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Transcript of Advisory Committee on Reactor Safeguards Reliability and PRA Subcommittee Meeting - April 4, 2018, Pages 1-255
ML18135A047
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Issue date: 04/04/2018
From: Christiana Lui
Advisory Committee on Reactor Safeguards
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Lui C
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NRC-3626
Download: ML18135A047 (255)


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Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION Title: ACRS Reliability and PRA Subcommittee Docket Number: N/A Location: Rockville, Maryland Date: April 4, 2018 Work Order No.: NRC-3626 Pages 1-2 NEAL R. GROSS AND CO., INC.

Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.

Washington, D.C. 20005 (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005

-3701 www.nealrgross.com 1 1 2 3 DISCLAIMER 4 5 6 UNITED STATES NUCLEAR REGULATORY COMMISSION'S 7 ADVISORY COMMITTE E ON REACTOR SAFEGUARDS 8 9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.

15 16 This t ranscript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.

19 20 21 22 23 1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

+ + + + + ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS) + + + + + RELIABILITY AND PRA SUBCOMMITTEE

+ + + + + WEDNESDAY APRIL 4, 2018

+ + + + + ROCKVILLE, MARYLAND

+ + + + + The Subcommittee met at the Nuclear Regulatory Commission, Two White Flint North, Room T2B1, 11545 Rockville Pike, at 1:00 p.m., John Stetkar, Chairman, presiding.

COMMITTEE MEMBERS:

JOHN W. STETKAR, Chairman RONALD G. BALLINGER, Member DENNIS C. BLEY, Member VESNA B. DIMITRIJEVIC, Member WALTER L. KIRCHNER, Memb er JOSE MARCH

-LEUBA, Member DANA A. POWERS, Member

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-3701 (202) 234-4433 HAROLD B. RAY, Member JOY L. REMPE, Member MATTHEW SUNSERI, Member DESIGNATED FEDERAL OFFICIAL:

CHRISTIANA LUI ALSO PRESENT:

PAUL AMICO, Jensen Hughes SUSAN COOPER, RES KAYDEE GUNTER, Jensen Hughes*

J. S. HYSLOP, NRR JEFF JULIUS, Jensen Hughes ASHLEY LINDEMAN, EPRI SEAN PETERS, RES MARY PRESLEY, EPRI MARK SALLEY, RES

  • Present via telephone

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-3701 (202) 234-4433 T-A-B-L-E O-F C-O-N-T-E-N-T-S Opening Remarks

................................

....4 John Stetkar, ACRS Status of Joint NRC/EPRI HRA Project for MCRA Scenarios in Fire Events

..........

9 S. Cooper, RES Updates to NUREG

-1921, Supplement 1

...............

15 A. Lindeman, EPRI M. Presley, EPRI Overview of NUREG

-1921, Supplement 2

..............

54 S. Cooper, RES Supplement 2

- Decision to Abandon LOC Scenarios

................................

.....92 M. Presley, EPRI Supplement 2

- C&C Impact on Safe Shutdown

........58 S. Cooper, RES MCRA HRA Project Status and Path Forward

.........197 S. Cooper, RES A. Lindeman, EPRI M. Presley, EPRI Public Comment................................

...200 Discussion Among Members

.........................

201 Adjourn................................

..........

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-3701 (202) 234-4433 P R O C E E D I N G S 1 1:00 p.m. 2 CHAIR STETKAR: The meeting will now come 3 to order. This is a meeting of the Reliability and PRA 4 Subcommittee, the Advisory Committee on Reactor 5 Safeguards.

6 I'm John Stetkar, Chairman of the 7 Subcommittee Meeting. ACRS members in attendance are 8 Ron Ballinger, Dennis Bley, Harold Ray. I believe 9 we'll be joined by Dana Powers and Matt Sunseri, Jose 10 March-Leuba, Walt Kirchner will join us, Joy Rempe, and 11 Vesna Dimitrijevic. Christiana Lui of the ACRS staff 12 is a designated federal official for this meeting.

13 The subcommittee will hear presentations 14 on the Joint NRC EPRI project on main control room 15 abandonment, human reliability analysis in fire 16 probabilistic risk assessments, in particular, the 17 draft quantification guidance.

18 The subcommittee will gather information, 19 analyze relevant issues and facts, and formulate 20 proposed positions and actions, as appropriate for 21 deliberation by the full c ommittee. 22 The ACRS was established by statute, and 23 is governed by the Federal Advisory Committee Act.

24 This means that the committee can only speak through 25 5 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 its published letter reports. We hold meetings to 1 gather information to supp ort our deliberations.

2 Interested parties who wish to provide 3 comments can contact our office requesting time, after 4 the meeting announcement is published in the Federal 5 Register. 6 That said, we also set aside some time for 7 spur-of-the-moment comments from members of the public 8 attending or listening to our meetings. Written 9 comments are also welcome.

10 The ACRS section of the USNRC public 11 website provides our charter, bylaws, letter reports, 12 and full transcripts of all open full committee and 13 subcommittee me etings, including slides presented at 14 these meetings.

15 The rules for participation in today's 16 meeting were previously announced in the Federal 17 Register. We've received no written comments or 18 request for time to make oral statements from members 19 of the publ ic regarding today's meeting.

20 We have a bridge line established for 21 interested members of the public to listen in. To 22 preclude interruption of the meeting, the phone bridge 23 line will be placed in the listening mode during the 24 prese ntations and the committee discussions. We'll 25 6 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 un-mute the bridge line at a designated time to afford 1 the public an opportunity to make a statement or provide 2 comments. 3 A transcript of the meeting is being kept 4 and will be made available as stated in the Federal 5 Register notice. Therefore, we request that our 6 participants in this meeting use the microphones 7 located throughout the meeting room when addressing the 8 subcommittee.

9 Speakers should first identify 10 themselves, and speak with sufficient clarity and 11 volume, so that they may be readily heard. Please make 12 sure that the green light on the microphone in front 13 of you is on when you're speaking, and turn it off when 14 it's -- when you're not. Helps our transcript.

15 At this time please check all of your 16 cellp hones, any other beeping devices, annoying 17 electronic equipment, and so forth, and turn them off.

18 Otherwise, we will smash them.

19 We will now proceed with the meeting, and 20 I call upon Mark Henry Salley of the NRC staff to begin.

21 Mark. 22 MR. SALLEY: Thank you, and good 23 afternoon. I'm Mark Henry Salley. I'm the Branch 24 Chief of Fire and External Hazards and the Office of 25 7 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 Research. I have Sean Peters with me. He's the Branch 1 Chief for Human Factors and Reliability Analysis.

2 I'm going to give you a little opening for 3 this today, and this is another NRC EPRI project that's 4 worked under the joint MOU. I think it's important 5 when we start out, that a number of successes we've had 6 working together with EPRI, in fire PRA, fire modeling, 7 post-fire safe shutdown circuit analysis, and in fire 8 HRAs, you're going to hear today.

9 So, there's a string of things. We work 10 together for a common goal, and we can pull our 11 resources, as you'll see today, and we can come ou t with 12 a high-quality product.

13 You're going to be hearing from Dr.

Susan 14 Cooper from the Office of Research, as well as Ashley 15 Lindeman and Mary Presley from EPRI.

16 But before I turn it over to them, I just 17 wanted to give a little ba ckground here to kind of set 18 the stage for this. In 2005, again, the first big 19 project we worked with EPRI in the fire area, was 20 NUREG/CR-6850. 6850 had a little bit of HRA

-- just 21 a bit, I believe, in task 12 -- and there was clearly 22 identified a need to do more detailed HRA in the 23 risk-inform performance

-based environment.

24 So, we got together, we put a joint team 25 8 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 together. In June 2009, if you remember, they came to 1 the subcommittee and presented the work they had done 2 to-date. In December of that yea r we put a Federal 3 Register notice out with the draft report. We received 4 public comment on it.

5 We came back in April and September of 6 2011, and presented to you. And then we finally 7 published the report

-- NUREG-1921, which is also 8 EPRI-1023001, in July of 2012. 9 So, that was a huge step forward for fire 10 HRA to use in the PRA applications. The one thing with 11 that report where it kind of stops short with the area, 12 and that was main control room abandonment. That 13 wasn't included in that first version of 1 921. 14 And it's interesting, if you look at 15 deterministic regulations if you recall, which for the 16 plans that are the, as we call, Appendix R plans, 17 Section 3G and 3L talk about dedicated and alternative 18 shutdown, which is your main control and abandonment, 19 we needed something for the risk

-informed 20 performance

-based, and also we haven't looked at that 21 topic, if you think about it, since 1981.

22 So this was an area that clearly a lot of 23 work could be done. So, we got the group back toget her 24 to look at this, and

-- check my dates here

-- on 25 9 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 May 4th of 2016 we presented to the group, and August 1 2017 we published Supplement 1 to NUREG

-1921. That's 2 also EPRI 3002009215.

3 And that, of course, is the qual

- -- excuse 4 me, the qualitative HRA appr oach for main control room 5 abandonment.

6 So, the next piece to come up is what you're 7 going to hear about today. And this is the 8 quantitative piece. Before I turn it over, there's one 9 other area I'd like to point out in fire HRA, where we've 10 done quite a bit of work, that some of you may be 11 familiar with, and that's new reg 2180, which is the 12 incipient fire detection.

13 And as we got into that project, we looked 14 at it, we saw that HRA was a key element into doing the 15 incipient fire detection.

16 So, without further ado, I'd like to turn 17 it over to the group here, and get started.

18 CHAIR STETKAR: Green light on, talk, 19 green light off, don't.

20 DR. COOPER: All right, thank you, Mark.

21 Susan Cooper, Office of Research. I'm going to go 22 ahead and kick things off here with the presentation, 23 which, as Mark said, focuses on main control room 24 abandonment, and more particularly, we're going to 25 10 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 spend most of our time on the most recent 1 report -- draft report on quantitative guidance for HRA 2 main cont rol room abandonment scenarios.

3 So, for today, in general, we're going to 4 provide an update to the overall project and, as I said, 5 we're going to want to focus on the second product of 6 the research for main control room abandonment.

7 This particular work is based on -- built 8 on the original fire HRA guidelines, which Mark 9 mentioned, which is NUREG

-1921, that established the 10 basic process of how to do fire HRA.

11 And then, again, as Mark mentioned, 12 NUREG-1921 supplement 1, which is the qualitative HRA 13 guidance for main control room abandonment scenarios, 14 was published in August of 2017.

15 So, those two were the basis for the next 16 product on main control room abandonment. As with 17 those other products, the quantification guidance is 18 built on the experience of the authors, as well as other 19 experts or expertise that we accessed with respect to 20 developing NUREG

-1921, performing NFPA 805 21 submittals, reviewing NFPA

-805 submittals, so on and 22 so forth. 23 This is the last piece of the research that 24 we planned for main control room abandonment, and that 25 11 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 is the quantification guidance.

1 So, the agenda for today is to do a little 2 bit of a review of the project's history and background, 3 including introducing the project team. Because 4 supplement 1, which is on the qualitative analysis, did 5 undergo some changes after we presented to the 6 subcommittee back in May of 2016, we wanted to talk a 7 little bit about what those updates were, responses to 8 comments here from the ACRS.

9 In addition, we had a peer review and peer 10 review comments to respond to, as well. So we will 11 spend a little bit of time talking about those updates.

12 And then, as I mentioned, we like to spend 13 most of our time talking about supplement 2, the new 14 product, which you have in draft form, which is the 15 quantitative guidance for HRA for main control room 16 abandonment scenarios.

17 We're going to give a bit of an overview 18 of how we went about this project, and what guidances 19 we provide. In particular, we divide up, and we'll 20 talk a little bit more about this, divide up the 21 scenarios into what happens before abandonment occurs, 22 what happens during the decision to abandon the control 23 room, specifically on loss of con

- -- for 24 loss-of-control scenarios. And then also, what 25 12 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 happens once you left the control room and you're now 1 implementing your safe shutdown strategy.

2 Then, we're going to wrap up with a quick 3 mention of our status future work and any closing 4 remarks. So, that's the agenda we propose for today.

5 Now -- 6 MEMBER BLEY: Sus an? 7 DR. COOPER: Yes.

8 MEMBER BLEY: Let me just make a little 9 minor, minor point here. I hope you folks have noticed 10 that you haven't been consistent through this report 11 in defining your phases 1, 2 and 3. There are quite 12 a few places where you say, phas e 1 ends at the decision 13 to abandon the control room, which is old speak, I 14 think. 15 DR. COOPER: Okay. We will look for that, 16 but that is true. You're right.

17 MEMBER BLEY: There's at least two or 18 three -- 19 DR. COOPER: That does need to be

-- 20 MEMBER BLEY:

-- places that you'll 21 catch. 22 DR. COOPER: Okay. Okay, good. Thank 23 you. That is definitely an error that will need to be 24 corrected. Thank you.

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-3701 (202) 234-4433 Okay, project history and background.

1 So, for -- specifically for the main control room 2 abandonment project, the fire events, the objective is 3 to provide HRA guidance specifically for those types 4 of scenarios where the fire conditions have been

-- you 5 know, have created the instance where you have to leave 6 the control room

-- the operation has to leave the 7 control room.

8 And there are two different cases that are 9 considered. There's what's called the loss of 10 habitability

-- or LOH -- and that's where it's

-- the 11 conditions in the control room are not such that people 12 can st ay there safely.

13 So, that's one case. And the other one, 14 which is going to be of more interest for today, is going 15 to be loss of control, with the acronym of LOC. And 16 we'll talk a little bit more about those later.

17 We identified i n NUREG-1921 when it was 18 published, that we needed to do more work in main 19 control room abandonment, that we had only gone so far 20 in that -- with that guidance.

21 And part of the reason why we have left it 22 until now is that it is a pretty complex topic with a 23 lot of plant

-specific differences, a pretty wide range 24 of capabilities for the remote shutdown panel, which 25 14 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 also has an associated impact on the procedures and the 1 strategy that you have for shutting down, so that does 2 make it more difficult to develop g eneric guidance for 3 those -- some of those reasons.

4 So, this is the project team specifically 5 for supplement

1. You see on the NRC side Tammie 6 Rivera and I are on the team. Stacey Hendrickson could 7 not make it today, but she's is on one of the bridge 8 lin es that Chris has set up, so I think it's separate 9 from the public line, so if we want to talk to her, we 10 can talk to her. John Wreathall is not available 11 today. 12 And then, on the upper side, both Mary 13 Presley and Ashley Lindeman are here today with me, an d 14 Paul Amigo and Jeff Julius are there in the audience, 15 and Kaydee Gunter is also, I think, on the line with 16 Stacey, and Erin's not made it with us.

17 So, this is the same team we had for 18 supplement 1, with the exception of Nick Melly of NRC 19 is not on the team for supplement 2, which is more 20 HRA-related. He provided

-- there is a stronger PRA 21 element to supplement 1, and they needed his support 22 there. 23 He's going to be a peer reviewer for 24 supplement

2. All right.

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-3701 (202) 234-4433 MEMBER BLEY: Mr.

Stetkar. We did not 1 write a letter on supplement 1, did we?

2 CHAIR STETKAR: We did not.

3 MEMBER BLEY: Are we planning to write a 4 letter on the whole thing, now?

5 CHAIR STETKAR: I think that's something 6 that we should discuss after this.

7 MEMBER BLEY: Okay. They haven't asked 8 for it. 9 CHAIR STETKAR: They haven't asked for it.

10 MEMBER BLEY: Okay.

11 DR. COOPER: Okay. We're now going to 12 discuss some of the updates to supplement 1, the 13 qualitative analysis, and Ashley's going to take over 14 on that. 15 MS. LINDEMAN: Okay. So, we were here 16 about two years ago in May of 2016, when we presented 17 our first draft of supplement

1. And since then, we've 18 done a lot of work. We took the comments from the 19 meeting here and addressed them, that we could. There 20 was other comments that we took that had a longer time 21 frame to resolve.

22 But, we went with a slightly revised 23 version in peer review in the summer of 2016. So, I 24 asked the peer reviewers to review for technical items, 25 16 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 and if it mee ts the needs of the intended users.

1 The peer review comprised a variety of 2 stakeholders, PRA practitioners from both the industry 3 and the NRC, HRA analysts, likewise from the industry 4 and the NRC. And then we also reached out to some 5 cognitive and behavio ral science analysts.

6 So, we also got a lot of feedback from the 7 peer review, which, you know, we incorporated into our 8 final draft. So, EPRI published the report in August 9 of 2017, and as I understand that the NRC version of 10 the report is currently in pu blications.

11 There's been a

-- several changes since 12 the version that you guys last formally received in May.

13 Various edits and clarifications from both the ACRS 14 comments and the peer review comments, so didn't want 15 to go through those kind of one

-by-one, but wanted to 16 acknowledge that there were several places where we 17 found clarification wasn't good.

18 We also felt that we needed some way to walk 19 through the process. In NUREG

-1921 there's a good 20 framework of the HRA process, and we felt since 21 supplement 1 used basis from 1921, we also felt it was 22 necessary to walk through and guide the analysts on what 23 pieces are relevant from 1921, and what pieces of the 24 HRA process are enhanced in supplement 1 in that 25 17 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 guidance. 1 We did add a dual un it timeline example in 2 section 7, which is the timing and timelines. I have 3 a picture of that and we'll go over some of the important 4 tidbits and links between actions and communications.

5 There was a

-- 6 MEMBER RAY: By dual unit you mean a dual 7 unit cont rol room? 8 MS. LINDEMAN: Yes.

9 MEMBER RAY: Okay.

10 DR. COOPER: Dual unit shutdown.

11 MS. LINDEMAN: Yes.

12 DR. COOPER: But

-- 13 MEMBER RAY: Okay, there's so few dual 14 unit control rooms, that's why I asked. There's only 15 one that I know of, so I assume you're not talking about 16 that. Or both units are controlled from the same 17 control room.

18 DR. COOPER: Susan Cooper. Yes, it is for 19 a shared space control room.

20 MEMBER RAY: Okay.

21 DR. COOPER: So, it could be two separate 22 control boards with in a shared space.

23 MEMBER RAY: Yeah.

24 DR. COOPER: There are other ones.

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-3701 (202) 234-4433 MEMBER RAY: All right.

1 DR. COOPER: There are other ones.

2 MEMBER RAY: Right. Well

-- 3 MR. HYSLOP: On the west coast.

4 MEMBER RAY: I wasn't sure. As I said, I 5 just wanted to ask what dual unit, whether it meant two 6 units side by side, or

-- 7 MR. HYSLOP: This is J.S. Hyslop. Yeah, 8 from data 5, you know, just because they're not shared 9 from the same space doesn't mean that you don't have 10 a dual unit shutdown. There's some places that don't 11 have alternate shutdown boards and they just have 12 different panels and things like that, and so you have 13 multiple shutdowns going on at the same time. That's 14 possible. 15 MEMBER RAY: Yeah, absolutely. And I was 16 trying to distinguish between that and the shared 17 control room space.

18 MS. LINDEMAN: All right. One of the 19 other comments that we received from the ACRS was 20 addressing the variability and the capability of the 21 remote shutdown panel design. So yeah, there's a new 22 se ction that looked at a BWR and a PWR and the type of 23 function and capability and instrumentation in the RSDP 24 design, recognizing that each panel, each plant, is 25 19 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 weak. 1 CHAIR STETKAR: Be careful, by the way, 2 Ashley, and folks up front. You've received no 3 c omments from the ACRS on supplement

1. 4 MS. LINDEMAN: Oh, I'm sorry.

5 CHAIR STETKAR: You've received comments 6 from individual members in a subcommittee meeting.

7 So, be careful, because we're on public record. The 8 ACRS has not made any recommendations formally on 9 supplement

1. 10 MS. LINDEMAN: Thank you for clarifying 11 that. Additionally, since the draft in 2016, we 12 continue development on appendix B, which is command 13 and control, so that was more sought out and more 14 developed at the time of publication.

15 We also added appendix Delta, which was 16 insights from operator interviews conducted both by the 17 NRC and the industry.

18 Supplement 1 also introduced three phases 19 of main control room abandonment, and I'll briefly 20 discuss each phase. We have phase 1, which is 21 associated with actions taken prior to the decision to 22 abandon. 23 So, in this scenario we're very early on, 24 and actions are directed, as usual, from the main 25 20 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 control using the EOPs. That's probably the last time 1 we're really going to spend on phase 1, as the 2 supplement 2 really focuses on the quantification 3 differences for phase 2 and phase

3. 4 Phase 2 is the decision to abandon, and 5 there's a little bit different terminology, depending 6 on if the habitability criteria are met, so you're on 7 a loss of habitability situation, or a loss

-of-control 8 situation.

9 And phase 2 is really important for the 10 loss-of-control scenarios where there's time to make 11 the decision, the cues come in and they're developing 12 into a situation where the plant may no t be controlled.

13 How we've defined the loss

-of-control 14 situations is, it's not something like the multiple 15 scurrilous operations less than in fire PRA, where 16 there's a set of equipment involved in a flow diversion 17 or other -- a loss-of-control situation is 18 plant-specific, and it requires an iterative process 19 between the plant operations and the fire PRA and the 20 fire HRA team.

21 So -- so usually the PRA team would come 22 and define conditions that may require abandonment, and 23 they would discuss with the operators to see times or 24 conditions where fires can develop and needs would 25 21 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 exist. 1 So, this is a good example of the iterative 2 feedback between training and procedures.

3 CHAIR STETKAR: And actually, it's 4 presented in the guidance that way, that the PRA people 5 know everything about the scenario and they present it 6 to the operators and ask them, will you leave.

7 That's not the way the real world works.

8 The operators are faced with deteriorating conditions 9 in the control room. They will decide to leave or not.

10 The PRA has to deal with that decision. So, the PRA 11 people should never say, here is the scenario, will you 12 abandon the control room or not, from the scenario 13 perspective of the PRA. Because the PRA is a piece of 14 paper. 15 The operators should be faced with a 16 scenario of, here are the indications that you have, 17 here are the effects of the fire, including 18 non-safety-related stuff, including secondary stuff, 19 including coordinations with whatever's goin g on with 20 the fire brigade. And then ask the operators, under 21 these conditions when do you think you would leave?

22 When do you think you would leave. Not, will you leave?

23 If they say, never, that's good. If they 24 say, well, we don't think, you know, these conditions 25 22 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 are tenable, we would leave, then the PRA has to deal 1 with that, and that's a fundamental problem with the 2 way it's presented in supplement 1, because it's always 3 the PRA analyst presents a PRA scenario to the 4 operators, and asks them, wha t would you do during this 5 PRA scenario? Not, what would you do during a fire.

6 I just make that comment. It's too late 7 for us to have any impact on supplement

1. We might 8 be able to pull that into supplement 2 somehow.

9 DR. COOPER: Susan Cooper, and I'll let 10 Mary talk, too. We'll take a look at that again, but 11 I -- in the -- I think it's section 4 of supplement 1 12 that specifically addresses the decision to abandon, 13 although there's some discussion in section 3, which 14 is the PRA modeling part. But there are two principle 15 criteria for being able to credit loss

-of-control 16 scenarios that we talk about.

