9 MR. APOSTOLAKIS:
What accident?
10 MS. McKENNA:
The accident --
11 MR. APOSTOLAKIS:
That involves that particular --
that involves -- yeah, you're 12 MS, McKENNA:
13 talking about, you have a set of accidents that were 14 evaluated in your FSAR.
f%
()
15 MR. KRESS:
It's the FSAR design basis accident?
16 MS. McKENNA:
Yes.
And you're looking at the 17 change that's being made, and how does that change affect 18 the probability of any of those accidents?
19 MR. KRESS:
Are those probabilities normally 20 determined in the course of an SAR?
21 MS. McKENNA:
They are normally determined in some 22 qualitative sense.
They may not have been a quantitative 23 -
evaluation.
I think they were typically looked at as 24:
anticipated operational occurrence that you would expect 25 once during the year, or something like that, or the more
[-s i
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limiting events that while maybe not. anticipated --
. (d' 2
MR. KRESS:
So you are~looking at percent change 3
in the --
4 MS. McKENNA:
I mean, I think you're kind of 5
looking at,'you know, if it's kind-of big enough to be 6
noticeable, then there probably is one.
And, you know, if 7.
you're kind of in the noise that would be the minimal.
It's 8
a.hard thing to do given the degree of quantification that l
9 probably didn't exist originally.
10 MR. AKSTULEWICZ:
If I might add, this is Frank 11 Akstulewicz.
Where we see this happening more frequently is 12 where licensees have proposed the numbers for the scenarios 13 themselves and then they make the argument that the change 14 from what they predicted would have been the case to the
()_
15 second case is so small.
And the numbers in themselves 16.
generally don't appear in the FSARs and we didn't ask for 17 them.
But what we're seeing with the increase in technology 18 that-licensees are now trying to predict these numbers.
19 MR. APOSTOLAKIS:
But you could though -- I mean, 20
.it seems to me that you can take advantage of the -- it's 21 not that I have the answer, by the'way, I'm just speculating 22 here.
23 MS. McKENNA:
- Yes, j
.24 MR. APOSTOLAKIS:
Of 1.174 and look at the core 25 damage frequency.and.then there may be a number of ways that
)
1
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one can-approach this.
For example, if-you have a
/ {
2 distribution of the. core damage frequency which I think-most
\\J 3
people should have, you can now give qualitatively what the impact of the proposed change would be on that distribution 4
5 without'really quantifying the change itself.
6 MR. KRESS:
Yeah, which direct.
7' MR. APOSTOLAKIS:
Yeah, for example, you can say 8
it may affect a little bit the upper tail or the lower tail, 9
and this and that, and then create a semi-qualitative 10
-argument why this is under 50.59.
Now, if you want to push 11 it a little further than that, remember there is a Region 12 III in 1.174 where the change is considered so small that 13 even if the core damage frequency is above the goal, it's 14 still allowed with some restrictions.
()
15 Would it be possible to maybe break up Region III 16.
into-two regions and say that, you know, below a certain 17 number it's not only small, it's extremely small.
So they 18 Lcan do it without coming to us.
Again, I'm not saying that 19.
it should be done that way, but here is another way of 20 approaching it that frees you from having to argue that the 21 particular number which you don't know is small.
22 In other words, you can argue in terme of regions 23 and impact on distributions and create an argument that 24 says, well, yeah, this is so minimal that why bother with 25
-it?
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L
. ell,-I think you're still asking the 1
MR.:KRESS:
W 2
determination of a number from looking at the PRA. -What I 3
was suggesting is that one go to the generalized PRA and-24 pick out attributes of changes that you'would expect not.to
~5 have a significant effect at all on the PRA and.use those 6-attributes as performance criteria that says, if.you meet l
l 7
these attributes, then you automatically are.in. Region III 8.
without having to go to the PRA, without having-to quantify 9
it, if you could do that, you save everybody a lot of 10-trouble.
l
~11 MS. McKENNA:
Well, I think we would agree that we 12 would expect in most cases you're not going to see 13 quantification that there will be qualitative arguments 14 along the lines that you were talking about.
(
15 MR. KRESS:
But if you'could set those up ahead of 16
' time to guide us as part of the' rule itself, you would -- I 17 think you would have a long way --
18 MR. APOSTOLAKIS:
But this is not mutually 19 exclusive with what I'm saying.
I mean, you can have a
)
20-process that says --
21 MR. KRESS:
It's not -- it's not --
22 MR. APOSTOLAKIS:
-- try to do this if you can.
23-MR. KRESS:
It's consistent --
24 MR. APOSTOLAKIS:
Or if you can get some --
25 MR. KRESS:
-- with what you're saying, but a b
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different.way to look at it.
VlI'b; 2'
MR. APOSTOLAKIS:
There may be a number of things 3
-that people.can do to give you a convincingJargument that 4
the change is minimal.
And that comes -- there is a whole 5
spectrum of things from looking'at the distribution of core 6
damage. frequency and arguing without giving specific 7
numbers, arguing what the impact might be of the proposed
-8 change as I said earlier, you know, maybe it affects really 9
the lower tail or it's in the middle or whatever, and then 10 if necessary and appropriate, bring into this 1.174 all the 11' way down to what Dr. Kress said, where you are really 12 arguing purely qualitatively that this thing is buried in 13' the noise in the PRA, and it satisfies such and such 14 criteria, therefore, you know, I don't have to worry about (3 !
x,J 15 it.
16 So there can be a --
17 MR. KRESS:
So long as you make a reassessment of 11 8 what the noise is in-the PRA.
19 MR.'APOSTOLAKIS:
Yeah.
20 MR. KRESS:
And I don't think that's really been b
21 done.
22-MR. APOSTOLAKIS:
But we do have an indication 23 from 1.174 what the noise is.
24
.MR. KRESS:
.Oh, yeah, absolutely.
25 MR. APOSTOLAKIS:
See, that's'the thing.
L V[)'
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1 MR. KRESS:
But for heaven sakes, stay away from
/)
2
. numbers like 1 percent, 10 percent, because those are so V
3 void of.any defensibility, intellectual content, all sorts
-4 of -- you're just going to really -- I can't see how you can-5 approach it that way at all.
6 MR. MILLER:
Somewhere you have to -- ultimately.
7 you're going to depend on the judgment of licensees --
8 MS McKENNA:
Yes.
9 MR. MILLER:
-- and the judgment of the NRC 10 inspectors and so forth.
And minimal it has to be defined 11 such that judgment comes into play.
And 1.174 certainly 12 depends on that judgment.
13 MS. McKENNA:
Yeah, and the difficulty, I think 14 with doing it under 50.59 is that you are -- you have more
()
15 reliance, if you will, on the licensee's judgment.
You 16 know, whether that's a problem or not is kind of in your own 17 mind.
But, I mean, that clearly is they are making the 18 judgment that it was minimal and proceeding with the change.
19 We are trying to minimize the after-the-fact, 20 well, that was clearly more than minimal, we don't 21?
understand why you would have proceeded with that change
'2 2 '
without 23 MR. MILLER:
Bt the number of after-the-facts has 24 been~ pretty small, hasn't it?
I mean, where you questions 25
[~
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MR. BARTON:
Where you challenged the safety
}
2 evaluation of the --
3 MR. MILLER:
I think we asked that question --
4 MS. McKENNA:
Yeah, and whether it's small or 5
large is again kind of a judgment factor.
There have been 6
cases where at least the questions have been raised.
The 7
cases where upon final review and dialogue we said, now, 8
that was clearly an unacceptable change that would never 9
have been accepted, I would agree is small.
10' MR. APOSTOLAKIS:
Let's not forget that 50.59 in 11 its present form has been used for a long time.
12 MR. BARTON:
Thirty years.
13 MR. APOSTOLAKIS:
And that -- I mean, judging that 14-a change is zero must be more difficult than judging whether
(~s) 15 a change is small.
So all the problems that we are 16 discussing now must have been faced in the past and somehow 17 the industry and the staff have come up to an understanding.
18 MR. KRESS:
Judging that the change is negative is 19 easier than --
20 MS. McKENNA:
Well, I mean, I would agree that the 21-experience in terms of making judgments about whether 22 problems may be increased would be very transferrable to a 23 judgment that it's been no more than minimally increased.
24 Because if it clearly met the one, it would clearly meet the 25 other.
It's kind of-how far that envelope can be pushed n-
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that we're really talking about.
()
2
.MR. APOSTOLAKIS:
Now, Region III in 1.174 still I
3~
requires NRC' review; is.that correct?
4 MS. McKENNA:
I think the whole premise of reg 5
guide 1.174 is that they require NRC review because of the 6
naturefof the kinds of changes that you're. talking about.
7-There are tech specs or plans or other things that require 8
of you --
9 MR. BARTON:
Those changes are a much higher level 10 than what we are --
11 MR. APOSTOLAKIS:
But they are still low.
12 MR. MILLER:
They have probably been lower than 13 those lows.
14 MR. APOSTOLAKIS:
50.59 Version 10 eventually
,/(,(
15 might say Region III11s -- no review required.
But this is 16-too soon.
17 MR. BARTON:
Too soon.
18 MS. McKENNA:
Yeah, I think you're right in 19 certain respects, it's too soon, and we are still within the 20 bounds of looking at the criteria individually with 21 probability separate from the consequences and with respect 22 to the accidents that were evaluated in the FSAR which are
.3<
-your design basis type of accidents so that we're a little 2
24-bit'away yet from the risk-informed approach that I think is 25 more fully _ developed _in the reg guide 1.174, the core damage
'./
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frequency.
2 MR.'APOSTOLAKIS:
But'you can still do a
(
3 risk-informed flavor?
4-MS McKENNA:
Certainly.
Certainly.
Yes.
5-MR. BARTON:
So what are you really doing 6
. accepting limits on consequences?
7 MS. McKENNA:
What we are proposing is not to 8
adopt that as part of the rule, but to change -- we were
-9 proposing the rule language of the consequences of the 10
. accidents previously evaluated no more than minimally b
11 increased.
12 MR. APOSTOLAKIS:
Like what consequences are 13.
these?
14 MS. McKENNA:
I'm talking about radiological 1(3
( )
15 consequences.
16 MR. KRESS:
-- to describe them.
l 17 MR. APOSTOLAKIS:
That's going to be minimal.
18 It's really the frequency that will govern it, right?
I l
19 mean, I can't imagine that you will see a significant change 20 there --
l 21 MS. McKENNA:
Well, depending --
22 MR. APOSTOLAKIS:
-- for the same reasons that the 23 level 3 FRAS --
g 12 4 MS. McKENNA:
It's a' function of what kind of a L
change the licensee is making.
If they're making a change
.25; (9
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to a spray system or a filtration system, something like
[J1-2 that, you may have a direct bearing on what the consequences 3
of the design basis accidents would be.
4 MR. APOSTOLAKIS:
Or you can look at LERF, the 5'
large early release frequency like 1.174 does.
Right?
And 6'
say your consequences are fairly insensitive to -- unless 7
.you do something really big to any changes.
And it's really 8
the frequency that should be --
9 MR. MILLER:
You could take-that in as part of the 10 judgment call.
11-MR. APOSTOLAKIS:
No, but that's what 1.174 does.
12 And you remember the two metrics are core damage frequency 13 and LERF.
So in that sense you.are building on that.
On 14 the other hand, the rule as it is now mentions consequences;
()
15 right? 3md you can change that?
Can you eliminate the word i
16
" consequences" from the rule, 50.59?
17 MS. McKENNA:
I mean, if the Commission chooses to 18 do rulemaking they could change that.
19 MR. APOSTOLAKIS:
Of if this committee chooses to 20 write a letter to that effect.
I 21 MS. McKENNA:
And, you know, the committee could 22 choose to recommend whatever the committee feels 23 appropriate.
