ML20210Q778

Transcript of 990810 ACRS Meeting on Severe Accident Mgt in Rockville,Md.Pp 284-370.With Viewgraphs

ML20210Q778
Person / Time
Issue date:	08/10/1999
From:	Advisory Committee on Reactor Safeguards
To:
References
ACRS-T-3086, ASB-300-883, NUDOCS 9908160117
Download: ML20210Q778 (114)

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013 N A_ ACRsT-sore OFFICIAL TRANSCRIPT OF PROCEEDINGS g

NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS

Title:

MEETING: SEVERE ACCIDENT MANAGEMENT TRO4

'ACRS' R E T;'RN O R I G I N A' TO BJWHITE M/S T-2E2E 4,s. m THANKS!

O Docket No.:

Work Order No.:

ASB-300-883

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LOCATION:

Rockville,MD DATE:

Tuesday, August 10,1999 PAGES:284 - 370 0908160117 990810 q

PDR ACRS j

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DISCLAIMER UNITED STATES NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS AUGUST 10, 1999 i

The contents of this transcript of the proceeding of the United States Nuclear Regulatory Commission Advisory A.

Committee on Reactor Safeguards, taken on August 10, 1999, as reported herein, is a record of the discussions recorded I

at the meeting held on the above date.

This transcript had not been reviewed, corrected

'and edited and it may contain inaccuracies.

lo

\\N 1

284 1

UNITED STATES OF AMERICA 2-NUCLEAR REGULATORY COMMISSION 3

ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4

5 6

MEETING:

SEVERE ACCIDENT. MANAGEMENT 7

8 9-U.S. Nuclear Regulatory Commission 10 Room 2B3 11 White Flint Building 2 12 11545 Rockville Pike 13-Rockville, Maryland 14

/

15 Tuesday, August 10, 1999 16 17 The Subcommittee met, pursuant to notice, at 8:30 18 a.m.

19 20 MEMBERS PRESENT:

21 22 THOMAS S.

KRESS, Chairman, ACRS 23 DANA A.

POWERS, Member, ACRS 24 ROBERT L.

SEALE, Member, ACRS 25 O

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PROCEEDINGS

()-

2

[8:30 a.m.)

3 DR. KRESS:

Let's come to order, please.

4 This is the second day of our subcommittee meeting 5

on Severe Accident Management.

Today we only have one thing 6

on the schedule, and that is to review the proposed final 7

version of the source term rule and the draft versions of 8

the associated Reg Guide, DG-1081 and the Standard Review 9

Plan, so I don't have any comments to make before we start.

10 DR. POWERS:

Did we get our written comment that 11 we were promised-yesterday?

12 MR. BOEHNERT:

No.

It never came in.

13 DR. KRESS:

It hasn't come in yet, no.

It has 14 nothing to do with today's work, I don't think anyway.

With

()

15 that I will turn it over to -

Rich, you or Jay or --

16 MR. BARRETT:

Actually, Steve Lavie is going to 17 start out by describing the rule and the proposed Reg Guide, 18 and we will move into a discussion later on of the pilots 19 with Jay Lee.

20 MR. LAVIE:

Good morning.

I am Steve Lavie with 21 Probabilistic Safety Assessment Branch in the Division of 22 System Safety Assessments in the Office of Nuclear Reactor i

23 Regulation.

24 The effort I am going to be presenting this 25 morning started out several years ago.

We.have had the O

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opportunity to brief this subcommittee and the full ACRS on 2

.several occasions, the most recent being November, 1998.

3 This morning I am going to discuss the status of 4-the effort.

The Staff lis expecting the ACRS to notify the 5

Commission of its position on publishing the final rule for 6

use and the draft guide for public' comment-.

7 In my briefing this morning'I intend to discuss 8'

the status of the final rule and any changes made to the 9

proposed rule language.

I will then briefly update you on 10 some of the changes that been made in this document as a 11 result of office concurrence comments.

As you pointed out 12 in,the transmittal letter, your view and the office 13 concurrence has been working in parallel.

14 I will then discuss the draft Guide.

First I am 15 going to discuss the objectives of the Staff in developing 16-the Guide and then a briaf discussion of the more 17 significant policy decisions or highlights.

I am not going 18 to try to go through it word for word obviously.

You have 19 had the opportunity to read it and I'm sure you will read it 20

.some'more but I am going to hit some of the high points.

21 Now in the final rule our objective was to enable 22 the use of the alternative source term by operating 23 reactors.

When the source term was put together it was 24 primarily put together for future reactors.

There was an 25' interest in using it for operating reactors.

We did a I

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rulemaking plan to find out how we could get there and the

()

2 final -- this proposed rule and now this final rule was an 3

outcome of that analysis process.

l

.4 In keeping with the direction that was provided to 5

us by.the Commission the-Total Effective Dose Equivalent 6

Criteria were' incorporated-in the final rule.

Now the final 7

rule is voluntary and is applied only to those facilities 8

who desire to use an alternative source term.

9 We included in the rule some conforming changes 10 for the Part 100 rule issued in December, 1996.

These are 11 needed for future licensees.

These are a few areas where 12 references to TID 1484 were left rather firm and it was the i

13 result of exemptions in the Westinghouse design 14 certification process.

We now have eliminated those 15 problems.

16 The proposed rule was published in March of 1999.

17 The NRC received seven public comment letters, none of which 18 had an objection to publishing the rule.

There were several i

19 suggestions, only one of which resulted in a change to the 20 language of the rule.

There were some suggestions for 21 clarifications in the statement of considerations which we 22 did include.

23 DR, POWERS:

Do you have any idea why you got 24 little comment from the public sector on this proposed 25 change?

l I

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n 288 1-MR. LAVIE:

I-really can't say.

Somehow we didn't

()

2 get very high on the radar.acreen.

I think what largely is l

3

.a possibility is the fact that our rule doesn't allow a 4

licensee to do anything without coming into another process.

5 He still has to come into the license amendment process and 6

there is a'public notice at that time in the Federal 7

Register that that is the amendment, so that'the public does l

8 have another opportunity to challenge us.

9 The only public comment that came close to a i

i 10 concern, which I think you are implying, was the State of I

11 West Virginia -- excuse me, the State of New Jersey, which 12 pointed out to us they agreed with our position on emergency 13 planning.

I believe we shorted an awful lot of discontent 14 down by discounting emergency planning straight out.

()

15 DR. POWERS:

You could have said that the research l

l 16 backing this up was so outstanding that 17 MR. LAVIE:

True, but I don't think the public 18 necessarily understands all that research.

f i

19 DR. POWERS:

I would have said it though.

l 20 MR. LAVIE:

I would also like to think that it was l

21 so well written nobody -- it just dazzled everybody.

22 DR. POWERS:

That's right -- so clear --

l 23 MR. LAVIE:

So clear --

l 24

[ Laughter.)

25 MR. LAVIE:

Two of the public comments we received O

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'1' suggested changes in the definition of the source term and

()

2 the source term definition we had was lifted largely out of 3

1465, and very deliberately so for consistency.

However, 4

the comments that we received from the public implied to us 5

'that we were having a problem with that.

6 One of the comments --

7 DR.-KRESS:

What was that problem?

8 MR. LAVIE:

I'll get into it.

One of the comments 9

noted that the phrase "from reactor core to the containment" 10 while accurately describing the NUREG-1465 characterization 11 limited the definition to a LOCA.

This could give rise to 12 the interpretation that the selective implementations were 13 not allowed under 50.67.

14 DR. KRESS:

I see.

(

15 MR. LAVIE:

That was never our intent, to limit 16 the implementations so obviously we needed to do something 17 getting rid of the term "from reactor core to the 18 containment."

19 DR. POWERS:

I understand why you would want to do 20 that, but doesn't that pose you a challenge because the 21 people formulating this -- they looked at the release from 22 the fuel and they looked at the deposition during transport 23 and they said okay, this is what comes into the containment.

24 Now if I try to apply that to the fuel handling 25 accident, which I think was one of the major concerns O

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here --

r

(

2 MR. LAVIE:

Right.

3 DR. POWERS:

-- I don't have that transport 4

problem and I didn't affect the noble gases at all, but 5

presumably it does affect the iodine and the cesium.

6 MR. LAVIE:

This is one of the challenges the 7

Staff had in working on the draft guide is that the way we 8

are currently still regulating plants is that while the LOCA 9

may be the most risk-significant sequence within design 10 basis space we look at, we are still requiring licensees to 11 look at all accidents, and as a result the draft Guide 12 needed to look at the other accidents so the Staff did 13 work -- working with the definition of 1465 an't the tables 14 of 1465 -- develop some guidance licenseed could use to 15 apply some of these insights to the other accidents.

16 In most cases you will find our final source term 17 for those other accidents looks very, very similar to the 18 source term we currently have.

In other words, there were 19 no insights for us to transfer, but the definition that we 20 have here has to address everything in the Reg Guide as well 21 as the LOCA.

22 DR. KRESS:

But what bothers me a little about it 23 is in the future some persons who will read that and say, 24 oh, it's only from the fuel, so I will figure out how much I 25 can take credit for deposition in the primary system and in

[

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and try to add that into it and somebody will have to

()

2 explain, no, that is not the way it is supposed to work.

3 MR. LAVIE:

I understand what you are saying and I 4

believe that is something that the Staff will have to be 5

alert for when licensees try to come in and do something --

6 DR. KRESS:

As long as there is something in the 7

Standard Review Plan or Reg Guide --

3 MR. LAVIE:

Yes.

Of course our Reg Guide and our 9

Standard Review Plan are written to allow the flexibility 10 that both of those documents provide, but there is -- a very 11 strong position in our draft guidance is that if a licensee 12 decides to change the source term, the fraction of releases, 13 the timing and anything of that nature, he definitely has to 14 come back to us for approval.

That is not something he is

(

15 going to be allowed to do under 50.59.

16 That is one of the reasons why we needed to change i

17 the definition as well, because we had locked that down so 18 hard somebody found a place where we should allow them to 19 change, and in that regard the second comment noted that the 20 phrase " magnitude and mix" could be interpreted in a way 21 that would prevent licensees from implementing desirable 22 fuel management programs without approval under 50.67.

23 What they were referring to of course is if they 24 do anything to change the inventory in the core they have in 25 fact changed the magnitude.

That of course wasn't our ANN RILEY & ASSOCIATES, LTD.

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intent.

We were referring to the fraction of the core

'[^\\

2 inventory released, so we changed the definition to refer to G) 3

" fraction of core inventory."-

4 DR. KRESS:

that is a' good change, I think.

5 MR. LAVIE:

We changed that in the final language 6

and in the discussion and the statement of considerations to 7

make sure that is understood in the future as we move 8

forward on this.

9 A'few things changed during the office concurrence 10 process that you did not get a chance to see in your package 11 and I would like to go through these now.

12 As we have already discussed,.the definition of 13 the source term was revised.

We made several editorial 14 changes in many sections of the package to try to clarify

()

15 it.

We don't believe that any of these editorial changes 16 changed the intent or the content.

l 17 Based on discussions with the OGC, several of the l

18 responses to public comments were revised in the interest of i

19 improving the responsiveness to the question and l

20 establishing a clearer record of how the comment was 21 dispositioned.

22 Again, our overall response to comment did not 23 change.

It's just the way we addressed our rationale that 24 changed.

j 25 We did make changes to the environmental l

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assessment, once again with the assistance of OGC, to

()

2 provide a clearer, more legal conclusion by expanding on the 3

draft.

We originally said something of the nature " Changes 4

that are covered by existing regulation are therefore safe."

5 Well, we all had a feeling we understood what we meant 6.

there..OGC had a concern that other people may not 7

understand that, and so that was expanded to explain how the 8

existing regulation ensures that environmental assessments 9

will be done.

10 Also in the process a new administrative 11 requirement was issued to us involving voluntary consensus 12 standards.

Our conclusion on that was that there was no 13 appropriate voluntary consensus standard found in this area.

14 On the schedule we have this session broken out

)

15 into two phases, the rule and the draft Guide.

I am 16 pre ared to go right into the draft Guide and then hold more 17 questions until we get through both of them, or I'll take 18 questions now on the rule, if there are any, 19 DR. KRESS:

I think we ought to go on.

20 DR. POWERS:

Just charge right into it, 21 DR. SEALE:

Yes.

22 MR. LAVIE:

Right into the draft Guide?

Okay.

I 23 The draft' Guide was where we ended up spending a 24 great deal of time.

As we pointed out, the rule was an 25 enabling rule.

It allowed them to do something, but we then ANN RILEY & ASSOCIATES, LTD.

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294 li Lended upLwith a Reg Guide that had to explain an awful lot "2'

of. material.

3 This was compounded by things that occurred'during 4

the proposed rule stage, things we were asked to address --

51 risk, some-other things that came into play -- and also the 6-selective. implementation..If you remember from when we came 7

to you with the rulemaking plan the Staff's position was 8

very -- not: encouraging with regard to selective

.9 implementation.

10 We thought timing only would be appropriate but 11 that.if you.were going to do any dose calculations we felt 12 you needed to do all of them.

13 The Commission didn't agree with our position and 14 asked us to address selective-implementation.

This

)

15 magnituded the level of'our effort significantly, trying to 16 ~

come up with some language that provided the-flexibility but 17 also maintained the control that we were asked to maintain.

18 DR. KRESS:

On the selective implementation, ACRS 19 agreed with selective implementation and as best I remember 20 the reason was if you started making parts of the new source 21 term -- you know, there's not that many parts --

22 MR. LAVIE:

Right.

23 DR. KRESS:

-- so you can talk about the timing 24 mostly or the mix of radionuclides or those magnitudes.

If 25 you took any part of those and combined it with the old TID O

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14840,.you still, it appeared to us, had a relatively robust

([

2-source term that wouldn't give you any risk problems.

3 MR. LAVIE:

Right.