17 And one is, that there is explicit 18 procedural guidance that obviously has to have been 19 developed not just from the PRA, but operations has to 20 have agreed to, and they made some decisions.

21 The other one is based on interviews, you 22 get a consensus opinion from the set of operators. And 23 we have even questions

-- guidance questions

-- on how 24 to interview.

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-3701 (202) 234-4433 And at least it was not my intenti on -- nor 1 did I think it said that, but we'll look

-- we'll 2 certainly look and make a correction if needed

-- but 3 the idea was not to feed or lead the operators, per se.

4 It was -- because otherwise you're not 5 going to get the answer you want. You're not going to 6 say, well this is happening, aren't you going to leave, 7 then? 8 No, we don't do that. We try to understand 9 what kinds of situations they think. What's

-- and it 10 might be system

-based, it might be equipment

-based. 11 It depends on plants. So, you're right, if it comes 12 across that way, we should fix it, but that was not what 13 we intended.

14 CHAIR STETKAR: Take a look at the 15 guidance for the operator interviews. My personal 16 opinion is they're very leading. They stress the 17 importance of the PRA expert stressing the importance 18 of the PRA scenario to the operators, so that the 19 operators know it's really important that they know 20 when to leave. Because this is the PRA scenario.

21 DR. COOPER: Okay.

22 CHAIR STETKAR: So, be careful.

23 MS. PRESLEY: Was that last

-- sorry, this 24 is Mary Presley. Was that last comment with respect 25 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 to supplement 1 or supplement 2? 1 CHAIR STETKAR: Supplement 1, because the 2 guidance for the interviews is in supplement

1. 3 MS. PRESLEY: Okay, because there are some 4 specific things, and I think that's an area we've timed 5 for some improvement in supplement
2. So, it 6 wouldn't -- when you look at

-- 7 CHAIR STETKAR: I'm trying to keep 8 separate -- 9 MS. PRESLEY: When we look at phase 2, if 10 you think we still are using that language, please let 11 us know, because I think

-- hopefully, we'll have fixed 12 that. 13 CHAIR STETKAR: I quite honestly

-- we'll 14 get to supplement

2. I didn't see it as much in 15 supplement 2, because supplement 2, you focus more on 16 quantifying human performance within the context of PRA 17 scenarios.

18 I saw it more in supplement 1, and in 19 particular, in the guidance for the interviews, where 20 I felt that they were too focused on a set of predefined 21 PRA scenarios in asking the operators their response 22 within the context of that PRA scenario.

23 You know, you've had a fire that's disabled 24 all feedwater, and you may or may not have control from 25 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 the main control room over the pressurizer PORVs.

1 Would you leave?

2 You know, it's not as blatant as that , but 3 that type of notion, rather than saying

-- there's a 4 whole bunch of alarms. Half of the control room is 5 black. At what point do you lose confidence in your 6 indications, and decide to leave.

7 Regardless of whether or not you have main 8 feedwater, or can control the PORVs, because that might 9 not be the thing that prompts them to leave, you know.

10 We have to get back away from this specific PRA event 11 cut-set mentality and

-- 12 DR. COOPER: Okay.

13 CHAIR STETKAR: So, look at that guid ance 14 for the interviews.

15 DR. COOPER: Okay. Yeah, and

-- Susan 16 Cooper here. Yeah, the team members that are here 17 today, we had some discussion this morning about moving 18 forward with supplement 2 and what improvements we 19 would do next.

20 And we are examining possibilities of 21 providing a roadmap that

-- even better than it does 22 now, shows where 1921 guidances is overarching.

23 Supplement 1 is good enough, supplement 2 has done a 24 better job, and whatever.

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-3701 (202) 234-4433 So, this feedback is very helpful. So, 1 thank yo u. We'll do what we can with it.

2 MEMBER SUNSERI: So, I'm just getting 3 involved and I haven't looked at all the previous stuff.

4 So, let me just ask for my confirmation here. We're 5 talking about situations not solely associated with 6 habitability of the control room, but situations where 7 it may not be the best decision to operate the plant 8 from the main control room. Is that right?

9 MS. LINDEMAN: That is correct, yeah.

10 DR. COOPER: That is correct.

11 CHAIR STETKAR: These, in princip le, 12 could be fires that do not occur inside the main control 13 room itself. Could be out in some instrument and 14 control paneled room that disables, you know

-- I'll 15 use the technical term, snarky. Makes all of your 16 displays look kind of snarky.

17 MEMBER SUNS ERI: Yeah. No, I get this 18 spurious in

-- stuff like that. Yeah, I get it.

19 CHAIR STETKAR: Open circuit's hot, you 20 know. 21 MEMBER SUNSERI: I just was wanting to 22 make sure I understood.

23 CHAIR STETKAR: Or it could be a fire in 24 the control room itself.

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-3701 (202) 234-4433 MEMBER SUNSERI: You could be having those 1 symptoms before you even know there's a fire.

2 MS. LINDEMAN: Yeah, okay. All right, 3 and then the final phase that we'll talk about in the 4 main control room abandonment scenario is phase 3, and 5 those are the actions o nce command and control and left 6 the main control room.

7 So, this is a graphic of

-- not to scale 8 of the three time phases of main control room 9 abandonment. Just as I presented earlier, we have 10 phase 1, which is the period before abandonment, 11 phase 2, which is the time period for making that 12 decision to abandon the control room, and then phase 3, 13 which is the time period factor.

14 CHAIR STETKAR: Ashley, leave that up for 15 a moment. I was going to wait until we got to here 16 because I think this is my only opportunity to whine.

17 We had some discussion two years ago about why does the 18 quantification and qualitative analysis in 19 supplement 1, for the decision to abandon the control 20 room, the things that occur during that phase 2 block 21 there, why does that apply to loss

-of-control 22 scenarios? Why does it not apply to loss of 23 habitability?

24 In supplement 1 you've added additional 25 28 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 rationale for loss of habitability and why it is 1 absolutely certain that they will absolutely leave, and 2 that you onl y need to know, do they leave too late.

3 I'm concerned about their leaving too 4 early. I'm concerned

-- and why is that important?

5 It's important because it shifts that vertical line 6 between phase 1 and phase 2 to the left.

7 And maybe they don't have enough time to 8 accomplish the stuff in the main control room, that 9 you're taking credit for them doing in the main control 10 room, and that when they abandon, they find out they 11 can't do it as well remotely.

12 They either don't have the amoun t of 13 indications, they have to rely more on distributed 14 local people doing things, and that can be important.

15 So, for example, if I have a fire in the 16 main control room, you say, well, according to our 17 criteria, the great gods of PRA and people who wrote 18 N UREG-CR6850, say, when I get to a certain visibility 19 or I get to a certain heat

-release rate, or something 20 in your plant

-specific procedures, I am told to leave.

21 And I do that, because otherwise I'm going to die.

22 Well, I don't necessarily know that, and 23 I don't necessarily trust procedures when I think I 24 might die. And furthermore, if I have a fire in the 25 29 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 main control room and my fire brigade is running around 1 with fire extinguishers, or whatever they're doing, 2 bumping into and distracting me, maybe I dec ide that 3 I really would like to leave. Long before it gets to 4 hot or too smoky.

5 You talk about people putting on Scott 6 Air-Paks, you know, and staying in there until things 7 get so that they can't see. I was toying with the 8 notion, if you've never worn a Scott Air-Pak and tried 9 to communicate, understandably at all you'd understand 10 that people cannot do that. They're meant to make it 11 so that you don't die before you get out of where you 12 are. 13 So, why this artificial distinction abou t 14 loss of habitability requires no cognitive decisions.

15 There's only an uncertainty about, do they stay too 16 long, versus loss of control, where you do say, there 17 can be a much broader variability in the decision time, 18 because there might not be those specific criteria on 19 when do you discuss your indications enough to decide 20 to leave. To me, there's no fundamental difference.

21 DR. COOPER: Susan Cooper, and I'm going 22 to start answering the question, and I may defer to my 23 colleagues up here, or maybe throw a lifeline there to 24 the audience.

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-3701 (202) 234-4433 So, the first part that I'm going to 1 identify, and that is, why not do something more 2 detailed for loss of habitability than, you know, 3 something similar to what we do for loss of control.

4 And I'm going to

-- but the first answer, 5 which probably is not going to fly, and that is that 6 HRA is doing what the PRA needs, and they haven't asked 7 us to do that. They don't think it's important enough 8 that we dig into those details.

9 If they do different calculations to look 10 at whether or not there makes a difference, it's not 11 going to make a difference.

12 The second part is, that at least for the 13 plants we have now, the control rooms we have now, the 14 remote shutdown panels we have right now, the 15 abandonment strategies we have, the reluctance to leave 16 the control room is maybe even more of a concern than 17 we might have thought.

18 I mean, I think everyone who's done 19 anything with fire and has talked to operators, you've 20 heard something like, well I'm not going to leave until 21 my feet are on fire, or something like that.

22 And I've heard stories like that, and I've 23 heard people tell me that they're

-- you know, about 24 their reluctance. But we did look into that as part 25 31 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 of the development of the quantification guidance for 1 su pplement 2, and the result from the experts that we 2 got was that that is the driving factor.

3 And it has to do with the familiarity and 4 the capability

-- well mostly the familiarity of the 5 control room, and being there, and not wanting to go 6 someplace else.

That is the driver. Now

-- so I mean, 7 that's kind of the basis.

8 Now, if you had a chance to take a look at 9 supplement 1, we did go back and add some material into 10 the section on the decision to abandon related to 11 habitability. A nd in particular, we went back and 12 tried to explain some things that apparently haven't 13 been documented elsewhere, and Nick Melly was

-- and 14 I think Tammie Rivera also was more instrumental in 15 writing up the section, trying to better fill in the 16 blanks on what was in 6850 about the criteria for 17 habitability, and how that links back to actual human 18 subjects, and what you would be experiencing physically 19 if those habits, you know, those kinds of conditions 20 exist in the control room.

21 And, you know, some of the author team has 22 also compared that with other environmental factors, 23 like, you know, trying to control equipment and local 24 plant stations where the panels were hot to the touch 25 32 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 and, you know, what are those temperature limits, and 1 stuff like that.

2 And so, you know, we did go back and look 3 carefully at that, and we recognize that it's not a 4 sharp cut in time.

5 CHAIR STETKAR: I hope you read the 6 transcript, and read your words as an outsider.

7 Because you're talking about this as a dispassionate 8 fire modeler might talk about it. You're not talking 9 about it in the context of a fire in the control room.

10 And I'm not talking about something that 11 you spit on and it goes out. It's obviously a 12 meaningful fire. It's generating smoke. It mi ght be 13 generating a lot of heat. It may have a combination 14 of environmental conditions with smoke, and effects on 15 my instrumentation.

16 And there are people who are going to be 17 trying to put the darn thing out. And that is not me, 18 as an operator, because i f it is me, then I'm violating 19 some other PRA rule that says I can't do this. Or some 20 procedure rule that says I can't do this, despite the 21 fact that I might want to do it.

22 I'm certainly being distracted, and at 23 some point my cumulative distraction leads me to decide 24 maybe it's better that I do leave. Let them put the 25 33 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 darn fire out.

1 Maybe I can come back if there's enough.

2 But maybe I don't trust that other stuff well 3 enough -- perfectly, let's say

-- and I decide 4 to -- see, I don't see philosophically why this big 5 focus on loss of control, and total ignorance of loss 6 of habitability. It's conditions that the operators 7 are faced with.

8 DR. COOPER: So, the other piece is 9 operational experience.

10 CHAIR STETKAR: We've had a lot of fi res 11 where people have decided not to leave the control room 12 until -- 13 DR. COOPER: We haven't had any fires 14 where we'd have left the control room.

15 CHAIR STETKAR: Yeah. Okay, and that's 16 my whole point. Or we're pushed to leave the control 17 room. 18 DR. COOPER

Well, there 19 were -- internationally there may have been one where 20 they left the control room. But there certainly have 21 been fires in the US where they have not left the control 22 room, and we've spent some time looking them.

23 Browns Ferry

-- as a matter of fact, Mark 24 Sallie dug up or found an info video interviewing some 25 34 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 of the Browns Ferry operators in some of the conditions 1 that they were experiencing

-- hot panels, plastic 2 falling -- you know, popping out of the instruments, 3 and stuff like that.

4 So, we don't have a lot of operational 5 experience, but the operational experience we have also 6 shows that they're not going to leave, even if it 7 is -- even if the conditions are not optimal. Now, I 8 know we do have examples of people putting on

-- you 9 know, using the Scott Air

-Paks and staying in the 10 control room.

11 We've also had a few interviews that said 12 that they were going to do that.

13 CHAIR STETKAR: No no no. I don't care 14 what they say they're going to do. I'm 15 interested

-- you say you have experience that people 16 have done that? I'd be really interested to hear

-- to 17 read about that, because I'm not aware of people that 18 have done that.

19 DR. COOPER: They did in Browns Ferry.

20 CHAIR STETKAR: Browns Ferry was 21 30 -- god, I can' t -- 33 years ago. I'm sorry, 40 22 years, 75, 43 years ago.

23 MEMBER BLEY: Now, I've talked to lots of 24 people -- a number of people in control rooms who say, 25 35 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 no problem with the Scott Air

-Paks. I haven't talked 1 to anybody who's actually had to try to do tha

t. We 2 don't do -- I'll be Charlie today

-- what's done in the 3 Navy We don't put people out in fires anymore. At 4 least not many plants.

5 Some years ago some good send their people 6 to firefighting school and have to do this stuff.

7 These days, not so much.

8 CHAIR STETKAR: Is that right?

9 MEMBER BLEY: Yeah, that's right. At 10 least the ones I've talked to. And so, most of them 11 have never been in that hot, smoky environment with 12 breathing apparatus on and trying to see. They just 13 kind of been told it's okay. But if there is real 14 experience there that's documented, it'd be real 15 interesting to see it.

16 MS. PRESLEY: So, I just

-- I think one 17 other maybe already obvious point is that HRA, we only 18 have so much resolution we can go into.

We can 19 postulate how the operators might behave, and we can 20 interview them and what they think they're going to 21 behave, and we can look at the sparse operating 22 experience and try to extrapolate, but we recognize 23 this is something that has uncertainty.

24 And we talk about the uncertainties 25 36 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 associated it and how you have to look at that. But 1 for the other

-- there are other consequential 2 decisions that we've seen in operating experience, 3 where operators have kind of delayed it as long as 4 possible. 5 So, this is a model, and it's the best we 6 can go forward at this time with the experience and 7 information we have. I think it's the best

-- 8 CHAIR STETKAR: We'll talk more about 9 uncertainty later. I mean, you can just get one shot 10 -- 11 MEMBER BLEY: I'd like to turn John's 12 question around a little bit then, and ask you about 13 your interviews. Did you find plants

-- and I assume 14 you talked with trainers as well as operators, and where 15 folks are essentially trained to believe they're never 16 going t o have to abandon the control room. I was 17 looking at your discussion of reluctance, so that's 18 fine. 19 Is there a belief out there that this 20 never -- it's not a real scenario, we're never going 21 to have to do this? Do plans actually go through the 22 drill an d move the control out to the distributed or 23 local control areas?

24 DR. COOPER: Susan Cooper. All 25 37 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 plant -- all interviews that we've done

-- and I think 1 that includes the rest of the team, including those out 2 in the audience

-- have indicated that they pra ctice 3 at -- train on certain aspects of abandonment.

4 Usually, doesn't in

- -- almost always never includes 5 the actual decision.

6 But it does include all the moving parts 7 once they've left. So, that's

-- and that's 8 Appendix R. So, they've been doing that for some time.

9 Since I'm at the NRC, I'm not doing the actual work.

10 I may need to throw this to either what EPRI or some 11 of our consultants in the audience.

12 But I -- for another project I do know that 13 that particular plant, they had their own fire training 14 facility onsite, which included the capability of 15 producing fairly large fires.

16 All of the field operators there were 17 trained on fire brigade, and they were moving toward 18 getting more of their licensed operators also trained 19 in fi re brigade, even some people in management.

20 So, that familiarity was there. That 21 having been said, the capability of the remote shutdown 22 panel was such that I think they didn't really imagine 23 needing to leave, because they could transfer control 24 of indivi dual pieces to their remote shutdown panel, 25 38 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 and just basically have another local panel that's 1 taking some of the load of control without 2 actually -- because for us abandonment means command 3 and control, all operations leave the control room, not 4 that some pieces of it have been farmed out elsewhere.

5 So, in that particular case the way

-- and 6 there are other plants that probably have that sort of 7 capability, where they can, you know, select specific 8 systems and trainings and equipment, and, you know, 9 selectively move the control from the control room to 10 their remote shutdown panel. And then they don't have 11 to leave. 12 MEMBER BLEY: At the bottom line, I think, 13 from John's point of flipping this around, the 14 habitability, it just really doesn't sound like 15 anybody's thought real hard about the habitability 16 issue. 17 MR. SALLEY: Hey Susan, if I could just 18 jump in -- 19 MEMBER BLEY: Yeah.

20 MR. SALLEY:

-- for a second on the 21 habitability, and let's take our trip back in time to 22 Browns Ferry. If you go back to the Browns Ferry fire, 23 '75, and you look at the habitability, of course nobody 24 wanted to leave the control room then, and they did a 25 39 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 lot of heroic a ctions to not do that.

1 They breached a lot of barriers and opened 2 fire doors so that they can move the smoke. They went 3 as far as taking the plant air system and bringing in 4 air lines and chucking them open to literally blow smoke 5 out of the main control room. 6 So, they clearly weren't going to leave 7 the, you know, leave the main control room. That's 8 pretty much their safe zone. That's what they're 9 trained to do.

10 After Browns Ferry, we also made some 11 design changes. A lot of plants have smoke purge. So, 12 we can now align the HVAC and we can do a purge so that 13 they can, you know, stay there longer. Breathing 14 apparatuses

-- the Scott Air

-Paks -- was brought up.

15 Some plants even brought in line masks 16 where they have, you know, air cylinders that are 17 compressed and you open your line mask, and you have 18 an unlimited amount of time.

19 So, I think there is a lot to do that. The 20 key, I think, in the decision point

-- and when I was 21 reviewing this with Susan, was when that SOS makes that 22 decision to throw the transfer switch. Because one he 23 throws that transfer switch, enters those procedures, 24 then he's locking himself into, this is how I'm going 25 40 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 to do shutdown now.

1 So, even though they may leave some people 2 in the main control room to monitor things and assist 3 them to do work, once they make that procedural jump, 4 they start that process, then they start into their hot 5 shutdown. So, that's kind of the key there.

6 DR. COOPER: Yeah, I guess

-- this is 7 Susan here

-- just to add to that, not all , but many 8 of the plants' safe shutdown strategies also are a 9 single path to success.

10 So, not only are you giving up all of the 11 indications and other capability you have in the 12 control room, but now you're on, you know

-- there's 13 on ly one train of equipment that you can rely on for 14 shutdown, and if anything goes wrong, you know, you 15 don't have

-- at least not procedurally 16 identified

-- options to do other things.

17 So, that can also be considered a 18 deterrent, you know, so far as, you k now, what I have 19 in the control room. What are my options in the control 20 room, versus when I leave? And I go to a different set 21 of procedures and different capabilities of equipment.

22 CHAIR STETKAR: I think we need to be a bit 23 cognizant of the time. But I did want to dwell on this 24 a little bit, because we won't have a chance in the 25 41 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 supplement 2 discussion.

1 Mary mentioned this is our model and this 2 is what we've had today. There's another way of 3 formulating the model. You mentioned uncertainties.

4 We'll talk more about uncertainties in supplement 2, 5 or I will.

6 One could develop an uncertainty 7 distribution, and I don't care whether it's loss of 8 control or loss of habitability, or some amalgam of the 9 two, that says there's some prob ability that they will 10 leave at time key

1. There's some probability that 11 they'll leave at time key 2, and there's some 12 probability that they'll leave at time key
3. 13 That's pretty simple. I didn't try to get 14 any more sophisticated than that. They don't have to 15 be precise probabilities. Each of those 16 keys -- key 1, key 2, key 3 -- has implications about 17 what you can accomplish in what you're calling phase 1, 18 and what you can accomplish in what you're calling 19 phase 3. 20 So, they have implications on your 21 qu antification of human error probabilities, that will 22 eventually feed into the PRA.

23 Now, key 3 is too late for phase

3. That 24 makes the quantification in phase 3 pretty darn easy.

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-3701 (202) 234-4433 If key 1 is too early for phase 1, maybe you don't get 1 a chance to do some of the stuff that you're 2 already -- you're taking credit for them doing very, 3 very reliably in phase

1. 4 I'm not talking

-- but that's a different 5 type of model than you've established. It's a 6 different modeling thing. I'm curious why your 7 experts didn't propose that model. That

-- why you've 8 latched onto this particular type of model.

9 DR. COOPER: There isn't any interview 10 that I can recall

-- I'll ask Mary and Ashley to 11 remember too

-- I don't remember anyone bring up the 12 notion o f leaving too early.

13 MS. LINDEMAN: I have one comment loss of 14 habitability.

15 CHAIR STETKAR: Is that because you only 16 asked them what's the latest you might leave under these 17 conditions?

18 DR. COOPER: No.

19 MS. PRESLEY: The bias towards reluctance 20 was so str ong that there was no

-- I mean, we tried to 21 ask the question in many different ways, and

-- Paul 22 Amico from Jensen Hughes 23 CHAIR STETKAR: Paul, we don't know who 24 you are, so make sure you identify yourself.

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-3701 (202) 234-4433 MR. AMICO: I'm Paul Amico from Jensen 1 Hughes. So, there's no question that this is a 2 simplification. Okay, I mean, you know

-- and as are 3 many things are in PRAs are simplifications. We don't 4 do T-1, T-2, T-3 for different options for feed and 5 bleed, for example.

6 We always say, well what is the leas t 7 amount of time you have available for it to get to feed 8 and bleed, and that's the way we do it.

9 In this particular case, the least amount 10 of time is, the longer they wait in the control room 11 for a habitability situation, that's the least amount 12 of time to accomplish everything else in phase

3. So, 13 that tends to maximize that part of the probability.

14 As to leaving too early, I guess we're a 15 little bit conservative in that too, in that we actually 16 give very, very little credit

-- we don't say, we'll 17 they can stay for 16 minutes, so they do 16 minutes worth 18 of stuff. 19 Generally, we only give them credit for 20 those first few actions, like trip the reactor, trip 21 the turbine, those things. And then we say, well if 22 this turns into an abandonment scenario, basically we 23 assume they've got to do everything in the abandonment 24 shutdown process.

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-3701 (202) 234-4433 We really don't give them credit for the 1 fact that before they left the control room, maybe they 2 started this pump, or maybe they did this thing. We 3 still say they have to do that, as part of the execution.