Up to now, I mean, the committee -- we have 24 not'had a recommendation to eliminate the use of 25 consequences as a separate criteria.
}/
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~1 MR. APOSTOLAKIS :
So there will be a subcommittee 1
j' 2
meeting on June 19th --
3 MS. McKENNA:
Yes.
4 MR. APOSTOLAKIS:
-- to discuss this in more l
.5.
detail?
.6 MR. KRESS:
Is " consequences"_ defined in the rule 7
anywhere?
8 MS. McKENNA:
No.
9 MR. KRESS:
Well, we could just redefine it as 10-being --
11 MS. McKENNA:
But, again, I think you have to take 12 it back to the whole phrase, as the consequences previously 13 evaluated in the SAR which, you know, we don't in most cases 14.
'/.4
/
15
!WR. KRESS:
Okay.
Well, that's a definition you 16 17 MR. APOSTOLAKIS:
Does it have to be tied to the 18 SAR?
19 CHAIRMAN SEALE:
I think it would be very helpful 20 on the 19th when you come in that one of the things you do 21 is to outline for the committee what a 50.59 review was in l
22 the first 20 years of its existence before anybody thought 23.
about safety goals, or any of those other things. ~ And my 24 recollection is that you look to see what you were talking l
25, about','you've convinced yourself that you were talking about l[D ~
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things that were within your license basis.
And the
/T 2
question was, do you in any way violate the license basis as
\\/
3 a result of the change?
4 MS. McKENNA:
I think that's a very good point, 5
because, I mean, that was the intent of the rule from the 6
beginning.
7 CHAIRMAN SEALE:
And that's quite different from 8
what we're talking about here about CDFs and LERFs and all 9
of these other things.
And that's the first 20 of the 30 10 years we're talking about.
And maybe we want to go back to 11 where we got our -- where we developed the culture of 50.59 12 and the expectations for what it's supposed to do for us.
13 MR. APOSTOLAKIS:
And maybe change that part.
14 CHAIRMAN SEALE:
Well, and then we have to ask
,m
(_)
15 ourselves, yeah, but we also asked, you know, are we 16 throwing the baby out with the bath water.
17 MR. APOSTOLAKIS:
That's not a good idea.
18 CHAIRMAK SEALE:
That's not a good idea.
And 19 that's why I'm saying, I think we ought to ask ourselves 20 what did we really do with it originally, and what do we 21 think it ought to be doing for us now.
22 MS. McKENNA:
Yeah, and I think --
23 MR. APOSTOLAKIS:
Or another way of putting it, 24 what was the intent?
l 25 CHAIRMAN SEALE:
Yeah.
m
(
)
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MR. APOSTOLAKIS:
And do we now have different
()
2 tools that will help us achieve that in a better way?
3 CHAIRFmR SEALE:
And also, is that intent still a 4
valid expectation?
l 5
MR. SHACK:
That is, as I read, you know, you 6
really do have an attribute-based feature --
7 MS. McKENNA:
Yes.
for the equipment malfunction which 8
MR. SHACK:
9 Dr. Kress --
10 MS. McKENNA:
Yes, that's correct.
11 MR. SHACK:
And I was sort of -- I mean, my gut 12 feeling is that probably satisfies a large fraction of the 13 cases.
And that really is within -- you know, you stay 14 within the design basis --
)
15 MS. McKENNA:
The judgment, yes, correct.
16 MR. SHACK:
They even have something here about 17 operator actions, you know, that are criteria that even I 18 could understand.
19 MS. McKENNA:
As I say, we tried to speak to both 20 on a qualitative sense and attributes, but we felt that, you 21 know, in order to minimize disputes that it would be helpful 22 to give some kind of sense of where we would view that 23 they've gone too far.
Obviously we are open to feedback 24 from other offices and divisions and the committee that that
)
i 25.
may be more harmful than. helpful, and, you know, that's i
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fine, that would be helpft.1 input.
But we were trying to
[ )\\
2 accommodate a range of possible changes that would occur.
\\~
3 MR. SHACK:
I mean, I would sure take those two 4
paragraphs and try to avoid that last one.
5 MR. APOSTOLAKIS:
Which paragraphs are we talking 6
about?
7 MS. McKE$lA:
He's referring to the draft 8
statement of considerations that we provided where we tried 9
to give some guidance on how we would characterize " minimal" 10 and did try to speak to it.
So we felt that the guidance 11 that exists for instance in 96.07 that talked about the 12 changes.are so small which is the guidance that many 13 utilities -- well, we think that would meet this more than 14 minimal or no more than minimally increased.
We talked p)
(
15 about if you remained within your design basis that that 16 would be certainly no more than a minimal --
17 MR. SHACK:
You mean, if I meet the attribute l
18 basis, I don't have to then make the argument.
19 MS. McKENNA:
No, that's right.
That was really i
20 more of a -- you know --
21 MR. SHACK:
An alternative?
22 MS. McKENNA:
-- an alternative upper bound, if L
23 you will.
As I say, I would think that most would be I
24 attribute based because of the nature of the kind of changes 25 that they're looking at.
But that I think as was mentioned,
)
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'that_we-do see licensees who are turning to some of their
()
2 tools to evaluate the effect of the change and saying, well, 3
before this is what we had and this is the change that we've
'4 made and therefore the answer would now be this.
And we're 5
saying, well, if that's one thing you're doing, this is how 6_
we would judge whether that has been successful in 7
demonstrating that it can be done.
That was the approach 8
that we took.
i 9
MR. BARTON:
Are we still on the slide that's 10 blurry?
11
_MS. McKENNA:
Yes, but I think we can move from 12 that.
13 I just wanted to touch on a couple of other 14 aspects of what we're focusing on with respect to the rule
()
15 itself.
One of the things that we are trying to do is to 16 provide definitions-for certain of the terms.
And one thing 17 that we are looking at was a changed facility as described 18 in the SAR.
And there were two points we were trying to 19 make with that.
20-One was the question of whether the facility only 21 means the hardware, the actual things you can touch?
And 22-our view was that you needed to look a little more broadly 23 than that because if-you're changing some of the other 24 information in the SAR, you are going to be_affecting the.
25 margins insofar as by changing those other attributes other
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1~
. changes.could be made.
Obviously changing an analysis does
(}
2 not by itself impact the safety of the plant, but that once 3
having changed that and you make other changes there could 4:
be an effect.
So we're thinking that they needed to look 5.
more than just saying, well, did I actually change something 15 physically in the plant?
7-The second part of that was additions to the 8
facility.
We have had occasions where there's a question of 9
whether you would interpret change as including -- adding 10 something that wasn't previously there.
We feel that falls 11
. within the definition of change, but it has on occasion been 12
. viewed differently.
So we're trying to be explicit that an 13 addition is a change that needs to be considered from its l
14 impact on what the rest of the facility thinks it may be
~()
15 connected.
It may be located near something that say, well, 16 I looked at my SAR and it doesn't talk about having this 17 particular thing would not be a sufficient basis for not 18 performing an evaluation.
19 And it mentioned a question of minimal already.
I 20 won't dwell on that.
And I spoke to the issue on margin 21 that'we were planning to provide some definition to clarify 22
'the' connection to acceptance limits and developing on that.
23 Just moving on quickly to a few other things that 24 you would ha"e seen_in the, rule package that we were 25 proposing, as I mentioned, we were proposing to put in-ANN RILEY & ASSOCIATES, LTD.
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' definitions.
I had mentioned specifically " facility", but (I
2' we-were planning to include for completeness, also l
'3
" procedure" and " tester experiment" just so, you know, we'll l
4 have an~ idea of what was meant by those.
5 The formatting we did describe in the draft notice 6-of trying to take advantage of doing rulemaking to put 7
pieces where they, we think, maybe fit more logically.
8
- Certain aspects were, when changes were made they were kind
- of'added on at the end and maybe that wasn't the best way to 10 deal with these things.
So suggesting that maybe it would L
11
-be helpful to restructure'it.a little bit.
L 12 We've mentioned this last one before, the question 13 of whether to retain the term "unreviewed safety question".
14 I the proposal that we circulated we suggested not'using a
()
_t rm,.just listing the criteria as saying, if it meets any 15 e
16 one of these criteria it requires a license amendment.
17 That's still an open-question.
I mean, there are those who 18 would like to keep the unreviewed safety question kind of l
.19
'for it's historical or regulatory background, there are
'20 those that would maybe substitute :another term for 21 convenience that you can, you know, call it something short
~22 :
without saying;it's a-thing that requires a license
-23
-amendment.
l l.
24-MR.JAPOSTOLAKIS:
Also,7it's really a terrible L
L25
. term to use when you're communicating with the public.
9' '
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MS. McKENNA:
Well, that was the reason why were
,~N 2
suggesting the change in the first place that it has certain
(
)
l 3
connotations that maybe were not consistent with the view 4
that it's a question of whether it requires a regulatory 5
review.
6
. CHAIRMAN SEALE:
You're going to drive your 7
friends in DOE crazy if you do that, though, because they l
8 live and die by that 9
MR. APOSTOLAKIS:
They should do it.
Do it.
l l
10 MR. POWERS:
On the other hand, I agree with l
11 George, they should be driven crazy.
12
[ Laughter.]
13 CHAIRMAN SEALE:
Well, I agree, but I mean, 14 they're going to die if you do that.
4, }j f
15 MR. POWERS:
Let me suggest the term " FRED".
16 MS. McKENNA:
FRED.
What does " FRED" mean?
17
[ Laughter.]
18 MR. POWERS:
Nothing.
19 MS. McKENNA:
Nothing.
It's just a term, all 20 right.
21
[ Laughter.]
22 MS. McKENNA:
Well, we have a lot of suggestions 23 for what the term would be and certainly I think this is not 24 a closed issue.
And I think when the Commission voted on 25 cur paper earlier, we had one Commissioner who said, keep (m).
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the term; we had one who said, get rid of the term; and two
. \\
2 who did not speak to the issue.
So we really don't have a
' -(J 3
good sense.of where the Commission may lie on this issue.
4 MR. POWERS:
Now, again, can we write a letter 5'
that says, get rid of this term?
6
[ Laughter.]
7-MR. APOSTOLAKIS:
You have 1.174.
You can find a 8.
term that says, this particular issue should be evaluated --
9 as such that should be evaluated according to that guidance.
10 Then it becomes a bureaucratic term and it does not attract 11 any attention about "unreviewed safety".
12-MS. McKENNA:
Well, I think what we did was --
13.
MR. APOSTOLAKIS:
Because that's really-what we're 14 talking about --
r 15 MS. McKENNA:
-- kind of went to the bureaucratic 16 and say that these changes require a license amendment 17 because that is kind of how the pass-through works is that 18 it if wasn't an unreviewed safety question that required an 19 amendment so we said, well, let's just go right to it.
20 MR. APOSTOLAKIS:
Yeah.
So now we would say it 21 would require a request for change in.the CLB.
I guess we 22 drop the "C",
the licensing basis; right?
So we make the 23 connection very nicely.
- 24 MS. McKENNA:
Well, = yeah, that's an approach.
25, MR. APOSTOLAKIS:
Anything to boost the h
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(
1 significance of 1.174.
f~')
2
[ Laughter.]
. w_-
3 MR. BARTON:
You ought to be a salesman, George.
4 CHAIRMAN SEALE:
He is.
5
[ Laughter.)
6 MR. APOSTOLAKIS:
Of intellectual goods only.
7' MS. McKENNA:
That's fine.
Just listed here, we 8
are looking at some questions on reporti-' and recordkeeping 9
One of the things that comes to -- when you start looking a i
10 minimal increases and probability of consequences and again 11 looking to 1.174 for guidance we see a focus on cumulative 12 effects.
And we're saying, well, how can we get a handle on 13 cumulative effects when you're talking about changes that 14 are being made by the licensee at its plant?