4 DR. KRESS:

So it seemed like to us it was 5

acceptable to take just about any part of it and use it in 6

any combination with the 14840.

7 Is that the conclusion you guys reached?

8 MR. LAVIE:

Well, to some degree the Staff has a 9

difference of opinion there, although I think we are working 10 to an agency position on it.

While we agree that from a 11 technical standpoint the work that was done in the i

12 rebaselining study by Research showed that in the majority 13 of-the cases any results done with the old source term would 14 bound the new source term.

That tended to allow the mixes D)

(

15 you are referring to.

16 Where that conclusion did not hold up, such as the 17 cesium in the sump water, the risk argument comes in very 18 strongly, that this isn't risk significant.

Now on the 19 other side of the story, getting away from the technical for 20 a moment, there is the regulatory side -- that the NRR Staff 21 has concerns about maintaining a clear, logical design 22 basis.

23 DR. KRESS:

I see -- I meant to ask you what that 24 really means because the purpose of applying the new source j

)

25 term is to make changes to the plan.

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' 1' MR. LAVIE:

That's correct.

c.

2

'DR. KRESS:

Or the operating procedures or 3

something,.and so'you are changing the design basis.

You 4

are changing the plan.

5 MR. LAVIE:

Right.

6 DR. KRESS:

What you mean here is you still meet 7

.all of the traditional deterministic requirements that are 8

in the rules?

9 MR. LAVIE:

That is NRR's position right now is 10 that we have not tried to change the way we have done all 11 the calculations to date.

We did not want to take that on 12 with this draft Guide with the time schedule the Commission 13 gave us, i

14 There is a separate effort going on in

(

15 risk-informing Part 50 and we may see some of these other 16 accidents drop out of the picture as that effort proceeds.

17 Our concern is that, yes, you are changing the 18.

design basis, and if a licensee came in and told us they 19 were going to revise the fuel handling accident and get rid 20 of the charcoal filters in the spent fuel pool building, 21 that seems very clean.

We can approve it and you can go on.

22 We start to get a little more concerned however 23 when we start getting into components that are affected by 24 more than one accident or for instance the control room.

If

, 25 we have the control room design based on 5 rem whole body I

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for one accident, 25 rem TEDE for another accident, it gets I) 2 very, very muddy and difficult in our mind to maintain a b/

3 clear design basis.

4 Part of the reason why the draft Guide is as long 5

as it is is to try to meet both of those goals, maximum 6

flexibility and clear design basis.

We do have a. question 7

in the announcement of the proposed Reg Guide asking for 8

additional input from the public on whether or not we could l

9 make it simpler or whether -- or on the other side of the 10 fence have we plugged all the holes?

11 We will obviously be looking forward to those l

12 comments from the public as we move forward.

1 13 MR. BARRETT:

Steve, if I could just add a word --

14 MR. LAVIE:

Sure.

n()

15 MR. BARRETT:

I think this question of selective 16 implementation is one that is going to come up a lot now.

17 For instance, in risk-informing Part 50 the same question 18 came up -- would we require the industry to go whole hog 19 into the new way of doing business or would we allow them to 20 selectively choose parts of the risk-informed Part 50, and 21 the Commission once again in that case came down on the side 22 of selective implementation.

I think the arguments pro and 23 con are the same in both cases and probably in future cases 24 as well.

25 I think Steve characterized the reason for going b

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with full = implementation.

I think the principal reason for

()

2 giving the industry the flexibility to go for partial 3

implementation is that requiring full-implementation puts a 4

high hurdle in front of the industry.

It basically requires 5-an enormous, in many cases an enormous investment to make 6

the transition all at once, and so the idea of selective 7

implementation we think, and I think that more and more the 8

Staff is coming around to this point of view, that it will 9

give an incentive for more utilities to get their oar in the 10 water if they can do it one step at a time.

11 The feeling.is that eventually we will get 12 relative full implementation in some of these initiatives.

13 DR. SEALE:

If we run past the code words here for 14 a minute, the real immediate low-hanging fruit, to mix a

()

15 metaphor, is the ability to invoke.the timing and to the old 16 source term as far as release fractions are concerned -- and 17 so on.

18.

MR. BARRETT:

Right.

19 DR. SEALE:

That is really the major selective 20 implementation alternative, isn't it?

21 MR. BARRETT:

Yes.

22 DR. SEALE:

And I guess if you say it that way, it 23 simplifies the problem as far as my perception is, that it 24 allays a lot of the fears that there's some crafty 25 son-of-a-gun out there that is going to be figuring out how n

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-to'really ride this-horse into a whole new arena of source

'l 2

terms and so forth, so I think maybe our code words do us a 3

disservice in this case.

4 DR. KRESS:

Well, there is the cesium issue.

You 5

are going to handle that in a different arena though, I 6

~ think.

7 DR. SEALE:

Yes, and as a matter of fact, if you

'8 just said " timing," then you might not have the cesium issue 9

to worry about, calling it selected implementation.

10 DR. KRESS:

Well, I have never been very worried 11 about selective implementation of this source term.

I think 12 you have a different issue when you talk about selective 13 implementation of risk-informed Part 50.

14 DR. SEALE:

Oh, yes, sure.

()

15 DR. KRESS:

You know, it is a broader subject and 16 harder to -- harder to. determine what the ramifications are 17 but the way I see it is'you have a certain level-'of safety 18 margin with the current regulation and by risk-informing, 19 what you are doing is I think allowing some reduction in 20 that margin because of the better knowledge that you have, 21 and by selectively implementing those rules, I think you are 22 just cutting away the margin a little bit at a time until 23 you get down to this other level, so I think in principle it 24 is probably a good principle to have.

25 I agree with the selective implementation.

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1 Probably some clever guy can' figure out some way to use it, 2

but I think it would be by accident if they could get 1

3 DR. SEALE:

In the general context of the source 4'

term.

5 DR. KRESS:

It's in the source term.

I can't 6

see --

7 DR. SEALE:

That's what I am saying.

I just think 8

we are kind of tying ourselves in knots maybe unnecessarily.

9 MR. BARRETT:

We worried over the cesium question 10-but I think what we finally came.down to is that the cesium 11 is what the cesium is.

You know, we are not changing the 12 source term.

We are just changing the calculation of the 13 source term and so, you know, it is a generic issue and it 14 is one that we need to deal with.

15 DR. KRESS:

I think that is the right way to look 16 at.it.

You know, you have uncovered some new information, 17-basically.

18-MR. LAVIE:

Part of the concern the Staff, the HRR 19 Staff has on selective implementation is not so much with 20 timing only because we have all agreed that the timing only 21 is probably pretty easy, but our concern is more from the 22 standpoint that we have to write the document to cover the 23 crafty individual that comes in and decides to mix chemical 24 form and timing, let's say, in a way that is not good.

25-We also have the concern that inasmuch as the O

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plants we are dealing with were all licensed in the old 2

deterministic scheme that.over the years our guidance to

'3 these licenses has'got us to a point where we believe we do 4

have a margin of safety in our calculations.

How big that 5

margin of safety is in our calculations is'obviously 6

everybody has a different view on it.

Some think the margin 7

is huge, others think it's small, but over the years as we 8-Hgo through the selective implementation process, not only

.9 with the source term but we are also looking at other 10 aspects of these analyses.

11 We are concerned with, we look for instances with 12

-our meteorology.

We see that we have 99 percent meteorology 13 and we decide that, hey, we don't need a do 99 percent 14 meteorology, let's go to 90 percent meteorology.

But we may

(/

15 be stomping on the toes of a decision made a few years ago.

16 that said we can buy this because we have 99 percent 17 meteorology.and there is where we have our concern with 18 selective implementation, is where we are eating away at 19 this margin that we may not have thought about, and 20 particularly as we get with creative -- I am not going to 21 say shifty, but creative approaches to this, and there will 22 be creative approaches.

We have already seen a few come in.

23 Okay.

As we pointed out earlier, the Draft Guide 24 is written from'the staff's traditional design basis

'eterministic analysis approach.

Hopefully, some day in the d

25 g' /)

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future, we will get to consequence curves, or more s()

2 probabilistic analysis,'but right now we are still with the 3

design basis deterministic approach.

4 We mentioned in our November 1998 briefing that we

'5

.had chosen not to simply endorse NUREG-1465, but to 6

establish the concept of an alternative source term.

The 7

Draft Guide establishes some minimum standards for what 8

constitutes an acceptable alternative source term and then 9

documents a source term that is acceptable to the staff, one l'

10 for PWR, one for BWR.

i l

11 DR. POWERS:

One of the questions, those criteria 12 that you have in the draft on what constitutes a source 13 term, yeah, they are pretty good, but they are boundary 14 conditions for setting up the source-term.

()

15 MR. LAVIE:

Right.

16 DR. POWERS:

And I was sitting there and saying, 17 now, suppose a guy comes in and he says I gct this new magic i

18 fuel and it is different.

And I come up with a source term.

19 What are the mechanics by which the staff would examine that 20 source term?

Would it be strictly in terms of those 21 criteria that you set down or would the staff go beyond 22 that?

23 MR. LAVIE:

When we wrote those criteria, we were 24 looking to put down something that we felt would be a point l

25 to start discussions, that we intended to set a very, very ANN RILEY & ASSOCIATES, LTD.

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high threshold.

Part of that reason is when we look at l

])

2 environmental assessment for why we can go ahead with this 3

new source term, it is very, very clear, we have taken a 4

great deal of credit for all the peer review and all the 5

research done on the old source term.

Since we have taken 6

that significant amount of credit for all that effort that 7

went into the 1465, that we expect that someone coming in 8

with an alternative would meet a similar threshold.

9 We are currently doing something in this regard 10 with one of the pilots that Jay will be discussing later 11 today, I believe, and where they ask for changes in the 12 timing.

And they are going through a process.

We have a --

13.

the lab is working on it, I believe, right, Jay?

14 MR. JAY LEE:

Yes.

(_)

15 MR. LAVIE:

We have a lab -- one of the labs is j

16 looking at it to try to decide whether or not what they 1

l 17 propose is suitable.

18 We see a very high threshold.

It is difficult in 19 the space of a Regulatory Guide to write a real black and 20 white description, because we don't know where they are l

l 21 going to decide to make approaches, and it is undoubtedly 22 going to come down to the individual reviewer and his 23 supervision.

24 DR. POWERS:

I guess I was looking for something i

25 in there that said something to the effect that you have got I

/ \\

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to have a technical basis, an experimental basis or a well

()

2 founded, analytic basis for what makes up the. source term.

3 I mean I think it is different between timing issues and 4

compositional issues.

But it seemed to me that -- I have 5

liked all of the things that were in'there on what this new 6

source term has to be.

I didn't find any fault with those 7

at all.

.8 MR. LAVIE:

Okay.

9 DR. POWERS:

But there was -- it seemed to me 10' there was something -- there was not an alert that there was 11 more to it.

And I think you touched on it when you said we

-12 have got a large body of experimental and analytical peer 13 review research backing up this alternative that we show for 14 you and we would expect something similar to that on any

()

15 modifications that were made to it.

16 MR. LAVIE:

Okay.

17 DR. KRESS:

Does that fit?

18 DR. POWERS:

Well, maybe it does.

I guess that 19 just didn't strike my --

20 MR. LAVIE:

Come across strong enough.

21 DR. POWERS:

When I looked at what it is, it is 22 2.4 on 12 is what he has circled for ca.

I just -- I will 23 tell you where the concern comes in, is that a guy could 24 come in and say, I have looked at it, and I think that 25 cesium is really going to be in the form of cesium ANN RILEY & ASSOCIATES, LTD.

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ruthoferronate, and that has a volatility of zip at 3,000 t

,2 degrees.

3 MR. LAVIE:

Right.

~4 DR. POWERS:

And you say, well, you know, I don't

'S even know what-cesium ruthoferronate is, but I don't believe 6

that.

And the guy says, yeah, yeah, but you don't get to 7

review it because that is not one of these criteria here.

8 That is where the concern.in.

9 MR. LAVIE:

Okay.

10 DR. POWERS:

You know, it fits everything here i

11

.that you have laid out.

Why are you looking at the cesium 12 ruthoferronate?

i 1

13 MR. LAVIE:

The concern is we need to make very 14 sure that the words we have put in there are not exclusive

)

15 or interpreted as being all inclusive.

16 DR. POWERS:

Yes.

I may just look at it.

It is 17 nothing.

18 MR. LAVIE:

Certainly.

19 DR. POWERS:

I don't have anything constructive to 20 propose here.

21 MR. LAVIE:

Words need to be -- okay.

Okay.

The 22 Draft Guide does address accidents other than LOCA.

As the 23~

. lesser accidents, while perhaps less risk significant, they 24 are still part of the traditional design basis.

The 25 licensee may not have to do them, however, if they do, we h

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felt it better to have the guidance up front

()

2 The first big issue, and we have already touched 3

on it briefly is the scope of implementation.

When -- this 4

is one of the biggest issues we have addressed.

You may 5

remember that we told the Commission in our proposal in the 6

rulemaking that we thought that. timing only was a good 7

selective implementation, but that -- and beyond that, we 8

expected it to be an all or nothing situation.

9 The staff believes that an applicant should 10 evaluate all the impacts to the proposed change.

The 11 rebaselining study provides a basis for discounting most 12 source term related impacts.

For example, they increase 13 cesium.

If the licensee performs a LOCA analysis, the staff 14 can make a finding with reasonable assurance that the

)

15 ultimate source term is safe and that future modifications 16 can use the design basis updated for the alternate source 17 term and TEDE.

Thus, the licensee could make future changes 18 on the 50.59, 19 The staff believes currently, and we will look 20 when we get the questions in during the public comment 21 period, is that the selective implementations would need to I

22 come in under 50.67 to extend the alternate source term to 23 another~ change beyond that already approved.