4 So, it's a simplification which I would 5 say, you know, tends to be on the conservative side.

6 We minimize the amount of time they have to execute 7 phase 3, and we also give very little credit for doing 8 things in the control room before they have to abandon.

9 And that's really the simplification.

10 CHAIR STETKAR: Thank you. We'll talk 11 more about phase 1 when we get into supplement

2. 12 MEMBER BLEY: Let me just ask something to 13 make sure I understand the model. Just back up one 14 slide, please. Phase 1 here is described as the 15 associate -- time associated with actions taken before 16 the decision to abandon. Now go to the next one.

17 Actually, the decision to

-- it depends on 18 what you mea n by the words. The decision to abandon 19 is right at the end of phase

2. But I think what you're 20 saying is, at the end of phase 1, you've decided 21 to -- at least your words say, see if you are to abandon.

22 DR. COOPER: So

-- Susan Cooper here.

23 Not exactly that. It's actually

-- I think the way we 24 described it is, if you were to know when all the cues 25 45 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 were available and occurring

-- you know, 1 existing -- indications of any kind, environmental 2 conditions, or whatever

-- the point at which that 3 information is available in some way, that means that's 4 the cue for abandonment.

5 So, what that end of phase 1 is really the 6 cue for abandonment, which is, in fact, probably a 7 collection of cues, and they accumulate over time. So, 8 figuring out exactly where that is, is a little bit 9 tricky. 10 So -- but that's really the end of phase 1, 11 is when the so

-called cue for abandonment occurs. But 12 it's a lot fuzzier than a cue.

13 CHAIR STETKAR: The difference, when I 14 think of loss of habitability

-- and at least the way 15 I read the guidance

-- is that the cue to abandon the 16 loss of habitability is when you meet those magic 17 criteria for visibility or heat, temperature, things 18 like that.

19 And those things are calculated by fire 20 models. And it might take quite a w hile for those 21 things to develop. But it said in the guidance that 22 once they make that decision, the time

-- from that 23 condition until they make the decision

-- is minuscule, 24 so that phase 2 -- the time in phase 2 for loss of 25 46 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 habitability

-- is essentiall y zero. 1 You get the cue, you decide to leave, 2 you're definitely going to leave when you get the cue, 3 and you're not going to leave before you get the cue, 4 and until those conditions are met, people are sitting 5 in the control room doing, happily, everything that 6 they would normally do, and it might be 30 minutes.

7 And I will tell you that if I was using the 8 guidance as it's written, I would do that in my PRA, 9 because that's what the guidance tells me to do.

10 MEMBER BLEY: And I read it differently in 11 different places.

12 CHAIR STETKAR: Okay.

13 MEMBER BLEY: The words didn't seem 14 consistent as I went through, on what these things 15 actually mean, and how you

-- 16 CHAIR STETKAR: But it seemed pretty clear 17 that the loss of habitability cue is dete rmined by fire 18 modeling, either smoke density or temperature, and that 19 once you meet those crit

- -- or whatever

-- there might 20 be different plant

-specific criteria

-- but once you 21 meet those criteria for fire modeling, there's not a 22 degrading condition whe re there's vagueness. It's, 23 people decide to leave and they leave. And before 24 that, they decided not to leave

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-3701 (202) 234-4433 MEMBER BLEY: But only if those things are 1 codified in the procedure for telling them

-- 2 CHAIR STETKAR: That's true. They have 3 to be - yeah. 4 DR. COOPER: Susan Cooper. With respect 5 to habitability, the criteria that are calculated doing 6 the fire modeling end up being pretty severe. So, 7 you're right, it's not

-- it's actually an accumulation 8 of effect. They may actually make the decision before 9 they reach the actual criteria as we calculate.

10 CHAIR STETKAR: Yes.

11 DR. COOPER: Because, for example, for the 12 visibility criteria, as I recall, that criteria said 13 that you cannot see this far. In other words, if the 14 ind ications are rubbing the panel here, you cannot see 15 those indications, because the visibility is just not 16 there. 17 So, if they needed to read that and they 18 thought this was getting to be a problem, they 19 probably -- depending on how the scenario evolved and 20 w here the smoke was, and stuff like that

-- they may 21 leave earlier than what the calculation would say.

22 So, the calculation is a simplification 23 for the longest time they would stay in the control 24 room, which, at least as far as phase 2, gives them the 25 48 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 least amount of time to implement their shutdown 1 strategy. 2 So, as Paul said, it's a simplification.

3 You know, we could

-- there are other things we could 4 do, but that's

-- there are tradeoffs.

5 CHAIR STETKAR: But I

-- you know, my

-- 6 ME MBER KIRCHNER: Can you go to the next 7 slide, Susan? So, you don't put some kind of 8 distribution on each of these vertical lines. My 9 thought would be

-- maybe it's a variant of what you 10 were saying earlier

-- 11 CHAIR STETKAR: Yeah.

12 MEMBER KIRCHNER:

-- th at they aren't 13 going to be that precise. Even if they are calculated 14 precisely -- at 38 minutes, for example, or whatever 15 those lines are

-- the reality is, even in your case 16 of visibility, it might be billowing smoke in one corner 17 of the room, and the ot her half of the room is fine.

18 So, they're not going to go until the whole control room 19 is filled with smoke, or whatever the scenario is.

20 So, isn't there some distribution that 21 should be put on these to look at the sensitivity or 22 uncertainty, and propagat e that in execution of what 23 is then subsequently analyzed? I don't understand.

24 MS. LINDEMAN: So, for loss of habitabil

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-3701 (202) 234-4433 ity -- right? T equals zero is the start of the fire.

1 And fire -- and analyzing it, we have a distribution 2 of heat release rates based on, you know, certain 3 cabinet type.

4 And when you run your calcs for loss of 5 habitability, you'll discretize that distribution, so 6 you may fires of 50 kilowatts, 100 kilowatts, 200, etc.

7 And as a result, there are different times when the 8 habitability criteria are met, you know, on maybe the 9 order of eight to nine minutes anywhere, to roughly 30, 10 depending on the fire growth.

11 So, in that aspect there is a range of times 12 for loss of habitability, and I'm not sure if we did 13 a good jo b of explaining that before.

14 MEMBER KIRCHNER: I presume the same would 15 obtain for a loss of control.

16 MS. LINDEMAN: So, we'll talk about loss 17 of control timing

-- so, if we go to the slide

-- I don't 18 want to go to the slide before because I don't want to 19 go backwards. But that

-- 20 CHAIR STETKAR: You don't want to.

21 MS. LINDEMAN: That figure is a construct 22 to help analysts think about the response in phases.

23 And the way we use the timing information is maybe the 24 more important point. And when you see how we use the 25 50 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 timing information in phase 2 and 3, and 1, maybe this 1 will be little bit more clear.

2 Because I think we're getting caught up on 3 lines on a diagram which are constructs, not 4 hard -- they weren't meant to be hard lines, and we'll 5 see there's some squish, and this is actually an item 6 that we have to describe more of what that squish is 7 used for. 8 DR. COOPER: Mary's exactly right. This 9 is Susan. The important of the phases, though

-- the 10 time phases

-- is that we treat them differently in HRA, 11 and the way we develop the quantification guidance, the 12 kinds of qualitative analysis you need to do, what 13 actions operators are taking and where, what procedures 14 we're using, those are all different.

15 And that's why the different phas es are 16 important to us. So

-- but they are constructs not 17 necessarily measurable in all places.

18 MEMBER SUNSERI: So, I was going to ask 19 another question. I mean, you know, I hear talk about 20 loss of control and habitability and all that stuff.

21 But I thin k from an operator

-- from being a former, 22 you know, operator in one of these plants, it always 23 seemed to me like it wasn't a matter of that, but it's 24 a matter of, is this a fast

-moving issue, or a 25 51 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 slow-moving issue. Right?

1 And so, it all comes down to the cues, not 2 times. Right? So, an operator on a fast

-moving 3 thing, maybe all they can do is tell the guy that's at 4 the board, trip the reactor, we're leaving. And that's 5 the initial step of the shutdown process, or the 6 transfer pr ocess. 7 The other situation may be if the 8 slow-moving thing, the shift supervisor says, hey look, 9 we're losing this thing. We're going to have to go in 10 a few minutes. I want you to do these three things, 11 which is in accordance with my shutdown guidance.

12 Right? 13 When we leave I want the reactor tripped, 14 I want the auxiliary feedwater pump started, whatever 15 it is, you know? And then, you know

-- but once again, 16 it's not so much time

-driven. It's cue

-driven. 17 MS. LINDEMAN: Mm hmm. Okay.

18 MEMBER SUNSERI: An d, you know, it 19 shouldn't be, you know, when the visibility is down to 20 whatever the lumens, it's going to be when you can't 21 see the controls anymore, or whatever the thing is.

22 Right? 23 DR. COOPER: You're right. It's very 24 context-specific. And so, there a re variations of 25 52 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 main control room abandonment scenarios, including, 1 you know, what's happening, and why is it happening that 2 way. So, yes.

3 MEMBER SUNSERI: And, by the way, I 4 wouldn't ever recommend this as like an ongoing thing, 5 but I've been involved in the startup of a couple of 6 plants, and one of the things that we had to demonstrate 7 was that you could trip the reactor and establish a 8 cooldown rate from outside the control room, and it 9 wasn't as scary as we thought it would

-- I mean, the 10 operators -- it wasn't as anxious of a

-- now granted, 11 there was a control situation, a lot of oversight, and 12 all that kind of stuff. But, you know, having walked 13 through that

--- but, I mean, you know, with the modern 14 instrumentation of the plants and the shutdown transfer 15 panels and the remote shutdown, it's a quite doable 16 thing. 17 MS. LINDEMAN: Okay. All right, well, I 18 guess due to time we'll just kind of skip to the next 19 slide, which is the timeline for doing it is at the end 20 of May. And I realize that this graphic is really 21 difficult to see, and, you know, even the point of 22 showing this isn't to demonstrate that you can 23 construct a timeline that includes all the actions for 24 two units.

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-3701 (202) 234-4433 What I'd like to highlight is, you know, 1 one of the outcomes of supplement 1, which was having 2 a narrative and a picture for the analysts to identify 3 all of the actions, but also all of the critical 4 communications and staffing locations, and, you know, 5 we believe that's, you know, one of the most powerful 6 outcomes of supplement 1 is giving this tool to the 7 analysts, not only for feasibility, but, you know, the 8 entire scenario.

9 DR. COOPER: Susan Cooper here. If you 10 can't read the graphics, the blue lines are where 11 communications are occ urring between operators, and 12 would indicate, you know, probably some kind of 13 coordination that's required.

14 So, that's one of the keys of this kind of 15 timeline. It doesn't have to be dual unit, but to show 16 that. But this is just trying to show all the activity, 17 and try to get a handle around what all's going on, which 18 could be important for staffing considerations also.

19 MS. LINDEMAN: Time, sequence, actions.

20 I think with that we'll all kick it back over to

-- well, 21 we're currently under development, whi ch is 22 supplement 2, which is the quantification guidance.

23 DR. COOPER: Susan Cooper. I'm going to 24 give you an overview of supplement 2 first. And then 25 54 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 we'll get into some of the details.

1 So, supplement 2 has been developed to be 2 a companion document to both NUREG

-1921, which is the 3 overall fire HRA guidance, and then, supplement 1 to 4 1921, which provides a qualitative analysis guidance 5 for main control room abandonment scenarios.

6 The high-level approach that we used, 7 although we

-- you know, we developed a construct of 8 the different phases, at least for the purpose

-- the 9 focus of quantification, we looked mostly at phase 2, 10 which is the decision to abandon, and that's 11 specifically for loss of control.

12 And then, phase 3, which is im plementation 13 of the main control room abandonment safe shutdown 14 strategy. 15 We used supplement 1 to try to identify key 16 issues that should be represented in quantification for 17 both of these phases. We used these consensus list of 18 issues, and compared them to existing methods, to see 19 how well existing methods could be used to represent 20 what we thought was important for main control room 21 abandonment.

22 As a result of those comparisons, the 23 author has developed some strawman approaches for 24 quantification. And then, what we did with

-- and it 25 55 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 was a little bit different between the two phases. In 1 phase 2, which is the decision to abandon, the team 2 developed some candidate decision trees to be used for 3 quantification for command and control issues. 4 Specifically, for shutdown after leaving the control 5 room, we just had that list of key issues.

6 And then, we brought in some experts and 7 had a panel to discuss those issues, and confirm or 8 modify the strawman approaches. And then we used that 9 inp ut to complete the quantification approaches for 10 both phase 2 and phase

3. 11 I want to talk a little bit about the expert 12 panel. There were a number of things that we wanted 13 to do. We wanted to keep a balance between the NRC and 14 the industry, so far as number of people on the panel.

15 So, we had two people from the NRC and two people 16 actually from the author team.

17 In both cases, we wanted to make certain 18 that the experts had knowledge of operations and 19 training, fire

-related experience, but specifically, 20 rel ated to main control room abandonment.

21 So, we wanted people that had experience 22 with either developing the fire models, doing the HRA, 23 or, from the operations side, had an understanding of 24 what those kinds of operations involved.

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-3701 (202) 234-4433 So, that -- those were the guiding 1 principles for the experts. The other thing is, we 2 wanted to -- down the line we talked about the fact we 3 wanted to make certain that the experts had a wide range 4 of understanding, not just for one or two specific 5 plants , because we were developing a method that was 6 going to be generic. So, we wanted to make sure it 7 wasn't just, you know, I just know this one plant. So, 8 that was important also.

9 So, the experts we had

-- from the NRC side 10 we have Harry Barrett, formerly of NRR, and he was an 11 NFPA-805 reviewer. He's since retired. We got him 12 just before he left.

13 And then, also, we had Jim Kellum from NRO, 14 who has decades of experience as operations trainer, 15 so he represents lots of plants. And then, from the 16 EPRI side, industry side, we had two of our 17 authors -- Jeff Julius and Erin Collins, both with 18 Jensen Hughes, which, between the two of them, 19 represented a lot of plant and plant analyses.

20 We used the experts differently between 21 phase 2 and phase

3. For phase 2 we started off by 22 confirming, or focusing, whether or not we got the key 23 issues right. That should be represented in 24 quantification.

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-3701 (202) 234-4433 After that we had the experts take a look 1 at the strawman decision trees. As a result of that 2 they made some modifications and prioritizations. And 3 then, we went ahead and did an actual HEP development, 4 starting with worst

-case scenarios, best

-case 5 scenarios, intermediate, and so on and so forth.

6 For phase 3, which was the impact of 7 command and control on the implementation of safe 8 shutdown strategies. We didn't use the experts to 9 develop HEPs for a quantification tool. We simply used 10 them to confirm or prune our key issues list, and then 11 to identify priorities and associated context for what 12 we wanted to include in our guidance. So, that's how 13 we used the experts in the two different phases.

14 MEMBER KIRCHNER: May I ask you a 15 question? Did you then kind of take a representative 16 plant of different types and just run through it to see 17 if this is what the experts decide this is what the 18 operators might do?

19 DR. COOPER: We did not

-- this is Susan 20 Cooper -- we did not have specific example scenarios 21 to go through in doing these developments. But the 22 discussions naturally led to plant

-specific examples 23 that were brought into the discussion.

24 But the end results were not based on a 25 58 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 plant-specific input, you know. It was

-- and the 1 answers were consensus answers. So even if one expert 2 brought in, you know, I have this information that I 3 know about this plant, and then another expert will 4 offer something else, and then all of those opinions 5 were brought together into a consensus, so far as, you 6 know, in the case of phase 2 -- the decision to 7 abandon -- there were consensus HEPs that were 8 developed.

9 And then, for phase 3 there was just a 10 consensus that across the board these are the things 11 that we think would be most important, you know, 12 generically.

13 So, the end result is generic. The actual 14 discussions in getting to that answer might hav e 15 brought in some plant

-specific information.

16 So, how to use supplement 2, the purpose, 17 of course, for supplement 2 is to provide that 18 quantification guidance that's beyond the scope of 19 NUREG-1921, which does provide quantification guidance 20 for other fire scenarios.

21 For the most part, although there's some 22 types of operator actions and human failure events that 23 we identify in supplement 2 where 1921 guidance is 24 sufficient, and in the case of supplement 1, there are 25 59 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 places where we repeated that guidance because we 1 thought it was important, there's some cases where 2 supplement 2 expanded on concepts that were started in 3 supplement 1, and so there may be some redefinition.

4 Command and control is definitely one of those 5 instances.

6 And, at least in the draft that you have, 7 we've tried to indicate where 1921 certainly in those 8 cases, if that's the guidance you need to use, we've 9 indicated that. And we've tried to also indicate where 10 you need to go back and look at supplement

1. 11 We've alrea dy mentioned that we're 12 considering trying to provide some additional help to 13 the analysts on how to sort those things out, and of 14 course welcome your comments on how we can continue to 15 improve that. Next slide.

16 So, that's the end of the overview. And 17 then, we're going to go into, specifically, discussion 18 and decision.

19 CHAIR STETKAR: Let me intercept you here.

20 DR. COOPER: Okay.

21 CHAIR STETKAR: Because you're going to 22 skip phase 1 and I'm not. The guidance in supplement 2 23 for phase 1 is, I'll call it thin. Let me quote a 24 couple of passages.

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-3701 (202) 234-4433 During phase 1 operator actions are 1 directed from the main control room. Similar to other 2 fire scenarios, these actions are not necessarily 3 unique to main control room abandonments, since th e 4 cognition and execution for these actions are very 5 similar, if not identical, to fire scenarios where the 6 fire is not inside the main control room, or even 7 internal events PRA actions following a reactor trip.

8 Section 2.2 says, up until the point of the 9 decision to abandon, the operating crew is responding 10 to the fire from the main control room, so the guidance 11 in NUREG-1921 is applicable and sufficient to evaluate 12 and quantify phase 1 actions.

13 I look at 1921

-- 1921 says, ah, main 14 control room abandonment is a different issue, and 15 that's why we're having this meeting today. 1921 16 focuses an awful lot on distributed actions being 17 guided from the main control room with people running 18 around in the plant doing things.

19 It doesn't talk much about fires inside the 20 main control room. Inside the main control room.

21 Which brings me back now to my loss of habitability.

22 How is it that I can use the guidance in 1921, or 23 guidance for HRA, for internal events, to quantify my 24 actions inside the main control room, when, as Walt 25 61 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 said, over in the corner there's smoke billowing out.

1 Now, it hasn't got

-- I can still see 2 things. And, oh, by the way, the fire brigade is 3 pushing me out of the way because they want to get to 4 the corner, and the only way is through me.

5 So, how is the guidance for quantifying 6 fires outside of the main control room, I can almost 7 say, that the guidance in 1921 applies because as long 8 as I'm not being distracted by people trying to put out 9 the fire, if one of those p eople who might be me.

10 Or, potentially in fear for my own 11 survivability, I can say, well, it doesn't make too much 12 difference if the fire is out in a cable

-spreading room, 13 or out in some other location, because I'm just reacting 14 to whatever indications are coming in, which 1921 does 15 a fairly decent job.

16 I was hoping, during phase 1, that you 17 would say, well, for fires inside the main control room, 18 you have to think about much different things. But you 19 don't say that. You say that I just use standard, 20 everyday human reliability analysis until I have to 21 abandon, and everybody knows that the abandonment thing 22 is the most important stuff.

23 So, can you address that? Why does this 24 phase 1 not need separate guidance to alert people to 25 62 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 the fact -- especially for fires inside the main 1 control room

-- that that is a different beast than 2 anything else that has been addressed in the guidance 3 to-date? 4 DR. COOPER: So, especially with you 5 reading things directly, we need to make a correction 6 that it's not up until decision to abandon

-- 7 CHAIR STETKAR: That's what it says, 8 though. If I'm going to

-- 9 DR. COOPER: We need to correct that.

10 CHAIR STETKAR:

-- read the guidance

-- 11 DR. COOPER: We need to correct that. So, 12 I would say that it's shorter than it should be. I will 13 agree that we need to add something there. I would say 14 that for fires in the control room, that 1921 probably 15 can still address that, because we do address 16 environmental factors and their influence on operator 17 performance. How ever -- 18 MEMBER BLEY: That's typically

-- 19 DR. COOPER:

-- it doesn't

-- it's 20 typically outside the control room.

21 MEMBER BLEY: It's typically outside the 22 control. I wanted to be

-- 23 DR. COOPER: It's typically outside the 24 control room. So

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-3701 (202) 234-4433 MEMBER BLEY:

But in their behalf, it does 1 identify the things that it does to you. It's just not 2 in the control room. Which is important. I'm not 3 disagreeing.

4 DR. COOPER: Yes.

5 CHAIR STETKAR: Typically, the 6 environmental factors, though, ar e presented in terms 7 of accessibility, you know, stay times, and things like 8 that, which can, in principle, be extended to the main 9 control room, but

-- 10 DR. COOPER: There

-- yeah, there's some 11 other influences. But yes. Yeah. So, I think you're 12 correct. We should add some more guidance there. We 13 need to clean up the way we discuss the construct of 14 the time phases is tripping us up there.

15 But definitely, we need to add some words 16 so that 1921, which, as you say, usually the 17 environmental factors is coming in on plant locations 18 at -- local plant locations.

19 MR. AMICO: Yeah. And

-- 20 CHAIR STETKAR: Paul, you have to

-- every 21 time you have to identify yourself.

22 MR. AMICO: I know. I'll get to that.

23 This is Paul Amico from Jensen Hughes again, because 24 I can't sit down and keep quiet. So, we have been using 25 64 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 1921 for -- keep in mind the wording may be a little 1 wrong, but the point being that the actions in phase 1 2 are up until the point where you have the cues, where 3 now you might consider abandoning.

4 Up until that point, the situation is the 5 same. Whether it eventually becomes an abandonment 6 scenario or not, you're operating only from the EOPs 7 and the fire response procedures.

8 Now, when I say we use 1921, 1921 instructs 9 you to address the context under which the operators 10 are performing. And we do look at what kind of fire's 11 occurring in the control room, how big it is

-- because 12 we do do the analysis, even for non

-abandonment 13 scenarios about what's happening

-- and we make 14 ad justments to the PSFs in the existing models.

15 So, for the HCRORE model, we would say, 16 okay, their fighting the fire in the control room.

17 That's a distraction. We're going to add four minutes 18 to time delay. Or, we're going to add three minutes 19 to the cognition time, because these other things are 20 occurring.

21 So, we actually do quantify those aspects 22 of the actions in the control room. We may add to 23 execution time because somebody

-- because there's a 24 big fire and there's a big commotion.

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-3701 (202) 234-4433 So, we do actually consider that the stress 1 of the operators in performing the actions on the 2 control panels will be higher. And so, we'll address 3 the THERP stress factors.

4 So, all that really is addressed by 1921, 5 and we do, in fact, use different adjustments to the 6 things that happen in the control room

-- if there's 7 a fire in the control room, versus if the fire is 8 someplace else and they're performing the same actions.