What we've r~
1
(,))
15 proposed in this dras that we've circulated for comment 16 would be to make a revision to the 50.71(e) update rule to 17 indicate that when_the licensee makes their FSAR update that 18 they include information on the cumulative effects of l
19 changes they have made to the probabilities or consequences.
20 MR. KRESS:
Well, I'd like to see you get rid of 21 that too.
22 MS. McKENNA:
Okay.
Well, that's --
-23 MR. KRESS:
Make this rule such that you 24' automatically know that over any lifetime of the plant the 25.
cumulative effects are acceptable, and just don't worry l
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about them anymore.
You don't have to track them, you don't
(\\
2 keep account of them would be in my mind a much better way w-l _
3 to -
I-mean, if you're going to have this concept that 4
these things don't matter, then you could also have the 5
. concept they don't matter in the cumulative sense, also.
6 So, therefore, there's no reason to --
7 CHAIRMAN SEALE:
It's just part of the licensing 8
basis.
9 MR. KRESS:
Part of the license.
10 MR. APOSTOLAKIS:
So if you multiply excellent by 11 N -- does it matter what N is?
12 MR. KRESS:
That's right.
Because we know there's 13 a limit to N.
You know, N has a practical limit.
14 MR. SHACK:
Calculus is a little different in 15' tennis.
l 16
[ Laughter.)
17 MR. KRESS:
Well, we use three for ties, it's 18 easier to multiply.
19.
MS. McKENNA:
I suspect this would be more of a --
20 may come more into play for consequences where it is 21 gomething that you can calculate and you could have -- we 22 kind of have a record of effects.
You know, it may be a
'23 valid point with respect to probability that is something we l
24l
~can look at.
We are in the process of getting feedback from 25 otherstand, you know, we will see what the view is on that
.I, sI.
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386 1:
point.
2 The second part was, we were looking in terms of 3
trying to not have:a. big increase in burden.
We're looking 4
at whether the separate reports that's presently required 5
_under 50.59 of changes to facility and procedures made is 6
.necessary would suggest that the tests and experiments _be 7_
maintained because those are the things ---test experiments 8
not described in the SAR and you would not have any -- if 9
there were changes to the facility, they should be reflected 10 back into the FSAR update.
11 Part of the rationale here was that since it is a
- 12
' summary report and a brief description, it's not terribly 13'
' nformative, that generally if someone wants to really i
14 understand the changes they have to look at the full
)
15 evaluations in any event.
So we're suggesting this to see, 16 you know, again, whether there's a sense of how useful that 17 report of changes is and that may survive or may not 18 survive.
19.
The last bullet I just mentioned was something we 20 are wrestling with, with respect to backfit questions and 21 information collection requirements through changes to 22' requirements for them to do evaluations and retain records.
23 And it's difficult because one of the reasons we were going 24 into the rule in_the first place is some degree of 25.
clarification of what's required now versus what should'be
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required.
And so, therefore, doing backfit before that this
()
- 2 was a requirement and now it's this is causing us some 3
difficulty.
In some of these things we say, well, that was 4'
what the rule meant all along, and the licensees may differ.
5 So it is an issue that.is still, I think, we're going to o
6 have to continue to refine our analysis on that point.
7 MR. APOSTOLAKIS:
I think it will help you to take 8
the point of view that what you'are trying to do is develop 9
a fourth region in 1.174 where things do not -- I think it's 10 going to help you a lot.
Are there three now?
11 MS. McKENNA:
Yes.
l 12 MR.'APOSTOLAKIS:
You are developing the fourth j
J 13 which goes to infinity, f
MS. McKENNA:
Yes.
14
./~
.15 MR. APOSTOLAKIS:
That's all that's-a statement.
16 MS. McKENNA:
Okay.
17 MR. APOSTOLAKIS:
Why are you objecting to it?
l 18 Not you, my colleague?
19 Oh, I like attributes.
I don't want to calculate 20
-- you don't have to calculate.
It's a point of view.
21 MR. KRESS:
It doesn't hurt to have the point of 22 view as long as you don't have to quantitatively determine l
23 some delta.
Right.
25 CHAIRMAN SEALE:
That's an attribute --
E
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-1 MR. KRESS:
Performance-based, risk-informed --
2' CHAIRMAN SEALE:
But what I'm trying to say is it 3_
is a stake you reach as a result of the consideration of 4
attributes.and not numbers.
5 MR.-APOSTOLAKIS:
Right.
But the point-of view 6
helps a lot.
7 MR. KRESS:
What point of view is that?
8 MR. APOSTOLAKIS:
It helps you find a new term for l
l 9-what's now USQ.
It helps you argue that you don't need to
-10 worry about the consequences or consider the frequency that 11 matters.
You see, there is a lot of stuff that's behind
'12' that point of view.
13 MR. KRESS:
Or to argue that you don't have to 14 worry about cumulative.
()
15 MR. APOSTOLAKIS:
Right.
And creates a basis for 16 doing something better five years from now.
See, point of 17 view is very important.
18 MR. BARTON:
We'll see on the 19th.
19 MR. KRESS:
Yeah.
20 MR. BARTON:
Whether they received a point of 21 view.
22-MR. SHACK:
It could be a long day.
23 MR. BARTON:
That's all right.
24 CHAIRMAN SEALE:
It better not be.
25
[ Laughter.]
l 3
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MR. BARTON:
We're getting used to long days.
(
2 MR. SHACK:
Long evenings, huh.
3 MR. BARTON:
Go ahead.
4 MS..McKENNA:
Well, I hesitate to put up this last l
5 slide in view of some of the comments we've had earlier, but 6
7
[ Laughter.]
8 MR. BARTON:
Well, that's all right.
You might as 9
well just charge on.
10 MR. APOSTOLAKIS:
Now, for example, you would 11 never put these things up there if you had that point of 12 view.
)
L 13 MS. McKENNA:
Yes.
14 MR. APOSTOLAKIS:
You see, there is such a thing
)
15 as change in the frequency by 1 percent.
This is a 16 distribution for the frequency.
See, point of view is 17 important so this really -- you wouldn't have put up there.
18 MS. McKENNA:
Okay.
I think I already explained 19 why we did it --
20 MR. APOSTOLAKIS:
No, I understand.
21 MS. McKENNA:
-- just the give --
22 MR. APOSTOLAKIS:
It's because you didn't have 23 that point of view.
u l
24 MS. McKENNA:
Correct.
That's right.
25 So maybe we'll skip over the probability pieces
... T
[
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and I'll just touch on for a moment the consequences part
(~}
2.
because that is an area where obviously you do have V
3 quantification.
And we are -- we've circulated a couple of l
4 proposals and there may be others forthcoming that kind of l
5-looked at whether giving a flat no more than half a rem or 5 6
percent something like that.
7 The other idea which we circulated which was an 8
attempt to be responsive to minimal with respect to impact 9
on decision is that if you are far from the limit a larger 10 increase -- it's kind of the Reg 1.174 philosophy -- far 11 from the limit a larger change can be accommodated without 12 having any impact on your decision.
The closer you get to 13 your limits the more important the smaller changes become.
14 MR. APOSTOLAKIS:
And we know how to handle that, O
15 right?
16 MS. McKENNA:
Yes.
17 MR. APOSTOLAKIS:
Shades of gray?
18 MS. McKENNA:
Yes.
So we circulated an idea if 19 you are below a certain point that a 10 percent change would 20 be minimal as you approach the limit you converge on a 1 21 percent and obviously you couldn't exceed the limit.
22 MR. KRESS:
Except, I'd rather take the point of 23 view that we're in a region where the gray is all white.
24 You don't have to worry about where you are?
25 MR. APOSTOLAKIS:
Let's start thinking about it
/
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-and we'll see'how it turns out.
L [~ );
I 2-MR. KRESS:
Okay.
v-I-
3 MS. McKENNA:
As-I'say, we've been trying to work l
l
'4 within the structure of the rule and the parameters whichi 5
the accidents previously evaluated and the separate
^6-probability.in consequences and margin.
I mean,:that was --
7.
and the approach we had. outlined was to do this near term, 8
.shall we.say, change to provide some degree of flexibility
.9 of'the.maybe increased perspective.
I-think the Commission
'10 is clearly interested'in the longer term in perhaps going to 11 other approaches as we get more experienced with the.
12
_ risk-informed regulation where the staff is in the loop in 13:
terms of reviewing the. changes, but I'm not sure we're ready
-14 to adopt'all of-the things that you were suggesting at this
'/'y j
- (,j ;
15
_ point.
16 MR. APOSTOLAKIS:
Well, you know, we may help in
- 17
'some way.
18 MS. McKENNA:
That's certainly --
19 MR. APOSTOLAKIS: 'Right?
20-MR. KRESS:
Yeah.
That's what we're here for.
21 MR. APOSTOLAKIS:
I mean, the Commission has
'22 stated that they want to move towards risk-informed 23; regulation.
So, you know, anything we can do to foster that 24L ewould be great.
125-MS. MdKENNA:
'I appreciate that.
l I
b
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l 1
MR. APOSTOLAKIS:
It's a point of view.
t
[ )t 2
MS. McKENNA:
Are there any other questions or f
3 comments?
s 4
MR. BARTON:
I see one of the usual suspects in l
I 5
the audience.
Gay, do you have any comments?
6 MR. HOLAHAN:
I was hiding back in the corner.
7 MR. BARTON:
Yeah, but he didn't hide well enough.
8 MS. McKENNA:
Not well enough, huh?
9 MR. HOLARAN:
Gary Holahan, from the staff.
I 10 guess I agree with Eileen that a lot of these things are 11 still under discussion.
I think there are a lot of 1.174 12 risk-informed thoughts that might be brought to this issue, 13 but fundamentally, you know, until you substitute, you know, 14 a living PRA as the licensing basis instead of the FSAR,
()
15 you're going to have limitations on how you contest the l
16 licensing basis with, you know, risk thoughts.
I think to a 17 large extent 50.59 is going to have to be a licensing test j
i 18 of some sort, but you can have risk insights and risk 19 thoughtful licensing, you know, insights.
20 MR. APOSTOLAKIS:
That's what I meant by point of 21 view.
And let's not forget that the first principle of 22 1.174 is to demonstrate compliance with the existing 23 regulations and so on.
So you can easily accommodate other 24 things under that principle.
25 MR. HOLAHAN:
- Yeah,
[/
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MR. APOSTOLAKIS:
SO I don't think there is any
[-
2 disagreement here.
-V 3
MR. HOLAHAN:
One other thought that I would just 4
sort of drop on the~ table that I am so surprised that no one 5
'else' raised was the idea of addressing initiating event 6
frequency and probability and I think of safety margins as a 7
' measure:of success criteria and consequences.
One thing 8
that 50.59 does in. testing those separately is it gives you 9
some defense in-depth philosophy in 50.59.
And if you roll 10
.all of those together and say I'm going to make my decisions Lil based on, you know, the end products as opposed to the 12 pieces, then it becomes more difficult to figure out where
.13 defense'in-depth is in this process.
So, I mean, there can 14 be a roll for doing these things in pieces.
1 f) 15-MR. APOSTOLAKIS:
Not all defense in depth is 16 good.
17 MR. SHACK:
I need defense in depth on a change 18 that's, you know,. minimal.
-19 MR. APOSTOLAKIS:
Yeah, I mean, it's minimal.
You
)
20
-are dealing with things that are in the noise by definition.
21 So I'm not saying that this is not a point to be 22 investigated --
23 MR. HOLAHAN:
It's a point of view.
I
~
^24
[ Laughter.]
25-
.CRAIRMAN SEALE:
Okay.
i
~'
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~
MS. McKENNA:
Well,_that is what I wanted to-
}
2' discuss 1with the' committee at'this point.
In summary, I 3'
think I'd' mention that we do have'this memo that you've seen i
4 that we've put'before the Commission.