What the staff 24 is looking at in that area is that if we do have a licensee 25 who comes in, for instance, ar ~

, poses to remove the

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charcoal filters from the spent fuel building, these

(

2 particular filters don't serve any other purpose than the 3

fuel _ handling building, that we could approve that and we 4

would allow him to change his design basis to use TEDE and

.5 the alternate source term for the fuel handling accident.

6 That allows him to change the design basis for the filter.

7 If that particular licensee then wanted to remove 8'

the charcoal filters from inside containment, you would need j

9 to LOCA analysis.

Okay.

That particular licensee would 10 need to come in under 50.67.

11 Now, I have given you the example of the case we 12 are most concerned with, someone coming in with something 13 really simple and expanding upward.

Obviously, you will 14 notice our method creates a situation, if a licensee chose O)

(,

15 to come in and do a LOCA as a selective implementation and 16 not call it a full implementation, he, in essence, has done 17 the same thing as the full implementation folks have done.

18 However, we had to write it to address the other direction, 19 someone who might move from a timing only to a full fledged.

20 We believe as a minimum they need to do the LOCA, and then 21 we can treat it as a full implementation.

22 Another area of policy is the scope reanalysis.

23 They are a large part of the design basis.

The majority of 24 the plants that are out there now are based in some degree 25 on a calculation of the source term.

An awful lot of I

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1 decisions made in the Emergency Operating Procedures, alarm 2

set points, radiation monitor design are based on the source 3

term.

The source term cuts through a very large part of the 4

plant design.

Having come from the industry and been 5

responsible for these calculations, it is amazing where the 6

source term shows up.

7 DR. POWERS:

As well as it should.

8 MR. LAVIE:

As well it should.

So now we come in 9

and we pull that little pin out of the bottom, we say we are 10 going to let you replace that little pin.

What happens is 11 it is all above us.

So we needed to think real hard about 12 this, and, fortunately, the rebaselining study gave us some 13 insights that told us an awful lot of these concerns, we 14 didn't need to be worried about.

So we tried to give some 15 guidance to licensees as to what they did need to be worried 16 about, and also to the reviewer when these amendments come 17 in.

18 We believe that all radiological and 19 non-radiological impacts must be addressed.

Okay.

As an 20 example of a non-radiological impact, very early out in the 21 process we had some people running around saying we are 22 going to get rid of containment sprays because they are no 23 longer needed for iodine removal.

Well, obviously, that 24 could have an impact on your containment pressure design.

25 So look at all the impacts.

1 l

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309 1-We don't believe that a complete recalculation of

()

2 the design basis is necessary, and we very specifically in 3

this word " recalculation," we do believe that the concerns 4

have to be evaluated, but we don't seen them recalculating 5

all 300 calculations, or whatever, that form the 6

radiological design basis.

7 We also believe that scaling and scoping analyses 8

could be used for certain evaluations where they may be able 9

to look at say we have 40 calculations done for EQ, I have 10 one calculation that sets up the source term.

I go through 11 that, I find out my MEV per second, per centimeter in Energy 12

-Group 3 has only gone up by 2 percent, therefore, my dose is 13 only going to go up by 2 percent.

But I know I have a 14 factor of two design maroin, therefore, I don't need to

()

15 recalculate the dose.

That could be appropriate, with 16 adequate justification.

17 Now, we also feel that if the calculation was 18 b'ased on 14844 and the traditional dose methods can be shown 19 to bound the results that would be obtained in the analysis, 20 if the analysis were reperformed with the AST and TEDE, that 21 the calculation does not need to be reperformed.

The 22 rebaselining study allowed us to make that conclusion.

23 However, the staff does feel that since you have 24 updated your design basis to put the alternate source term 25 and TEDE into your design basis that if, in the future, ANN RILEY & ASSOCIATES, LTD.

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there was a. reason'to redo those calculations, that you

()

2

.would update it for what was in your design basis at that 3

time, the alternate source term or TEDE.

Once again, this 4

is going to our concern regarding the integrity of the 5

design basis.

6 The' cesium issue.

When we looked at the -- tried 7-to write the Reg. Guide, we realized there were two sets of 8

impacts.

The staff does not expect licensees to come in and 9

change the source term just for the sense of changing the 10 source term.

We really believe that we are not going to see 11 any of those, that we are going to see amendment requests in 12 order to remove a charcoal filter or change some timing 13 requirement, and they are going to use the alternate source 14 term to justify that plant modification.

()

15 Obviously, the plant modifications need to be 16 analyzed.

We also feel that there are some impacts from the 17 alternate source term that also need to be considered.

As 18 you are aware, the revised source term in 1465 included some 19 increases in parameters as well as decreases.

]

20 Now, a rebaselining study by research has shown us 21~

that for all analysis based on containment atmosphere, the 22 alternate source term results would be less limiting, a 23 conservative situation.

The study also showed', however, 24 that the increased cesium in the containment sump water 25 would increase the long-term integrated doses.

The i

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rebaselining study also showed that the crossover between

()

2 the TID 14844 results and the NUREG-1465 results would occur 3

somewhere between 30 days and four months post-accident.

4 Now, when we look at our regulations and our

-5 regulatory guidance, we find that with the exception of the 6

equipment environmental qualification, post-accident 7

integrated doses are based on a 30 day exposure period, 8

thus, there is no significant impact.

Our TMI Lessons 9

Learned doses were all based on 30 days.

Our plant 10 shielding analyses were based on 30 days, so there is no 11 impact.

12-However, there is an impact in EQ, a potential 13

. impact in EQ, and the staff believed that this impact must 14 be considered.

Late in the process, the staff decided that l

()

15 we had potentially a generic issue here that needed to be 16 considered in the context of all reactors.

As a result, a 17 generic-safety issue has been identified to resolve this 18 concern.

19 Our intent is with the Draft Guide it will 20 continue to use, allow licensees to use either 1465 or 21

. TID 14844.for EQ doses until such time as the generic issue 22 is resolved.

Those plants who come in as pilots or get 23 approvals.in the interim period would fall under whatever 24 action is going to be taken on the generic issue.

25.

.Okay.

Extended burnup fuel, a favorite topic of h

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everybody.

The NUREG-1465 source terms, as you are well

()

2 aware, were based on fuel behavior obtained at burnup levels 3.

at' lower than 40 gigawatt days per metric ton of uranium 4

and, as a result, 1465 can contain a disclaimer regarding 5

the applicability of results, particularly the gap activity, 6

to extended burnup fuels.

7 The group of us that worked up the source term 8

working group met with representatives from Research, 9

Reactor Systems, to address how the data in 1465 could be 10 extended to address burnups at currently approved levels.

11 The assumptions in the Draft Guide are deemed to be 12 acceptable up to 62 gigawatt day per metric ton of uranium.

13 We do not have a wealth of experimental bases, but we 14 believe we have a sufficient regulatory basis consistent

()

15 with the deterministic design approach we are using these 16 data in.

The staff's analysis is in an attachment to the 17_

regulatory analysis for this rulemaking.

18 DR. KRESS:

When you give a value for burnup, Reg.

19 Guide rule, are you referring to the average burnup of the 20 core, or are you referring to the hot bundle or the biggest, 21 longest burnup bundle or --

22 MR. LAVIE:

We are referring to the average over 23 the peak rod.

24-DR. KRESS:

Average over the peak rod.

25 MR. LAVIE:

Right.

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DR. KRESS:

Now, if that average were 62, I am not n()

2 sure what the spread would be.

3 DR. SEALE:

What would the spread be?

4 MR. LAVIE:

The spread -- what the hottest pallet 5

could be?

6 DR. KRESS:

I was thinking, I just wanted an 7

average burnup.

8 MR. LAVIE:

Over the entire core.

9 DR. KRESS:

Full weighted, weighted on the whole 10 core.

What would I get with a 62 as the peak?

11 MR. LAVIE:

I believe I have seen data that Ralph 12 Meyer had that said that we ratio like 1.6.

13 DR. KRESS:

Could I use the flux distribution to 14 get that, Dana?

15 DR. POWERS:

No, because the peak rod average is 16 fuel that has been in the reactor for typically for three 17 cycles.

18 MR. LAVIE:

Three cycles.

19 DR. KRESS:

Flux, distribution and time.

20 DR. POWERS:

And there is going to be other fuel 21 in there that it has only been in there one cycle.

22 MR. LAVIE:

Right.

23 DR. KRESS:

It is time and flux.

l 24 DR. POWERS:

And you are going to have roughly a 25 third, a third, a third.

That is, you are going to have 60, I\\

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-- 30 a quarter, around 60 -- I mean I am talking really-2' round numbers here, a. third at about 40 and a third about 3

20.

4 DR. SEALE:

And the enrichments within a given --

l 5.

will vary 30 or 40 percent.

6 MR. LAVIE:

The rod we are talking about is rather j

7 hypothetical because the rod with the highest burnup will l

8

.not be.in the peak power position.

9 DR. SEALE:

The highest prior.

10 DR. KRESS:

Where will it be?

11 MR. LAVIE:

Probably in Region III.

12 DR. KRESS:

On the periphery.

13 MR. LAVIE:

The periphery.

-14 DR. POWERS:

It depends a little bit on their fuel 15

. handling.

16 MR. LAVIE:

Right.

17 DR. POWERS:

And there are a couple of strategies 18 that people have,.I mean classes of strategies, so it is not 19 readily predictable.

Now, what is known is that all that j

20 work in 1465 took very round number approaches to that.

I 21

.think they did in the fuel source term co-package 22 calculations that constitute much of this, recognize there 23 were basically three regions of fuel, and that there was a 24 cosine burnup dependence in the thing.

25 MR. LAVIE:

But that is about all is what I think.

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DR. POWERS:

The details really don't work it out.

()

2 DR. KRESS:

And, basically, the only thing they 3

'did with that was how it affected thermal hydraulics.

I i

4 don't think they did anything with the source term.

5 DR. POWERS:

Well, no, it affected your total 6

inventories.

7 DR. KRESS:

Oh, yeah, well, they projected the 8

inventory, then they -- by the ORIGEN code, which took that 9

into consideration.

But then when they treated the release 10 from fuel, they treated it all as having the average 11 inventory.

12 DR. POWERS:

Yes, that is exactly right.

13 Everything was treated from that point on as if it had the 14 average inventory per rod.

/~N

()

15 MR. LAVIE:

Well, the fact that the actual 16 treatment in 1465 was average over the core gives us some 17 level of conservatism in the approach we are taking.

18 DR. KRESS:

It does.

That is what I was -- that 19 was giving me a little bit of comfort, by the way.

20 DR. POWERS:

Well, before you jump over all that, 21 recognize that what happens in a core degradation scenario 22 which gets you up through the early release is that what is 23 actually degrading there is the central regions.

24 DR. KRESS:

Central regions.

25 DR. POWERS:

Okay.

But, in fact, what they do is ANN RILEY & ASSOCIATES, LTD.

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they average that then over the entire quarter.

So, it is 3

i O

2 averages that are kind of complicated.

But, quite frankly, V

3 all:of these things are in the noise compared to the 4

uncertainty you have in the release itself, and that is what 5

-- 1465 tries to take some kind of a reasonable -- I 6

hesitate to use the word " bound" because they, 7

MR. LAVIE: -Right.

8 DR. POWERS:

-- the authors of 1A65 hesitated to 9

use word " bound," but, in fact, they kind of scope all that.

10 So worrying too much about this detail is really not 11 feasible.

12 The real issue is this gap activity issue.

The 13 inventory and the spectrum shifts are in the noise..

The gap 14 fraction inventory is the real issue, it seems to me.

15 MR. LAVIE:

Right.

16 DR. KRESS:

Which affects mostly valve closure.

j 17 DR. POWERS:

A few things.

18 DR. KRESS:

Maybe iodine, the iodine spike.

19 MR. LAVIE:

Yes.

In the analysis that we attached 20 the Regulatory Guide, we did consider the gap fraction very 21 carefully because, obviously, this was our concern in 22 getting into other accidents.

The LOCA was pretty -- what 23 we felt was pretty straightforward.

From a standpoint of 24 public health and safety, the gap is a small fraction of the 25 full inventory, although there would be some effects with O

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the timing.

We felt there was enough -- the LOCA was pretty

()

2 well self-limiting in that regard.

3 However, we did note in the write-up that there is 4

work still going on in this area and that we expect as the 5

work goes on that we may be updating this guidance.in the 6

future.

There is currently right now, in two different 7

offices, work going on to look at extended burnup fuel with 8

regard to fuel handling accidents.

This is the 9

NUREG/CR-5009 effort.

The materials folks are having this 10 redone by Oak Ridge.

NRR is having it being redone by PNL, 11 to try to find out whether or not we can license above 12 62,000 gigawatt day per ton.

13 There has been some preliminary information coming 14 out of that work.

The preliminary information right now

()

15 indicates that the two labs are coming up with markedly 16 different results-and some efforts are going to be done to 17 try to pull them together.

18 Okay.

As I pointed, the research is continuing 19 under the agency's high burnup fuel program.

And as you are 20 well aware, Ralph Meyer presented this program to the ACRS 21 in a meeting earlier this year.

I am certainly not going to 22 try to steal Ralph's thunder.

I will get in real trouble, 23 real quick, if we get too deep.

24 DR.. POWERS:

Now, Ralph talks a lot about the 25 activity insertion accidents and LOCA, Appendix K types of O-ANN RILEY & ASSOCIATES, LTD.

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things, and seems to skirt the issue of source term pretty o

)

2 scrupulously in his presentation.

What is it going to get 3

for you in the area of source term?

4 MR. LAVIE:

The thing we are worried about, what 5

we hope, coming out of the work that Ralph is doing in 6

there, is the issues regarding fragmentation and the 7

appearance of a release based on heating.

We have 8

traditionally treated this as a gap release and some melt 9

release.

Apparently, the work that is coming out of CAPRI 10.