9 I think that's the context we're talking 10 about. And we do try to base that on actual operator 11 interviews, to the extent that that's something that 12 is reasonable to do.

13 So, that's, I think, the context that 14 they're trying to lay here is, 1921 covers the things 15 you do in the control room when there's a fire in the 16 control room, up u ntil the point you reach the cues, 17 where you may want to abandon. That's phase

1. 18 MS. PRESLEY: We could probably stand to 19 make that a little more explicit in our guidance.

20 CHAIR STETKAR: That's

-- you know, I did 21 a quick search of 1921, and it's

-- to my mind it's not 22 as clean as Paul makes it sound, because it

-- 1921 23 focuses mostly on main control room abandonment, and 24 it -- I can read it to make it sound that way, but since 25 66 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 we're now development guidance explicitly for these 1 sc enarios, some of which are fires in the control room, 2 some of which are not fires in the control room, but 3 all affect the integrated performance of people in the 4 control room, or decisions to leave.

5 See, quite honestly, I'd feel more 6 comfortable about this notion of loss of 7 habitability

-- have to be careful here because I don't 8 feel comfortable about it at all

-- but if there was 9 enough guidance to say that the evaluation of team 10 performance in the main control room for fires that 11 occur in the main control room, has to be really, 12 really, really careful to account for the environment, 13 the stress, everything that Paul just mentioned

-- 14 MEMBER BLEY: I think you're at a spot

-- 15 CHAIR STETKAR: I'd feel more 16 comfortable.

17 MEMBER BLEY:

-- where the developers in 18 the method know exactly how to use it and the place they 19 want to use it, but a third party coming to the guidance 20 and trying to do an analysis based on the guidance, may 21 be confused.

22 CHAIR STETKAR: If I

-- I tend to read 23 it -- 24 MEMBER BLEY: Or take the w rong turn.

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-3701 (202) 234-4433 CHAIR STETKAR: I tend to read it as that 1 third party. I would pick up this guidance, quite 2 honestly, as a human reliability analysis 3 practitioner, if you will, and say, well, okay, if one 4 of the actions

-- if I have eno ugh time in phase 1, is 5 to try to start an auxiliary feedwater, and if I can't 6 do that, try to start main feedwater. If I can't do 7 that, try to depressurize and start condensating.

8 If I can't do that, try to initiate feed 9 and bleed, and maybe I got 27 min utes to be able to do 10 that, and I've got 27 minutes because the smoke density 11 doesn't get up to whatever it's supposed to be until 12 36 minutes.

13 Well, I have procedures, I have training, 14 I've done this oodles of time for my internal events 15 at power risk assessment. I'll just use that human 16 error probability, because you say I can.

17 MEMBER BLEY: And that's

-- honestly, 18 that's what I would do.

19 MS. PRESLEY: We can make that link more 20 explicit. But I think also the integrated timeline is 21 an important piece, because it shows who's where, doing 22 what. And if there's a part that's being taken off for 23 the fire brigade and fighting the fire in the control 24 room, that would be reflected, and we would take that 25 68 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 into account in the analysis.

1 CHAIR STETKAR: That's not

-- I'm worried 2 about -- I'm not part of the fire brigade. I'm worried 3 about the fire brigade people pushing me out of the way 4 because the only way to the corner is through me, and 5 me having to battle with them, because I have to loo k 6 at these indicators here.

7 So, it's not depleting my resources for the 8 fire brigade. That's

-- take a separate fire 9 department, you know. They're still going to want to 10 disrupt me to put the fire out, not to mention 11 whatever's going on with the fire, it self. 12 MR. JULIUS: Jeff Julius from Jensen 13 Hughes. The pieces missing in that discussion is, 14 looking at the overall

-- all the phases, because a lot 15 of times the procedures in phase 2, or once you've made 16 that decision, you go and you turn off the feedwater, 17 you turn off everything you do.

18 And so you pick it up, and so you give 19 people -- fire protection people and people at the 20 plant that don't like the PRA people, because I was 21 telling them, I'm not giving you any credit for this 22 in phase 1 because you were taking quick

-- you were 23 following procedure guidance and you're turning these 24 up, and we're only going to model th e failure to restart 25 69 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 it in phase

3. 1 So, some of those

-- you're right. It's 2 probably a case, as Dennis said, that as a developer, 3 we know when we've seen that, but when you look at these 4 in isolation

-- you can't look at them in is olation.

5 You have to look at the overall scenario.

6 MS. PRESLEY: So, you didn't even get to 7 phase 2. So, this

-- I guess that goes with

-- 8 MEMBER BLEY: I'm sorry to interrupt you 9 already. Have you let anybody else try to use this?

10 MS. PRESLEY: No.

11 MEM BER BLEY: Not yet.

12 MS. PRESLEY: Not yet. No. Our peer 13 review -- we'll talk about peer review in the next

-- 14 MEMBER BLEY: Different.

15 MS. PRESLEY: Yeah. Well

-- okay, so to 16 echo what Susan had discussed about high

-level 17 approach, the high

-level approach is the same. We kind 18 of took -- looked top

-down and bottom

-up. We 19 developed a list of factors that we thought were 20 important to the quantification for the decision to 21 abandon and loss of control. We did that based on the 22 information from the interviews that the analysts have 23 done and that we had

-- the team had done with the NRC 24 folks, as well as our understanding of the kinds of 25 70 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 literature.

1 So, we've pulled all of that together, and 2 for each factor, we tried to kind of underst and the 3 range of what we've seen and what might be seen. So, 4 we kind of about what's the best

-case, what's the 5 worst-case, and what are some of the intermediate cases 6 we've seen.

7 And then we looked at a set of HRA methods, 8 and we looked at failure modes and mechanisms, and those 9 methods, to see if there was anything related to either 10 issues or failure modes that we need to add our list, 11 or anything that we could use kind of

-- I would say 12 off-the-shelf -- without a ton of modification.

13 So, we found that there's one that we 14 thought maybe we could use, and we started playing with 15 it, trying to adapt that, and found really it was 16 stretching the method too much, and ended up developing 17 our own decision trees based on the factors that the 18 team thought were important through the reviews and the 19 issues list development.

20 And then we took that strawman to our 21 experts and got some more feedback, and that ended up 22 consolidating our three trees into one tree, and 23 getting some ATP values to quantify the tree with.

24 So, that was the overall process, and I'll 25 71 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 go through a little bit more detail on each step.

1 So, the first

-- when I said we had our 2 issues tabled, this is one of three slides, and I'll 3 go through this fairly quickly. The first issue tha t 4 we came up with was procedure content. Whether or not 5 there was an explicit definition of what the criteria 6 were for abandonment.

7 We saw quite a variation from, if there's 8 a fire in this area, the supervisor should consider 9 abandoning. So, that was kin d of our worst

-case. It 10 was very open

-ended. And the best

-case would be, these 11 are the systems you should look at. If they're not 12 functional, then abandon.

13 So, we saw quite a range. We didn't see 14 anything super explicit, which would have been our 15 best-case. So, most of them fell under the 16 intermediate or worst

-case, where they provided some 17 indication of what location is important, or when the 18 fire is identified and confirmed, or whether or not your 19 emergency procedures are working the way they should 20 be. 21 So, that was the first

-- our first thought 22 was, the procedure was very important. We'll see what 23 the experts had to say, but we had parsed it into three 24 layers. 25 72 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 Then, we looked at time available, and 1 across the set of analyses, we saw that the time 2 available was typically 30 minutes or less from what 3 we've seen. So, we parsed that up into best/worst/

4 intermediate case.

5 And then, when we looked across the 6 training spectrum, the worst

-case was only classroom 7 training at the mini mum level -- I think once every two 8 years or something

-- you might have some classroom 9 training on the criteria to abandon.

10 The best-case is realistic training in a 11 simulator. Maybe it's integrated with the actual use 12 of the shutdown panels, that

-- I'm not sure we've seen 13 any instances of that. So the best

-case in this case 14 is quite a high bar that's not really seen in the 15 industry. 16 The intermediate cases where you have 17 detailed classroom training which talks through the 18 criteria. Maybe we'll talk about, you know, what 19 exactly are the criteria? How do you know you've met 20 them? You might have some simulator training where 21 they actually simulate the conditions, and you have to 22 figure out you've abandon

- -- you have to abandon.

23 So, there's a range on training, and the 24 best-case we don't really see. So, cues and 25 73 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 indications was another issue that we thought was 1 really important.

2 So, the procedure tells us when we need to 3 abandon. The cues and indications tell us how do we 4 know that that criteria's been met? There's a ton 5 happening. We don't know exactly, necessarily, what 6 exactly the operators are going to see, because we only 7 trace some cables

-- the ones that are important in the 8 PRA. 9 And some fires may be fast

-growing, some 10 may be slow

-growing, and this was

-- the cue and 11 indication is really not one like triple little HRA, 12 where you have a parameter or a couple of parameters 13 that you're looking at that's trending, and you see the 14 parameter, it matches the level, you go do an action. 15 This is not that. This is a unfolding 16 scenario that's getting progressively worse. And so, 17 the cues and indications, being able to interpret what 18 you're seeing against your criteria, was one important 19 aspect. And we're going to talk about that a little 20 more when we talk about the timeline for phase 2, and 21 how you build that.

22 We talked about reluctance, and initially 23 our thought was that reluctance was highly tied to the 24 capability of the remote shutdown panel, and the 25 74 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 comfort and familiarity with the main control room, and 1 just this inability

-- like, it's a bad day, we don't 2 think we'll ever actually abandon.

3 And we saw, through some of the operator 4 interviews, that there was

-- there's kind of a

-- it's 5 hard to get oper ators to see some of these PRA 6 scenarios, that they were so Appendix R-minded that it 7 was really beyond some of their imaginations to get to 8 this scenario.

9 Now, AB&C is what we thought

-- or our 10 initial thoughts

-- the capability of the remote 11 shutdown pan el for phase 2 turned out, through our 12 expert opinions, to be one of those areas where they 13 didn't think it was necessarily that important, so 14 we'll talk about why that is and what happens to that 15 information, in a couple of slides. But that was our 16 first cut, was based on those three factors. Next.

17 Staffing and Communication. So, this has 18 to do with how much backup you have in helping make that 19 decision. Best

-case is you have the STA or other crew 20 that are monitoring actively the criteria to abandon, 21 a nd helping you watch that, so you have

-- ready to make 22 that decision once you get to that point. The 23 worst-case is, if Justin's your supervisor, everyone's 24 tacked out doing other things, and he needs to make that 25 75 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 decision with little input.

1 And then, finally, transfer the procedure 2 with that main control room abandonment criteria. So, 3 you need to get to the main control room abandonment 4 procedure to abandon. It wasn't always clear in the 5 scenarios that we had, that there was an explicit 6 procedural path that gets you there.

7 And some of our operator interviews found 8 that there were situations where that was true, and we 9 thought that was pretty important to bring up. Again, 10 with our expert opinion, we found that was ac tually not 11 necessarily a driving factor for this HEP, and so I'll 12 talk about that a little bit when we talk about how we 13 end up pruning some of the trees.

14 MEMBER REMPE: Again, this isn't my field, 15 but when I was reading your report on page 34, you talk 16 ab out a situation where the staff needs

-- there are 17 certain staff members

-- like the shift technical 18 advisor -- needs to be in the control room to make the 19 decision to abandon. And there's a certain time that 20 they have to be there after the start of the e vent. 21 And if this person isn't there, you can't 22 make that decision to abandon. And is this a situation 23 that ought to be cleaned up if you found this to occur 24 at a plant? Am I misreading your report?

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-3701 (202) 234-4433 MS. PRESLEY: So, some clarific ation is, 1 the shift technical advisor might support that 2 decision. So, in order to credit his support of it, 3 he will never be making the decision.

4 MEMBER REMPE: But he needs to be there for 5 them to go forward?

6 MS. PRESLEY: No, he doesn't need to be 7 ther e. He's not required.

8 MEMBER REMPE: It says, required to 9 support the decision. He has to be there if

-- 10 MS. PRESLEY: That's poor wording.

11 MEMBER REMPE: Okay. Well, again, I 12 don't know

-- 13 MS. PRESLEY: Yes, thank you.

14 MEMBER REMPE:

-- a lot about tha

t. 15 That's why I said that to start.

16 PARTICIPANT: What section was that?

17 MS. PRESLEY: Page

34. 18 MEMBER REMPE: You know, again, I'm just 19 like going, well if that's the case, this reminds me 20 of other things we've heard of where critical folks 21 aren't there to make a decision, and

-- so never mind 22 I guess is the answer to my question.

23 MS. PRESLEY: Well, thank you for pointing 24 out that -- 25 77 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 MEMBER REMPE: Yes, thank you for clearing 1 that up -- 2 MS. PRESLEY:

-- poor wording.

3 MEMBER REMPE:

-- bad choice.

4 DR. COOPER: Not what we meant.

5 CHAIR STETKAR: Some shift supervisors 6 would say it would be a good thing if the shift technical 7 advisor was out, you know, cleaning the ice off the 8 windshields.

9 MS. PRESLEY: Next slide? Okay, so -- 10 CHAIR STETKAR: That would be Zion.

11 MS. PRESLEY: We're not naming it in here.

12 So, our beautiful timing fire growth picture, which you 13 guys probably cannot read the text on, which is okay 14 at the moment, because I'll walk you through it, 15 but -- so t he point is, is that the timing is not as 16 clear cut as the typical read

-the-parameter, 17 take-an-action, that the definition of T

-- we have 18 T-delay and T

-cog is our typical timing nomenclature.

19 And T-delay is the time to get the cue, and 20 T-cog is the cognition time. So, between the time you 21 get the cue and the time you make the decision, and so 22 that's like phase 1 and phase

2. 23 So, that is not a clean line, and it's 24 highly linked with your procedure and your training.

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-3701 (202) 234-4433 It's -- and your cues and indications. Those three 1 things are intractable from each other. So, you have 2 to understand how the procedures work and how the 3 operators are trained, and what the expectations are, 4 versus the progressions scenario.

5 So, we came

-- we actually

-- I have a 6 printout -- so we came up with a half

-dozen of these 7 fire growth scenarios. But basically, it walks 8 through -- you have -- the fire starts at reactor trip, 9 then you have your immediate memorized actions 10 complete. 11 And then you have that fire that happens.

12 You might have had an alarm. So then, you have 13 an -- you've acknowledged the alarm. You know that 14 there's -- you've gotten a fire alarm, you're going to 15 go send someone to go

-- 16 MEMBER KIRCHNER: Do you always assume 17 reactor trip with the fi re starting?

18 DR. COOPER: It won't be modeling it with 19 PRA if you

-- 20 MEMBER KIRCHNER: Mm hmm.

21 DR. COOPER: It won't be modeled in the PRA 22 if there's no reactor trip. So, the fires we care about 23 will have a reactor trip.

24 CHAIR STETKAR: In your opinion, it would 25 79 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 not be modeled in the PRA if there's no reactor trip.

1 PRAs do model fire scenarios that do not result in a 2 reactor trip, but disable, for example, necessary 3 cooling water systems.

4 MEMBER KIRCHNER: Right. And then the 5 reac tor trip -- 6 CHAIR STETKAR: I have done that said 7 PRAs, so I can say PRAs do that. Perhaps none that you 8 ever did. 9 MEMBER KIRCHNER: And then the reactor 10 trip may come well after the fire.

11 CHAIR STETKAR: Right. That's right.

12 And that's why it's important. But it is important 13 that the start of their scenario

-- it's one of the 14 things I look for

-- is the initiation of the fire. And 15 indeed, the reactor trip can occur sometime after that.

16 Whether it's caused by the fire, whether 17 it's coincident, whether it's somebody manually trips 18 the reactor, that begins a certain type of transient.

19 But the fire can cause a tran

- -- can cause a disruption 20 of cooling without tripping the reactor.

21 MEMBER KIRCHNER: Yeah.

22 CHAIR STETKAR: And that

-- that is -- 23 MEMBER KIRCHNER: So, my question is, are 24 all the scenarios you look at reactor

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-3701 (202) 234-4433 with the fire alarm? Or is this just an example?

1 DR. COOPER: I want to defer that 2 question. 3 MS. PRESLEY: I would say

-- 4 MEMBER KIRCHNER: I mean, the more likely 5 thing is that you would have a fire somewhere in the 6 plant, and it would take sometime either to recognize 7 you had a problem, or to do grade equipment, or to get 8 to reactor trip. But I wouldn't see them coincident.

9 MS. LINDEMAN: Yes, that's correct. A 10 common simplification is the fire starts at T equals 11 zero, and there's also a reactor trip at T equals zero.

12 I believe in supplement 1, we acknowledged that that 13 simplification may not be appropriate in all instances, 14 and, you know, it's dependent on a lot of things.

15 Right? 16 The fire can happen like a transient, and 17 that's not associated with a piece of equipment, so it 18 can take time for that fire to grow and develop. Or 19 you can have a fire on the right location and a reactor 20 trip -- 21 MEMBER KIRCHNER: So, let's go back to 22 Browns Ferry. When did they discover the fire, and 23 when was the reactor tripped?

24 MS. LINDEMAN: I would say the fire was 25 81 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 detected rather quickly, based on my recollection.

1 MR. SALLE Y: Browns Ferry

-- so it was a 2 manual trip on Unit

1. After they had the fire and they 3 fought it for quite a while. So, there was an amount 4 of time, and the key on Browns Ferry was they, at that 5 point, knew they lost all their cooling systems. So, 6 they were pretty much done.

7 Now, the interesting thing is Unit 2, 8 because Unit 2 was a sympathetic trip. There's

-- you 9 know, it was sympathy that they were going to lose it 10 too, so they tripped that manually.

11 CHAIR STETKAR: But the point is that the 12 fire da maged -- the effects of the fire damage begin 13 at time T zero when the fire occurs. The reactor trip 14 is simply some of that that occurs. It could happen 15 at zero, it could happen, you know, 17.3 minutes after.

16 That doesn't necessarily start the PRA 17 scenar io. The PRA scenario starts when you get some 18 damage to equipment that can affect the nuclear power 19 plant. Cooling the core in particular.

20 MS. PRESLEY: So, that point is 21 not -- this timeline's a simplification. So

-- 22 CHAIR STETKAR: But see, in supplement 1, 23 indeed, that's one of the things I looked at. And 24 supplement 1, perhaps, is not belabored as much as we 25 82 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 just belabored it. But it is

-- that distinction is 1 made in supplement 1, that the reactor trip doesn't 2 necessarily nee d -- 3 MEMBER KIRCHNER: Yeah.

4 CHAIR STETKAR:

-- to have gotten 5 started -- 6 MEMBER KIRCHNER: Because coincident was 7 your fire start.

8 CHAIR STETKAR: T zero starts the fire.

9 MR. AMICO: Paul Amico from Jensen Hughes 10 again. Yeah, but again, is it

-- it's mor e like a 11 typical PRA assumption that we

-- that we don't

-- we 12 look at everything. For example, all the failures that 13 occurred due to the fire, we assume they happen 14 immediately, as was brought up.

15 It's similar to when we look at a failure 16 to run, for a p ump. It could really occur any time.

17 And if it occurs anytime, it could change the amount 18 of time you have left to do some action. So, we don't 19 get into that. A failure to run, we assume it happens 20 at T zero, whether it does or not.

21 And so, the thing here is, we're talking 22 about is that in the PRA assumption, we bring everything 23 back to happening simultaneously, so that you get the 24 worst effect

-- the least amount of time, the least 25 83 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 amount of heat removed from the plant.

1 If you say everything happens at T zero, 2 I've got the most latent heat, I've got the most decay 3 heat, I've lost all my equipment at that time. And 4 that's not unique to the abandonment scenario.

5 That's not unique to buyers. That's 6 pretty much the way we do all of our PRAs.

7 CHAIR STETKAR: Okay, that's

-- and 8 again, you're speaking of the way you do all of your 9 PRAs. I've done PRAs that do look at the timing of fire 10 damage. 11 MR. AMICO: And indeed PRAs do look at the 12 timing of fire damage. It's called fire growth 13 detection, fire ignition detection, growth and 14 suppression, so that you get a sequence of extending 15 damage, depending on how long the fire exists, and where 16 it is. 17 And indeed it's not unique to fires. For 18 example, if I look at losses o f offsite power and 19 station blackouts, I parse my models

-- and I'm saying 20 now, I, rather than we, as the royal 21 everyone-does-it-this-way -- I parse my model in terms 22 of, what's the likelihood that I recover offsite power 23 within X minutes? And if I do, I have certain 24 opportunities.

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-3701 (202) 234-4433 Why minutes? I have different 1 opportunities

-- zed minutes

-- I have three 2 opportunities, and maybe, you know, one more. So, this 3 course distinction of times is not what everyone does.

4 I mean, it's not what everyone does on 5 these time

-sensitive things, to always presume 6 everything is worse happening at T zero. That's a 7 holdover from LOCA analyses. It's not necessarily the 8 best thing to do for fires.

9 MS. PRESLEY: And because it shows on this 10 view graph , that doesn't mean that we are requiring

-- 11 CHAIR STETKAR: No.

12 MS. PRESLEY: So, I want to clarify. So, 13 for this example, we're not requiring that. We 14 acknowledge it as a typical simplification. But we're 15 not requiring it. But this

-- 16 MEMBER KIRCHNER: What I was objecting to, 17 I guess, is making Rx trip coincident with fire starts, 18 or fire alarm. The fire might go on for quite a while 19 before you realize you have a problem. And then, much 20 later in the scenario, you trip the reactor, manually 21 or autom atically. 22 And then, you may have a heck of a lot less 23 time to do other actions to mitigate the problem. So, 24 I'm just -- maybe this is misleading me and this is not 25 85 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 the way you actually do the analyses, but putting Rx 1 trip coinciden t with the fire alarm seems magical.

2 DR. COOPER: Susan Cooper. I agree. I 3 agree. 4 MEMBER KIRCHNER: Magical, in fact.

5 DR. COOPER: I'm not sure that's the point 6 that she wanted to make with this graph. And I 7 guess -- but I agree with you. Probably at s ometime 8 after the fire is acknowledged and the local operator 9 has been found out what

-- after he made his 10 investigation and calls back to the control room and 11 they make an assessment as to where that fire is now 12 located, and now they'll have some guidance about 13 whether or not they're going to have a reactor trip.

14 So, I think there's

-- and we'll fix this.

15 I don't think this graph is actually in the report.

16 CHAIR STETKAR: That is not.

17 DR. COOPER: Yeah, it's not in the report 18 yet. It's something we're trying to use to help 19 explain some things. So, the feedback you've given 20 here to help will help us decide whether we want to use 21 it or not.

22 But the point is that we're trying to 23 illustrate that we understand that there is a 24 progression of things. And this is

-- and she's got, 25 86 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 I think she said, 12. So, we do have multiple cuts.