And'what we said we
~
5' said there was that "unless otherwise directed" we would T6 proceed to develop 1the rule along the lines that.we had 7
-outlined.
We will be meeting with the Commission this 8
afternoon.
They also will be taking up the question of the 9'
guidance on FSAR updating.
So we're not sure how much depth 10
'we will get into on some of these issues with the Commission
-111 in view-of:the time, but --
12 MR. BARTON:
Where are.you in meeting with NEI and 13.
_trying to come taa closure on the difference with their 14 guidance?
A,,
15; MS. McKENNA:
You know, we sent comments, I think, 16
-when we met back in February we had noted that we had sent 17 comments.
There was some reaction with some of the phrasing 18 about, you know, where we thought that their guidance was 19 inconsistent with-the rule that, you know, there could be 20 enforcement issues.
And --
21' MR. BARTON:
Well, I remember-the two letters that 2:2 flew back and forth, right-23 MS. McKENNA:
-- after.that exchange of letters we h
.24 have.not'had_further dialogue specifically on 96.07.
There's?a' lot of_other' things going'on.
I think maybe with 25:
P cem '
y J
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395 1
the rulemaking issues on the table, you know, it's a little
/T 2
hard to settle on the guidance until you know what the rule V.
3-language ^is.
'4' MR. BARTON:
But that will come up because that's 5;
one of the things the Commission asked us to go look at.
6' MS. McKENNA:
Oh, yeah, and I certainly would-7
- because I think the last letter from NEI had indicated that-8~
members.were planning to. adopt the guidance by the end-of-
.9'
. June.
So obviously --
10 MR. BARTON: 'Is that the meeting today?
11 MS. McKENNA:
Yes, the Commission meeting today 12 and NEI is the first speaker on 50.59.
They're going to 13
. talk about FSARs, 50.59 and some other issues.
14 MR. BARTON:
50.59 and FSAR, okay.
15 MS. McKENNA:
Yes.
16 MR. BARTON:
Any other questions or comments or 17-divine guidance for Eileen for her to look at between now 18' and'the 19th of June?
19 MR. APOSTOLAKIS:
I believe this is closed for 20 today.
21 (Laughter.]
22 CHAIRMAN SEALE:
Do we have any comments from 23 any6ody else?
12 4 '
(No response.]
~
25 MR. BARTON:
No other comments?
Well, thank-you NN ANN:RILEY & ASSOCIATES, LTD.
Us l Court Reporters 1250 I Street, N.W.,1 Suite 300'
)
E Washington, D.C. 20005 (202) 842-0034'
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l 396 l
l' very much, Eileen.
^'t 2
MS. McKENNA:
Thank you.
,<j '
3 MR. BARTON:
We'll be looking forward to speaking 4
with you more on the 19th on some more details on where 5
you're going with the rulemaking.
Thank you.
6 MS. McKENNA:
Great.
7 MR. APOSTOLAKIS:
By the way, one last-question, 8
MS. McKENNA:
Sure.
9 MR. APOSTOLAKIS:
Is this going to take two years 10 also?
11 MR. BARTON:
Everything is on a two-year cycle.
12 MR. APOSTOLAKIS:
Oh.
Really, it will?
13 CHAIRMAN SEALE:
It depends on how responsive you 14 are.
,~)
15 MS. McKENNA:
I think there's an inherent
,.v 16 timeframe for doing rulemaking established by the process.
17 Beyond that it's really a question of agreement on the 18 issues and the degree of comments and what it takes to 19 resolve them.
20 So, I mean, the Commission has obviously put this 21 on a high priority.
They've indicated in their SRM they 22 wanted it on an expedited basis. But I certainly would not 23 try to predict whether it would be complete in two years or 24 not.
25 MR. BARTON:
Thank you, Eileen.
~'
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1 MS. McKENNA:
Thank you.
'2' CHAIRMAN SEALE:
Okay.
We got some time back.
I 3
know a lot of people are working on things, writing one 4-thing and another.and our next session is scheduled with 5
visitors at 1:30.
6 MR. APOSTOLAKIS:
Good.
7 CHAIRMAN SEALE:
I think what we'll do is just go 8
ahead and recess for lunch.
But I urge anybody to use the 9
excess time for writing notes to Dana or whatever.
So, see 10 you at 1:30.
'11 (Whereupon, at 12:02 p.m.,
the meeting was i
12 recessed, to reconvene at 1:30 p.m.,
this same day.]
l 13 14 A( p) 15 16 17 18 19 20 21 22 23 24 25
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AFTERNOON SESSION
)
2
[1:30 p.m.]
3 CHAIRMAN SEALE:
We'll come back into session now.
4 We have a presentation this afternoon on the proposed 5
standard review plan, section and reg guide for 6l risk-informed inservice inspection of piping.
We'll have 7
staff and also some industry representatives in 8
presentations, I believe.
Where is George?
9
[No response.]
10 MR. UHRIG:
Well, this is his subcommittee.
'll CHAIRMAN SEALE:
It's his subcommittee.
12 MR. SHACK:
He just stepped out for a minute.
He i
13 was here.
i i
14 CHAIRMAN SEALE:
George?
()
15
[ Pause.]
16 CHAIRMAN SEALE:
Well, I see that we have our 17 friends from NRR and Research here.
Who is going to lead
'18 off?
19 MR. KING:
We were going to come up and take the 20 table.
21 CHAIRMAN SEALE:
Go ahead.
I'll deprive him of 22 his prerogatives until he gets here anyway.
23
.[ Laughter.]
~ 24 CHAIRMAN SEALE:
I invited them to come on up 25/
here.:
[ l' h
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399 1
[ Laughter.)
2' CHAIRMAN SEALE:
I invited them to go ahead and 3
take their seats there.
l 4
MR. APOSTOLAKIS:
Sure.
Sure.
I'm sorry I'm 5
late.
6 CHAIRMAN SEALE:
That's all right.
7 MR. KING:
Did you want to say anything, George, 8
or should we just go ahead?
9 MR. APOSTOLAKIS:
Welcome.
10 MR. KING:
For the record, my name is Tom King, 1
11 I'm with the Office of Research.
With me at the table are l
12 Gary Holahan, and Gotam Bagchi from NRR.
What we wanted to 13 do today was summarize where we stand on the risk-informed 14 reg guide and SRP on ISI.
15 I t '.i:4k you're vugraph package has Jack 16 Strosnider's name on the front, but Jack couldn't make it so 17 Gotam is filling in for him.
Gotam can turn the slides for 18 me.
19
[ Slide shown.]
20 MR. KING:
What I wanted to do is just quickly l
21 summarize by way of some background just to refresh your 22 memory on where we stand on this and what's happened since 23:
the last time we met back in early May.
I'll summarize the 1
24 Lindustry activities and schedule that we're working on to l
'25 interact and complete those.
I'll summarize the key
['y
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1 attributes of the reg guide and SRP, and what our approach 2'
is to finalization and then the schedule.
3
[ Slide shown.]
4' MR.. KING:
As you'll recall, back in early May' 5
when we met with the committee we informed you of a change 6-in direction with this reg guide and SRP and that we were 7
not proposing to issue it as a final at this point in time.
8 We were posing to issue it as a final draft for trial use L
9-
'and that was brought about by the fact that we still have 10 three pilots that we haven't completed, we have two topical 11 reports we haven't completed.
We've got three code' cases 12 under review and we felt at this point it would be better to 13 complete those before we actually finalize the reg guide so 14 that we could factor any lessons learned, insights, so and
.()
15 so forth in and also see at that point exactly how much 16 detail is needed in the reg guide versus incorporating by 17 reference the topical reports or the other documents.
18 MR. APOSTOLAKIS:
Well, on that though, the 19 counter argument is twofold.
One is you have already issued
-20 NUREG reports that apply this approach to Surry.
One was 21 issued in February of
'97, so we're talking about more than 22 a year ago by PAL, Pacific Northwest Laboratories.
Right.
23 Their prior risk-informed ISI to Surry.
And there's a lot 24 of stuff there about the importance of piping segments and 25 so on.
So it's not that you expect to really learn
,\\]_-
-(
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something revolutionary from the pilots.
I' i 2
The second is that the Commission, as you know, in
'D 3
approving 1.174 two or three weeks ago made it very clear 4
that they expect the staff to go back every year and tell 5
them what lessons they have learned from other applications l
6 and propose possibly desirable revisions.
So, instead of 7
issuing it for trial use, why don't you issue it for final 8
use and then a year later you will do what the Commission 9
asks you to do with respect to 1.174 which I am sure they 10 will ask you to do also with respect to the other guides.
11 MR. HOLAHAN:
Well, there's one significant 12-difference between, you know, working from a draft, whether 13 the draft is called " draft" or whether it's called "for 14 trial use" and putting out a final document.
And it has a
(~N i
)
15 legal -- there's a legal standing to the document that's 16 different between the two.
When the staff puts out a 17 regulatory guide, that becomes the formal staff position.
18 If after a year we want to go back and change those 19 requirements, that's subject to the backfit rule.
And there 20 are certain requirements and standards it has to meet to 21 make those changes.
So the staff's -- yeah, the staff has 22 been asked to go back and reflect operating experience after 23 the fact, but how you do that and what standards you are l
24 held to and how hard it is to do makes a difference about 25 whether this is a final document or not.
(/
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(-
402 l'
And that's one of the reasons that we felt the 2
likelihood of us making some changes between this version
~
3
'and some final version was high,enough so that, you know, we 4
didn't feel that we were prepared to call this, you know, a 5
formal staff position having never been tested.
And I 6
'think, you know, the PAL document you're referring to is-not 7
by the licensee, it's not an application.
It was part of 8
the methodology development.
9 MR. BAGCHI:
It is a project.
10 MR. HOLAHAN:
Yeah, and that's not the same type
'11' of document we've had in the other cases where it's been 12.
actually tested in the licensing process and we were more 13 comfortable with that.
14 So, you know, I see these as whether we put it out
](j 15 in final or not makes a difference, even though -- even if 16 we call it a final, we'll revisit it in a year.
Probably 17 the Commission will in fact expect us to do that.
18 But I think it makes a difference what you call it 19 at this stage and how ready you are for the thing to be 20 considered.a final staff position.
21 MR. APOSTOLAKIS:
But also a part of this argument 22-has to be the -- as you say, the likelihood of change, and 23 since you have already removed the appendices which are very 24 technical and detailed, and the rest of the document really 25 is' at the level where I don't know what kind of major change O
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you will find from the pilots to effect.
I 'Y 2
MR. HOLAHAN:
That may be the case.
We need to
' \\j 3
' reflect on that when we're making a decision.
It seems to 4
me the backfit_ rule applies to the ACRS as well as the rest 5
of us.
When we all come back a year from now and say, you 6
.know, having gone through these pilots we've learned some 7
' things we'd like to change, you know, there are some burdens 8
associated with those changes.
l 9
MR. APOSTOLAKIS:
But shouldn't we also look at 10 the downside of this though?
11 MR. HOLAHAN:
Yes.
12 MR. APOSTOLAKIS:
It seems to me that issuing --
13 first of all based on our subcommittee meetings and full 14' committees with you and the industry it seems that there is
()
15 aJremarkable' consensus that this is a good thing to do, that 16 it will reduce radiation exposure, it will be less 17 expensive, it will look at failure mechanisms that, you 18 know, were not really addressed in the past in a more 19 vigorous way --
j i
20 MR. HOLAHAN:
Yes.
j 21 MR. APOSTOLAKIS:
-- and then we turn around and H22
.say, this is for trial use.
I mean, aren't we sending the
.23 wrong message out there regarding our willingness to embrace 124 risk-informed regulatice 4 in particular this regulation.
l 25:
MR. BAGCHI:
This is Gotam Bagchi from the staff.