-- CABRI, rather, is showing that they are getting releases 11 at lower temperatures than we currently believe is the case, l

12 and that is why that is a very high position in the agency's 13 program to resolve that.

This is a significant issue for 14 Reactor Systems.

15 And you will perhaps notice in Reg. Guide is that 16 with regard to the reactivity excursion accidents, we have 17 specified that these are being -- the releases in these are 18 being treated on a case by case basis.

Reactor Systems is 19 treating eaca one of these individually.

Hopefully, out of 20 the work that the agency's program is doing in foreign 21 research is we will be able to come up an improvement in the 22-methodology we use for analyzing this accident.

23 Iodine species, --

24 DR. POWERS:

In other words, you anticipate that 25 phrase, "we will treat these on a case by case basis," will ANN RILEY & ASSOCIATES, LTD.

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someday be replaced with a paragraph.

)

2 MR. LAVIE:

Replaced with a paragraph that 3

specifies what it is.

For the time being, we have told them 4-to use the:same gap fractions we are currently using in 5

existing guidance.

We have no basis to change them.

We 6

certainly have no basis to go to 3 percent.

So we are 7

sticking with the gap fractions that were given primarily in 8

NUREG/CR-5009.

9 One of the other issues we had to do for this 10 Draft Guide is that, since we are addressing other 11

-accidents, the question of iodine species for other 12 accidents came up.

And there is very, very little we could i

13 put our hands on, research that gives us an awfully lot of j

14 warm, fuzzy feelings about the species for these other

()

15 accidents.

An awful lot of work has been done on the LOCA.

16 Some additional work has been done on steam generators.

But 17 using -- in our deterministic methods, we are not really 18 concerned about what has happened in the reactor coolant 19 system in a steam generator tube rupture.

.20 This gives us the ability in a deterministic, 21 design basis space to draw some inferences with regard to 22 the iodine species.

There are a great deal of uncertainties 23 here, obviously.

We believe, however, there is adequate 24 conservatism in defense-in-depth.

25 DR. KRESS:

Just for the record.

\\

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MR. LAVIE:

Okay.

()

2 DR. KRESS:

I would like to say that I have a 3

conflict on this particular issue, the iodine species.

That 4

is just for the record.

5 DR. POWERS:

I have a conflict, too, because I 6

don't understand, not because.of any prior work.

7 DR. KRESS:

See, I did the prior work that 8

establishes those 95, 4.85 and.15.

9 DR. POWERS:

Okay.

So we should regard with a 10 great deal of suspicion.

11 DR. KRESS:

A great deal of suspicion, correct.

12 MR. LAVIE:

This is where we ended up.

We 13 determined we were going to put it in the Draft Guide as a 14 starting point.

Obviously, depending on public comments, we

()

15 will certainly consider changes.

Very late in the process, 16 the industry gave us a technical position on iodine species 17 for a fuel handling accident.

That position advances cesium 18 iodide as a predominant form rather than element iodine.

19 This position will be considered with other public comments.

20 From a preliminary standpoint, it looks 21 interesting.

We need to find out if we have other work that 22 takes an opposing view.

But we are looking to something 23 with the fuel handling accident.

The source term we have 24 here is based on Reg. Guide 1.77.

The work that that is 25 based on is back into the 1972 timeframe, and at that time O

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the only thing they were worried about was the organic form,

()

2 because there was no pool DF for organic.

They identified 3

.25 percent organic and then assumed everything else was 4

elemental.

5-It was good back there in the deterministic times.

6 If we can be a little bit more realistic, we will.

We will 7

consider that in the future.

8 DR. SEALE:

If you go to the fuel handling 9

accident, that is a very different environment than the 10 basis that you used for youl Operating situation.

Were you 11 comfortable with the database you had to make those 12 distinctions?

13 MR. LAVIE:

Okay.

These parameters here, as I 14 point out, were not based on 1465 at all.

These are based-()

15 on the original work done back in 1971.

It is the current 16

_ approach.

I have looked over that data.

It today's view, 17 it seems to be extremely conservative, and that is why we 18 are going to look, see whether or not we can do something 19 better on that one.

20 The database we have for the other gap fractions 21 are based on I said NUREG/CR-5009, which is currently being 22 redone.

The data from that did look very, very similar to 23 the data that the Research folks have developed.

We are 24 looking at an iodine fraction of 12 percent.

Ralph Meyer 25 presented some data here that came in at 9 percent for nobel ANN RILEY & ASSOCIATES, LTD.

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gases and when you realize it is a little bit more

(

)

2 short-lived and make the adjustment, that brings it up to 3

about 10 to 11 percent.

The data is appearing consistent.

~

4 We feel that for the current purposes, until we have 5

something that will make a change, that we think the numbers 6

in 5009 will stand for the time being.

7 DR. SEALE:

But you clearly have a situation 8

where, if you will, there is graded quality.

9 MR. LAVIE:

Yes, there is a graded quality.

10 DR. SEALE:

In the data that you are using to 11 support these different distinctions --

12 MR. LAVIE:

Absolutely.

13 DR. SEALE:

-- and fuel response.

14 MR. LAVIE:

Absolutely.

There is very, very

()

15 little empirical data that we can use for a fuel handling 16 accident.

As a matter of fact, the data that is here from 17 the fuel handling accident was work that Westinghouse did in 18 1972 and looks I have had recently, because I am working on 19 an issue similar to this, is that no one else but l

20 Westinghouse has looked at this and nothing has been done

)

21 since 1972.

22 DR. POWERS:

Well, there has been some interesting 23 efforts by Kleykamp in Germany to use as a double collimated 1

24 X-ray diffraction, to look at what the chemical forms of 25 species in the gap regions are.

And he comes up with things O

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that no human being has ever heard of before.

I am

()

2 wondering if that doesn't give you some insight on -- that 3

material might not give you insight about this fuel handling 4

accident?

5 MR. LAVIE:

It should.

6 DR. POWERS:

It is not going to give you the split 7

between elemental and organic for iodine.

8' MR. LAVIE:

Right.

9 DR..

POWERS:

But it is going to tell you something 10

'about --

11 MR. LAVIE:

Whether we have a lot of cesium or 12 not.

13 DR. POWERS:

-- your industry proposal and 14 whatnot.

()

15 MR. LAVIE:

I am not sure the industry referenced 16 this paper.

17 DR. POWERS:

Nobody seems to because it --

18 MR. LAVIE:

Right.

19 DR. POWERS:

And it is only work I know of where 20 somebody has tried to actually identify the species that 21 exist in the gap region.

I I

22 MR. LAVIE:

Right.

23 DR. POWERS:

There was some, work done at Oak 24 Ridge, not by my colleague to my right, but some of his 25 confederates, in which they tried to do it, but they didn't ANN RILEY & ASSOCIATES, LTD.

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have this capability of two blazed, two diffraction -- dual s' )

2 Ldiffraction X-ray diffractometer in a hot cell, which is a 3'

unique capability, and it must take heroic exposure times to 4

do this.

5 MR. LAVIE:

.That would be a good one to look at, 6

and we-will have a look at.

To summarize briefly, the 7

industry's work, the reference work done by several 8

researchers, and the approach they did was not specifically 4

9 to identify with a great deal of certainty that the cesium 10 was there.

They found the evidence, based on thermodynamic 11 considerations and so forth, that the cesium had to be there 12 because of the behavior of the gas they did collect.

13 Like I said, those type of worries give us a 14 little bit of a pause, but maybe there is some background in

()'

15 this work that will help decide whether there is validity dn 16 their approach.

17 DR. POWERS:

Yeah, the problem with thermodynamic 18 analyses is that if you leave the species out, it is not 19 going to show up and whatnot.

i 20 MR. LAVIE:

Right.

j 21 DR. POWERS:

But just for whatever it is worth, it 22 is useful to look at some of that stuff that goes on at the 23 Transuranium Institute because they have unique capabilities 24 and whatnot.

25 There is other work going on that relates ANN RILEY & ASSOCIATES, LTD.

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8 325 i

i particularly to the LOCA.

The stuff you have drawn from

()

2 1465 is now bordering on ten years old.

And we find these 3

hints, I wouldn't call them definitive enough to go out and 4

make great changes, but they could pose great changes.

And 5

there is work going ~on at-the RTF in Canada that is 6

interesting and provocative.

7 What.I am thinking is for the LOCA analysis coming 8

into containment, sure enough, people in the PHEBUS program 9

are saying, well, it was cesium iodide coming in, but it 10 promptly turned into silver iodide, a different beast.

11 MR. LAVIE:

Right.

12 DR. POWERS:

And for the RTF I am thinking of, 13 sure enough there was organic, but it wasn't methyl 14 organic -- methyl iodide, it was plate propyl iodide or

()

15 something like that and what-not, and ILwonder if that

.6 changes anything here.

17 MR. LAVIE:

Obviously there is a potential for it.

18 We --

19 DR. POWERS:

I mean they are saying in the PHEBUS 20 tests right now that they think the iodine they had 21 suspended in the containment atmosphere was predominantly 22 organic and I mean they had low levels but they are saying 23 everything might be organic and what-not.

I 24 On the other hand, if the RTF is right, 25 partitioning from water of these higher molecular weight i

O ANN RILEY & ASSOCIATES, LTD.

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iodides is not really different than the partitioning of

()

2 elemental iodine -- in' fact, taking elemental iodine as 3

representative might be a conservative position in some 4

cases.

5 MR. LAVIE:

W?ll, concern as far as the 6

partitioning is that we have decided, as you have noticed, 7

to treat PCCS leakage source term and any releases by a 8

steam generator's main condensers as being elemental..

9 The way we can support that, and we feel it is 10 justifiable, is that in most of the deterministic analysis 11 that we are doing the assignment of the iodine species is 12 largely irrelevant.

13 For example, there is no distinction made in dose 14 conversion factors for elemental as opposed to organic 15 iodine.

16 We are. assuming in our deterministic analysis, for 17 instance for steam generator tube rupture, that the activity 18 is transported from the primary system to the secondary side 19 with no-additional plate-out.

20 The only additional credit they are getting is 21 partitioning, so we believe in a deterministic sense that 22 what we are proposing here is justifiable.

However, of 23 course as data becomes available -- just as with 1465, as 24 better data becomes available, it will certainly be looked j

25 on and necessary changes made.

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1 Jay is going to talk to shortly here regarding the

()

2 work he has done on the pilots, and I am just going to 3

mention from the standpoint of the draft Guide, the draft 4-Guide incorporated positions and technical methods developed 5

in the review of the pilots to date.

We finished the Perry 6

one.

We have got one in-house now,'two in-house right now 7

on Grand Gulf.

Jay will say more on those.

8 In addition to bringing insights from the pilots, 9

the Guide also contains some other improved assumptions and 10 methods dereloped outside the pilot reviews, and I have 11 tabulated some of the changes in the slides.

12 One of the important points we made when 13 developing this' guidance is if we didn't have a basis for 14 change the current assumptions and. regulatory guidance, b

g,j 15

. Standard Review Plan were used.

If we didn't have a reason, 16 status quo maintained.

17 Some of the more significant changes -- the 18 containment spray model.

We have changed our guidance with 19 regard to generating the source term for accidents, that 20 fuel damage estimates are going to be based on integrated 21 enthalpy rather than DMBR with the exception of reactivity 22 excursion accidents.

23 We believe, those of us and also Reactor Systems 24 believe that that is a bit more appropriate approach for 25 generating the source terms.

We look at accidents such as ANN RILEY & ASSOCIATES, LTD.

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the locked rotor accident where you have a pressure to

()

2 transient that lasts in the order of seconds.

We end up 3

with 18 percent fuel' damage because of our belief that any 4

time a rod exceeded DNBR it was damaged, so we have gone to 5

an integrated method that is a little bit more realistic.

6 We expect-that in many cases this will eliminate some of the 7

fuel damage in these other lesser accidents.

8 Reduced iodine spike value for the steam generator 9

tube rupture was lowered from 500 to 335, as was done on the 10-steam generator alternate plugging criteria effort -- only 11 for the steam generator tube rupture.

12 We have allowed credit for main steam line 13 deposition in boiling water reactors.

14 With that, I have finished my prepared statement.

()

15 I'm willing to field more questions.

16 DR. KRESS:

Where do your containment spray 17 removal models show up?

Are they in the Reg Guide?

18 MR. LAVIE:

The source term of reference is in the 19 Reg Guide.

We specified references to the NUREG documents 20 that describe the models.

21 DR. KRESS:

Does it also contain guidance on how 22 to deal with suppression pools?

23 MR, LAVIE:

The discussion on the suppression pool 24 in the Regulatory Guide currently states that we will give 25 credit on a case by case basis.

We gave credit for the O-ANN RILEY & ASSOCIATES, LTD.

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suppression pool in the Perry application because we were

()

2 able to show that it was an appropriate item to do.

Excuse 3

me?

4 MR. JAY LEE:

No, we did not give it.

5 MR. LAVIE:

I'm sorry.

Getting confused here.

6 DR. KRESS:

It depends on the amount of bypass, I 7

guess you get --

8 Mk. JAY LEE:

Yes.

9 DR. KRESS:

-- and whether the pool is saturated 10 or --

11 MR. LAVIE:

Right.

I'm sorry, I got a little 12 confused.

Yesterday at this time I was in London so I am a 13 little -- not exactly sure what time of the day it is right 14 now.

(Oj 15 Any other questions?

16 DR. SEALE:

It is Tuesday.

17 MR. LAVIE:

It is Tuesday.

18 MR. BOEHNERT:

About five hours later than London.

19 DR. POWERS:

A couple of just mechanical 20 questions.

21 MR. LAVIE:

Sure.

22 DR. POWERS:

There is talk in the Reg Guide about 23 USQ determinations in 50.59.

I think that language is 24 disappearing?

25 MR. LAVIE:

Yes.

O(s /

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DR. POWERS:

Do we need to make a -- does this

-(

2 have to hold its breath or I mean how are you going to

'3 handle that?