1 It's not just one picture.

2 CHAIR STETKAR: When you think of these 3 things, I always

-- you know, we

-- we get trapped in 4 this too, so I can say we. We tend to get pigeonholed 5 into things. This, for some reason, seems to be the 6 guidance for quantifying main control room abandonment 7 for fires that happen only during full power operation.

8 Now, I think

-- the fire doesn't know 9 what's going on. The people in the control room live 10 in the control room 24/7. So, think about shutdown 11 conditions. There's no reactor trip. Reactor trip is 12 shut down. On the other hand, the fire has 13 all -- causes some damage that results in a trajectory 14 of the plant, and results in responses of the people.

15 Now, if the plant happens to be operating 16 at power, one of the things that the fire might do is 17 trip the reactor. One of the things that the people 18 might do is trip the reactor.

19 But that's irrelevant to guidance for how 20 to think about this in the sense of a PRA. Fire damage 21 begins at zero.

22 DR. COOPER: We have not develop guidance 23 for shutdown fire.

24 CHAIR STETKAR: But no. My point is that 25 87 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 shutdown fire is no different

-- the fire doesn't know 1 and the people don't know.

2 DR. COOPER: So

-- 3 CHAIR STETKAR: So, why do we have to 4 pigeonhole the guidance for, you know

-- 5 MS. PRESLEY: The point of this is to say 6 that timing is not as clear cut as in

-- and I think 7 we've all -- we've just furthered the demonstration 8 that this is true. So, even with my simplified 9 version, which is not clear cut, it could be even more 10 less clear cut.

11 So, at some point you're going to have a 12 fire. At some point you're going to have an alarm.

13 Some where you're going to have a reactor trip. Then 14 you do your immediate memorized actions. When you get 15 your alarm, you send someone to confirm it locally.

16 That person eventually will come back and 17 report with, you know, what's going on and where the 18 fire is, and confirm that you have a fire. Then, you're 19 going to start seeing at some point instrumentation 20 failure. 21 And then, at some point you're going to 22 decide that that instrumentation failure is 23 significant enough that your major systems and 24 instrumentation has been impacted.

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-3701 (202) 234-4433 And then, you're going to get to the point 1 where, yes, I think I've lost control. I need to 2 abandon. So, that's

-- so, the order of those things 3 happening, and how compressed or elongated they are, 4 depends on the fire modeling piece and what scenario 5 you're modeling.

6 But you can't just look at, you know, this 7 cue says I need to look at these three pieces of 8 equipment. When does my modelings of these three 9 pieces of equipment are gone?

10 You have to look at the totality of the 11 picture. So, thank you for proving my point for me.

12 MS. LINDEMAN: We'll get a better picture 13 -- 14 MS. PRESLEY: Yeah. And there's, you 15 know -- like I mentioned, this is one snapshot of one 16 kind of progression we looked at. We looked at a 17 half-dozen of these, and it depends on what your cue 18 says. 19 So, if your cue says consider abandoning 20 after a fire in the cable spreading room after local 21 confirmation, then in this particular graph, local 22 confirmation comes before you have major systems 23 identified.

24 Well, are they really doing to do that? Or 25 89 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 are they going to wait a little bit? Are they 1 going -- you have to start asking questions about 2 training. 3 Are you trained to confirm any particular 4 equipment? Or do you take t his verbatim? So, the 5 procedure progression and the fire growth progression 6 need to be matched up so you understand what's 7 happening.

8 That was kind of the point of this graph.

9 So, if you want to go to the next one.

10 MEMBER BLEY: But before you

-- before 11 you -- 12 CHAIR STETKAR: I'm sorry. I'm sorry I 13 was away for a little while.

14 PARTICIPANT: I have one comment.

15 CHAIR STETKAR: Hold on. Jazz, let 16 him -- 17 PARTICIPANT: Oh, I'm sorry.

18 CHAIR STETKAR:

-- finish talking, 19 please. 20 MEMBER BLEY: It's hard to hear back 21 there. If you want to keep something like this, you 22 know, the words here make sense. The discussion makes 23 sense. But I'd really urge you, if you're going to keep 24 something like this, that you keep at least a couple, 25 90 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 to say, there's a couple of different ways this could 1 happen. 2 There are lots more. But showing one kind 3 of anchors in somebody's head that, yeah, the first 4 thing that ever happens is that the reactor gets 5 tripped. And then we start watching the fire. And 6 they happen in this order, and that's not

-- your point 7 was they don't.

8 MS. LINDEMAN: And I think what's in the 9 report is actually just a bullet list of the things that 10 you consider.

11 CHAIR STETKAR: In supplement 1 -- I'm 12 staring at it right now

-- in chapter 7 of 13 supplement 1, there is a discussion about this relative 14 timing, and it's clear that zero is when the fire 15 starts, and things happen after that.

16 In the latter part of section 7, it says, 17 PRAs often simplify this by assuming the reactor trip 18 occurs at zero, but the construct in supplement 1 19 actually does distinguish between the

-- JS. 20 MR. HYSLOP: Yeah, this is JS. I guess 21 I'm not sure I need to say what I was going to say since 22 you just did, but often, yeah, the trip is assumed at 23 T equals zero, often. And some of the reasons 24 sometimes is just we haven't traced all the cables, so 25 91 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 we're not sure what will happen.

1 But there is a fire growth modeling that 2 occurs, and if you wanted to take advantage of that and 3 say you d idn't damage in the target sets, I guess you 4 could delay it.

5 CHAIR STETKAR: Any more discussion on 6 step one, because if there's not, I'm going to call for 7 a break, because we're going to shift gears here to talk 8 more in terms of models and methods, and th at sort of 9 stuff, and we need a break. So, let's take a break and 10 return at 3:15.

11 (Whereupon the above

-entitled matter went 12 off the record at 2:56 p.m., and resumed at 3:16 p.m.) 13 CHAIR STETKAR: We're back in session.

14 MS. PRESLEY: Okay. So, Step 2 which we 15 did in parallel with the issues list, actually a little 16 bit of an iterative process, but we listed several HRA 17 quantification approaches to see what was out there, 18 what might be used, and what we might be able to pull 19 from. And the ones on the screen are the ones we looked 20 at. 21 The cause-based decision method and 22 decision tree method, HCR/ORE, which is a time 23 reliability method.

24 We looked at IDHEAS At

-Power. 25 92 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 We also looked at

-- we're familiar with 1 IDHEAS G and we looked at the cognitive literature stuff 2 underlying it. So while that wasn't one of the 3 quantification methods we looked at specifically, we 4 did look at the failure mechanism there.

5 We looked at SPAR

-H. 6 We looked at NARA and CREAM.

7 So if you want to go the next.

8 MEMBER BLEY: NARA's still not public; 9 right? Except for a couple papers?

10 DR. COOPER: Susan Cooper. Yes, that's 11 correct. 12 And we did, we'll see later that we did use 13 NARA. And that was from one of the papers. Among the 14 authors on the team we do have access to the non-public 15 version and can make internal comparison. So, it's 16 good. 17 MS. PRESLEY: So, our initial, so after 18 we'd looked at this set of methods we thought maybe we 19 could adapt the cause

-based deficiencies. At the high 20 level, the failure modes, the op erator, information 21 interface and the operator procedure interface, 22 failure modes seem to be potentially applicable.

23 So we started there and we went through the 24 review process. And we went tree by tree and we asked 25 93 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 is the failure mode of the tree still applicable? We 1 looked at each branch point and kind of performance 2 shaping factor associated with the tree and we said, 3 Are those the right ones for the failure mode? Are they 4 still applicable? And are there dominant failure 5 modes or mechanisms missing from the set of trees, from 6 the set of CBDT trees that we should, we should be 7 accounting for?

8 And as we went through we found that at the 9 failure mode level it was pretty applicable. But once 10 we started going through we were stretch ing the method 11 more than maybe it was intended to. We were 12 reinterpreting things.

13 For example, four of the trees talk about 14 the operator procedure interface. But what procedure 15 step are you really talking about? We found we were 16 convoluting the transfer to get to the abandonment 17 procedure and then the actual decision to abandon cue.

18 We were conflating the two as we went through the 19 case-based decision trees.

20 We saw some, or there were binary decisions 21 where we thought more gradation might be warranted.

22 And some of the trees just required more 23 reinterpretation than we were willing to make.

24 So we said, okay, we'll pull what we can 25 94 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 from it and what we think is important, but we're really 1 not going to go with the existing method and try to just 2 adopt that wholesale.

3 So we ended up with three new decision 4 trees: 5 Failure to transfer to the main control 6 abandonment procedure; 7 Failure to understand the criteria have 8 been met; 9 And then, so, if we get to the criteria then 10 we have to understand the criteria have been met. And 11 then once you understand the criteria have been met, 12 you have to actually make the decision.

13 So the last one is reluctance of delay in 14 making the decision.

15 MEMBER BLEY: In the report itself isn't 16 there just one?

17 MS. PRESLEY: In the report there is one.

18 So this is what we went into from the discussion.

19 So, so that formed the discussion that the 20 skeleton of what we discussed with the

-- if you want 21 to go to the next slide.

22 MEMBER SUNSERI: Wouldn't the reluctance 23 to del ay just be a subset of one of the other ones?

24 MS. PRESLEY: Well, that's what the 25 95 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 experts told us. So, so yeah.

1 We, we thought it might be a separate 2 factor after we looked at it, but it turns out that 3 reluctance is primary driving factor from the expert 4 elicitation is that reluctance is key. And it 5 underlies everything. So it will always be there. So 6 it's built into the base HEP.

7 There wasn't a separate branch point 8 called out reluctance, or there weren't levels of 9 reluctance b ased on the quality of the remote shutdown 10 panel because an operator doesn't know that plant X has 11 a great remote shutdown panel, but theirs is really 12 crumby. They just know that they have a remote 13 shutdown panel and it's not the control room.

14 So they, they might not

-- they would not 15 necessarily have more or less reluctance than another 16 operator at a more or less capable plant.

17 So, so one of the, one of the key points 18 was that reluctance needs to be built into a base HEP, 19 and we don't need to look at fact ors around that.

20 We also learned that timing, which we 21 thought would be important, was going to be a key 22 differentiator.

23 And then the other piece was we thought 24 procedures were really important: how you get to the 25 96 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 procedure and the quality of the procedure. And there 1 was a lot of discussion about the process the operators 2 go through of integrating information to always be 3 looking ahead at what's coming, and that they would have 4 an idea of what the criteria are based on their 5 trainin g. 6 And so there are prudent actions that all 7 operators they need to understand as part of their 8 fundamental training. And if they get

-- start seeing 9 indications of spurious operations, they're going to 10 start thinking about the abandonment criteria.

11 And s o that was more important more of a 12 dominant factor than just the procedures themselves.

13 So, so that was also, from an offsetting perspective, 14 built into the base HEP. And it actually goes with 15 training as well. So we pulled out training as one of 16 the b ranch points in the final, in the final tree.

17 MEMBER BLEY: Let me ask a kind of broad 18 question about that.

19 Let's say 20, 30, 40 years ago we would 20 argue the same things about the emergency operating 21 procedures, the LOCAs and all that kind of stuff. And 22 w e did. 23 And then we saw more and more. And some 24 utilities ran tests of their old experienced operators 25 97 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 who produced relevant, newer procedures. And pretty 1 soon everybody was coming on board. But they have a 2 better chance to do well with more elaborate 3 procedures.

4 But that only came after a lot of 5 exercising the procedures and getting used to them. We 6 don't exercise these procedures very much. I don't 7 know how much people even look at them when they're not 8 in the midst of it. And most of them are never in the 9 midst of it.

10 And do you have a sense for whether that's 11 what's going on here, or is it just there's something 12 about this that doesn't lend itself to writing a linear 13 procedure that will be helpful to you?

14 MS. PRESLEY: So, in the process of doing 15 the HRA some of our team members have found that there 16 was great potential to improve the procedures. There 17 were extra actions in there that people, well, while 18 you're there we're going to do it, but it would 19 challenge the time, the feasibility from the timing 20 perspective.

21 So there was definitely a lot of refinement 22 possible. But from a cognitive perspective I think we 23 don't understand the exact progression that is here and 24 exactly what the operators will be s eeing. And that 25 98 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 was talked about a lot. So, having some high level 1 criteria and training the, training that could be a 2 little more agile is important where, where we just 3 don't know how the scenario might unfold.

4 One of the things the experts did talk 5 ab out was management philosophy and whether or not the 6 operators are trained to think at the higher level and 7 encouraged to do that. So, I think, I think in this 8 particular scenario we can't be so prescriptive because 9 we just don't know what it's going to look like. And 10 I don't know if

-- 11 DR. COOPER: Yeah. Susan Cooper. I'll 12 just add to that.

13 There seems, despite the fact that we had 14 experience among the author team with making changes 15 to procedures, getting certain utilities to buy into 16 changing the procedures to have more explicit criteria 17 for the decision to abandon the loss of control, when 18 we got the expert panel together there seemed to be some 19 pushback on making, you know, funneling analysts to 20 saying that's the solution to this problem as opposed 21 to looking more at the experience of the operators and 22 not getting sort of fenced in into particular criteria.

23 Exactly where that's coming from is hard 24 to say. But certainly we don't have any experience to 25 99 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 show us which is the right way at this point. I don't 1 think we've run across any plant that is doing training 2 on the decision to abandon, except in the classroom.

3 MEMBER BLEY: Thank you.

4 MS. PRESLEY: There is one that was 5 brought up during the

-- there was one plant that was 6 br ought up during our elicitation that they were doing 7 it. But even in that case they said, you know, we do 8 the classrooms training and then we go into the 9 simulator to do it. So they're sort of seeded to think 10 abandonment already. So maybe it's not reali stic. 11 MEMBER KIRCHNER: How often is the remote 12 shutdown panel tested, "tested" at a typical plant?

13 Once a week, once a month, once a shutdown, once a 14 refueling?

15 MS. PRESLEY: What do you mean by 16 "tested," like trained on? Or even observed and 17 checked. 18 MEMBER BLEY: To make sure the switches 19 work and that kind of stuff?

20 MEMBER KIRCHNER: Everything, yeah.

21 MR. AMICO: This is Paul Amico again from 22 Jensen. 23 So, the question is like to actually 24 operate things? Because they don't

-- 25 100 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 MEMBER KIRCHNER: Well, or check that it's 1 operating.

2 MR. AMICO: Yeah. I mean, they don't 3 actually go through and start pumps and things like that 4 using that panel.

5 MEMBER KIRCHNER: No. But I mean at least 6 inspect it.

7 MR. AMICO: Right.

8 MEMBER KIRCHNER:

Ensure that it's

-- 9 MR. AMICO: It will vary from plant to 10 plant. Jeff, I don't know if you have the

-- you know, 11 at least during the refueling outage they would check, 12 they would energize it to check the meters come on and 13 everything like that. But every plant would do it 14 differently.

15 DR. COOPER: Susan Cooper. There are 16 some plants that have their remote shutdown panels 17 energized all the time.

18 MR. AMICO: That's true.

19 MEMBER KIRCHNER: That's what I would 20 expect. That's why I was asking.

21 DR. COOPER: But they still have to 22 transfer control from the control room to the remote 23 shutdown panel. I don't know when that testing is 24 done. I seem to remember that Paul or one of our other, 25 101 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 other authors in the audience, has run across that that 1 may not happen so often.

2 MEMBER SUNSERI: So I don't, I mean I may 3 be mixing up, and I'm sure I am mixing up some things 4 here, but I'll ask for some clarification. It seemed 5 to me like I recall during triennial fire inspections 6 every three years a reg guy goes out to the plant, 7 inspects. And they walk the operators through a lot 8 of these fire scenarios and actually time them to make 9 sure that the timed responses are within the regulatory 10 or the analyzed limits.

11 It would seem to me that that exercise or 12 that piece exercises some elements of what you're 13 talking about up here. So I guess I'm surprised that 14 operators then are reluctant, because they do get a 15 chance periodically to walk through these procedures 16 and become more comfortable with them.

17 Can you comment?

18 DR. COOPER: Susan Cooper. So, so the 19 part where they've left the control room and they're 20 taking actions, either at the remote shutdown panel or 21 at local plant stations, yes, it has been and is being 22 exercised quite a lot. You could say it's familiar in 23 a certain sense.

24 The parts that aren't exercised are things 25 102 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 like the decision to abandon the control room. What 1 we've heard I think almost universally is the way that 2 they train abandonment scenarios s tarting in the 3 simulator is that the trainers for the operators will 4 say you have an abandonment scenario, show me what 5 you're going to do next. Which really is about 6 exercising all of the steps that are needed to be taken 7 in the control room before you c an leave. 8 Like what actions do you have to take to 9 transfer control; what other pieces of equipment you 10 might need to operate if you haven't tripped; or 11 whatever, those kinds of things that will be exercised 12 but not the decision.

13 Th e other piece that's not exercised, 14 which we're going to talk about after Phase II, and that 15 is what's happening at the remote shutdown panel with 16 the supervisor who is trying to keep track of all the 17 things that are going on either at the remote shutdown 18 panel and the variety of local plant stations out at 19 the plant. You know, his, his communication with them, 20 the way he keeps track of going to the procedure and 21 so forth, that also

-- you know, there have been some 22 plants that have said they've done that, but that's 23 rare. 24 So that piece also is not trained often.

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-3701 (202) 234-4433 MS. PRESLEY: Okay. And so the last piece 1 is that we just wanted to point out, because this came 2 up in the expert elicitation and the bounds of it, our 3 estimation was based on current U.S. fleet.

We did 4 include performance working factors that may be like 5 training, above what the current fleet is doing, to show 6 that there are potentials for improvement. But we 7 didn't look at what new designs were. They might have 8 a second main control room which has, you know, 9 virtually the same capabilities.

10 So that wasn't in the scope of the what 11 we're looking at.

12 So, Step 6. Our drumroll please.

13 Our final tree that we came out with with 14 the -- and consolidating the three trees into one. And 15 as I mentioned, the reluctance, you don't see a branch 16 for that. That was baked into the base HEPs, which is 17 why they all start fairly high. And the way to

-- I'll 18 talk across the branches.

19 The first was abandonment logic explicit 20 in the procedures. So is there some indication of what 21 the criteria are?

22 MEMBER BLEY: Do you mind if I interrupt 23 you just a second.

24 MS. PRESLEY: Yes?

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-3701 (202) 234-4433 MEMBER BLEY: For the other members, if 1 you haven't looked at decision trees and HRA methods, 2 don't get confused. They are not like event trees.

3 They're really just a truth table of conditions. And 4 when you analyze your plant, you know what the 5 conditions are. You come into this tree and say for 6 this scenario, under these conditions it's a certain 7 place here. It's jus t saying, yeah, I do have the 8 criteria document in the procedure. It's only 9 classroom training and it's not

-- if you work your way 10 through this tree you come in with your conditions, 11 match it up, and read the number off the end.

12 I'm sorry. Just this con fuses people.

13 MS. PRESLEY: Thank you very much. Yeah, 14 thank you very much for that background.

15 So the first question that we ask then is, 16 is the abandonment logic explicit in the procedures?

17 Now, we mentioned that it's not as much of 18 a driver as we initially thought, but it's still an 19 important driver. And instead of three gradations, 20 which we originally had, we pared it down to one. And 21 is it really purely judgment

-based or is there some 22 criteria that are documented in the proce dure that the 23 operators can refer to and monitor?

24 So you can go up or down based on your 25 105 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 answer to that question.

1 The second question asks for simulator or 2 talk-through training specifically on the decision to 3 abandon. So everyone kind of gets the trainin g on the 4 abandonment procedure but have they actually simulated 5 what they're going to see and how they're going to think 6 about the decision and how they're going to make that 7 decision? 8 So, while this is not standard practice, 9 this is one area that people could improve. So the 10 question is, is it classroom only or do they go that 11 one step above where they actually do talk

-throughs or, 12 again, a simulator run?

13 And so then the third question has to do 14 with training and understanding of the scenario. So, 15 do they have an awareness of the urgency? And this gets 16 to different, different scenarios progress at 17 different rates.

18 So how much time you have is important, but 19 it's equally important to know if the operators 20 understand how quickly they need to make the decision.

21 So this, this gets

-- 22 MEMBER BLEY: Sorry to interrupt again.

23 MS. PRESLEY: Yes?

24 MEMBER BLEY: When I read something 25 106 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 earlier in these where it said is this time Phase III.

1 Well, this is the time from when they decide to aban don 2 until the PRA shows when they wouldn't be able to get 3 everything done. That's not something in an 4 operator's head.

5 MS. PRESLEY: No. Yeah, so that is the 6 operator will not know if they have 5 minutes, 25 7 minutes. But they would know, they would unde rstand 8 if it's a fast progressing or slow progressing fire.

9 They would be able to tell you what are the types of 10 things they might check in different scenarios before 11 they would make the decision.

12 So the kinds of questions that you should 13 be asking it's do you know you have 5 minutes, or how 14 much time do you think you have? It would be questions 15 like, okay, what would you check before you made the 16 decision? Or how would you make the decision?

17 And then you can start getting an idea of 18 how much time they think they have and what they would 19 do. And that would give you an understanding of 20 whether or not they have an awareness of the urgency.

21 MEMBER BLEY: Question. I haven't looked 22 at these procedures in quite a few years so I don't know 23 what they look like now. Do they give hints of the 24 urgency and time available to carry out all this stuff 25 107 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 to the operators?

1 MS. PRESLEY: I don't believe they do.

2 But Paul can.

3 MR. AMICO: Okay. Paul Amico again from 4 Jensen Hughes.

5 So, it really va ries a lot from plant to 6 plant. Unlike EOPs, these fire abandonment procedures 7 are completely different. There's no Westinghouse 8 approach, or CE approach to an abandonment procedure.

9 So it varies greatly.

10 Some of them are changing. As a result of 11 the f ire PRAs and 805

-- and then J.S. can talk to this 12 also because he's familiar

-- the plants are realizing 13 that they do need to make improvements. So you are 14 seeing some cases now where it's sneaking into the 15 procedure that you need to make this decision w ithin 16 25 minutes, or some range. So it varies greatly, 17 Dennis. 18 It's just but we're starting to see 19 improvements in that, also improvements in the 20 training. So, so it's one of the benefits.

21 MEMBER BLEY: It's like I remember but 22 it's getting better.

23 MR. AMICO: Yeah. Yeah. It used to

-- I 24 mean, some of these procedures were so simple, like when 25 108 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 the shift manager feels that they can no longer control 1 the plant from the control room, consider abandonment.

2 MEMBER BLEY: That's it.

3 MR. AMICO: And, you know, and it's 4 getting better because the PRAs are starting to say 5 these are the things that you are likely to see. And 6 they're putting that in as the cues to consider. And 7 they're giving some indication of the urgency.

8 MEMBER BLEY: That's good. Okay, thanks.

9 But it's still varies.

10 MS. PRESLEY: Yes. So sometimes you have 11 time-critical actions linked with fires in different 12 locations, but it's definitely all over the map still.