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'1 Sir, to address that squarely I think the demonstration is
(}
2 going to be when an actual application has been reviewed and 3
approved.
The reg guide helps facilitate getting the information in an organized manner so that the staff can do 4-5 their current kind of reviews, but this burden of having to l
l 6
go back and change the regulatory guide with the perspective 1
7 of the lessons learned is a severe burden on the staff.
And 8
sometimes it's almost too. onerous to even attempt a change.
9 There are numerous documents like that that have not seen 10 any upgrade because of those kinds of burdens.
They fall by 11 the wayside.
12 This is best to avoid by issuing this document as 13 a for trial use particularly because this is the only place 14 where there was absolutely no experience before we tried to
()
15 write the reg guide.
We had the benefit of the WOG report 16 primarily and we gleaned as much information out of that as 17 we could.
And that report, for example, the qualitative 18 method wasn't available substantively for us to incorporate 19 all of the insights from that kind of an approach.
20 MR. APOSTOLAKIS:
Well, I don't know that it is a 21 unique case.
I think the regulatory guide on graded quality 22 assurance had similar problems and perhaps bigger problems 23 in some sense because at least you can quantify the j
i 24 significance of what you're doing in terms of risk much more l
25 than the --
l l
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405 l'
MR. BAGCHI:
'I was only making the point that had f
2 been reviewed by the staff for some time.
This is the only 3
. case where the reg guide is well' ahead of any kind of a 4-review by the staff.
5 MR. KING:
I think we all agree --
6.
MR. APOSTOLAKIS:
Yeah, let's finish.
-7 MR. KING:
Yeah, we all agree it's a' risk-informed 8
ISI is a good thing.
We like to see it implemented as soon 9
as_is reasonable.
From that standpoint I think getting 10 something out as soon as possible that opens the door for
.11 industry to come in and start making submittals is one of 12 our most important objectives.
13 MR. APOSTOLAKIS:
The industry has already come 14 in,
()
15 MR. KING:
They've come in with three products, f
16 yeah.
f 17 MR. APOSTOLAKIS:
So it's not a question really of 18 releasing it just to attract more pilots.
I mean, we 19 already have three and we don't seem to have enough time to 20 review them.
21 MR. KING:
But it sends a signal that we are now 22 ready to review them.
We've got enough infrastructure in 23 place that we're ready to process them.
And I think that's 24 an important. signal to send.
25
.Anything we do -- I mean, one of the problems with
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406 1
the appendices and trial uses versus final was the degree of
-[~3 2
technical discussions that still had to take place and by 3.
discussions that had to take place.on how much is in the 4
body of the guide versus the appendices versus, you know, 5
not. included in there, all of which were going to hold this 6'
document up.
And part of the reason we chose this approach, 7.
taking the appendices out, trial use, was to help keep this 8
thing on track, deliver it on a schedule close to'what we 1
9
.had originally promised because we think that's an important 10 thing to get this thing out for use.
(11 We could go back and revisit the appendices, 12 revisit whether this thing ought to be a final, but it's 13 going the slow things down.
14 MR. APOSTOLAKIS:
The appendices I'll grant you,
()
15 okay.
You can issue a NUREG report that you --
16 MR. HOLAHAN:
But remember, one of the reasons 17 that we were considering trial use as opposed to a final 18 document, there was this thought that perhaps in the. future 19 after the pilots have been done and after there was 20 experience with a quantitative and a qualitative methodology 21 that they might come back as appendices.
Okay.
And I think 22 that becomes much less likely if you make this a final 23
' document that you're going to append pieces to later.
.24 I think if you decide final document now you're 25 closing some offthose options.
And that's, you know, a i
\\-)D
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. judgment matter as-to what -- but we all want to go to the
/' '
2 same place, the question is, what's the best way to get.
~
L 3
.there?
4-MR. APOSTOLAKIS:
Well, you don't seem to close 5
them.
I mean, it's probably that it will be a little more 6
difficult.
Because the Commission explicitly said, come 7
back in a year and tell us what you've learned.
8 MR. HOLAHAN:
Yes.
9 MR. APOSTOLAKIS:
And I don't have the SRM in 10 front of me but, you know, they are open to suggestions for 11 revision. -So clearly they expect that this will happen.
12 By the way, did we have the reviews of the pilots 13 completed in all the other cases with the issued regulatory 14 guide?
()
I 15 MR. BAGCHI:
At least one.
4 16 MR. APOSTOLAKIS:
The inservice testing, we had 17 the pilot?
18 MR. BAGCHI:
Yes, sir.
19 MR. APOSTOLAKIS:
And also --
20-MR. HOLAHAN:
Tech specs, we did.
21 MR. APOSTOLAKIS:
-- tech specs and GQA --
22 MR. RUBIN:
Let's get the facts. Right, they were
- 23
' -- Mark Rubin from the staff, GQA was completed, tech specs 24 were essentially completed, they had been to the Commission 25
'for' review and approval, but hadn't been issued for some
-[ \\
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408 li logistical issues.
.IST was well underway,-maybe 80, 90 cb"'\\ '
2 percent' completed before the guides were issued.
And I if I 3-remember --
'4-MR. HOLAHAN:
In the IST area we had done h BWR 5
owners' group similar application a year earlier.
6
~ MR. APOSTOLAKIS:
And.since you are giving.us 7
percentages, what is your estimate of how complete the 8
review of the Westinghouse document is?- WOG, whatever_the 9
number is.
' 1'O MR. RUBIN:
You mean the WOG?
11 MR. APOSTOLAKIS:
Yeah.
12 MR. RUBIN:
Well, our review just 80 percent 13 MR. APOSTOLAKIS:
Eighty percent?
Well, that 1
14 should be satisfactory.
l
-15 CHAIRMAN SEALE:
What about Surry?
16 MR. APOSTOLAKIS:
And Surry?
17 MR. BAGCHI:
If you would permit me, I will give 18
.you a status of what the industry report is.
Surry, I have 19 a timeline on this.
20 MR.,APOSTOLAKIS:
Do you need the lights on?
21 MR. BAGCHI:
No, sir, this is fine.
'22 Surry had initially planned-to submit-their 23' application in June 1996, the final plan submittal December
'24
.1996, and it came in finally in October 1997 partially and 25L then we' requested augmented submittal which was received in
[
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409 1
D'ecember 1997.
And after.that there is a request in front 2
of the' Commission'for fee waiver.and until that is decided L
.3 Surry is not playing.
So the staff cannot move with the 4
Surry_ review until those kinds of questions are resolved.
5 These are not easy issues.
For example, Vermont 6
Yankee we have sent REI Vermont Yankee was in outage and 7
they had all kinds of resource problems that they were.not 8
able,to respond to our questions, they have not been able to l
9 meet with us.
10 The staff's rightful emphasis has always been the
.11 actual applications, the pilot plans.
That's where we learn 12 most.
And if you really want to know about the WCAP, WCAP 13 came in March 1996.
We issued a huge set of questions, I 14 think at least 200 and as a result of that they turned 15
- around and very quickly provided a revision that was in 16 October 1997.
And now we have some issues with it, but we 17 dearly need to understand how the application of this report 18 to a pilot plan is going to make a difference.
19' We, for example, don't know how to compare the
. 20 number of wells -- the actual number of wells that they were 21 examining before and compare them to what will come out of-22 this and even have a deterministic sense of whether or not
.23
-the' staff agrees with that.
24.
Those kinds of comparisons are not going to be 25 available until we have done.some real-life review on a
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410 1
plant and.therefore the WCAP review process has been
[
2 hampered.
We really do need to apply this to a plant and
(
3 understand how.we should' improve.or change the WCAP 4
requirements or criteria so that the final safety' evaluation
-5 report could be issued.
That's what we were planning.
6 MR. APOSTOLAKIS:
Now, before-I forget, Mr.
7 Dinsmore wanted to say something.
8 MR. DINSMORE:
Steve Dinsmore from the staff.
All-9 I was going to do was remind you that we had-finished the 10
. graded QA-SER before the final issuance of the reg guide or
' 11 the issuance of the final reg guide.
12 MR.'APOSTOLAKIS:
Well, it seems to me that this 13 is an issue that -- I mean, it's not clear cut, but there 14 are advantages and disadvantages and you are looking at it e-.( j 15 from -- well, and justifiably so, of course, from your 16 perspective what burdens it will create to you and so on.
17.
And I'll come back to -- well, to the other point, the 18 downside.
The industry also gets a message, my 19 understanding is that this is the first time the Agency is 20 issuing a regulatory guide for trial use?
21 MR. BAGCHI:
No.
-22 MR. APOSTOLAKIS:
I read somewhere that even the 23 CR, what is it?
' 24 MR. KING:
CRGR.
25 MR. APOSTOLAKIS:
CRGR, they asked you what that-(^
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411 1
meant.
2 MR. HOLAHAN:.Yes, they did.
3 MR. KING: 'Yes, they did.
4 MR. APOSTOLAKIS:
So we are to assume that these 5
guys had never seen it before.
So here we are in the risk 6
informed era and we are innovating now, we are creating new
'7 terms.
The industry gets a message that I'm sorry, you 8
know, the staff again.is not embracing this.
They are doing 9
everything they can to delay it.
Now, I understand, you
(
10' know, what Tom said earlier that in fact you can view it as 11 an' effort on the part of the staff to expedite things and I l
12 appreciate that.
13 And then we have the Commission's advice, if you
-14 can call it that, to the staff that every year they should t
(,)f 15 come back and possibly revise the guides which tells me that 16 that revision perhaps is not as difficult as Gary is 17 implying.
So we have to make a decision based on these 18 conflicting requirements, and I fully appreciate your 1
19 position.
I don't think it's a frivolous position, but have 20 you thought about this downside.and you concluded that still l
- 21 you should go ahead with trial use?
22 MR. KING:
Yeah.
My own view is we wanted to do 23 whatever action would get things moving, both the staff 24 review, the industry submittals, the topical reports,
-25 whatever action would.get:those things moving is very
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412 1
important. 'And at least my_own personal view is issuing
-['T -
this for trial use, and it's current form is the action that
.\\ g 3
~will get, things moving quickest.
Anything else is going to
- 4 result in further delay.
5 MR. APOSTOLAKIS:
I think we're going to come back 6
to this' issue when the industry -- I understand the industry 7
will make a presentation too?
So perhaps, you know, you 8
guys will stick around and we'll talk about it again..
9 MR. KING:
All.right.
Of course.
10
[ Slide shown.]
11' MR. KING:
Okay.
Two things that have happened 12-since the. meeting in early May was we did have the CRGR 13 meeting.
They did endorse issuing these for trial use in 14 their current form.
And, in fact, the package is -- right
()
15 now has been sent to the EDO and I understand it has been 16 signed by him and it's at the Chairman's office for 17 pre-review before it's distributed to the rest of the 18 Agencies.
19 MR. APOSTOLAKIS:
So what is there?
I missed a 20 word?
21 MR. KING:
The reg guide and SRP.
22 MR. APOSTOLAKIS:
Okay.
23 MR. KING: 'The SECI paper has a cover to transmit 24 it up to the Commission.
)
i L
25' MR. APOSTOLAKIS:
Okay.
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l 413 1
[ Slide shown.]
2 MR. KING:
Okay.