4 MR. LAVIE:

That is the problem with similar 5

changes going on at the same time --

6 DR. POWERS:

I understand, yes.

7 MR. LAVIE:

so that we expect the 50.59 rule to 8

hit the street before we issue the final Regulatory Guide, 9

.in which case the final Regulatory Guide will be revised to 10 match 50.59.

11 DR. POWERS:

Don't you think you need to say 12 something for the reader that says "And here is what it will l

13 look like."

14 MR. LAVIE:

Okay.

15 DR. SEALE:

Especially if you want the public 16 comments to be particularly helpful.

17 DR. POWERS:

Similarly in the discussion of core 18 inventory, you call out 1.02 times the licensed rated 19 thermal power.

20 MR. LAVIE:

Right.

21 DR. POWERS:

That is the way it has always been, 22 but there's movement afoot to make that maybe not always 23 universally true -- I mean it can be 1.01 if one conforms to 24 certain changes and things like that.

25 MR. LAVIE:

I believe there was a footnote on that O

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page --

()

2 DR. POWERS:

Ah -- maybe I --

3 MR. LAVIE:

-- that implied to use whatever yo1 4

DR. POWERS:

Okay.

Maybe there is.

I don't see 5

the footnote here.

6 MR. LAVIE:

Okay.

Maybe it got dropped off in 7

editing.

8 DR. POWERS:

Maybe it is someplace.

I have to 9

admit not reading every footnote.

n 10 MR. LAVIE:

Okay.

Yes, we put a note in.

We want 11 to give the plants that were going with the changes on --

12 DR. POWERS:

Instrumentation.

13 MR. LAVIE:

-- on instrumentation if they were 14 getting a lower margin they could use the lower margin.

(f 15 However, we spent a great deal of time on the words there 16 because there is a very large spectrum.

Apparently there 17 are plants out there now that were not licensed to Appendix 18 K,

okay?

They don't have 1.02 now, so the footnote was 19 added to use in essence what was in your design basis, but 20 if it is not there I am going to have to look for it.

21 DR. POWERS:

Well, it may well be there -- I just 22 didn't see it.

23 On this non-LOCA fraction of core inventory in the 24 gap group, it gives you Iodine 131, which I assume is all 25 the iodine.

It gives you Krypton-85, other noble gases, and O

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other halogens.

( )

2 I wonder why "other halogens" would be different 3

from iodine'and why_they even deserve mention.

4 MR. LAVIE:

Okay -- the reason why those were 5'

broken out separately in NUREG CR-5009 is there is a 6

significant difference in the half-life of Iodine-131 and 7

the other iodines that affect its fraction.

8 DR. POWERS:

Okay.

Just a half-life problem.

9 MR. LAVIE:

Right, half-life problem.

10 DR. POWERS:

Okay.

11 DR. KRESS:

So the I-131 means I-131?

12 DR. POWERS:

It apparently means I-131.

13 DR. SEALE:

Yes.

I thought it was a very crisp 14 run-through on this Reg Guide and Standard Review Plan.

(

15 DR. POWERS:

Yes, it was.

16 DR. KRESS:

Yes, very nicely done.

We appreciate 17 that -- which brings us to a question.

We are doing well on 18 the Agenda, which is good.

We were not scheduled for a 19 break until 10:15.

I propose that we just go straight on 20 into the next presentation.

21 DR. POWERS:

I think we ought to demand that the 22 next speaker provide us with a copy of his trip report to 23 the Helsinki meeting so we know what he learned up there.

24 DR. KRESS:

Yes, I think we ought to, too.

25

[ Laughter.)

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MR. JAY LEE:

The last two pages do that.

()

2 DR. POWERS:

You tried to get out of it with two 3

pages of viewgraphs.

I think we want the whole trip report.

4 MR. JAY LEE:

Good morning.

I am Jay Lee and I am 5

with the same branch as Steve Lavie is, the PSA Branch under 6

Rich Barry.

7 Steve discussed this morning abut rulemaking and 8

draft Reg Guide along with the Standard Review Plan.

My 9

portion of the discussion will be concerning how we are 10 doing with the pilot programs and some alternative source 11 term technical issues that ACRS members informally raised, 12 and so we'll discuss about that.

13 The heading's the same as Steve's did --

14 implementation of alternative source term at operating

'A

(,/

15 reactors, and the third discussion point will be pilot plant 16 reviews and source term technical issues.

17 Looking at the big picture, what we are trying to 18 do with the new revised accident source term is of course we 19 have three source term tasks.

One is rebaselining, 20 rulemaking and pilot plant application reviews.

Those are 21 three tasks we undertook and we are proceeding with it.

22 The first item, the rebaselining work is really 23 done by Office of Research.

It is completed already and the 24 rebaselining evaluated the impact of implementing the 25 revised source term for operating reactors.

(

)

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DR. KRESS:

We thought that was a pretty good l

)

-2 piece of work, by the way, when we reviewed it.

3 MR. JAY LEE:

Yes.

Yes, Research did well.

Jason 4

Schaperow and Charlie Tinkler are both here this morning, 5

and they briefed you on April last year and a complete 6

summary of results in the rebaselining work is presented in 7

a SECY-98-154.

8 Basically the two major points that we learned 9

from this effort is that, number one, alternative source 10 term indeed resulted lower doses compared to TID source 11 term, and the second item being that there were no 12.

show-stoppers using the alternative source term at the 13 operating reactor.

14 The second effort we undertook is of course

)

15 rulemaking, and Steve described it this morning, about the 16 final rule and the draft Reg Guide.

We briefed ACRS on the 17 draft rule last November, last year, and I believe a final j

18 rule along with the draft Reg Guide and SRP is due to the j

19 Commission September 10th.

Is that still the date, Steve?

20 MR. LAVIE:

YEs.

21 MR. JAY LEE:

Okay.

The last task we had for 22 implementing alternative source term at the operating 23 reactor is pilot plant reviews.

24 We received five pilot plant applications quite 25 awhile ago.

You know, after we issued this draft Guide, O

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making it available-to the public, our utility folks seemed

[)

2'

.to think that -- they lost somewhat the interest on the

. %,7 3

pilot plant, saying that they would rather wait until we j.

-4

' finalize the draft Reg Guide and the rulemaking rather than 5

they trylto commit.their resources at this time as a part of 6

a pilot plan program.

7' But anyway'among five applications we received,.we 8

completed one.

That is the Perry.. We have two currently 9

under' review.

That is the Grand Gulf and the Indian Point.

10 The remaining two are on hold -- that's Browns Ferry and 11 Oyster Creek.

We are' holding these on the request of

~

12 licensees.

They asked'us to hold it because they don't want 13 to commit their resources at this time.

Their resources are 14 not available so they did not formally withdraw their 15 applications, but they asked us to hold it-until further.

16 The first pilot program we completed is at Perry 17 Unit Number 1.

They requested eliminating the main steam

'18 isolation valve leakage control system and increase MSIV 19-leakage rate -- it is quite an increase from, for example,

'20 25 CFH to 100 CFH -- and also the 100 CFH total from the 21' four steam line, increase that number to the 200 CFH total.

22 We completed review last February and we issued 23 the license amendment March, this year.

24 Now in the case of Grand Gulf, the first 25 application that we received from Grand Gulf is really ANN RILEY & ASSOCIATES, LTD.

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limited scope application that.we briefly discussed this i

()

2 morning.

This is selective implementation for the fission 3

product release timing.

4 Right now in the NUREG-1465 for PWR we have 30 5-seconds for the initiation of the gap release.

Now Grand 6

Gulf is requesting to change that to the -- for the gap 7'

release initiation time to the 121 seconds.

This is a 8

minimum time of fuel clad failure time and we are currently 9

reviewing it.

As we briefly mentioned this morning, we are 10 getting help from the Research, also their contractor, 11 INEEL -- that is I-N-E-E-L.

12 We expect to complete this review this month.

We 13 are pretty close to completing this particular selective 14 implementation application from Grand Gulf.

()

35 At the same time we expect to receive a full scope 16 application from Grant Gulf some time in September.

They 17 originally told us it fus going to come in some time in July 18 and now it is August.

Now they are saying that it will come 19 1 in in September, so we expect that.

I 20 The other pilot program plant we are currently 21 rev.' ewing is Indian Point 2.

They requested to remove 22 in-containment filtration system.

We reviewed this and we 2:3 issued some additional -- request for additional information 24 I think back in February, I believe, six months ago or so.

25 It is so slow to come we have not received yet their O-ANN RILEY & ASSOCIATES, LTD.

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responses for our request for additional information, so it

()

2 is being delayed.

3 Like I mentioned for the Oyster Creek and the 4

Browns Ferry, Jacer their requests currently we are holding.

5 We are not doing anything at this time.

6 Now we are going back to the Perry, how we did it, 7

-the Perry licensing amendment.

What could we do or what 8

could we have done or what have we done with using this 9

alternative extant source term in their plant design and 1

10 their operation.

11 Now source term of course we used the NURE"-1465.

12 We used only gap release and in-vcesel release, not the 13 ex-vessel or late in-vessel releases.

14 Like I mentioned, they were able to delete main I

)

15 steam isolation valve leakage control system.

This is quite q

p 16 a relaxation on their part and so now we have calculation.

17 Of course, we do not give any credit and they were still 18 able to meet 25 rem TEDE outside bound EAB and LPZ and also 19 meet the control room fire and TEDE criteria.

20 Allowable MSIV le;xage, as I mentioned, they 21 increased.

This is another relaxation using alternative 22 accident source terms.

23 Now for the main steam isolation valve leakage 24 reduction after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and also containment leakage 25 reduction after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, we did not give a credit.

We 1

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'l maintained, we assumed MSIV leakage will continue for 30

()

2 days, which is very conservative indeed.

Also the came 3

thing is.true for the containment leakage will cratinue at 4.

that same rate for 30 days.

But after we finis 1ed this 5.

Perry review, our source term test group met and we decided 6

that maybe this is too conservative and the draft Regulatory 7

Guide right at this time we are giving a credit, lowering 8

both leakages, from the containment and the MSIV to less 9

than 50 percent if the' reduced leak rate is supported by 10 plant configuration and analysis, namely reduction of 11 pressure inside the containment.

12 So that is the change we made and the lessons 13-learned, so to speak, from the Perry review to the current 14 draft Regulatory Guide.

()

15 Now I have a few other items that we were able to 16 do'--

17 DR. KRESS:

Wait -- are you going to -- on the j

i 18 Perry, you said you still met the 25 rem TEDE at the site?

]

19 MR. JAY LEE:

Yes -- EAB and the LPZ.

)

20 DR. KRESS:

What did it go from and to?

21 MR. JAY LEE:

Of course they had a TID source term 22 then.

They were going with 300 rem thyroid and 25 rem whole 23 body.

I don't remember the exact number --

24 DR. KRESS:

How close they were to those limits?

25 MR. JAY LEE:

They were fairly close.

I don't

-[ '

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remember the number but I think they were about range of 80

()

2 percent or so approaching the 300 rem thyroid number.

3 DR. KRESS:

When you redid it with changes, you 4

got the --

5 MR. JAY LEE:

When we redid it, about 22 rem.

6 DR. KRESS:

22 TEDE.

7 MR. JAY LEE-22 TEDE with all the additional 8

relaxation.

9 DR. KRESS:

That is still mostly thyroid, isn't it 10 at Perry?

11 MR. JAY LEE:

Yes, major contribution is thyroid.

12 Other things we did for the Perry review is we did 13 give credit for the main steam line aerosol deposition.

14 DR. KRESS:

They did do the worst two hours?

()

15 MR. JAY LEE:

Yes, they did.

Yes.

They followed 16 worst two hours and of course proposed rule of 25 rem TEDE, 17 yes.

18 For the main steam line aerosol deposition we 19 considered only gravitational sedimentation.

That is the 20 only credit we gave.

21 Drywell aerosol deposition --

22 DR. POWERS:

What kind of flow regime do you have 23 in the main steam line?

24 MR. JAY LEE:

Pardon?

25 DR. POWERS:

What kind of flow regime are you in ANN RILEY & ASSOCIATES, LTD.

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the main steam line?

()

2 MR. JAY LEE:

We assumed to be a well-mixed.

3 DR. POWERS:

Well-mixed?

4 MR.' JAY LEE:

Yes.

Licensee -- they proposed a 5

combination of well-mixed and plug flow but we felt that

'6 well-mixed assumption is indeed more conservative for the 7

dose calculation, 8

DR.-KRESS:

The well-mixed gives you less 9

deposition?

i 10 MR. JAY LEE:

It will show up the activity at the 11 end-of pipe much earlier than the plug flow.

12 DR. KRESS:

Oh, that's what you are worried about.

13 MR. JAY LEE:

Yes.

14 DR. KRESS:

Shows up, f

15 MR. JAY LEE:

So we believe that the well-mixed is 16 more conservative.

Is that right, Jason?

17 MR. SCHAPEROW:

This is Jason Schaperow from the 18 Office of Research.

Well-mixed flow will give you a shorter 19 residence time for pipe, and as Jay said, it will show up 20 earlier at the end of the main steam line.

21 DR. KRESS:

Is it a significant difference?

I 22 would have thought it would be relatively insignificant.

23 MR. JAY LEE:

It is not really significant but it 24 did make a difference, l

25 MR. SCHAPEROW:

I don't recall the actual numbers i

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but.it did make enough of a difference for us to say we are

()

2.

not sure we are comfortable with plug flow yet.

We naven't 3

really; looked at the thermal -- we haven't looked at the 4

thermal gradients down the steam line yet, carefully enough 5

to decide that we could actually give the additional credit 6-for the. plug flow.

7 DR. POWERS:

I am wondering about the issue of 8

consistency.