13 And then so after

-- 14 MEMBER BLEY: One more thing. Is the 15 staff doing anything about that to encourage that these 16 become more consistent and useful to the operator?

17 MR. HYSLOP: Well, I was just going to

-- 18 MEMBER BLEY: You've got to say who you are 19 again. I'm sorry.

20 MR. HYSLOP:

J.S. Hyslop. We are seeing 21 in our, you know, we had an application meeting with 22 the licensee and we didn't encourage it because, you 23 know, we were at a certain stage of analysis and stuff 24 like that. But they came in and said we're going to 25 109 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 re-do our analysis. So this is one of the better 805 1 main control analyses that was done.

2 I said, Why are you doing that? You did 3 one of the betters.

4 He said, We're updating our procedures to 5 be more specific on the criteria for abandonment.

6 And so I don't know, I don

't think, I don't 7 think the staff is encouraging it at this point, but 8 we're hearing it happen.

9 MEMBER BLEY: Do you have any hints as to 10 whether INPO's pressuring this work or not?

11 MR. HYSLOP: I don't.

12 MEMBER BLEY: Okay.

13 MS. PRES LEY: So then the last, the last 14 thing it asks about is how much, how much time to you 15 have available to make that decision. And the way we 16 calculate time available is we look at how long it takes 17 to actually be successful in the Phase III action and 18 see what the leftover time is. And that's your time 19 margin to make a decision. So, basically, that's how 20 much you can delay before the downstream actions won't 21 be effective anymore, so.

22 DR. COOPER: If I can just add. The point 23 is, as Matthew was saying, th e actions taken to shut 24 down the plant after you've left the control room are 25 110 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 practiced. You can get times for those. And you can 1 also talk about you'd need a little extra time for 2 recovery, or you certainly factor in travel time. So 3 you can, you can estimate all those times based on 4 actual demonstrations.

5 And then you can total up all those times, 6 using the integrated time lines to account for overlaps 7 and so forth, and then you can get an estimated time 8 for implementation of the safe shutdown strategy.

You 9 might want to give yourself a little bit of a margin.

10 But the point is you have an overall system window that 11 you've calculated for your thermal hydraulics on when 12 you reach core damage.

13 So you subtract off what you think you need 14 for implementing all those act

-- executing all those 15 actions for shutdown, and also subtracting off when you 16 got the cue, and then you've got something left over 17 for your decision. That's, so it's a calculated thing.

18 Since it's not trained in the control room, it's not 19 like we can go out and collect data on it or anything 20 like that.

21 MS. PRESLEY: And next slide.

22 MEMBER SUNSERI: Well, I had one question 23 on that slide before you leave it.

24 Does it -- my mind can't go through the 25 111 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 permutations as quic kly as you start it

-- but does it 1 make a difference on what order you ask these questions?

2 It seems like if you brought the awareness question up 3 earlier it might change the outcome.

4 You know, because if you are unaware that 5 you're in an urgent situation and you're using your 6 judgment, not procedures, to drive the outcome, you 7 might get in a different place than you would if

-- see 8 what I'm saying?

9 MS. PRESLEY: Yes. So I should probably 10 describe how the numbers came to be.

11 So, the numbers came to be we did, we asked 12 the experts to give us estimates for the worst case, 13 which is judgment

-based cue, only classroom training, 14 and no awareness of urgency, and for 5 minutes and 25 15 minutes. And then they gave us the best case 16 probabilities.

17 And then what we asked them to do was a 18 parallel comparison between each branch point pairs.

19 So they actually went scenario by scenario and said we 20 think this scenario is better or worse than that 21 scenario. 22 So in that case it doesn't matter whether 23 you said it first or not. They thought about the 24 scenario as a whole when they compared it against.

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-3701 (202) 234-4433 MEMBER SUNSERI: Okay, so I think I see.

1 It doesn't matter if you ask the three questions in any 2 order, you still get through the branc hes and you still 3 get through the

-- 4 MS. PRESLEY: Yeah.

5 MEMBER SUNSERI: I get it.

6 MS. PRESLEY: Yeah.

7 MEMBER BLEY: Your concept might be right.

8 MEMBER SUNSERI: Yes.

9 MEMBER BLEY: But this is simply a truth 10 table. 11 MEMBER SUNSERI: Yes.

12 MEMBER BLEY: And so if both of them are 13 in one direction it's under that condition of both being 14 one way or both being the other. It's not a scenario 15 in the sense of when we think of something happening 16 over time.

17 CHAIR STETKAR: I guess

-- don't switch it 18 yet. Leave it on the screen.

19 I very much appreciated the discussions in 20 Supplement 1 and Supplement 2 about how complex all of 21 this is and all the variability and how some plants are 22 better and some plants are worse. And we've heard a 23 lot about that today. What I was really surprised 24 about was that your experts, considering all of that, 25 113 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 have assessed that there's between an 80 percent and 1 98 percent success rate of always doing this successful 2 with enough time left.

3 To me that seems really darn ed good, given 4 all of the stuff we've heard about variability, about 5 reluctance. This says the worst it can be is they'll 6 be 80 percent successful in leaving with enough time 7 left to do everything they need to do in Phase III.

8 That's the worst it could be, an 80 percent success 9 rate. 10 A lot of students in school would be really 11 happy after a lot of studies to have an 80 percent 12 success rate. So I'm really curious how your experts 13 came up with this very, very highly likely success, with 14 no uncertainty by the way, because Appendix A where you 15 discuss the expert elicitation specifically says that 16 you didn't look for uncertainty in the expert 17 elicitation process.

18 MS. PRESLEY: So I'm going to caveat that 19 with it's 80 percent given we've met the feasibility 20 criteria. 21 CHAIR STETKAR: Sure. Obviously, yes.

22 MS. PRESLEY: So you've already met a 23 fairly high bar to get into that. Right? You've 24 weeded out your students that didn't study.

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-3701 (202) 234-4433 CHAIR STETKAR: This is a plant where it's 1 left up to the supervisor. If you think it's a good 2 idea, get the heck out of the control room. That you've 3 talked about it in a classroom. And the people aren't 4 aware of the urgency that I need to get out of here, 5 and I, by the way, I have to make that decision within 6 5 minutes, and I'm still 80 percent successful. Eighty 7 percent successful.

8 DR. COOPER: Susan Cooper. Feasibility 9 also requires even if there's judgment in making the 10 decision only, the procedure only has judgment as a 11 criteria, there needs to have been interviews of the 12 operators and a consensus opinion on what constitutes 13 a loss of control where they would leave the control 14 room that has to have been obtained.

15 So there is another piece to that bar. So 16 that's an important piece of the feasibility.

17 So it's not like they have no notion of what 18 it is that would represent or be defined as loss of 19 control. 20 CHAIR STETKAR: Right.

21 DR. COOPER: So there is another little 22 bit more there.

23 CHAIR STETKAR: And in your interviews you 24 mak e it very clear that loss of control is they have 25 115 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 to know that if the core is going to melt they're going 1 to leave. That's the way you've characterized it, is 2 that loss of control is the plant is on a trajectory 3 that you cannot prevent the core from melti ng from 4 inside the control room. Look in your guidance.

5 And, of course, if I'm an operator I'm 6 going to say, Well obviously if I know the core is going 7 to melt I'm going to leave.

8 DR. COOPER: Susan Cooper. If it doesn't 9 say it, it should say this because what the operators 10 believe and what we've discussed in detail is that they 11 need to tell us what those conditions are. Not that 12 we tell them that this is it. They have to tell us what 13 those conditions are.

14 And then and it has to be a consensus answer 15 from more than one operator. So it's not like we tell 16 them this is what the situation is, are you going to 17 leave? It's what are the conditions that you think 18 define loss of control? And that has to be a consensus 19 answer. 20 MEMBER KIRCHNER: Susan, one thing on this 21 chart. Is T available for decision? It's a 22 calculated quantity?

23 DR. COOPER: Yes.

24 MEMBER KIRCHNER: From a PRA or whatever?

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-3701 (202) 234-4433 DR. COOPER: No. It's calcul

-- well, it 1 has a number of different inputs. The first and mos t 2 important input is going to be some kind of thermal 3 hydraulic calculation associated with the scenario 4 that says when core damage would be reached if you 5 haven't been successful with the shutdown strategy.

6 Other pieces of it are going to be, for 7 example, I mentioned you're going to, for each of the 8 actions that are required for shutting down the reactor 9 after you've left the control room there have been 10 demonstrations on those actions and you can collect 11 times on those. And that was discussed even in 1921. 12 We have some more I think in Supplement 1.

13 So those, those pieces so you can measure 14 out how much time you need for, for Phase III, and you 15 can add in some time for some communications and so on 16 and so forth. And then you need to also subtract off 17 some time to when you think the cue is going to come 18 in. 19 But that's, so that calculated

-- that's 20 a calculated time with a number of different timing 21 inputs. But it's a back calculation from all of those 22 different things.

23 MEMBER KIRCH NER: Yeah, I understand 24 that. I'm just going through this logic and thinking 25 117 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 I'm the operator, I don't know whether I'm going to have 1 5 minutes, 5 to 25 minutes, or 25 minutes.

2 DR. COOPER: No, you don't. You don't.

3 It's an HRA calculated to make a dis tinction between 4 if you have 5 minutes to make the decision, we're making 5 a distinction saying that that's going to be more 6 difficult, or we think it's going to be less likely that 7 they can -- 8 MEMBER KIRCHNER: I agree with the notion 9 that if you have more time to make a decision the human 10 error probability of the first order should go down.

11 DR. COOPER: That's what it's, that's what 12 it's supposed to say, yes. That's what I would expect.

13 MEMBER KIRCHNER: But I don't know that as 14 th e operator, as this fire commenced

-- 15 DR. COOPER: No, you don't.

16 MEMBER KIRCHNER:

-- and I'm starting to 17 make this decision.

18 DR. COOPER: You don't.

19 MS. PRESLEY: So the part that you know, 20 so everything on this side is things the operator would 21 know. So you would, you would have, either you would 22 or you wouldn't have an awareness of the urgency. You 23 would either understand it as progressing quickly.

24 MEMBER KIRCHNER: Well, I'm going to tell 25 118 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 you as an operator, former operator, if I'm thinking 1 about aba ndonment, this is urgent.

2 MS. PRESLEY: Yes.

3 MEMBER KIRCHNER: So the answer is yes, 4 I'm already under the gun. I feel the pressure. We 5 need to make a decision.

6 MS. PRESLEY: So all of this is just saying 7 if we have more margin we may be more successful.

So 8 this has nothing to do with whether or not the operators 9 understand how much time they have. It's just purely 10 how much margin do you have.

11 CHAIR STETKAR: And if you have

-- again, 12 I'm personally very skeptical of these numbers that 13 they've got here.

14 MEMBER KIRCHNER: I am.

15 CHAIR STETKAR: Because if you have more 16 margin, yeah, you get the difference between 80 percent 17 success rate and 98 percent success rate. Both of 18 those to me are very, very successful.

19 Now, if it was a difference between 1 20 percent success rate and 98 percent success rate I'd 21 say, yeah, maybe you thought about the problem a little 22 bit. But I don't think your experts thought about the 23 problem, quite honestly. That is my personal opinion.

24 DR. COOPER: Well, so the -- I mean, I 25 119 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 don't know if it's helpful.

1 CHAIR STETKAR: Because, because I can't 2 read anything in your appendix that tells me what your 3 experts thought about or what their uncertainties were 4 or how they, how they did their evaluations.

5 DR. COOPER:

Okay. 6 CHAIR STETKAR: It simply reports their 7 results as point estimates.

8 DR. COOPER: So are you asking for the 9 answer or are you asking us to put the answer in the 10 report? 11 CHAIR STETKAR: I would really like to see 12 -- I mean, if you have the answer that would be great.

13 But I'd certainly like to see it for the benefit of 14 people who use this guidance.

15 DR. COOPER: Sure.

16 CHAIR STETKAR: Because if users look at 17 the rationale that your expert team used and said, Well, 18 gee, maybe

-- I'm not sure that anyone would but I'll 19 leave the field open

-- I'll look at that rationale.

20 I'm not sure that that really applies for my plant. And 21 maybe, maybe I want to do things a little bit 22 differently. Maybe I want to

-- I'll use this 23 conceptual fr amework but let's skew things differently 24 for my plant.

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-3701 (202) 234-4433 Now, I can't do that unless I understand 1 what rationale your experts used and if they did have 2 uncertainties, if there are ranges. I mean, if this 3 is a consensus opinion and two people said it's 1.0 and 4 another person said that it's, you know, .007.

5 MS. PRESLEY: It ranged from .1 to .3, so, 6 for the .2 or the, yeah, the 2 to the minus 5. A very 7 tight range.

8 CHAIR STETKAR: But those are, those again 9 are single point estimates. They aren't

-- 10 MS. PRESLEY: We only got single point 11 estimated.

12 CHAIR STETKAR: The .3 person I don't know 13 whether there was

-- what the range was or what.

14 MS. PRESLEY: Okay.

15 CHAIR STETKAR: It seems awfully for

-- 16 again, I'll come back without trying to be as 17 antagonistic, if I read all of the words that you have 18 in both Supplement 1 and Supplement 2 about the 19 uncertainty

-- and now I'm not talking quantitative 20 uncertainty, I'm talking about the variability from 21 plant to plant, the degrees of sophistic ation of the 22 training, of the guidance, of the experience of the 23 people, of the fact that, you know, when you say do they 24 experience time pressure? Well, Walt might say, well, 25 121 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 I always will feel that it's urgent for me to get out.

1 Other people might say, well, no. Hey, 2 wait a minute, you know, I think that we should really 3 take our time here and think through this because 4 getting out is a really bad thing.

5 Those are two different opinions. But, 6 but again, within the context of this, that only gives 7 you a differentiation between 80 percent successful and 8 98 percent successful.

9 MS. PRESLEY: So we can look and see what 10 other rationale we can pull for it. Susan?

11 DR. COOPER: Yes, Susan here.

12 There is quite a lot more we could docume nt 13 on the process that we used with the experts. We spent 14 a day with the experts. That might seem like a short 15 period of time actually, but everyone that was

-- served 16 the role as an expert had already been either part of 17 this project or aware of the iss ues. We didn't have 18 that, you know, week of exchanging information, reading 19 material, and so on and so forth. So we, we had an 20 educated group of experts.

21 But, nevertheless, we spent a whole day 22 doing all of this. And we did use a formal process of 23 getting each of the experts view, having them discuss 24 what went behind their numbers, and so on and so forth.

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-3701 (202) 234-4433 How much of that to document has been a question. We 1 don't want to document all of it because it would be 2 -- probably we don't need to document all o f it. 3 But more needs to be documented. I guess 4 I'm interested that maybe if you could clarify what 5 specifically you think you would like to hear about.

6 I guess you want to hear about what the expert, what 7 kinds of scenarios or contexts they were thinking about 8 when they were coming up with this. Is that what you're 9 asking about?

10 CHAIR STETKAR: I'd be happy to have seen 11 an expert's elaboration of uncertainty. I, I for these 12 conditions today believe that the worst it could be is 13 1.0 for the following reason; and the best it could be 14 is .07 for the following reason; and my best estimate 15 is, I don't know, .23 for the following reasons. None 16 of that rationale is there. So I can't look at the 17 reasons for why you say the range of your experts was 18 .1 to .3. 19 DR. COOPER: So, Susan again. So just I 20 want to clarify this.

21 CHAIR STETKAR: Because it doesn't strike 22 me as a valid

-- I mean, we've done expert elicitations.

23 DR. COOPER: Yeah.

24 CHAIR STETKAR: In many cases you ask, 25 123 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 well, for these conditions at least I'd behave 1 differently. How bad do you think it could be, and why?

2 How good do you think it could be, and why? And now, 3 within that range give me your best estimate.

4 But get them thinking about the range s 5 first rather than just focusing in on a single number.

6 Because people who are very, you said, very 7 knowledgeable, experienced, they know the process, 8 they know everything, tend to focus on very narrow 9 values, and may not have carefully thought about tho se 10 sources of uncertainty. And that can be dangerous, 11 especially because people are just going to pick these 12 numbers up and use them as the intent of the guidance.

13 DR. COOPER: I'm going to go ahead and let 14 Jeff. 15 MR. JULIUS: Thanks, Susan. This is Jeff 16 Julius of Jensen Hughes. And I was one of the ones that 17 was on that expert panel.

18 So, you're right, when we talked about 19 those we spent the day going over the different aspects.

20 We were pushed and looked at the different ranges of 21 the worst case and the best case, and then coming up 22 with our point estimate. And, yes, the description we 23 could add some text and explanation of the rationale.

24 Part of that is the recognition, or what 25 124 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 I was looking at this, was the action is feasible? It 1 was a fairly high bar with some conservatisms that are 2 in there. But the approach is not only just to use this 3 number, but in Section 5.3 it says use a sensitivity, 4 or set it to 1 and see what the results are. Because 5 there is a lot of complexity and variability in this.

6 An d also stretch it the other way.

7 I understand what you're saying. And 8 those reporting, you're right, doesn't give you a good 9 basis for using a multiplier of 2X or 5X on these numbers 10 if you wanted to skew it. And we can improve th at. 11 But there was the consideration in the 12 discussion on the pushing the ranges of the conditions.

13 And that most of the time the numbers that are showing 14 up here in this final decision tree were given that it 15 is feasible, and differentiating between a .3 or a .5 16 is, you know, is a difficult decision to make.

17 MEMBER BLEY: Jeff, since we've got one of 18 these people here I'm going to ask you a couple 19 questions.

20 First a comment. I kind of agree with 21 John, when you read the two documents and all the 22 caveats ar e in there about how bad this could be, I'm 23 surprised that you didn't think these are kind of 24 optimistic given all of those words. That's number 25 125 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 one. 1 Number two is we've separated the 2 habitability and loss of control. But if you're really 3 about to lose control, habitability has probably gone 4 to hell as well. And did you think about the 5 habitability conditions that might be going on in the 6 control room as you approach this point where you think, 7 ah, for control purposes I've got to get the heck out 8 of here? Was that really part of the thinking? Did 9 you guys discuss that as you went through this?

10 MR. JULIUS: This is Jeff Julius, Jensen 11 Hughes. 12 So the second question first. So the 13 comment first. The thinking on the loss of control was 14 more for the cable spreading room or instrument room 15 fires where you're not seeing the environmental 16 impacts. And

-- 17 MEMBER BLEY: If you're lucky.

18 MR. JULIUS: In general. And that the

-- 19 MEMBER BLEY: There's a guy over here 20 might say something.

21 Where is that cable spreading room 22 physically?

23 MR. JULIUS: Some are above, some are 24 below the control room.

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-3701 (202) 234-4433 CHAIR STETKAR: Assuming it's below

-- 1 MR. JULIUS: Yeah.

2 CHAIR STETKAR:

-- it may or may not have 3 shared ventilation systems. There might be a hole in 4 the floor.

5 MEMBER BLEY: It's something to think 6 about. But anyway, keep going.

7 MR. JULIUS: That's right. And that's 8 right, the fire is in the main control, there are in 9 the panels that are causing loss of control, you do get 10 a combination of the smoke and the system impact.

11 MEMBER BLEY: Were you thinking about that 12 when you made these estimates?

13 MR. JULIUS: Generally goes with 14 afterthought. It wasn't one of the primary.

15 MEMBER BLEY: Yeah. That's kind of what 16 John was talking about.

17 CHAIR STETKAR: What I was talking about 18 in terms of the rationale that it's clear that from what 19 we just heard that at least one of the experts for loss 20 of control had a particular fire location and a 21 particular set of effects on the personnel in the main 22 control room. Those effects not involving 23 habitability concerns at all, simply what's available 24 in front of them and how much confidence they have on 25 127 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 those displays and indications.

1 Could be different for that fire in the 2 main control room that never got to the loss of 3 habitability criteria, whatever those are. But still 4 resulted in enough snarky

-- I'll use that term again 5 -- indications and controls that they decide I can't 6 control it or I've lost confidence and have to leave.

7 But that would again be compounded by the 8 habitability, local environment conditions.

9 DR. COOPER: Susan Cooper. Yeah, I've 10 talked with some of the research staff on fire 11 protection about scenarios that could be considered by 12 habitability and loss of control scenarios. The 13 answer I got, which is a simplification, is that 14 probably loss of control criteria would be used first 15 before habitability criteria.

16 However, you raise an interesting point, 17 good point, that some of that habitability s tuff could 18 be happening while they're seeing some strange 19 instrumentation. So that's, that an important

-- 20 that's a good point.

21 I want to get back to the main question 22 about the expert elicitation. I, since I did not have 23 any preconceived ideas about the numbers, nor did I lead 24 them in numbers, I did go through the ATHEANA User's 25 128 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 Guide has some guidance on expert elicitation for 1 quantification I used that guidance, including the 2 controls, if you will, on probabilities.

3 And had some discussion with the experts 4 before we got into the quantification part about what 5 those numbers meant, including the case of the one 6 person who wasn't an HRA person or had any experience, 7 I talked with them about, you know, numbers of crews 8 going through simulators and how that might be related 9 to numbers.

10 So I -- and we did talk about a number of 11 different things. I guess getting back to the point 12 about, you know, how Supplement 1 sounds compared to 13 Supplement 2, I think the same kind of thing sort of 14 ended up happening for Phase III from my perspective.

15 Because I've been hearing about command and control and 16 how all these different things are going on, and they 17 never practiced it, and they've got all these phone 18 calls coming in, and they have no administrative 19 controls about who can open up the door and start 20 bothering you.

21 But then when it came right down to, well, 22 what's important about this, sort of like, Uh

-huh, I 23 know, I think there

-- the notion that probably with 24 their basic training and so forth that they're going 25 129 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 to get through this despite having any demonstrations.

1 So it did seem to me that when we got down 2 to talking with experts, people who as far as I know 3 would probably be the best or have the best knowledge 4 available in the industry about what might happen 5 because no one's seen this in a simulator, very few 6 people have actually done any kind of demonstrations, 7 integrated demonstrations after they left the control 8 room, when it got right down to it, as far as they cou ld 9 imagine it didn't seem to be as big of a problem as, 10 you know, when you're just sort of asking them for some, 11 you know, like complaints about the process, it didn't 12 end up, you know, when it came down to it that they 13 thought that seemed to be that impor tant. 14 It was a little bit of a surprise to me to 15 be honest, because I was, you know, especially like I 16 said with the command and controls, like, well geez, 17 you know, we don't know what kind of procedures they 18 have. They probably haven't practiced. They'v e only 19 got one phone or one radio and they've got everyone else 20 calling them. And, you know, it's going to be kind of 21 a nightmare.

22 But when you got right down to it it was 23 sort of like, well, so what's important about that?

24 Not that much.

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-3701 (202) 234-4433 So I don't really know how to

-- you know, 1 what kinds of messages to take away from that. I think 2 one message for me is that even with the people I would 3 have expected to have the best understanding of this 4 context, that we don't understand very much about this 5 context still. And we probably need to get more 6 information.