' Schedule just to refresh your 3 memory, we've got-the three pilot plants, the current target 4-dates for completing those reviews are December of this 5 year. We've got the two topical reports, the Westinghouse 6 _ quantitative methods and the EPRI_ qualitative method. We're 7 still shooting for December of this year for-the 8. Westinghouse topical. The schedule for the EPRI has 9 slipped. It was scheduled for December of '98, it will slip 10 into '99 depending upon when EPRI responds to the questions '11 that were sent out months ago. So we don't have a specific 12 month yet. We need to see when we get some response from 13 EPRI. 14 And then the code cases -- the three code cases () 15 are under review and we added one additional item which we 16 call a 50.50(a) change or rule change and this would be 17 what's needed to actually get the code cases into the 18 regulations so they can be used. 19 (Slide shown.] 20 MR. KING: The key attributes to the reg guide and 21 SRP it's written to provide an acceptable alternative to the 22' current regulation. It does allow the quantitative or 23 qualitative approach recognizing that much of what's in 24-lthere is general guidance. But-it is -- has been -- a lot 25 of the detail has been taken out so it didn't appear to be ~ g 'I] ANN RIL2Y & ASSOCIATES, LTD. Js / Court Reporters 1250 I Street, N.W., Suite 300 Washington,.D.C. 20005 E (202) 842-0034 l; u-_------_--------_---
414 1 slanted toward the quantitative approach that it's tried to 2 put a balance in that will allow either approach. It does 3 build upon the. general reg guide. We tried to reflect our 4 interactions with industry both the topical reports and the 5 code cases as best we could in the document. It does allow 6 change's to ISI methods, locations and frequencies of 7 inspections. It does allow partial scope submittals, and it 8 does require four class-one piping, some NDE be retained 9 because of the defense in-depth argument. It doesn't mean 10 you can't back off from what's done today, but not eliminate -11 it totally. So those are the major elements of what's in 12 the guide in the SRP. 13 (Slide shown.] 14 MR. KING: As we had mentioned the approach to 15 finalization is issue it for trial use on completion of (j 16 these other reviews come back and finalize the guide. 17 Whether that will involve adding appendices, referencing the I 18 topical reports,. adding more information into the body of 19 the guide itself remains to be seen. 20 We do plan at this point in time to take the 21 existing appendices, clean up any remaining technical 22 concerns, issuing them as a draft NUREG for information so I 23 people will have the benefit of the work that NRC has done 24 in the quantitative area. We would hope to do that sometime 25 this summer. And in doing.that.we will address the / ~ ANN RILEY.& ASSOCIATES, LTD. Court Reporters [ 1250 Il Street, N.W., Suite 300 Washington, D.C. 20005-(202) 842-0034 L I u----
415 1 technical comments we received on those appendices as part (9 2 -of the public. comment process. .%J 3 (Slide shown.] 4 MR. KING: We would envision probably about a year -5 from now we would be ready to finalize the reg guide and SRP 6 assuming the schedules for the industry pilots and so forth 7 remained as shown on the previous vugraph and we would come 8 back to ACRS at that time with the final package and ask for 9 .a letter. But at this time we're asking for a letter.on 10 this trial use approach. 11 With that, do you have any questions? 12 MR. APOSTOLAKIS: I have a couple of comments. I 13 think the document regardless of whether it is issued in 14 final form or for trial use needs-a good editing job and I () 15 hope that will not delay releasing in one form or another by 16 a significant amount of time. 17 We all agree, of course, that we should only be 18 releasing quality documents. And I think it repeats a lot I 19 of stuff from 1.174 some of which may not even apply here or 20 there is not judgment as to whether they apply or not. For 21 example, I don't think you need pages 9 through 12 that give q 22 an overview of 1.174. And then we start again with element 23 one, describe what it is and go on for pages describing that 24 which I had hoped would have taken those elements from 1.174 25 and converted them.to something that is directly applicable } ANN RILEY & ASSOCIATES, LTD. -N/: Court-Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005-(202) 842-0034 n
1 416 1 to ISI. f~ )' 2 So if you'look, for example, at defense in-depth v 3 on page 17, it is a verbatim copy or a facsimile copy of 4 '1.174. It tells us again that we have to have a reasonable 5 balance between prevention of core damage, prevention of 6 containment failure, and consequence mitigation. 7 Now, do we really need to talk about prevention of 8 containment failure when we talk about ISI? I mean, you 9 know, you have to try a little bit to make it applicable to 10 the issue at hand. And similarly, but not to the same 11 extent the section on safety margin which by the way my 12 version ends very abruptly. Obviously it's a result of 13 cutting and pasting, and it doesn't make sense. So it 14 really needs a good editing job. n() 15 But what I find -- well, again, Figure 4.1 where l 16 you are saying data fracture mechanics go or expert 17 illustration process will be used, I don't know what it 18 means to put them all on the same level. Because it seems 19 to me expert process -- illustration processes will have to 20 be used no matter what. Perhaps you mean a formal, big-deal 21 kind of thing. Because you can't use really these codes and l 22 data without some judgment, I mean, some expert opinions 23 -interpreting the data and so on. 24-So if I really wanted to scrutinize this, the 25 question is whether they should all be on the same level or l [ ) ANN RILEY & ASSOCIATES, LTD. A/' Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 = _ _ _
417 1 the' expert opinion-elicitation process should be supporting ~ the other two and so on. }- 2 3 'But the thing that -- the part that I really find-p l '4 as needing more work is on page 24, 4.2.3, demonstrate 5 ~ . change in risk resulting from change in ISI program which 6 essentially says the change has to be evaluated and compared 7 with the guidelines presented in RG 1.174. Well, it seem to 8 me you could have said much more here. That, you know, risk 9 is expected perhaps to be reduced most of the time. Isn't 10 that something that we keep hearing in this room as a result 11 of risk-informed ISI? In which case, of course, those 12 figures would not apply; right? 13 And why copy the whole thing on defense in-depth 14 and be so economical here and frugal in your discussion of p) .(, 15 what the decision will entail? I mean some statements 16 showing that, you know, we really know -- I mean, this says 17 the change may be a risk increase, a risk decrease, or risk 18 neutrality. I mean, in principle, that's a correct 19-statement. But I'm not sure it's an appropriate statement 20 for this given what we are hearing from you in the industry. 21 Most likely it's going to be a reduction; right? 22 Plus the infamous unquantified benefits that we 23 keep making'a' big deal out of in the 1.174, well, here we
- 24 have benefits.
I mean we have identified them, reduced 25 exposure for example, or' radiation. So I would expect to .h~ ANN RILEY &' ASSOCIATES,.LTD. kl Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 .(202)'842-0034 _--_-__- J
418 1-see more here and less in defense in-depth. Because, again, /TL 2 ~ he message is indirect, but it's there. And the message I t D 3 got', and I'm sure it's not something you want to send.out is 4 that you're really reluctant to do this, you really don't 5 want-to do it now. Of course, it's not true. But if I go 6 strictly by the document, I think that's a reasonable
- 7 '
conclusion to draw. And I think it should be changed. I 8 'mean, all of this -- you don't give any on the history'of 9 the thing that this is based on Section 11 of ASME which is 10 20' years old and experience has not -- has taught us 11 otherwise and so on. It's as if it's just another change, 12 ve have 1.174, we'll evaluate it, thank you very much. And 13 I don't see that as being the proper message that this 14 report should be sending out because you have told us and ) 15 the industry has told us, this is a good thing to do. 16 MR. HOLAHAN: I think I'm becoming less optimistic 17 that you're editorial changes won't slow things down. 18 MR. APOSTOLAKIS: This is nothing. This is a 19 change that will not take more than half a day for an 20 exhibited person to write and another three hours for 21 experienced persons to review. '22 MR. HOLAHAN: Would the committee like to see it 23 again afterwards? 24 [No response.] 25 MR. APOSTOLAKIS: Would the committee like? I [} ANN RILEY & ASSOCIATES, LTD. ( /- Court Reporters 1250 I' Street, N.W., Suite 300 Washington, D.C. 20005 L(202) 842-0034 v i Lwa__.
i-419 1 would, but -- / 2. CHAIRMAN SEALE: Pardon? ,.V L 3 MR. APOSTOLAKIS: Would the committee like to see l 4 the. document -5 ' CHAIRMAN SEALE:. What was your answer? 6-MR. APOSTOLAKIS: That I personally would. And 7' I'm asking whether the committee would like.to see it? 8 CHAIRMAN SEALE: I would trust your review, 9 ' George. 10-MR. APOSTOLAKIS: Okay. That should expedite 11 things. 12 MR, SHACK: Well, I think the committee has to 13 -decide whether it needs editing or not. We haven't done 14 that. f~ i 15 MR. POWERS: George has. 16 [ Laughter.] 17 MR. APOSTOLAKIS: .That's also true. . Laughter.] j [ 18 19 MR. APOSTOLAKIS: And it's going to be put in your 20 place. 21 MR. HOLAHAN: I'm waiting for him to volunteer to 22 do it. 23 MR. APOSTOLAKIS: No, but really, I mean, it does 24 not reflect what we have heard here. That's what I'm ~ i 25 .saying. Now,'whether you,want to. write a whole essay on it, i ( . ANN RILEY & ASSOCIATES, LTD. /s - Court Reporters 1 -1250 I Street, N.W., Suite 300 I , Washington,.-D.C.-20005 ,(202) 842-0034 . _- - _ - ___ _ __ - _____ a
'420 l 1 or' just add 'a - couple of paragraphs, you know, I will leave l .2' that up to you. I'm not going to tell you how to. But I {w. L 3 think I believe it would be' helpful to you to know how I L 4 felt after.I read it. 5 MR. KING': I think it's helpful. I think the 6 document originally when you add the appendices was written ~7 to'be a' stand-alone document and as we've trimmed things out 8 of.it, it tends to then become unbalanced and a lot of 9 repetition. I agree it could probably be-done better. And '10 it probably wouldn't take a long time. -11 MR. APOSTOLAKIS: Why long? 12 MR. KING: I say it would not take a long time. I 13 MR. APOSTOLAKIS: Oh, it would not. Okay. Okay. 14 Assuming, of course, that the committee takes action. But (f-15 especially 4.2.3 I think needs some work. You really have 16 to show that you are aware of what is happening and the 17 impact that this will.have and just to say go use those 18 figures. It's not good enough. That's why we have general 19 guidance and then we have issue-specific regulation guides 20 trying to adopt that general guidance to this. 21 And with that -- yeah, that's it. 22 Any comments from members of the committee? 23-MR. BARTON: I agree with some of your earlier i .24-commente. I went through here, the repetition of 1.174, the 25 sectica'that just drops in the middle of a sentence, it does [)L ANN RILEY & ASSOCIATES, LTD. 1% Court Reporters .1250 I' Street, N.W., Suite 300 i Washington, D.C. 20005 '(202) 842-0034-
-421 1- 'need cleaning up, [) 21 MR. APOSTOLAKIS: Okay. .v 3. MR; SHACK: Well, we could have made these same 4 comments about every one of these reg guides. You know,. 5 they all kind of' repeat 1.174. You know, that was sort of a 6 ' style they adopted and, you know, just for parallel 7 construction if nothing else, you know, why should this one 8 look'different? 9 MR. APOSTOLAKIS: Well, I disagree with that for i10 two reasons. I think this is different. I don't think the ill repetitiveness was as pronounced in the other ones.