Suppose one says now why are you well-mixed 9

and you say, well, I am well-mixed because it is a highly 10 turbulent flow, and they say okay, if it is a highly 11 turbulent flow that makes you well-mixed, why don't you give 12 credit for turbulent deposition?

13 MR. SCHAPEROW:

The flow rates down the main steam 14 line'are about 25 cubic feet per hour.

It is a vary, very f

15 slow flow.

If you consider it as a plug, it would take

~

16 about three hours to get down the steam line, so it is

]

17 really a very slow flow rate.

My wild guess is this is very 18 laminar.

Actually this is kind of like it goes up into the 19 top of'the steam line kind of,- just a very, very slow flow 20 rate.

21 MR. JAY LEE:

Dr. Powers, I am not sure we are 22 going to see the turbulent flow in the main steam line.

23 Leakage itself is so low, it will be strictly gravitational 24 settlement.

25 DR. KRESS:

Now you wonder why they didn't give i

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credit for plug flow.

()

2

'DR.

POWERS:

Slow flow rates but big diameters 3

still.get you into turbulent regimes.

I think we can go on.

4 MR. JAY LEE; Okay.

For the drywell aerosol 5

deposition we used the simplified model that Sandia i

6 developed.

We just applied that.

We gave a credit.

7 Containment spray also we used simplified model 8

developed by Sandia.

I'll speak about more spray issues --

9 spray the region against unsprayed region later -- but yes, 10 we did give credit using a simplified method for the aerosol 11 and for the elemental iodine we still used our old SRP 12 methodology.

13 Now for the annulus effluent gas treatment 14 system -- ch, I'm sorry -- the suppression pool --

O g,,/

15 DR. POWERS:

What did you say you gave for the 16 spray action on elemental :.odine -- you used the old 17 Standard Review Plan methodology --

18 MR. JAY LEE:

Yes.

19 DR. POWERS:

-- there's been a spate of papers 20 published in the last -- one as recently as three years ago 21 and another one maybe 10 years ago, in which people look at 22 different approaches.

When you examined those papers, did 23 you #'ind that they brought nothing new to the table?

I mean 24 that is my conclusion is that they brought nothing new to 25 the table, but I wondered what your conclusion was.

O ANN RTLEY & ASSOCIATES, LTD.

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F 343 1-MR. JAY LEE:

Well, basically the aerosol

.()

2 dominated, 95 percent aerosol, and very little of elemental 3

iodines.

4 DR. POWERS:

Didn't make any difference?

You 5

could change that by factors of 10 and it still didn't make 6

a difference.

7 MR. JAY LEE:

Right, right, right.

8 Annulus effluent gas treatment system -- this is 9

equivalent to the standby gas treatment system and we did 10 not give any credit for the charcoal absorber.

Now they did 11 not ask for it and they do retain the HEPA filters for 12 aerosol removal but charcoal absorber we did not give a 13 credit.

14 Now control room, the HVAC initiation, they

)

15 currently had -- they did have the initiating the system at 16 time zero when they receive the signal, the safety injection 17 signal, but we were able to delay that for half an hour, 18 mainly due to the fission product release timing, so that is 19 another change we were able to make.

1 20 DR. POWERS:

You skilled over deposition in the 21 condenser and suppression pool.

22 MR. JAY LEE:

Oh, I'm sorry.

Yes, deposition in 23-the main condenser -- we did not give a credit because the 24 downstream of MSIV is not seismically designed.

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did not analyze the seismic qualification for the main O

2 condenser.

V 3

DR. POWERS:

It is not just a matter of no credit.

4 They didn't ask for-any?

5 MR. JAY LEE:

They didn't ask for it and we --

6 DR. POWERS:

Didn't volunteer?

7 (Laughter.)

8 DR. POWERS:

Suppression pool?

9 MR. JAY LEE:

Yes, suppression pool we did not 10 give-a credit.

It is just the NUREG-1465 fission product 11 Trelease timing is such a way that when fission product 12 in-vessel release come, why then the containment pressure is 13 not large enough to push it through the suppression pool.

14 We rather used drywell bypass 3eakage.

I think we used 3000

()

15 CFM.

16 DR. POWERS:

That is a healthy leakage rate.

17 MR. JAY LEE:

Right.

18 DR. POWERS:

And Perry has MARK III, right?

i i

19 MR. JAY LEE:

Yes, Mark III containment.

20 DR. POWERS:

So it has a very healthy leakage, 21 drywell leakage.

22-MR. JAY LEE:

Yes.

The control room charcoal 23 absorber, in this case they just reduce the efficiency over 24 charcoal absorber in order to meet 5 rem TEDE control room 25-operator dose.

They reduced from 90 percent removal O~

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efficiency to only 50. percent.

So that is another

'/5 Q

2 relax =ttion.

'3 Allowable engineer safety future leakage would 4

inczease.

They requested to increase by 50 percent from the 5

5 gallons per hour to the 10 gallons per hour.

That is 6

again yet another relaxation.

7 Allowable containment bypass leakage, they 8

increased from 5 to 10 percent.

That is, again, another 9

. relaxation yet 10 Now, suppression pool water PH, this is 11

. controlled, they propose to use sodium pentoborate from 12-their SLC system.

That is the Safety Liquid Control system, 13 and I will address that a bit later about the PH control.

14 For equipment qualification, in the case of Perry, O

(,/

15 they use TID source term, but they also assumed 50 percent 16 of cesium to be in the containment sump already at the time 17 of licensing.

So, therefore, the equipment qualification le was adequate for the Perry case.

19 Now, I am going into some technical issues that 20 Dr. Puuers and ACRS raised.

This is part of my Helsinki 21 tribute.

22 DR. POWERS:

Okay.

For members that may not be 23 aware, a major conference on iodine chemistry was held in 24 Helsinki and Dr. Lee had a chance to attend and I am anxious 25 to find out what transpired at that meeting.

C)

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Mk. JAY LEE:

You know, we invited you, Dr.

'O l

2 Powers.

I think you declined to attend thi.s time.

j 3

DR. POWED9' We don't have as much money as we 4

used to have.

5 MR. JAY LEE:

Okay.

The first item is a chemical 6

form of cesium.

Now, this is -- we debated this for three

]

7 days at Helsinki.

This is only one item.

8 The current interpretation of data from PHEBUS 9

test, that cesium hydroxide was not a form of cesium.

Now, 10 this their statement, but this statement itself really begs 11 the question.

If it is not the cesium hydroxide, then what 12 is it?

Now, they are -- you know, when we asked this 13 question, they would hesitate.

They are cautious about it.

14 I don't think they really know, but they do say, well, we i

o)

(,

15 found the cesium molybdate in the steam generator tube in l

16 the PHEBUS test, but I am not so sure whether that is really 17 the complete form of cesium.

Maybe cesium hydroxide plated 18 first, or maybe it converted to the molybdate form.

Or 19 maybe cesium is perhaps -- some portion of it anyway, was in 20 cesium molybdate form.

21 DR. KRESS:

The basic question is, does it make 22 any difference?

23 MR. JAY LEE:

It is going in the next slide, but 24 it doesn't really.

25 DR. KRESS:

Okay.

I will wait.

I will wait.

[s)

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1 MR. JAY LEE:

Yes.

And we, in our theory, assumed

()

2-that the cesium is really in the' cesium hydroxide form in 3

the Perry pilot plant evaluation.

4 Now, cesium may enter reactor containment in the l

5-form of cesium hydroxide, cesium borate or cesium iodide.

6 Cesium iodide perhaps maybe it is a small fraction, maybe 10 7

percent or so, coming into the containment as form of cesium 8

iodine.

Whereas, matter of fact, the cesium could be coming 9

in as cesium molybdate or cesium zirconate.

But once it 10 gets into the containment, cesium hydroxide may react with 11 the carbon dioxide to become cesium carbonate, or even 12 become cesium bicarbonate.

So it comes in with all the 13 different forms, we know that.

We just don't know the

'14 breakdown, that is the -- that was the problem.

()

15 Now, cesium hydroxide, cesium borate and cesium 16 carbonate are all basic materials, it raises the PH.

1 17 As I briefly mentioned, the PHEBUS FPT-1 cest 18 indicated that cesium molybdate was the chemical form of 19

. cesium deposit on the surface.

I did not really complete 20.

the final report of PHEBUS FPT-1 test result yet.

I am not 21 sure whether that is available now or not, but that is what 22 they have been saying.

23 And then in'the VICTORIA code runs, the Sandia ran 24 this code and they predict that the cesium is indeed 25 primarily cesium hydroxide vapor at the steam generator 1

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inlet.

Then it condenses into the tube and it converts to

()

2 the cesium molybdate.

So this sort of agrees with perhaps 3

the PHEBUS test.

But my point here is, according to 4

VICTORIA code runs, they do see the cesium hydroxide, at 5

least the beginning phase.

6

'Then'the Perry proposed adding the sodium 7-pentoborate from the existing standby _ liquid control system 8

to suppression pool to maintain suppression pool water PH 9

greater than 7.

Now, our -- the confirmatory calculations, 10 this is actually done Oak Ridge for Perry, showed that the 11 suppression pool water PH remained at greater than 7.

I 12 think a value was like 8.4 or so, when cesium is in the 13 chemical form of cesium hydroxide.

14 Now, just a couple of weeks ago, and we ask Cak

)

15 Ridge to redo the calculation, assuming that there is no 16 cesium hydroxide, no contribution from cesium hydroxide.

17 They came back with a calculation showing a little bit less 18 than with the cesium hydroxide, showing something like a 19 range of 8.2 rather than 8.4.

20 Now, the page I have in the Perry Safety 21 Evaluation Report had a table showing the contribution, how 22 much molds came from cesium hydroxide and that possibly 23 misled you, Dr. Powers.

That table, I found out it is not 24 really complete.

Its numbers in the tables are all correct, 25-except it is not complete.

We did not list contribution O

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'from sodium pentoborate, so we will revise that table to 2_

include --

3 DR. POWERS:

That would be very helpful because --

4 MR. JAY LEE:

Yes.

So --

i 5

DR. KRESS:

That was probably most of it.

6.

DR. POWERS:

' Yeah, the sodium pentoborate 1

7 dominates everything here.

8 DR. SEALE:

My recollection is that the PHEBUS 9

experiment diagnostic is not dynamic with regard to the 10 cesium in the sense that you would have to wait until the 11 experiment is over and look to see what the product is, and 12 there is no way to interrogate during the chemistry leading 13 up to the end point to see whether or not there were 14 intermediate steps along the way.

So, you know, if the g_)

15 VICTORIA runs are suggestive of those reactions, and if we 16 believe the VICTORIA chemistry and all, there is not a

-17 surprise here at all, is there?

18 MR. JAY LEE:

No, not really.

Cesium hydroxide 19 itself, I think it is hard to sample and analyse.

20 DR. SEALE:

Yes.

21 MR. JAY LEE:

It is unstable compound, it reacts 22 fast, very reactive material.

23 DR. SEALE:

It is reactive, yes.

24 MR. JAY LEE:

Yes.

So they just -- they approach 25 it, I think, by process of elimination.

They found the O

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cesium molybdate and so it is great, but they just don't II 2

know what was in it before, particularly in the vapor form.

\\~/

3 DR. POWERS:

I mean these guys are caught in a 4

situation of grasping at any straw that comes along that l

5 will give you a hint of what the chemical form is and a lot l

l 6

of it comes from coincidences, that is, you find cesium and 7

you find moly and they.are'always together, so you say, 8

well, it is must be cesium molybdate, and it may not even be 9

that cesium molybdate, it may be one of the higher 10 molybdates.

They run thermal gradient tubes and they find 11 out deposition doesn't occur where you would expect for 12 cesium hydroxide, but it does occur where you would expect 13 for cesium molybdate or any other mixed oxide like 14 zirconate, uronate, or something like that.

So they are

(.

15 really grasping at straws here.

16 DR. KRESS:

The moly is the primary circuit, too.

17 DR. POWERS:

No, the moly is actually released 18 material.

19 DR. KRESS:

It is released?

20 DR. POWERS:

Yeah.

l 21 MR. JAY LEE:

Yes, it is fission product.

l l

22 DR. POWERS:

There is a bunch of it.

l 23 DR. KRESS:

There is a enough of it to pile up 24 with the cesium.

25 DR. POWERS:

Oh, yeah, there is a ton of it.

)

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DR. SEALE:

It is all that moly 99 in the --

()

2 DR. POWERS:

There is a bunch of moly in the

'3 system.

4 DR. KRESS:

Why does VICTORIA wait for it to get 5

on the surface before it converts then?

6 DR. POWERS:

I mean what is happening is that the 7

moly at the 700 degree centigrade just isn't stable enough 8

to reduce the cesium hydroxide vapor pressure.

l 9

DR. KRESS:

I see.

10 DR. POWERS:

And so it is really a condensed phase 11 conversion that -- and, again, it need not be that 12 molybdate.

That is what they have in VICTORIA, but there is 13 a bunch of molybdates.

You know, just start adding MO3 into 14 the formula, and in pairs, and pretty soon you get these

/%

(_j/

15 horrible long chains.

16 DR. KRESS:

VICTORIA uses equilibrium.

17 DR. POWERS:

Its speciation is done based on -- I 18 mean it is a dynamic.

19

.DR.

KRESS:

It is a dynamic, you put some rates 20 into in and that species based on --

21 MR. JAY LEE:

Okay.

So we will revise that 22 particular table in SER, adding the contribution from sodium 23 pentoborate.

24 The other subject area if formation of organic 25 acid.

Again, we talked about this a great deal and there O

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was a paper in Helsinki workshop about this formation of 2

organic acid.

Radiolysis of organic compounds such as 3

mainly the paint in the containment is ended up in the 4

containment sump water to form organic acid, now such as I

5 formic acid and acetic acid.

Now, these acids are -- is 6

weak acid, really, compared to the inorganic acids such as 7

hydrochloric acid or nitric acid, for example, and they do i

8-lower the PH.