7 It would be nice if people, you know, even 8 just motivated by some of the things here that we've 9 written down, that they would start looking at, you 10 know, looking at doing some training, at least having 11 some talk-throughs or whatever, doing some integrated 12 training, you know, once they get to the remote shutdown 13 panel, that sort of thing. And actually, actually sort 14 of see where

-- kick the tires and find out where the 15 problems are.

16 Right now we've just had some kind of a lot 17 of people that have been in certain situations with 18 anecdotal comments and concerns. But when it comes to 19 informing error probability there seems to be kind of 20 a more optimistic view than I wo uld have expected.

21 MEMBER BLEY: I guess I'm thinking this 22 thing -- and John's brought it up a few times

-- if 23 somehow when people are thinking about this they know 24 they're worried about core melt, and they focus in my 25 131 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 mind would I stay here if I think we could get core 1 damage? I think that makes it real easy.

2 In a real control room with a fire going 3 on, and I'm still driving the plant okay, I'm probably 4 not thinking I'm going to be in a core damage situation 5 pretty soon.

6 DR. COOPER: Yeah. We did

-- 7 MEMBER BLEY: I don't know if you were able 8 to keep the right mindset on these people. Of course, 9 we weren't there to see that.

10 I'm sorry. I cut off Matt.

11 DR. COOPER: Yes.

12 MEMBER SUNSERI: All I was going to say is, 13 well, may b e off key, so but anyway I've heard several 14 times now that the plants don't practice this. And 15 that's not my experience. I mean, my experience is the 16 plants have remote shutdown simulator panels near their 17 simulators that they practice it periodically.

I've 18 seen situations where smoke generators are brought into 19 the simulator to

-- 20 MEMBER KIRCHNER: Don't they do this when 21 they do a FLEX deployment?

22 MEMBER SUNSERI: Well, I don't know about 23 that. But maybe there's aspects of this whole scenario 24 that aren't being exercised. But certainly I think 25 132 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 that operators do the transition, that they practice 1 making the decision to go to the remote shutdown. That 2 they practice stopping the control. And they do it on 3 their simulators.

4 MEMBER BLEY: I think your experience is 5 more to the unique side from what I've heard about in 6 plants. 7 MEMBER SUNSERI: Well, maybe. But I mean 8 I can think of at least three plants

-- 9 MEMBER BLEY: I mean there's an awful lot 10 of plants not only don't have a sim ulator for the remote 11 shutdown panel, they don't even have a remote shutdown 12 panel. How many plants have just distributed stuff, 13 they go out and operate? Twenty or 30?

14 MEMBER SUNSERI: Good question.

15 MEMBER BLEY: I'm hoping Mark will have an 16 answer. I know you used to look at this stuff a lot.

17 MR. SALLEY: I'd almost go to J.S. for 18 that. I mean, yeah, a lot of the plants don't

-- 19 MEMBER BLEY: I'm sorry, I forgot J.S.

20 MR. SALLEY: Yeah. When 81

-12 went in a 21 lot of them had load control spaces, is wha t they called 22 it. 23 MEMBER BLEY: Yeah.

24 MR. SALLEY: So they were doing that at all 25 133 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 multiple places in the plant. For some they put

-- 1 MEMBER BLEY: Yeah. Local control 2 stations and just using those as a remote shutdown.

3 MR. SALLEY:

So 20 or 30 we could 4 guesstimate, J.S., unless you've got a better number.

5 MR. HYSLOP: J.S. Hyslop. There are a lot 6 of -- I don't have a number. I just know we've seen 7 cases where it's distributed. We've seen cases where 8 they've better panels. I'm not sure how many true 9 simulator remote shutdown panels, right, but I haven't 10 seen a lot of those but I know they're out there.

11 I don't have a number so I can't tell you.

12 MEMBER BLEY: It's a mix.

13 MEMBER SUNSERI: Well, I'll take that.

14 So I had another question and maybe this would be a good 15 time to ask it.

16 I've seen some human, or I'm familiar with 17 some human performance studies that show intelligent 18 beings that would have all the right information 19 available to them don't always make better decisions 20 when they have an unlimited amount of time. In other 21 words, having a time limit actually improves their 22 decision making because they don't end up second 23 guessing themselves and making the wrong decisions 24 later. 25 134 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 But that, your data doesn't seem to 1 indicate that. It seems like given more time they also 2 make a better decision.

3 CHAIR STETKAR: This isn't data. This 4 isn't data.

5 MEMBER SUNSERI: Well, analysis or 6 whatever it is.

7 CHAIR STETKAR: And remember, let me read 8 something. We h ave to be aware of time here because 9 we need to talk about Phase III and things. But my 10 concern about having the experts and the whole group 11 colored too much about preconceived notions of what 12 this is from not an operator's perspective, from a human 13 relia bility analysis widens perspective, is in 14 Supplement 1.

15 It explicitly says "loss of control 16 scenarios are those that will lead directly to core 17 damage if the operators remain in the main control room, 18 i.e., in the absence of operator actions taken 19 following abandonment. For each loss of control 20 scenario, or group of scenarios that share the same 21 characteristics, that would lead to core damage in the 22 absence of abandonment actions the HRA analyst will 23 need to conduct operator interviews to determine if the 24 abandonment procedures and equipment cover these 25 135 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 situations, and also whether the operators would 1 interpret the conditions as a loss of control." 2 Well, if you ask me if the core's going to 3 melt do I have loss of control? Well, hell yes. 4 Will I leave the control room? Well, hell 5 yes. 6 And if your experts know that these are 7 scenarios where the core is going to melt, if they don't 8 decide to leave the control room within 5 minutes, that 9 knowledge will color their evaluations, the same way 10 that the knowledge is not inside the control room, it's 11 in some place outside the control room.

12 DR. COOPER: So what I'm hearing you say 13 -- and because we're not saying that to the operators.

14 This is guidance to the analysts so they understand that 15 th ey're not to look all over the place for scenarios 16 to model those loss of control scenarios. They can be 17 informed by the PRA and other modeling as to these are 18 the ones that we're concerned about. We'd like to take 19 credit for them in the PRA. And HRA an alysts figure 20 out whether or not we can take credit for them in PRA.

21 We're not going to the operators and saying 22 if you don't do this you're going to melt, the core's 23 going to melt, are you going to leave or not? We didn't 24 run the elicitation that way.

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-3701 (202) 234-4433 The, you know, I guess, I guess what 1 probably is needed is to be more clear about how we talk 2 with the experts or operators versus what we're giving 3 guidance to HRA analysts. The HRA analyst needs to be 4 informed about this so they can have their, their 5 analysis focus and they can make sure that they're 6 focusing on the right things to support the PRA. But 7 that's not how you interact with the operators. You're 8 absolutely right.

9 So I'm not really sure what, what the 10 answer would be, but probably some beefed

-up guidance 11 on how you interact with the operators and so forth.

12 But to be real honest, except for the fact 13 that you need to find out from the operators what they 14 think are the set of conditions that they feel would 15 be loss of con trol, what they define as loss of control, 16 you know, I mean that has to happen. And I think we're 17 pretty clear about the fact that the operators guide 18 that definition. If that definition doesn't match up 19 with the PR

-- what the PRA says you don't get the 20 credit. That's bottom line.

21 So, anyway, and we didn't do the expert 22 elicitation that way either. I'll ask Jeff, one of the 23 experts. 24 MR. JULIUS: Jeff Julius, Jensen Hughes, 25 137 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 member from the expert panel.

1 Just to confirm what Susan said, that it 2 wasn't -- we didn't ask leading questions. We were not 3 asked leading questions in terms of conducting the 4 expert panel.

5 And just a clarification of earlier 6 statements. So the comment, when I was thinking about 7 the fire in the cable spreadi ng room I was 8 conservatively not taking credit for the smoke going 9 up in the control room. Because if there was smoke in 10 the control room, that would give some additional 11 indications to the main control room team that, hey, 12 maybe there should be some more urgency here and maybe 13 we should need to make this decision faster.

14 So I think that's a good example, though, 15 where that type of rationale, you know, the report would 16 benefit from having that kind of rationale or 17 additional detail added in Appendix A.

18 MS. PRESLEY: And I just, just to be very 19 clear, and since I have the notes in front of me, the 20 things that were

-- so, so we asked for each criteria 21 kind of what are the best, what are the worst?

22 We discussed, because we had a lot mor e 23 criteria here to begin with even, we ran through some 24 of them. But some of the things that were coming out 25 138 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 were operators know that there are only a few fire areas 1 that would lead to abandonment. So they are signaled 2 when they have an alarm in one of their areas. They're 3 starting to think right away about what those criteria 4 are. 5 They're thinking about the procedures are 6 important, but as soon as they're starting to see 7 effects they're going to start wondering about, because 8 they know those areas are c ritical, they're going to 9 start thinking forward. So that was on the why it's 10 reliable side.

11 On the not reliable side they were thinking 12 things like they brought up several historic events of 13 areas where they were reluctance and delays. They 14 talked about the David-Besse AFW failure where the 15 steam generator level was, you know, they kind of 16 wiggled their way out of it was low, it wasn't at the 17 rock bottom but they knew it wouldn't be at the rock 18 bottom because that's not the way that indicator works.

19 So they bought some time and delayed them.

20 Calvert Cliffs they had the

-- they were 21 supposed to do the SI injection but the shift supervisor 22 overrode the procedural direction and delayed that.

23 So they, they did bring up they talked 24 about the Robinson fire and the crew that was assembled 25 139 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 and the quality of that crew. And so when they were 1 talking about the HEP they were talking about these 2 sorts of things.

3 So we can put in a little bit of discussion 4 about what we have heard as the background. We didn't 5 specifically say, okay, in the fire's in your control 6 room and you're almost at habitability but not quite, 7 we didn't go quite into that level of detail but we did 8 push the bounds of best and worst. And we only 9 solicited a best estima te number. We didn't ask for 10 5th to 95th percentile because it wasn't, it wasn't that 11 level of expert elicitation.

12 So I just I want to make that clear and we 13 can document that. But the, yeah, the level of 14 resolution you see in there, that's what's in it and 15 that's what's not in it, so.

16 DR. SMITH: Let's, we do have to be a 17 little bit aware of time here. I don't know how 18 flexible people are in running long, but I don't want 19 to get too late.

20 For NRC staff, be aware that these number s 21 will be interpreted throughout the industry as 22 NRC-approved human error probabilities. These are 23 NRC-approved human error probabilities. Okay, I will 24 just put that

-- just be aware of that. It isn't, this 25 140 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 isn't -- once this hits the street these are c ast in 1 stone. 2 DR. COOPER: Susan Cooper. One thing I 3 want to add is that because we don't have demonstrations 4 of all of these pieces, especially here we're talking 5 about decision core damage, people are practicing this 6 in the control room. We haven't see n it happen.

7 So I think even with the experts I think 8 there's probably some aspects that they understand 9 about sort of conduct of ops that are not usually 10 touched by HRA but get more into, you know, conduct of 11 operations, you know, sort of your basic bible for how 12 the plant does business, which we don't always get to 13 that level of control, if you will, or operations in 14 HRA because we're

-- because some of those typically 15 well-practiced simulator exercises aren't the basis 16 for our understanding of how these operators will 17 perform. 18 There may be some additional things that 19 we need to talk about so far as, you know, what the 20 expectations are of the operators, especially going 21 back to the training and their fundamental 22 understanding of how things are going on, you know, 23 what's going on in their plant. So there may be some 24 more pieces that we need to add in that underline this 25 141 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 in addition to reluctance.

1 MR. SALLEY: Yes, Susan, if I could for a 2 second. 3 John, I understand exactly what you'r e 4 saying is you put the number out there and then for lack 5 of anything better the rank and file person who's doing 6 the work is going to see this number. Use this as a 7 reference and go with it.

8 What would you recommend that we do, you 9 or Dennis, your thoug hts on this to improve it or to 10 make it better or safer, whatever?

11 CHAIR STETKAR: My initial thoughts

-- and 12 again, these are personal, you know, it's a 13 subcommittee meeting so there can be ten different 14 interpretations here

-- at least bare minimum the 15 experts' understanding of what they were evaluating and 16 their uncertainties.

17 I'll come back to this notion of 18 uncertainty is if they, you know, this point number 19 really doesn't mean anything to me without 20 understanding what their unc ertainties are. And 21 saying that three experts, two of which has .1 and one 22 of which had .3 doesn't tell me anything either because 23 they were all people who

-- first of all, they were all 24 people who are very familiar with this process and could 25 142 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 be biased that way. They knew, they knew what they were 1 answering. And other folks might not know that the say 2 way. 3 So I think some notion of the fact that 4 there may be more uncertainty in these numbers than 5 people are led to believe, especially for this very, 6 very narrow, the worst it can be is 80 percent success 7 rate, and the best, regardless of what you say about 8 feasibility because the guidance for feasibility 9 actually is pretty good, but just given the fact that 10 it's feasible, if you pass that screen, it still sounds 11 -- it might be in my opinion it might be well justified 12 but I can't understand why they are, given the 13 documentation that you have.

14 Dennis. 15 MEMBER BLEY: I guess I'd start with 16 John's bare minimum. And when you have that I'd draw 17 some conclusions a bout it. 18 Like, if you hear from all of the people 19 who were on your panel that, no, they didn't consider 20 the environment, the degradation, habitability at all 21 as they looked at this. But put a caveat in that, you 22 know, the scenario we've quantified is with the clean 23 atmosphere.

24 CHAIR STETKAR: Basically for a fire not 25 143 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 in the control room. Now

-- 1 MEMBER BLEY: Or with smoke leaking in 2 from somewhere else.

3 CHAIR STETKAR: Yes.

4 MEMBER BLEY: No, it's a clean control 5 room. 6 CHAIR STETKAR: It's a clean control room.

7 MEMBER BLEY: I don't know what you'll 8 find when you're talking. That might not be the case.

9 Maybe some of them really thought about that. But if 10 you find other things as you go through that that imply 11 it's a more na rrow set than you intended, just be up 12 front about that and say, look, we did this. These are 13 guidance but this guidance really only applies to a 14 selected set of conditions. And for other conditions 15 it will be different.

16 CHAIR STETKAR: The problem is

-- and Jeff 17 and Paul perhaps can back this up

-- I believe that this 18 issue becomes most important quantitatively for fires 19 inside the main control room. But I could be wrong 20 there. I'm not sure.

21 Cable spreading rooms aren't the same 22 problem that they used to be because cable fire 23 frequencies in part are much lower than what people used 24 to have. And, yeah, you've got to consider transient 25 144 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 combustibles but you have to consider transients in the 1 main control room also.

2 I don't know how much you get into fires 3 in instrumentation and control cabinet rooms driving 4 this. But the problem with those rooms is they often 5 have the same shared ventilation system as the main 6 control room. So, as Dennis said, it's pretty 7 important to understand w hat the experts knew in terms 8 of the conditions when they established these

-- 9 MEMBER BLEY: Mark told us something 10 earlier that's a change to me. You know, when I was 11 aboard ship we had ventilation systems. That's the 12 first thing you did if you had a fi re was you killed 13 the supply vents and turned the exhaust vents on high.

14 Most plants, when I looked at them, had no 15 separate controls for inlet and outlet and you couldn't 16 adjust them like that. It was ventilation 17 on/ventilation off. You can either suffer in the smoke 18 or feed the fire with more air.

19 So if that's changed, and you were saying 20 you now have purge in a lot of the plants, that's a 21 difference. But I don't think we talked about that 22 sort of thing anyway, did we, in the report? I don't 23 remember seeing that.

24 CHAIR STETKAR: No.

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-3701 (202) 234-4433 MEMBER BLEY: It came up in the 1 discussion.

2 But that's a really important point if in 3 fact most of the plants now have the ability to purge 4 smoke, and especially in the control room, that really 5 woul d help. 6 MS. LINDEMAN: Ashley Lindeman. For lack 7 of habitability usually you would evaluate two cases:

8 one with no ventilation. And if you had purge mode you 9 would take that into account in your fire model.

10 MEMBER BLEY: Ashley, my problem is 11 habitabilit y and loss of control aren't separate 12 things. We parse them separately to talk about them 13 here and then we haven't done much with one. But often 14 they go together. And when they go together, that's 15 important.

16 CHAIR STETKAR: I do want to leave time for 17 Phase III because I have comments on Phase III analysis.

18 And there's a lot of good discussion I know you want 19 to get to in terms of command and control. So if we 20 can, let's go on to the Phase III guidance.

21 DR. COOPER: Okay. This is Susan Cooper.

22 I'm going to talk about our Phase III HRA quantification 23 guidance. And this is for the implementation of main 24 control room abandonment safe shutdown strategies.

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-3701 (202) 234-4433 Supplement 2, Section 4 provides the 1 guidance on the quantification of all of the HFEs that 2 would be associated with Phase III .

3 CHAIR STETKAR: Susan.

4 DR. COOPER: Yes?

5 CHAIR STETKAR: Before you get started on 6 this, because you're very quickly going to get into the 7 discussion of command and control, which is a pretty 8 interesting discussion, let me ask you a very leading 9 question, but one that I honestly came away being 10 somewhat confused.

11 Does your guidance recommend that an 12 analyst evaluate only implementation errors in Phase 13 III except for conditions where you identify very 14 specific command and control issues? So, for example, 15 if you say there's no command and control issue 16 according to the guidance here, everything in Phase III 17 is that only implementation or does it also include 18 cognition?

19 In other words , when I think of standard 20 typical HRA I have a cognitive part and I have an 21 implementation part and, you know, I parse it up that 22 way. 23 DR. COOPER: So

-- 24 CHAIR STETKAR: Because I read it in 25 147 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 different parts of the guidance, whether it's 1 Supplement 1 seems to lead me to believe that there is 2 absolutely no cognition associated with Phase III, that 3 it's strictly rote: follow a procedure, push this 4 button, eat that banana.

5 In Supplement 2 there seems to be a little 6 bit but it's always associated with this make a decision 7 about whether or not there is a command and control 8 issue. And if there's no command and control issue, 9 if it's literally a rote follow the procedure, then it's 10 strictly implementation. But I will submit that there 11 is never a rote follow the procedure. Somebody is 12 always going to be in control.

13 DR. COOPER: So it's a

-- there's a little 14 bit, there's a little bit of discussion about this.

15 What we discovered when we were developing this 16 guidance is that in particular th ere could be 17 differences between PWRs and BWRs so far as how, how 18 their strategies are laid out. For a particular BWR 19 the shut -- main control room abandonment safe shutdown 20 strategy is one path. There is one set of steps.

21 There's no alternative system written in the procedure 22 -- 23 CHAIR STETKAR: Right.

24 DR. COOPER:

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-3701 (202) 234-4433 work. 1 So a good portion of our guidance is 2 written for that particular set, that scenario. But 3 it recognizes that there could be other, other 4 strategies that might have decisions between either 5 using different systems, or you might try a system. It 6 doesn't work and you have the option written within the 7 procedure for shutdown, main control room abandonment 8 shutdown, to go to that other system or second system 9 or th ird system.

10 So there are some plants that have that 11 kind of strategy. But it's very much tied to what the 12 strategy is as documented in their safe shutdown 13 procedure.

14 CHAIR STETKAR: Let me, because I want to 15 get through this, let me just drop this as a su ggestion.

16 Take a look at the discussions in both Supplement 1 and 17 Supplement 2 of the guidance of Phase III and be 18 sensitive to whether or not the guidance reinforces the 19 notion that the analyst now should account for 20 cognition.

21 Now, at a particular plant for a particular 22 fire scenario with a particular set of procedures, 23 perhaps consideration of cognition says that it's not 24 a contributor. But only for that particular plant, for 25 149 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 that particular fire scenario, with those particular 1 procedures.

2 If you read the guidance, as I did as kind 3 of a skeptic, I'm led to quickly draw the conclusion 4 of the opposite, that in general you don't consider 5 cognition except for very, very specific cases that you 6 identify as particular command and control issue. And 7 I'm not sure that's what your intent was.

8 DR. COOPER: No, it's not.

9 CHAIR STETKAR: Okay.

10 DR. COOPER: And this is one of those 11 places where there is an evolution from Supplement 1 12 to Supplement 2. And it was actually

-- I mean, whether 13 or not it was late for all the authors, it was late to 14 getting to the document so far as there being a 15 distinction between how you treat these different types 16 of strategies so far as whether or not there's decision 17 making going on like there would be, say, l ike in EOPs 18 where you have, you know, alternative and another path 19 to go in your procedures, and other choices with respect 20 to systems and so on and so forth.

21 So that's, that's we do call it out very 22 briefly in Supplement 2 and we say that if that is the 23 kind of strategy we have, if we have, you know, response 24 not -- maybe equivalent of a response not obtained 25 150 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 column where you would go to another procedure or 1 another system, then this, the rest of this guidance 2 doesn't apply. So we recognize that.

3 The other thing is that we don't say there 4 is no cognition. But the way we treat it for those 5 strategies where you really only have one path, there's 6 only one set of things to do, we do look at the 7 interactions between operators, especiall y 8 communications between field operators and a 9 supervisor who might be recording information or then 10 later worrying about coordination, and the time that 11 it takes to do that.

12 CHAIR STETKAR: But that's, and the 13 discussion of time I think is done well there. But what 14 I'm talking about is the standard cognition of 15 identification diagnosis decision making. And 16 despite all the things you say that when people abandon 17 the control room I have a set of procedures that tells 18 me to do this, I'll guarantee you that those procedures 19 are not going to match what's happening in the plant.

20 And some supervisor is going to have to make a decision 21 about how do we adapt what we have to match what's going 22 on in the plant.

23 That may involve creative alte rnatives.

24 It may involve delays for decision making. It may 25 151 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 involve time to go get additional information for 1 people. It's never going to match the presumptions, 2 especially the way the procedures are written now, that 3 you have a certain Appendix R fire that says go do A, 4 B, and C and everything is going to be perfect, because 5 it never will.

6 DR. COOPER: So

-- 7 CHAIR STETKAR: And that's, I'm not trying 8 to get very specific. I'm trying to step back and say 9 why should the guidance for doing Phase III type human 10 reliability analysis be different from the guidance for 11 doing any other human reliability analysis, except for 12 the fact that there might be more complex things that 13 I'll allow you to get to here in a minute, in terms of 14 coordination of command and co ntrol communications 15 that may not apply, certainly do not apply to sitting 16 in the confines of the main control room with a set of 17 emergency operating procedures.

18 DR. COOPER: Well, some of what you're 19 talking about is, again, it's n ot all doc

-- some of 20 the steps, the interim steps we went through are not 21 documented. But we went through all of the pieces of 22 the definition of command and control that we 23 established in Supplement 1, which includes things like 24 situation assessment, and allocating resources, and 25 152 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 making decisions and so forth, and looked at each of 1 those to see what their contribution was for the 2 specific set of strategies that I just mentioned where 3 it's a single path through the procedure.