- And, 12 second, I don't think that in the other --
13 MR. SHACK: Look at defense in-depth. 14 MR. APOSTOLAKIS: Yeah, but when I talk about p). . quality assurance, I do have to worry about all these (, 15 16 bullets. I don't know that I have to worry about all of 17 these bullets in this case of ISI. That's a difference. 18 And the other one is -- now, I lost my train of thought. q 19 MR. BARTON. Tech specs, IST? 20 MR. APOSTOLAKIS: Yeah. 21 CHAIRMAN SEALE: IST? 22 MR. APOSTOLAKIS: Oh, yeah. Did we hear from the l
- 23 industry and the staff in the other cases'that, yes, this is 1
24-a goodfthing to do and that it will lead to risk induction, i 25- ,Which one was it? There was one and that fact was mentioned l [' ') . ANN RILEY & ASSOCIATES, LTD. /. Court Reporters
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422 1. in the regulatory' guide, I still remember it, unlike'this ~ -/O 2= one. ~. 5 3. So'I'm not asking for a major change, I'm asking 4 for somebody to take it and go to a' place all by himself or 5 herself and go over it and say, yeah, this is not necessary, 6 The obvious things, not to start the research project to see 7 how this affects what, but the obvious things,'like stopping 8 a sentence in the middle. 9 (Laughter.] 10 MR.'APOSTOLAKIS: So, any other comments? '11-(:No response.] 12 MR. APOSTOLAKIS: Shall we move on then to the 13 presentation by the industry? Okay. Thank you guys. 14 (Pause.] f( 15 MR. APOSTOLAKIS: Gentlemen. 16 (Slide shown.] 17 MR. BRADLEY: Are we ready? 18 MR. APOSTOLAKIS: Yes, I'm sorry. Go ahead. r '19 MR. BRADLEY: Good afternoon. We're here to 20 provide -- 21 THE COURT REPORTER: Your name, please? 22' MR. BRADLEY: I'm going to -- okay. My name is 23 -Biff Bradley.of NEI and seated at the table with me are Ken 24 Balkey from Westinghouse, Jeff Mitman from EPRI, Dave 251 Garchow from PSE&G.and-Karl Fleming from ERIN. [ ANN RILEY & ASSOCIATES, LTD. \\_- Court Reporters. 1250 I' Street, N.W.,ESuite 300 g, ' Washington, D.C. 20005 (202).842-0034~
i 423
- 1J I want to-discuss the industry views on the
( 2 subject of risk-informed inservice inspection. We do 3 appreciate.this opportunity and I think for once we may have 4 more bodies here than the NRC staff which is a rare 5 occasion. 6 We do want to also mention that a large number of-7 the prime industry people involved in development and 8 application of this approach are here in the audience today 9 -- and as a show of support and encouragement for the 10 importance of this issue. 11 [ Slide shown.) 12 MR. BRADLEY: I think a lot of these comments have 13 already been stated and eloquently so by some of the ACRS 14 members, but we would like to reiterate that risk-informed O(,) 15 ISI not only provides a safety enhancement for plant 16 operation but provides a significant worker exposure 17 reduction. 18 There is a tremendous amount of work that's been 19 done to lead us up to this point. And I think George 20 alluded to that. As you know, ASME had a multi-year effort 21 to review a tremendous amount of operating experience 22 inspection data and to develop and approve three code cases 23 for the use of RI-ISI. And that work is on top of the 24 significant and extensive work that's been accomplished by =25 the-industry through WOG and EPRI to develop methodologies -( / ')I; ANN RILEY & ASSOCIATES, LTD. x-Court Reporters 1250.I Street, N.W., Suite.300 Washington, D.C. 20005 .(202) 842-0034 g
424 ' lL ' 'for plant l application. "[l1 -2 (Slide shown.) Q[ '3 MR. BRADLEY: 'As you know for risk-informed ISI 4-there have been multiple' methodologies that have been 5; developed. And we believe that this has been an enhancement 6 to=the overall process that the development of two 7 methodologies and the potential that there may be.others as 8 well overall provides the opportunity-to cross-review and 9 technically improve both or any methodologies that may 10-apply. We believe that the methods that have been developed , 11 meet the general principals of reg guide 1.174 and continue-12 to believe'that this has been an aspect of this program that 13 has led ultimately to.a bettqr result. 14 [ Slide shown.) f (/~'s L ) 15' MR. BRADLEY: With regard to the regulatory 16 guidance, obviously we haven't had the opportunity to review ~ 17-the reg guide that's been before the Commission as we 18 understand or to'the EDO. Obviously we did have the 19: . opportunity to look at the earlier drafts of the guidance 20 and.as you know there were significant comments. 1 21 I recognize NRC is faced with a little bit of a ] .22 dilemma on:how'to most' expeditiously move this process 23-forward and I guess there are upsides and downsides with 24. ' regard'to whether the-guidance should be issued as final or 25 for. trial use. 4 -1 ANN RILEY &' ASSOCIATES,.LTD. -E/ Court Reporters 1250 I Street,RN.W., Suite 300 Washington,-D.C. 20005 (202) 842-0034 L ku_ man __i_ a_: _.__ _ I
425 1 It's our perspective, and we have discussed this- . f'} 2 extensively with our group and those utilities that have to N_- 3 make the decision to proceed to put the resources forward to 4 see to these applications that issuance of the guidance is 5 final would-certainly be the most preferred approach and 6 would provide encouragement and minimize any regulatory 7 . uncertainty.that might exist with regard to application of 8 these methods. 9 With regard to removal of the appendices, I know 11 0 our' comments have previously indicated that we did believe 11 the level of detail contained therein was out of context 12 with the other reg guides and we support the concept of 13 removing the detailed information from the appendices. 14 We believe the most appropriate way to incorporate .( f 15 the detailed technical information is by referencing the 16 topical reports that will be approved by NRC. 17 MR. APOSTOLAKIS: But wait a minute now. 18 MR. BRADLEY: Yes. 19 MR. APOSTOLAKIS: Are you saying they should delay 20 the release of the guide until the topical reports are 21 approved? 22 MR. BRADLEY: No. We believe that the guidance 23 . needs to be issued as final on the curre nt schedule and that 24 really.this one, in my mind is not significantly different .25~ 'from the other risk-informed applications in that there has J\\]_/ r -ANN RILEY & ASSOCIATES, LTD. Court Reporters 1250'I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034' u--
426 -1 been, if anything, I think more work accomplished already on
- T 2
ISI than on the other applications, tech specs, IST and QA. -(Y 3 And that there is enough work done that the foundation -- 4 the regulatory. framework that that guidance establishes, I 5 think should be capable of being articulated now. 6 Clearly there are technical details that can be 7 captured through the reviews of the pilots and the topicals. 8 And the approach we would like to see is the guide issue now 9 and proceeding along the schedule that the staff has 10 indicated to have the topicals as well as the pilot 11 applications approved by the end of this year. 12-MR. APOSTOLAKIS: So, if the guide is released 13 now, independently of whether it is for trial use or final, 14 it cannot cite the Westinghouse reports? () 15 MR. BRADLEY: It can't explicitly cite them. And 16 I guess I don't know that that's really necessary. I think 17 if the topical themselves are approved as -- 18 MR. APOSTOLAKIS: So that would evaluate them? 19 MR. BRADLEY: Right. 20 MR. APOSTOLAKIS: Fine. Now, again, why does the 21 industry support the removal of the detailed appendices? 22 They are too detailed or they're wrong, or what? 23 MR. BRADLEY: It's our belief that the -- there 24 are,,as I mentioned, multiple methods have been developed. 25 There are a lot of ways these methods can be used. Some ANN RILEY & ASSOCIATES, LTD. C Court Reporters 1 1250'I Street, N.W., Suite 300 Washington,'D.C. 20005 (202) 842-0034
427 1 utilities may desire to use methods that may meet the ) 2 regulatory guidance, but nay not be exactly the methods that 3 have been developed that would be captured in detail as in 4 the draft appendix. We just wanted to maintain the 5 flexibility to use methods as each utility would best see 6 fit. And, again, if you look at the other reg guides they 7 are just -- that level of detail does not exist in the other 8 topical reg guides. 9 [ Slide shown.] 10 MR. APOSTOLAKIS: Would approval of the 11 Westinghouse reports, though, do all these terrible things 12 that you just mentioned; that they will limit the number of 13 methods that people can use or that's a separate issue? 14 MR. BRADLEY: No, I don't think it would. And the /N (,) 15 Westinghouse people or the EPRI people can speak to that. 16 But I believe -- and it is a complicated process given that 17 we have three code cases, two methodologies, two topicals, 18 three pilots, and a reg guide and I'm sure there are going l 19 to be different opinions on the best way to intermesh all i 20 these things and achieve a timely result. However, our view 21 is that there is a schedule that's been developed by the 22 staff and it was just presented wherein the WOG topical and 23 the three existing pilots would be approved by the end of 24 this year and the EPRI topical would be approved in 1999. 25 And just in terms of keeping everything moving in the .(m) ANN RILEY & ASSOCIATES, LTD. '/ Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 l (202) 842-0034
E 428 l 1 industry,: 'I guess our. belief is getting the reg guide issued 2 . final'is an important_ step. l .3-There was a. lot of -- there was basically a pause 4 in'the progress of risk-informed while we've been' developing 5 these reg. guides over the last several years in the '6 expectation that things would regain momentum once.that 17 ' Rfinal' guidance is put out. So.this is a case where in order 8 ito gain that momentum'I.think it's important that the guide 9: be final. L10 RMR. APOSTOLAKIS: Has EPRI-already submitted a 11 report'to the NRC reque' sting approval? 12 MR. MITMAN: There is a report --- '13 MR. APOSTOLAKIS: Your name, please?' 14 MR. MITMAN: My name is Jeff Mitman. I'm with (O ' j 15 EPRI. There is a report that was submitted to the NRC in -- ~ 16 I want.to say -- July of 1996, and the staff has supplied 17 . questions back to us last you ear, and we're in the process 18 of finalizing those comments. Those comments -- 19 MR. APOSTOLAKIS: But it's not only the staff 20 that's slow? 21 MR. MITMAN: We've been slow on that also, yes. 2:2 MR. APOSTOLAKIS: In real terms now, Biff, what we 23 do everyday and so on, would it really make any difference '24' to you whether it's' trial use or final? I mean, the staff 25-is welcoming new pilots. They promise-to review the }Ex-<3-ANN-RILEY & ASSOCIATES,-LTD. Court Reporters 1250 I Street,=N.W.,. Suite'300-Washington,~D.C. '20005 '(202)-842-0034 i mw_ ._-.~l-
429 1 existing' pilot applications. Are we really talking about (Q\\ '2 perceptions-here? 3 MR. BRADLEY: If we wanted to rate things :' 1 terms u 4 of importance for.the industry to proceed absolutely 5 paramount, most important above all else is to approve the 6 pilot applications and the topicals. If it's a question of 7 whether, you know, whether that -- if the issuance of the 8 reg guide is for trial.use has a potential to affect that or 9 delay that, then I think we might, you know, reconsider and 10 I think NRC articulated that they were trying to move tnis 11 along as expeditiously as possible. And in their mind, .12 given their internal process, they may view that as the 13 case. But I wanted -- and I think this is a good lead in ' nto the slide I have here. i 14 () 15 (Slide shown.) 16 MR. BRADLEY: You know, as in any of the I 17 risk-informed applications, the one thing that matters is 18 seeing the application approved. And so I guess that's, you 19 know, the point I'd like to make, if we can meet those 20 schedules, if the staff can meet the schedules, and by the 21 end of this year that would provide a huge impetus to move 22 us forward, whether the guide was trial or final. 23 MR. APOSTOLAKIS: And so -- oh, I'm sorry. 24 MR. BRADLEY: If'the guide is issued trial and we 25 "we" being'the industry as well as NRC -- fail to deliver l
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430 11 on the schedule;by the end of this year with the topicals, I /~'i 2 think that would be viewed as a signal of -- or a lack ofE b 3 . encouragement to proceed. And we recognize that we as 4 industry have a part to play in making-this happen. ~There-5- 'areisome administrative issues with regard to review fees 6 'that have, unfortunately, slowed the process somewhat, and i7 that's really, in my mind, unfortunate given the nature of -8 this change. However, we are going to make every effort to -9 resolveEthose expeditiously and to work as an industry to /10- ~ ensure that-we do everything we can to help NRC meet'this >cil-schedule. 12 One of the things that I think is not real clear 13 in the schedules is exactly what is expected at the and of
- 14 this year.