9 But one point I would really like to point out 10 here is the end product of this formic acid and acetic acid 11 is carbon dioxide.

It will come to the -- eventually, it 12 becomes carbon dioxide, we just don't know how long it will 13 take to become a carbon dioxide.

And we will -- we did not 14 consider this particular item or formation of organic acid 15 in the Perry pilot plant, but we will review this work 16 regarding the formation of organic acid and we will address 17 its potential contribution to the PH in our next pilot 18 plant.

19 And the other two areas, really, this paper did 20 not mention, but didn't go into is, of course, paints.

How 21 much of paint material is in the sump water?

I think what 22 she did was she just added for her benefit, she added methyl 23 ethyl ketone solution, which is common organic source of 24 paint.

So she just added this ketone solution into the 25 water, then they checked -- she did her experiment.

So O-ANN RILEY & ASSOCIATES, LTD.

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there is two information about amount of organic material

()

2 such as paint in the sump and how it is leaching out, and 3

how much it is really soluble in the water.

That 4

information is not in the paper and we will look into that 5

and see what are the contribution to the PH value from this 6

organic acid.

We still strongly believe that the 7

hydrochloric acid is perhaps major contributing factor for 8

the PH value.

9 And this phenomena is not new but this work is a 10 bit new and we will certainly look into that.

11 DR. POWERS:

It's the arguments that they make on 12 the magnitude of the phenomenon that is so new.

You put 13 organics into water and they oxidize and then they go from 14 ketones to acids, like you say, to CO2 eventually.

They are

()

15.

making claims on an enormous effect that nobody else seems 16 to have seen anyway, and like you say, I mean the experiment 17 comes from dumping a bottle of methyl ethyl ketone into the 18 water.

19 MR. JAY LEE:

Right.

That simplifies the whole 20 experiment.

21 DR. POWERS:

Makes it simpler.

22 MR. JAY LEE:

Right.

23 DR., POWERS:

Makes the analysis a little tough 24 though.

25 MR. JAY LEE:

And for us to make use of such k-)'

/

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~1 information, it is difficult and certainly we will look into (A) 2 it..

We will see her follow-up work on this area.

We will 3

address that.

4 Now the electrostatic charges of aerosol 5

particles, this I addressed just a little bit last November.

6 I think we believe we discussed it.

We haven't changed our l

l 7

position that we still believe that neglect of electrostatic 8

charging effect is conservative.

I 9

Like I mentioned previously, no individual 10 particle will have any particular one charge for a long 11 time.

It changes constantly and the effect of charging j

12 could go either way.

It could enhance formation of a 13 particle there for enhancing the deposition or it could 14 inhibit the aerosol deposition.

It could go either way.

O

(,,/

15

.We just don't have any plan at this time to do l

16 anything with this.

Now we would certainly like to hear 17 from the committee.if you feel strongly otherwise.

We will i

l 18 not do anything.

19 DR. POWERS:.The fact is that there is nothing you 20 can do right now.

I mean there is no technology in this 21

area, i

22 MR. JAY LEE:

Right.

23 DR. POWERS:

What the problem comes down to -- you 24 have -- we are very confident in our ability to predict 25 aerosol's behavior under accident conditions.

We can retest i

[\\~-)

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it against a lot of experiments and they do very well.

If 2

"very.well" is defined factors of two accuracies, they are i

3 not unreasonable in these circumstances, but the problem is

)

4 none of those tests have ever tested the effects that are f

1 5

peculiar to nuclear aerosols, which is the charging 6

phenomena.

7 We'd probably get some information in principle 8

out of the PHEBUS program, but they have created a 9

containment that is so complicated none of the codes can 10 analyze it, so you just don't know what to do with this 11 charging effect.

I mean your slide'is absolutely accurate.

12 It could go either way, and there have been 13 arguments-that have been put out in the literature that say, 14 well, because of the irreversibility nature of it it is 15 probably conservative to neglect it, but nobody has ever 16 confirmed that.

I mean it is just a conundrum for the 17 entire aerosol community.

In a regulatory sense I don't see 18 how you do anything with it.

19 MR. JAY LEE:

I brought up this item since you 20 pointed out that --

21 DR. SEALE:

Yes, I should think in any event any 22 aerosol is going to have electrostatic effects with it and 23 they are part of the experimental data that has already been 24 in the assessment.

25 DR. POWERS:

That's right, every particle out

[}

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~there is charged,~but the distribution in charges has peaked 2

around zero.

3 DR. SEALE:.Yes 4

DR. POWERS:

Here what is happening is that that 5

peak is being up and down and it is exactly what Jay says 6

here is that if I look at one particle at any one time it 7

can have a charge from plus to minus,.several pluses to --

8 and it changes all the time because it is produced by this 9

flux of ions coming in on the particle and as soon as it 10 gets positively charged the negative ions flux in and 11 they -- but that flux is not self-regulating.

I mean as 12 many ions come in as can get there and so that will switch 13 it from positive.to minus and --

14 MR. JAY LEE:

And vice versa.

(D s,/

15 DR. POWERS:

Yes, and it is a very difficult thing 16 to analyze and the one thing you can't do is analyze an 17-average particle now all of a sudden and everybody knows, I 18 mean there's some work going on in Great Britain to try to 19 look at it and all they are finding is that outside of an 20 intense radiation field it is very difficult to work with 21 these things.

You can't preserve the charge.

22 I think this slide simply says yes, there is a 23

. piece that we just don't know right now.

24 MR. JAY LEE:

Dr. Powers, you also mentioned in

.25 your comment about aerosol shape factors.

Now the

,O.

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uncertainty in aerosol shape factors from the simplified

()

2 model. developed by Sandia is incorporated into the RADTRAD 3

code and we use the RADTRAD code for the dose calculation, 4'

so it is all in it, and we use the integrated probabilistic 1

5 treatment of uncertainty of major parameters such as aerosol L

6 shape factors, aerosol size, aerosol densities, and this 7

probabilistic use of whether you use 90 percentile 8

confidence level or 50 percent of your best estimate or 10 9

percent.

)

10 In the case of Perry we used 90 percent.

11 DR. KRESS:

When you do this uncertainty 12 treatment 13 MR. JAY LEE:

Yes --

1 14 DR. KRESS:

-- you have a value of the two shape

)

/7'\\

(J,/

15 factors but you vary it at time zero and it stays that way 16 throughout the whole calculation?

Varies with time?

17 DR. POWERS:

It is the integrated thing that he is 18 talking about there at a size-dependent shape factor.

j 19 DR. KRESS:

Size dependent shape factor?

20 DR. POWERS:

Right -- so that it essentially says 21 that primary particles are spheres and that as they 22 agglomerate together the shape factor is changing --

23 DR. KRESS:

Varies up to a constant value.

24 DR. POWERS:

Right.

Essentially you have a 25 spherical envelope but because of the packing things, you l

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20036 (202) 842-0034

g 358 l'

have a size-dependent shape factor.

j )

l 2

So.it varies over the course of the agglomeration 3

but also where you start and the slopes of that variation 4

change as you go.through the changing phases of the process 5

by randomly sampling from the uncertainty distribution on 6

things like what are the primary particle sizes and what are 7

the packing fractions --

8 DR. KRESS:

Plug it into the model --

9 DR. POWERS:

Yes, it is a Monte Carlo type of i

10 thing and then it integrates all that and then it gives 11 this.

]

i 12 DR. KRESS:

It is not bad.

Not bad.

13 MR. JAY LEE:

I think this will go more and more 14 to this probabilistic approach based on our confidence

]

()

15 level, how confident you are going to be.

16 DR. POWERS:

Do we have some way to predict what 17 the shape factors are?

I mean the only thing you can do is 18 treat it as an uncertainty and you say, well, you know, the 19 one thing I know is that the lowest shape factor is one and 20 the upper bound is probably, what, a chain or something like 21 that?

You know, chains kind of wrap around each other, 22 maybe it's four or five, so that, okay, I have no idea what 23 the distribution is on that but maybe it's roughly peaked in 24 the middle or something like that, so it even changes, even 25 that shape of that distribution gets changed.

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359 1

DR. SEALE:

You just don't know.

(~N t

j 2

DR. POWERS:

You are really in a blind here and I V

3 think what they have done on RADTRAD is about the best they 4

can do right now.

5 DR. KRESS:

It does sound like it.

6 DR. POWERS:

It is uncertain and I will treat it 7

and what else can you do?

You are right at the edge of 8

technology here.

This business of predicting shape factors 9

is the stuff that the EPA is spending millions of dollars 10 on, trying to figure out how to do it, and they haven't got 11 a good algorithm yet.

12 DR. KRESS:

I have been out of the business 13 awhile.

What is RADTRAD?

Is that a U.S.

code?

Is it like 14 CONTAIN?

O(_,)

15 DR. SEALE:

Jay's code. He is talking about his 16 baby there.

17 MR. JAY LEE:

RADTRAD is NRC code we are using for 18 the dose calculation developed by Sandia.

19 DR. KRESS:

In it is there use of full Smalakowsky 20 equation for aerosol agglomeration?

21 MR. JAY LEE:

Yes. Aerosol properties itself is l

22 already built into the code, taking it from the simplified l

23 model and not only the aerosol behavior and transport but l

l 24 sprays and all the fission product transport and this 25 modelling is in the code.

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20036 (202) 842-0034 f

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360 1

DR. KRESS:

I'm sorry, I haven't had a chance to

()

2 review your code, Jay.

I have to look at it.

3 MR. JAY LEE:

It is a rather thick document.

4 DR. KRESS:

I'll have to look it over one of these 5

days.

6 MR. JAY LEE:

Now the last technical item I would 7

like to bring up is containment spray coverage.

This is --

8 again Dr. Powers raised his concern on this subject area.

I 9

We consider when we do the dose calculation we 10 considered the spayed and the unsprayed areas in the 11 containment -- in other words, we already divide the 12 containment into the two nodes, so therefore the containment j

13 leakage occurs from the sprayed region as well as unsprayed 14 region, so that is really not to do with the spray removal

()

15 coefficient itself, but its genesis from both regions.

16 DR. KRESS:

How did you decide to partition the 17 rate of leakage from containment?

18 MR. JAY LEE:

Containment leakage is a design 19 value.

20 DR. KRESS:

I know, but you say you have two 21 nodes.

22 MR. JAY LEE:

Yes -- so let's say 40 percent is 23 unsprayed area, the 60 percent is the sprayed area --

24 DR. KRESS:

So you say 60 percent of the leakage 25 goes --

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20036 (202) 842-0034

I I

l I

361 ll MR. JAY LEE:

So you are dividing the activity

()

2 accordingly and assuming certain mixing efficiencies and 3

.then your releases from each node directly to the 4-environment, depending on how we do the sprayed and j

i 5

unsprayed region.

J L

6 DR. KRESS:

Okay.

7 MR. JAY LEE:

Now Dr. Powers, it comes to my 8

Helsinki trip report.

9 (Laughter.)

10 MR. JAY LEE:

This we talked about for three days 11 over there -- the iodine source term management in the 12 reactor accident.

We have three aspects here.

13 The first line of defense is of course pH control.

14~

We do this by chemical additives such as sodium hydroxide,

()

15 trisodium phosphate or sodium pentoborate, and we do have 16.

some disagreement with the Europeans and the Europeans 17

.always think more about it in terms of organic acids.

18 And conversion of iodine into organic forms.

But 19 we still believe, and Oak Ridge does too, we think the 20 really major influencing is pH, is inorganic acid, j

L 21 hydrochloric acid, nitric acid and sulfuric acid.

1' 22 Now, Ed Beame at Oak Ridge, he actually, you know, 23 did some tests using Hypalon at Oak Ridge.

They irradiated l

24 a piece of Hypalon and they measured the release of 25 hydrochloric acid, and I'm having some difficulty convincing O-ANN RILEY & ASSOCIATES, LTD.

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362 1-these Europeans that hydrochloric acid is indeed a major t ()

2 source, but they don't seem to quite come along with that 3

. idea as yet.

4 DR. POWERS:

I'm sympathetic with your problem on 5

that.

You have this particular reaction has been known 6

since they invented polyvinyl culoride.

I mean, one of the 7

first things they did was irradiate the stuff, and they 8

found HCL coming off.

It's been in the literature forever, 9

and,.like you say, those -- they're resistant, to say the 10 least.

11 MR, JAY LEE:

Right.

And the second line of 12 defense is, of course, containment spray.

Now, spray, this 13 will be operating relatively short period, let's say matter 14 of hours or perhaps not more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, removes iodine

()

15 in aerosol, not organic form but obviously the iodine in 16 aerosol form and inorganic forms.

17 Then the third line of defense is we have in the 18-U.S.

a really good engineered safety feature filtration 19' system.

Now, this system -- the U.S.

filters, we remove all 20 forms of iodine.

Now, this charcoal absorber we have is all 21 impregnated with TEDA, we call T-E-D-A.

It's triethylene 22 diamine impregnated charcoal, which creates a very efficient 23 site for physiochemical removal of iodine into the charcoal 24 absorber.

25 Now, Europeans, their filters are not -- I don't

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20036 (202) 842-0034 l

l

363 1

think it's all impregnated.

They're warning about the

()

2 organic iodine and the conversion of iodine into the organic 3

inside.the containment for 30-days or whatever the period l

4 and all that.

.But-actually, we -- as a matter of fact, in 5

the U.S.,

we have not only TEDA impregnated, but also 6

potassium iodine impregnated, core impregnated, which is 7

excellent' media for removing the organic iodine.

8 Over there in Europe, their filter is not as good 9

as ours, obviously.

10 DR. POWERS:

That is interesting.

11 MR. JAY LEE:

Now, I have last slide here for some 12 future considerations for the iodine source term management 13 under consideration.

14 Now, Europeans, they talk a lot about the silver

)

)

15 reaction with iodine.