" Complete staff evaluation" I think is the way i) 15 it was articulated on the slides. And exactly where that is 16 in the process of, you know, actually getting the approval 17 at the plant. I think it would be good to see sched' ales ~18 that reflect -- and I hope that's what this is reflecting, 19 that the plant approval would be issued by that date. But 20- .it would be good for the schedule, if not, to indict..te when 21 the actual change would be approved -- 22 MR. APOSTOLAKIS: Well, the staff cannot very well 23: 'put staff approval by December of '98. I mean, because they
- 24.
don't-know they will approve it; right? ~ as a target. ,25 'MR. BRADLEY: Yeah,.I mean, ANN RILEY & ASSOCIATES, LTD. f-k,/ JCourt Reporters 1250 I. Street, N.W., Suite 300 Washington, D.C. 20005 '(202) 842-0034 m: - - _ = _ _
431 l l 1 .MR. APOSTOLAKIS: The decision. 2 MR. BRADLEY: Right. 3 MR. APOSTOLAKIS: So what does " evaluation" mean? 4 MR. BAGCHI: Just as it says,-this is Gotam Bagchi L 5 of the staff, NRR. It means that the staff safety 6 evaluation recommending changes or whatever to the program 7 would be passed on to the Commission. The Commission has 8 asked for this and the Commission decision may involve 9 additional changes. That's a date that the staff cannot 10 predict, but it should be within weeks, not months after the 11 staff approval. 12 MR. BRADLEY: So this would be the date at which 13 the draft SER would be forwarded to the Commission or -- 14 MR. BAGCHI: Final safety evaluation of the staff () 15 moving forward to the Commission for comments or further 16 changes. 17 MR. APOSTOLAKIS: Assuming, of course, that the 18 issue with the fees is resolved in a reasonable amount of 19 time; right? 20 MR. BAGCHI: Well, over that too, I think I can 21 make an observation. I have seen some internal documents 22 'which indicate to me that it should be a matter of days, 23 perhaps a couple of weeks before this is resolved. But I 24 wouldn't want to make a commitment on the record for 25
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432 1 [ Laughter.] h 2 MR. APOSTOLAKIS: You just did. V .3 MR' BAGCHI:- No, sir. 4 MR. APOSTOLAKIS: Let's make it very clear. You 5 would like it to be released in final form, but if it is 6 released for trial.use and that expedites things you're 7 willing to live with it because-what is of paramount 8 importance for you is to have the safety evaluation report 9 as promised? 10 MR. BRADLEY: Right. For the topicals as well as .11 the' pilot plants. 12 MR. APOSTOLAKIS: The topicals are promised also 13 for '98, yeah. 14 MR. BRADLEY: Right. And I recognize that once. / 15 you put it before the Commission it's somewhat out of your 16 hands in terms of the schedule. And I think that's helped 17 us to understand what you intend by complete staff 18 evaluation. 19 MR. APOSTOLAKIS: Okay. 20 MR. BRADLEY: Another aspect I wanted to touch on l 21 is the regulatory process. The regulatory process for this l -22 ISI is a little bit-involved, and we have a need to p 23 understand how that process would be expected to work, I 24 mean, given the potential endorsement of code cases in 1 25 50.55a.we have reg guide 1.147 which is an NRC vehicle to t El,~.\\ ANN RILEY & ASSOCIATES, LTD. O-- Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202). 842-0034
433 1_ approve code cases. We have a reg guide.l.178 which-is .[ } 2' goingfto be the ISI reg guide, and it's -- as well as the 3 topical reports'that will be approved and have SERs issued. 4 And what we would obviously like to avoid is coming -- you 5 know,. getting the technical issued understood and resolved 6 'and then having late issues arise with respect to process. .-7 I think it's very important that the process be laid out and 8 understood by NRC and the industry up front, you know, 9 concurrent with developing the technical reports. 10 And I understand NRC is looking at preparing some c11 communications that will address their plans as well as the 12 process and we certainly encourage that. And we've seen on 13' some of the other risk-informed areas that process issues 14 can arise late in the game, you know, and in terms of -- I () 15 think_ tech-specs have been some examples of that where it 16 was -- you know, the SCR went all the way up to the 17 Commission and then there were issues that still continued 18 to arise. And we really want to try to head those off as 19 -part of the effort rather than at the end of it. 20 MR. GARCHOW: Hey, Biff? 21 MR. BRADLEY: Yes. 22 MR.- GARCHOW: This is Dave Garchow. From an 23 industry -- and.I'm here representing the Westinghouse _24 Owners Group: Executive Committee. I think this regulatory 25 process is morel key than we give it credence to. And we've -[ ANN RILEY & ASSOCIATES, LTD. d,-
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434 1 had some successes as an industry and in NRC where we've () 2 defined that up front. An example that comes to mind is 3 Option B of Appendix J. It was very clear once we got 4 through the technical issues the road map on a 5 utility-by-utility basis whether they made the choice to use 6 the option or not, and then how to proceed from there to get 7-to.that point. 8 So I think that we need to be real mindful that 9 once we get these complex technical issues resolved that 10 there's an easy pathway on a licensee-by-licensee basis to 11 1 harvest the results of the safety gain and the improvements 12 in dose that I think we all believe we're going to get. 13 MR. APOSTOLAKIS: Okay. Thank you. 14 (Slide shown.] () 15 MR. BRADLEY: Okay. One final slide, this is just 16 our conclusion. And just reiterate that, again, this is a 17 very important issue for industry. It's a unique 18 opportunity, we believe, to both enhance plant safety as 19 well as reduce radiation exposures. And, again, you know, 20 there is a committee within NEI that can serve as an 21 industry coordination point for these activities. We intend 22 to be active and to ensure that we do everything we can to 23 make NRC's job as easy as possible in meeting the schedules 24-they've laid out which we recognize are ambitious. 25 And that concludes my' comments. l b ANN RILEY & ASSOCIATES, LTD. 35-Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 L (202) 842-0034 )
r 435 1 MR. APOSTOLAKIS: Yeah, do you-have any comments? -(J~} 2 From anybody else? 3 -[No response.] 4-MR. APOSTOLAKIS: So now you are willing to live 5 - with December '98 approval? Because the last time we met i 6 you wanted it by next Monday. i 7 MR. BRADLEY: Well, we'll take it by next Monday, 8 but,'obviously, yeah, I think, you know, given what we have L 9 in front of us, especially the process considerations. You 10 know that's, I think, a doable date, but an ambitious date. But we. definitely would like to see things happen by that 11 12-data. 13 MR. GARCHOW: Some of the regulatory uncertainty 14 is actually -- we talked about the delays, some of the .r i 15 utilities are -- when we have, and I'll use the EPRI N. 16 example, but it wasn't a utility, we get 200 questions, 17 there's a cost in responding to them, so there's an analysis 18 done on probably a case-by-case basis as, is this something 19 that's ever going to result in some fruit and that we would 20 be able to harvest or are we-just kidding ourselves. So I 21-think a piece of this regulatory certainly puzzle, even as 22 we're in this part of the. process, is around, is this going 23 to end in a result? And when and where does somebody make 24 the decision that, well, maybe it's not going to end up in a 25 result. I [ ;; ANN'RILEY & ASSOCIATES, LTD. \\~/ Court Reporters 1250 I Street, N.W., Suite'300 Washington,.D.C. 20005 (202) 842-0034-w = _ _
436 l' .MR.;APOSTOLAKIS: But I'm a little surprised that () 2 you're:-saying that because-I look at what the staff has done 3 the last;maybe year -- let's say year. And what'have they 4: done? Well, they have approved the GQA program from South 5 Texas. -TheyLhave issued draft regulatory guides, they have-6- accepted justLabout all of the industry's comments; 7 especially that-big one about in Region III and the thing. 8 -That's really a big.one. -And they just accepted it. So it. 9 seems to me that they have shown a willingness to proceed 10 this way. .The' fact that the Commission, of course,. wants 11 risk-informed regulation hac helped tremendously. 12 'So I think the uncertainty is not really about 13-whether we're going-to get there, the uncertainty :Us when. 14-As the Chairman has said many times, "the train ~15 has already left the station" so what is it about Tucson, 16 Bob, that she said? The train is going to Tucson, or -17 something. 18 CHAIRMAN SEALE: Bearing down on Tucson. 19 MR. GARCHOW: I wouldn't disagree with that -- 20-MR. APOSTOLAKIS: Yeah, I mean, the uncertainty is 21-in -a different area. 22 MR. GARCHOW: Right. It's hard -- the fruit. <23 CHAIRMAN SEALE: I have a question. 24 MR. APOSTOLAKIS: Yeah. 256
- CHAIRMAN SEALE:
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437 1 going to get there? (j 2 MR. APOSTOLAKIS: Well, what's on it, I think more 3-or less you know. Come on -- 4 CHAIRMAN SEALE: Well, I think a part of your 5 problem though, is, each of these plants has its own 6 particular demographics, if you will, in the sense of how 7 much longer its license lasts, you have questions having to 8 do with the viability in each individual case of life 9 extension and what that might be. You have concerns about 10 how long it will take you to recover the investment that you 11-make in each one of these risk-informed modifications in 12 your regulatory environment and so on. And clearly the 13 longer you' wait the shorter the tail gets on each one of 14 those particular sets of constraints. So it's very clear, gg (,) 15 you have another set of parameters beyond the ones we see. 16 MR. KING: That was more to my point, Dr. Seale. 17 Okay. 18 MR. APOSTOLAKIS: So any other comments from the 19 committee? 20 [No response.] 21 CHAIRMAN SEALE: Does anyone from the staff have 22 anything else to add after hearing this? 23 [No response.] 24 MR. APOSTOLAKIS: Industry, public?- '25 [No response.] .[m'). ANN RILEY & ASSOCIATES, LTD. k/ Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 1
4 438 1-MR. APOSTOLAKIS: Thank you very much. We really (~' .v) appreciate you coming. '2 3 CHAIRMAN SEALE: Appreciate it very much. 4' MR. APOSTOLAKIS: Back to you, Mr. Chairman, and 5 15 minutes early. 6 CHAIRMAN SEALE: I see that. Do you want to ask 7 any questions of the committee before -- while we're still 8-here, or are you going to have us a letter? 9 MR. APOSTOLAKIS: There is a draft letter that I 10 think should be circulated and it will be easy to edit it if 11 the committee has opinions other than those of the authors. 12 It will not be a difficult letter to write. 13 CHAIRMAN SEALE: Okay. Well, why don't we see if we're ready to do future activities here? Are we? 14 O 15 MR. APOSTOLAKIS: No, I -- there are other things j. l 16 we have to do. 17 CHAIRMAN SEALE: Well, that's the next thing on 18 the agenda. 19 MR. APOSTOLAKIS: I mean, we need private time for 20 reviewing stuff. I mean -- 21 CHAIRMAN SEALE: I know, but what I was going to 12 2 do is give you -- get this thing out of the way and you'll
- 23 have more time.
24-MR. APOSTOLAKIS: Okay. Before we start what? 1!5 MR. BARTON: Future activities. .-D 'hm- ' ANN RILEY & ASSOCIATES, LTD. Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
439 1 MR. APOSTOLAKIS: Oh, I see. 2 CHAIRMAN SEALE: We're through with our formal -- 3 are we going to need the reporter anymore today? 4 MR. LARKINS: I don't believe so. 5 CHAIRMAN SEALE: Okay. Well, we can go off the 6 record. 7 [Whereupon, at 2:30 p.m., the meeting.was 8 recessed, to reconvene at 8:30 a.m., Friday, June 5, 1998.] 9 10 11 l 12 13 14 15 a 16 17 18 19 20 21 22 23 24 25'
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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: NAME OF PROCEEDING: 453RD ADVISORY COMMITTEE ON REACTOR SAFEGUARDS DOCKET NUMBER: PLACE OF PROCEEDING: Rockville, MD l were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear j Regulatory Commission taken by me and thereafter reduced to - typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings. LC C u w. Mike Paulus/Cindy Tho, mas I 1 Official Reporter Ann Riley & Associates, Ltd. t}}