I think I agree with that.

You know, 16 most of Westinghouse PWR control rod will have silver, and 17 the silver reacts really favorably with iodine, forming a i

18 silver iodine.

Once they form silver iodine, they stick and 19 they retain iodine in the containment sump.

So really, if 20 you threw in lots of silver iodine, the metal silver, 21 actually they will promote retaining iodine in the sump.

We 22 don't give any credit as yet for the Westinghouse PWR 23 containment sump having silver in it, but there are quite a 24 few papers in Helsinki showing that indeed silver acts 25

.really good retaining the iodine in the water.

O%

ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C.

20036 (202) 842-0034 l-

364 1-DR. KRESS:

How would you keep the silver I \\

2 dispersed in the water?

U 3

MR. JAY LEE:

Pardon?

4 DR. KRESS:

If you used it as management --

5 MR. JAY LEE:

Yes.

6 DR. KRESS:

-- by putting silver in the water 7

ahead of. time, how would you keep it dispersed in the water, 8'

keep it'from settling?

9 MR. JAY LEE:

You mean how are we mixing silver in 10 the water.

I don't know yet.

I really haven't thought it 11 out.

12 DR. KRESS:

That part hasn't been designed yet.

13 MR. JAY LEE:

Yes, hasn't been designed.

14 DR. POWERS:

As a mitigation technique, I don't

)

15 know that anybody is seriously looking at putting silver in, 16 though there is a Japanese paper that advocates that, and 17 they've suggested things like putting in silver wire foils 18 that float and move around and things like that.

19 The question I always that on that is, yeah, you 20 form silver iodide, but any prankster from high school knows 21 that when you form silver iodide, that it -- and set it out 22 in the air, it promptly turns into silver metal and stains 23 teacher's hands and things like that, it's great fun.

Have 24 I done something like that?

No.

I've only heard that this 25 could be done.

["N ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 1

Washington, D.C.

20036 (202) 842-0034

365 1

[ Laughter.]

()

2 DR. POWERS:

So, you know, if a visible photon can 3

cause silver iodide to decompose back into iodine gas and 4

silver metal, what in the world does a gamma or worse yet a 5

beta do to this material.

Okay.

So this idea that you 6

would put the iodine in and it would suck up all the -- the 7

iodine would get sucked up as silver iodide and the iodide 8

probably goes away I think is maybe a little optimistic, 9

that, in fact, yes, it will absorb some of the iodine, but 10 you'll get a steady state concentration where you're having 11 silver iodide being formed and then simultaneously 12 decomposed because of the -- the fact is the iodine is 13 radioactive and you slam one of these electrons through a 14 silver iodide crystal, it causes multiple reduction events O(_)

15 to occur.

Anybody that has ever tried to look at 16 photcgraphic film under an electron microscope knows that 17 you can't do that, 18 DR. KRESF.

It disappears.

19 DP

9ERS

Well, the little crystals quickly 20 turn into metailf c silver just from the electron 21 bombardment.

22 So I'm not sure that the enthusiasm that multiple 23 papers that showed up in Helsinki over silver iodine is an 24 answer to a maiden's prayer here on this issue.

It helps, 25 but so does the next item on this list there, the zinc O

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Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C.

20036 (202) 842-0034

366 1

issue.

I mean, lots of things help, but I don't think it 2

gets you out of the woods entirely.

3 DR.' SEALE:

And if you turn the lights on, it just 4-gets. worse.

5

[ Laughter.]

6.

MR. JAY LEE:

You mean actual application of it 7-really is too ideal at this time.

But we did talk about 8-that and there was current -- a few number of papers

-9 concerning that subject area.

10 Then, of course, we continued the participation of 11 severe accident fission product behavior research, such as 12 PHEBUS, I think.

There was a paper yesterday by the 13-research describing PHEBUS tests.

We are following them 14 very closely.

I think, as a matter of fact, next March or 15 so, they are going to have information meeting?

16 DR. POWERS:

That's right.

That's right.

And I 17 18 MR. JAY LEE:

And you will be --

19 DR. POWERS:

No, I think Dr. Kress is going to try 20 to attend there.

21 DR. KRESS:

I may be there this time.

22 MR. JAY LEE:

I hope my management will.

My i

23 management is sitting over there.

24 DR. POWERS:

I hope your management sees how much 25 you gain by attending that Helsinki conference.

.O ANN RILEY & ASSOCIATES, LTD.

U l

Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C.

20036 (202) 842-0034

367 1

[ Laughter.]

()

2 DR. POWERS:

Did that help, Jay?

3

[ Laughter.]

4 MR. JAY LEE:

Thank you very much.

-5 DR. KRESS:

What we need to do before we adjourn 6

is to decide on what to do at the full committee.

We have

.7 the full committee September meeting, an hour for this 8

subject, two hours for this subject, which basically says to 9

me I think we could repeat basically all of these i

10 presentations, j

11 DR. POWERS:

I think the presentations today were j

12 just excellent.

13 DR. KRESS:

Yes.

14 DR. POWERS:

Both of them were just outstanding f

15 presentations.

16 DR. SEALE:

Yes.

I want to compliment them.

If 17 you talk about the Helsinki meeting, that it was sort of in i

18 jest for a minute there with regard to this other issue, but E19 quite frankly, I was very pleased with what we got.

I 20.

thought it was to the point and very useful.

21 MR. JAY LEE:

Thank you.

22 DR. POWERS:

And a well designed presentation.

23 DR. SEALE:

Yes.

24-DR. POWERS:

So I would advocate to the extent 25 that we can just give this to the full committee.

I think O.

ANN RILEY & ASSOCIATES, LTD.

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20036 (202) 842-0034

368 1-they need to hear the full story.

()

2 DR. KRESS:

Well, what I would say is I think we 3

need all of these, and I don't think -- I'm not sure we can, 4

in two hours, cover all of Jay's and these, and we may want 5-to -- Jay may want to --

6 MR. JAY LEE:

Condense it.

7 HDR. KRESS:

Condense yours just a little.

8 MR. JAY LEE:

Yes.

i 9

DR. POWERS:

I think if he focuses more on what 10 they did for the pilots and less on the technical issues, we 11 can count those technical issues as satisfactorily handled 12 and then focus more on just what they did for the pilots.

13 DR. KRESS:

And I think our letter, if soon we 14 have one, which I'm pretty sure we will,.is going to focus 15 on the rule itself.

16 DR. POWERS:

That's right.

17 DR. KRESS:

That's why I -- this is going to help 18 us focus on the rule, but I don't think we're going to be in 19 a position to say too much about the pilot plants other than i

20 we're glad you got them and it looks like good stuff.

21 DR. POWERS:

Well, I think it's probably 22 worthwhile to point out to the committee the last couple of 23 slides, which says future considerations, things you're 1

24 thinking about.

That shows that you're on top of the 25 technology.

And I think it's worthwhile for the full ANN RILEY & ASSOCIATES, LTD.

\\

Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C.

20036 (202) 842-0034

I' 369 1

committee to understand that you are on top of the

'2 technology here.

3 DR. KRESS:

Yes.

That is helpful.

4

-DR.

SEALE:

The other point I would make is that 5

somehow or another, we need to have enough in here to be 6

able.to make the observation that the treatment of the 7

pilots has been done in a very technically sound way and

)

8 very complete way, and that the only way you can do that is 9

if you're on top of the technology and it's clear that they 10 are.

So to the extent that you -- sure, the pilot is the 11 product that the Commissioners are interested in, certainly 12 the NEI people who make value judgments about the things 13 that are going on and so on are interested in and all of 14 that; but it's up to us, I think, to make the point that

)

15 that expeditious treatment of those pilot applications is a 16 result of knowing what the technology is and applying it in 17 a responsible way.

So we need that much.

18' Maybe you want to put your slides that dealt with 19 the technical issues as just an addendum on the back so that 20 there's something in the record that says we got some 21 technical -- a summary of the technical data.

.22 MR. JAY LEE:

Okay.

23 DR. KRESS:

Before I adjourn, I 11 give anybody 24 else an' opportunity to -- you're fine.

25 Well, good _to see you, by the way.

/

t ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C.

20036 (202) 842-0034

p I

370 fi-1 DR. POWERS:

I wonder if we -- since we do have

(

2 some time relative to the planned agenda, do we want to take 3

a break and come back and discuss a little bit on our --

4 what we want to put together for the research report?

5 DR. KRESS:

Okay.

I can adjourn this meeting.

6 So at this point, I'll adjourn the meeting.

7

[Whereupon, at 10:43 a.m.,

the meeting was 8

concluded.)

9 10 l

11 12 13 14 15 1

16 17 18

)

19 20 21 22 23 24-25 ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C.

20036 (202) 842-0034

r 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:

MEETING:

SEVERE ACCIDENT MANAGEMENT CASE NUMBER:

PLACE OF PROCEEDING:

Rockville, MD were held as herein appears, and that this is the original

)

transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and I

accurate record of the foregoing proceedings.

i I

7A Mark Mahoney

[

Official Reporter Ann Riley & Associates, Ltd.

q ss

]

~

d

(")

v Implementation of Alternative j

Source Term at Operating Reactors f-o, Final Rule 10 CFR Parts 21,50,54 g

i Draft Guide DG-1081 i

sl' Draft SRP 15.0.1 B

Presentation Before ACRS Severe Accident "1anagement Subcommittee i August 10,1999 Stephen F. LaVie NRRIDSSA/SPSB L,_,

u..f% - n-, - omw

• e O

l I

Outline

• Status of final rule

• Changes between proposed & final rule

• Changes during office concurrence

• DG 1081 objectives

• DG 1081 highlights

• Scope of implementation oScope of reanalyses

• AST impact t

• Extended burnup fuel pg clodine species

• Methodology updates O

_.=

1

y.

1 6

Final Rule

• Objective

• To enable use of alternative source terms by operating reactors oEstabilsh TEDE criteria l

• Conforming changes for Part 52

• Published as proposed rule on March 11, 1999

• Seven public comment letters I

fg*No objection to publishing rule (M)

~ < -,-

o,. -, -.;

O Proposed -+ Final Rule

• Definition of " source term" changed to reflect the way it is used in draft guide and to address public comments

• Old

• Source Term refers to the magnitude and mix of radionuclides released from the reactor core to the reactor containment, their physical and chemical form, and the timing c!their release.

• New

• Source Term refers to the fractions of fission product inventory of radionuclides released from the reactor fuel, their physical and chemical form, and the timing of their release, i

f%

1 3

h of Alserene==.5 mar'reas se operemag tramrs =:

P 2

i

O Changes During Office Concurrence

• Change definition of Source Term

• Editorial clarifications & typos

• Revisions to text of some public comment responses

• Revision to environmental assessment evaluation-same endpoint

• Voluntary consensus standard requirement addressed i

i l

7%

(W)

O Draft Guide-1081 j

• Objective l

• Provide guidance for implementing rule.

• Maintain traditional design basis, deterministic I

basis

• Provide acceptable source term l

• Provide guidance on what constitutes an l

acceptable alternative source term I

2 Address selective implementation

• Address risk and EPP considerations i r%* Provide acceptable analysis assumptions, L($} incorporating insights from pilots l

(')

____,___,_a 3

6 Scope of Implementation c Full

• Selective

.< Complete replacement of oAST T1014844 with AsT o An enaracteristics

>< Address all characteristics other co inations of AsT j

1. 'M on olmplement TEDE dose Criteria

,rn t d; mey nvoiv.

only a single DBA analysis oMinimum analysis oTechnically justifiable I

requirement is LoCA e<Ma ntain clear, consistent, logical design basis osER limited to particular implementation; other

/%

implementations require i re-submittal under 550.s7

- n.,-..

_, ~,

O i

l Scope of Re-analysis l

! nAll radiological and non-radiologicalimpacts must

! be addressed I

l l *Not a complete re-calculation of design basis l

l *May use scaling / scoping methods to show existing,

analyses are acceptable oExcept: EAB / LPZ / CR doses should be calculated end-to-end off a calculation is to be performed to support implementation, or to support future modifications, AST and TEDE should be used (per design basis) i 7%

......h G

l P

4

_u AST mpact

• Licensees may use insights from re-baselining study to discount many AST impacts i

• Analyses based on TID 14844 and whole body / thyroid bound i

those based on AsTand TEDE

• Not true for containment sump sources over long term due to increased cesium

• Most regulatory dose requirements are based on 30 day exposure

• lmpact of cesium on environmental qualification doses being addressed as a generic issue

• Draft guide may be revised as this issue is resolved s s

(.M)

- e--

= -.n, a

O Extended Burn-up Fuel

• NUREG-1465 contained disclaimer that the source terms may not be applicable for fuel irradiated to high burnup levels (in excess of 40 GWD/MTU)

• Draft guide applicable to 62 GWD/MTU 1

• Rationale is in attachment to Regulatory Analysis oChange in gap activity fraction oChanges in core inventory, spectrum shift

• RIA (RDA, REA) being determined on a case-by-case basis. Ongoing research I

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odine Species

• LOCA / BWR MSLB / PWR LRA(cnmt) 095% Cst,4.85% elemental,0.15% organic

1. From NUREG-1465

• ECCS leakage oS7% elemental,3% organic s Assume retention of aerosol and particulate

• Assume 3% conversion of elementalto organic

• FHA c99.75% elemental, 0.25% organic (from RG 1.25)

• Releases via steam generators / main condensers 097% elemental,3% organic f~

(M)\\

OSame basis as EcCS O

I Methodology Updates

• New containment spray removal models

• Allow credit for main steam line deposition (BWRs)

• Base fuel damage on integrated enthalpy rather than DNBR

• Except: RDA/REA

• Reduced iodine spike multiplier (335 vs 500)

• Allow BWR CNMT & MSIV leakage rate to be reduced 50% after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> l

• Rad. analysis of LRA not required unless fuel damage is postulated r'%

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