4 And then identified what kinds of failure 5 modes might be coming from each of those pieces. And 6 that's on top of the execution.

7 And the end point that we reached was what 8 I'm going to be presenting so far as the main 9 contributor of really cognition, thinking, decision 10 making, controlling, that sort of thing. I'm not going 11 to -- I mean, I' not going to say that, you know, whoever 12 is at the remote shutdown panel looking at whatever 13 indications they may have there, they're going to be 14 following their procedure, getting information that 15 they can. They're going to be keeping track of what's 16 going on. 17 But based on the set of strategies that we 18 were trying to address here, and we tried to be

-- talk 19 about, you know, this is the scope we're looking at

-- 20 those steps of strategies do not really specify or 21 codify or formalize any of these kinds of deviations.

22 The reality is, of course, I mean, I realize the reality 23 is going to be different but we've made, we've made that 24 boundary. We've talked about some additional thing s 25 153 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 that might happen in the future, you know, so far as 1 other equipment that you might be able to credit if you 2 had time to do that, that sort of thing. But we haven't 3 gone beyond what is specified specifically in the main 4 control room abandonment safe shu tdown procedures.

5 If it's not in there now, we're not talking 6 about crediting some other innovative idea that might 7 be a recovery to failed system or a failed piece of 8 equipment. We haven't looked at that, no.

9 There's no procedural link to anything 10 else right now. It's not in the procedure right now.

11 There are efforts looking further, but that's, you 12 know, not

-- and we mention that there might be other 13 things that are happening in the future, but that's not 14 in this project.

15 CHAIR STETKAR: I just think it's a 16 regression in 2018 to give human reliability analysts 17 the notion that they ought not to think about cognition 18 as a fundamental part of their analysis, regardless of 19 preconceived notions about how specific the procedures 20 may be for a particular scenario. I believe, or some 21 belief is that they should always think it's cognition.

22 If they think about it and dismiss it for a particular 23 scenario, that it's not an important contributor, fine.

24 They've thought about it and dismissed it, and 25 154 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 documented it.

1 If they're surprised, they've thought 2 about it and, gee, they're surprised and they've 3 accounted for it. But the guidance ought to force them 4 to be surprised, not tell them to ignore it unless it 5 slaps them in the face from some other set of criteria.

6 Do you follow me?

7 DR. COOPER: Yeah.

8 CHAIR STETKAR: We've spent too much time 9 over the last decade talking about the importance of 10 cognitive performance and how people really make

-- 11 people don't make mistakes by pushing wrong button s, 12 you know. They occasionally push the wrong button but 13 that's not what gets people into trouble.

14 DR. COOPER: I agree. I agree.

15 The difficulty that I have is, again, 16 getting back to the variability on the remote shutdown 17 panels. And now we're not just talking about controls, 18 we're talking about indications. Because that's what 19 is going to drive someone to decide to do something.

20 CHAIR STETKAR: But my point is let the 21 analysts. This is guidance that's supposed to apply 22 to any plant for any fire. So let the analysts struggle 23 with that for their plant and their fire scenario.

24 They have to struggle with their plant, their 25 155 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 capabilities, their operators, their training, 1 whatever their procedures are and how well they fit a 2 particu lar fire scenario. That's their job.

3 And if the guidance gets too pigeonholed 4 with some preconceived notion about how all of the 5 procedure, you know, the average of all of the 6 procedures that you've looked at and what you think 7 might be important, I think that's a disservice to 8 guidance for performing human reliability analysis.

9 It's kind of back to the old THERP of you follow the 10 procedure and look up numbers in a table, and by 11 definition that's how people perform.

12 DR. COOPER: Ye ah, that's not, that's not 13 the picture. But the bottom line is, and as we get into 14 the later slides, for implementation of the safe 15 shutdown strategy you are talking principally about 16 single operators in individual locations by themselves 17 at a panel doing something that's been put out on their, 18 on their procedure. It's not a crew per anymore, at 19 least not the same type of structure anymore. That's, 20 so they're

-- 21 MEMBER BLEY: They don't, when they're 22 doing that they don't have somebody at some place 23 coor dinating all those activities?

24 DR. COOPER: Well, in principle they do.

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-3701 (202) 234-4433 But there's a lot of variation, there's a lot of 1 variation between plants so far as whether or not there 2 is actual coordination. In some cases

-- and we talk 3 about this some I think in Supplement 1

-- one of them, 4 I can't remember

-- but the point is that there could 5 -- or maybe I wrote it and we axed it out

-- but I mean 6 in some cases, you know, field operators are given 7 individual attachments. They go out. And the only 8 communication they really have with a supervisor is I'm 9 done, I'm going on to the next thing. You know, that's 10 it. There's no coordination.

11 Or if there is coordination it might be 12 between individual operators, field operators if 13 they're, you know, trying to control, you know, 14 singular level and injection or whatever, maybe they're 15 talking together on headsets. We can do that.

16 And then there are some other instances 17 where there is coordination. But the bottom line is 18 it's a lot of the communication is just reporting.

19 Now, when we get into this, we are trying to focus on 20 those places where coordination is needed and to model 21 something there.

22 CHAIR STETKAR: Why don't we go on because 23 -- 24 DR. COOPER: Yes.

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-3701 (202) 234-4433 CHAIR STETKAR:

-- I'm going to try to 1 finish by about 5:15 to no later than 5:30 certainly.

2 DR. COOPER: Okay.

3 CHAIR STETKAR: But 5:15 or so.

4 DR. COOPER: So, so I guess I'm going to 5 skip to the bottom so we can try to

-- of this slide 6 and just say that the principal focus of our research 7 fo r Phase III was to look at command and control and 8 to try to understand what was important about it for 9 the range of strategies that we were considering and 10 try to identify what needs to be modeled. And 11 sections, there are various sections in Section 4 th at 12 talk about. And Appendix B provides some of the 13 background.

14 And there is

-- this is one of the most 15 significant areas of additional research that we did 16 in supplement to, you know, expanding on what 17 Supplement 1 had.

18 So I'm just going to very quickly go over 19 this. This is the definition of command and control 20 that we put into Supplement 1. And it's based in a 21 military definition. We haven't found anything 22 better. 23 One of the main take

-aways that we have in 24 Supplement 1 in the conclusions is that we still think 25 158 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 there's not much out in the literature anywhere about 1 command and control, certainly nothing specific to 2 nuclear power plants.

3 So command and control is maintaining a 4 coherent understanding of the plant state; timely 5 deci sion making; allocating resources; coordinating 6 actions; managing communications.

7 And why don't we go to the next slide.

8 So for Supplement 2 we expanded on this 9 understanding of command and control. And as I 10 mentioned, we specifically went through each of those 11 aspects of the definition and tried to examine where 12 there might be failure modes or what aspects of it, of 13 those definitions were relevant or not relevant to the 14 main command and control safe shutdown strategies.

15 And then af ter that we, like the Phase II, 16 we developed a consensus on the likely relevant issues 17 among the author team before we went to the experts.

18 And the principal thing that we got from the experts 19 was to try to confirm the key issues and then try to 20 hone in on what they thought was the most important 21 thing that ought to be represented as a failure of 22 command and control in the implementation of the safe 23 shutdown strategy.

24 And this process is what I had mentioned 25 159 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 before. Until we got down to saying, so what's going 1 to matter? What's going to result in something, 2 something being done incorrectly? This is where we 3 might have seen a little bit of a disconnect between 4 all these concerns about, you know, how command and 5 control hasn't been actually practiced, you know, in 6 an integrated way with all the field operators and so 7 forth, and then coming to actually something that we 8 need to model.

9 So based on the information we got from the 10 experts we developed a set of screening rules for 11 whether or not you should model something as a, I think 12 we said we can either put it as an additional HEP or 13 failure mode, additional failure mode for an execution 14 action. That comes

-- 15 MEMBER BLEY: Is this the same experts as 16 before or different?

17 DR. COOPER: It is the same experts.

18 MEMBER BLEY: Okay.

19 DR. COOPER: And then to develop an HEP we 20 looked at existing HRA methods to try to find some 21 overlap of similar issues. There was no actual overlap 22 but there were some words that sort of seemed to sound 23 the same. And we felt like it was addressing some of 24 the same instances, and so we looked at the range of 25 160 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 those values, and then selected, the authors selected 1 a value to use. That's how that process went.

2 So this, I think there's a similar table 3 in -- 4 CHAIR ST ETKAR: I don't think that, just 5 for the record for this meeting, -- 6 DR. COOPER: Yes.

7 CHAIR STETKAR:

-- you don't publish that 8 value here, do you?

9 DR. COOPER: Sorry, publish what?

10 Publish what?

11 CHAIR STETKAR: In your slides. Oh yeah, 12 you do. I'm sorry, it's on Slide 51. We'll get to it.

13 DR. COOPER: So we have this table was in 14 Supplement 1. Actually, I think this might be a little 15 bit updated by our experts.

16 No, this, I guess this is from Supplement 17 1. We did make some upd ates from what you had seen.

18 But some of the key things that we wanted to highlight.

19 We found it helpful to think about in control room 20 normal operations first, and how it seemed like command 21 and control was working and what things, what were the 22 things that seemed to be helpful in supporting command 23 and control, and then trying to contrast that with what 24 we understood about main control abandonment 25 161 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 operations once you've left, once you've left the 1 control room.

2 And this just kind of highlights some of 3 th e key things.

4 When you're in the control room you have 5 kind of centralized cognitive entity that's 6 represented by the team. You are going to have some 7 coordination with some other plant people, including 8 the plant staff, including the fire brigade.

9 Becaus e you have the heads

-up board, and 10 everyone's in the control room for backing each other 11 up, you have shared visual cues. And because of the 12 simulator training and so forth you've got 13 well-rehearsed, tested plans. You know, your 14 resources are anticipati ng available

-- we could argue 15 about the limits of need for flexibility in response, 16 but that's in comparison to main control and 17 abandonment.

18 One of the key things is because we have 19 some of these things, this is recognition

-primed 20 decision making model is what my psychologists on the 21 team are telling me.

22 Another really key thing is the 23 communications are mostly face

-to-face and, you know, 24 voice communications model real time.

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-3701 (202) 234-4433 And because of the protocols for the 1 control room there should be restricted interruptions.

2 I mean, of course there will be phone calls. But you 3 have conduct of operations, or whatever, that limit 4 people coming into the control room. You have to ask 5 permission to get in, and so on and so forth. So 6 there's only so many people that are going to be there.

7 And you probably have some extra help answering the 8 phone. 9 In contrast, when you get to after you've 10 left the control room you are now at the remote shutdown 11 panel and distributed in the field there's the tea

m. 12 The operating crew is distributed through the plant.

13 The supervisor might be alone at the remote shutdown 14 panel. There might be another operator there. And 15 they're going to have to be coordinating with the fire 16 brigade, other plant areas, along with all of those 17 field operators.

18 Each operator, depending on where they're 19 located, is going to have their own view of plant 20 information. Most remote shutdown panels do not have 21 anywhere near the array of information that's in the 22 control room so far as indications. And most of them 23 don't have alarms.

24 And this gets to the point that I think 25 163 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 Matthew made earlier, there are parts of Phase III that 1 are frequently practiced, and that's the field operator 2 actions at the local plant stations. What's not so 3 much practiced is the coordination and interaction with 4 that supervisor who has got the procedure and is at the 5 remote shutdown panel and if he needs to be coordinated.

6 That coordination aspect is not frequently practiced 7 because they d on't do that integrated training, they 8 do the pieces, not all together.

9 So let's skip ahead.

10 So, communications are mostly going to be 11 radios or phones. Limit to the confirmatory 12 indications, and they may have to send somebody to go 13 find that information.

And we don't really have 14 information on how many interruptions are possible, but 15 there's no control on it that we know of.

16 So, the things that we, we had a set of 17 issues to discuss with the experts ahead of time. And 18 this slide and the next slide are the results of those 19 sorts of things. We actually we talked through with 20 the experts on one day and we continued our 21 conversations actually by phone and email to try to get 22 to this list of that kind of issues and concerns based 23 on w hat they -- their input.

24 So the role of the shift supervisor or 25 164 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 manager, whoever is in charge of command and control, 1 when they leave the control room they still have the 2 same responsibilities but they don't necessarily have 3 the same indications and controls at the remote 4 shutdown panel that they would have in the main control 5 room. 6 Communications are going to be different 7 and there are going to be time impacts associated with 8 that. 9 Most likely no alarms, and few indications 10 for the remote shutdown panel, so the ability to closely 11 monitor parameters, you know, is going to be different.

12 And the way, you know, the information 13 that's there, you know, you might have to pay more 14 attention to monitoring those parameters and so you 15 might be susceptible to distracti ons. 16 Coordination might be required, and it's 17 going to be complicated by different operators being 18 in different locations with communication issues.

19 There's a little more expansion on the next 20 slide, but the real, the real focus whe n we came down 21 to final discussions on what it is that we should be 22 most concerned with, the experts said we should focus 23 on coordination actions, especially things where they 24 weren't done properly that could result in irreversible 25 165 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 damage. This is again g etting back to the notion that 1 you have a strategy that has really one train of 2 equipment that you're going to be using for shutdown.

3 That's the design of many of the plant 4 procedures out there. That's what we found.

5 Just a couple things off of this slide so 6 we can try to get through to the end.

7 So while the shift supervisor or shift 8 manager continues to drive the actions that are going 9 to the procedure, for the most part they're not looking 10 at them, they can only monitor some of those actions 11 and record that they're done. But is of importance 12 when they have to coordinate those actions.

13 Allocation of resources, which is one of 14 those definitions of

-- one of those aspects of the 15 definition of command and control, that's mostly done 16 by the assignments to the various operators through 17 procedure attachments. That's how the strategy is 18 usually implemented in procedures as there's a master 19 procedure for the supervisor and then individual field 20 operators will have pieces of, you know, or attachments 21 to the overall procedure. But that's their 22 responsibility.

23 Communications are not, typically not 24 face-to-face. And many of those communications may 25 166 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 just be reports that things are done.

1 And then it was noted that communications 2 equipment and associated problems could be a concern 3 with those communications.

4 So, in focusing on sequencing failures in 5 particular, the authors went ahead and developed these 6 screening rules on when to model a command and control 7 failure. 8 We had various iterations on these rules 9 before we settled on this set that's shown in these next 10 two slides. But the first few steps mostly were 11 getting us to t hose sequencing failures. And then the 12 later steps have to do, are kind of related to what you 13 might call performance sha ping factors, or whatever.

14 One iteration of this was to actually give 15 different HEPs associated with those different 16 performance shaping factors that because we didn't have 17 enough information to know how important some of these 18 factors would be specifically for this context, we 19 decided to go with a single set of screening values.

20 And from my perspective, because no one's 21 modeled these sorts of things before I would use these 22 screening rules to say, you know, I don't want to model 23 thi s. How can I avoid this? And I'd look at these 24 screening rules and try to think about, you know, can 25 167 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 I design some compensatory measures by putting 1 something in my procedures so I can avoid having to 2 worry about this particular failure mode.

3 So, anyway, so the first step is just 4 asking whether or not command and control coordination 5 is required. And if it is, you need to continue with 6 the screening rules. They have to be done in order.

7 The next one is whether or not there are 8 sequencing of operator actions that need to be 9 coordinated. And if so, then we need to continue.

10 One thing actually kind of interesting 11 there was some feedback on because we weren't able to 12 come up with anything else, and that is the notion of 13 the irreversible failure within 15 minutes. We can 14 probably write some more up on that discussion, but the 15 idea was that it had to be a relatively quick failure.

16 You had an hour to discover there was something wrong 17 with your pump. We thought that was probably, probably 18 that would be discovered and something would be done 19 before it was irreversibly damaged, so.

20 CHAIR STETKAR: Like they did at H.B.

21 Robinson in the main control room with all kinds of 22 procedures and people there. They didn't discover it 23 in, it was like 39 minutes, that they had no cooling.

24 DR. COOPER: Yeah.

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-3701 (202) 234-4433 CHAIR STETKAR: Go on. Continue.

1 DR. COOPER: So I may be very interested 2 inputs on how we can develop a different number or what 3 number or range numbers there would be.

4 CHAIR STETKAR: The importa nt thing is

-- 5 and for the other members here

-- remember, whenever 6 it says "screened from consideration" that means 7 cognitive performance in the context of this 8 evaluation is perfect. The HEP is zero. That's the 9 way I would interpret this guidance as a practitioner.

10 DR. COOPER: No. I wouldn't say that.

11 CHAIR STETKAR: Well, tell me how I should 12 interpret it.

13 DR. COOPER: I would say

-- 14 MEMBER BLEY: It's the implication of 15 that. 16 CHAIR STETKAR: How would I interpret it 17 otherwi se? Because it says if I have no command or 18 control, if it's tossed out by any of these criteria, 19 then all I need to worry about is what I call about 20 implementation slips that can be accreted through a 21 THERP type analysis with recovery factors and, you 22 know, all of that neat stuff. That leads to a really 23 low probabilities typically.

24 DR. COOPER: Well, maybe not so low in this 25 169 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 sense because we don't allow for recovery of many kinds.

1 And there are other things, too. There are some 2 differences in how we h andle that, but.

3 MEMBER SUNSERI: Well, there doesn't 4 appear to be anything, at least from my view, unique 5 about these three things from a command and control 6 outside the control room or this, like an operator stuck 7 inside the control room.

8 CHAIR STETKAR:

Or inside the control 9 room. 10 MEMBER SUNSERI: That's what I mean.

11 CHAIR STETKAR: When you say we haven't 12 addressed this

-- 13 MEMBER SUNSERI: Firing up with the 14 suction valve closed, 15 minutes is plenty of time to 15 ruin that

-- 16 DR. COOPER: Okay. So you would have a

-- 17 the notion is that, okay, so if it

-- that's the short, 18 15 minutes or less. So I mean, I mean like I said, I 19 am actively soliciting input on that what number should 20 be. And if it was too generic. I mean, you obvious ly 21 have to find something out about the specific 22 equipment. How long does it take this pump to deadhead 23 if you have no suction. That's information you can 24 come up with. And you can compare that to whatever 25 170 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 number this is supposed to be.

1 But the next, the next things, I mean, I 2 mean that's the bottom line is what is the short period 3 of time for them not to notice? And the thing is that 4 we're also then going to ask, you know, what are you 5 doing to monitor this? You have somebody there that's 6 going to notice the pump's vibrating. Do you have 7 indications at the remote shutdown panel or somewhere 8 else that someone's looking at it. So that's the next 9 piece of the detection.

10 So the point is, is there a way you can fail 11 a piece of eq uipment so that it can't be used anymore?

12 CHAIR STETKAR: I'm sorry. This is 13 guidance, and you just said some words that I don't 14 recall reading anywhere in the guidance. I only read 15 a table that says here are the

-- I'm an analyst and 16 I don't want to do anything. I want any excuse for not 17 quantifying anything in the world. That's my world 18 view going in.

19 Anything that I can find here where the 20 Nuclear Regulatory Commission approved guidance tells 21 me I don't have to do anything, by God, I will not do 22 it. 23 So I didn't hear

-- read anywhere in the 24 guidance that it says, oh, by the way, you have to as 25 171 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 an analyst make sure that you have enough indications 1 at the remote control area so that you can discover the 2 bad thing, and the people are indeed looking at tho se 3 indications.

4 DR. COOPER: Well, that's the next step.

5 CHAIR STETKAR: And guiding people to do 6 it. 7 DR. COOPER: That's the next step. Maybe 8 they -- 9 MEMBER BLEY: That's one piece of it. The 10 other piece, I want to go back to where you said, no, 11 it isn't like concerning with success. Yes, it is. It 12 is. If you're going to screen it, then maybe the least 13 you ought to do is have some not too low chance of 14 failure that gets stuck in instead of that. Because 15 what you're sticking i n is zero if you don't include 16 it in the model.

17 CHAIR STETKAR: Well, if they get done, if 18 they still grudgingly keep it, there's still a 95 19 percent chance that you're successful. So you don't 20 have much margin there. You're either 100 percent 21 successful or 95 percent successful; right?

22 MEMBER BLEY: I think this would whittle 23 away at that 95 percent successful if you put in a 24 reasonable screening value. Screening implies 25 172 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 you're, well, here it implies you're throwing it away, 1 assuming that's

-- 2 CHAIR STET KAR: No, and that's, and that 3 -- 4 MEMBER BLEY: But if you put in .1 or

-- 5 CHAIR STETKAR: But if I'm 6 misinterpreting something, if I'm now going to use this 7 guidance, my interpretation of the guidance, reading 8 this stuff, is that if I meet in any one of these steps 9 screened from consideration the, I'll call it the 10 cognitive portion of my Phase III human error 11 probability is precisely zero. And I then am led to 12 guidance that says, yeah, I can go look it up and look 13 at a standard im plementation type of error.

14 DR. COOPER: Not standard. Not standard.

15 CHAIR STETKAR: Now, I need to worry about 16 the timing.

17 DR. COOPER: Yes. Not standard. And 18 only for this specific set of guidance that we're 19 talking about. And that's because unless c oordination 20 is required going through the supervisor, or it could 21 be just going through operators, unless that 22 coordination is required and it results in something 23 that fails a piece of equipment

-- that's what we're 24 looking to add is some kind of failure mode, additional 25 173 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 failure mode for a particular piece of equipment that's 1 a key, you know, key piece in the whole sequence of 2 things, that's what we're looking for. So.

3 MEMBER BLEY: I'm going to give you 4 something that will help you here.

5 DR. COOPER: Oka

y. 6 MEMBER BLEY: It's very different as you 7 go from plant to plant on what they have for a panel 8 or for a distributed system. And in a lot of cases you 9 don't have anywhere near the instrumentation you have 10 in the control room, so it's not clear that you'll 11 always have discharge pressure or that you'll have flow 12 indication. Gee, I got the pump running; maybe that's 13 all you see.

14 So then for your plant you've got to be very 15 careful about this one because unless somebody goes 16 running over near that plant

-- pump, you aren't going 17 to know it's clunking away. So it's very plant 18 specific in its implementation.

19 DR. COOPER: Okay.

20 MEMBER BLEY: And I don't remember if you 21 tell us that. I'm sure somewhere you tell us all of 22 this is plant sp ecific, but.

23 DR. COOPER: So, okay, I mean I guess, I 24 mean the key thing on this second one is that if you 25 174 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 get the operator actions that need to be coordinated 1 out of sequence, in other words you don't get suction 2 provided to the pump before you start the pump that you 3 can damage the equipment. But maybe if we just leave 4 out the timing piece that's enough.

5 But the point is that we're looking for 6 ways that the coordination can fail. In particular the 7 experts wanted us to focus on sequencing failure. So 8 if we could get things out of sequence, mostly because 9 you've either lost track of what people have done and 10 you get to the point where you want to start a piece 11 of equipment and you've either not kept track of or got 12 confused in some communications and didn't realize that 13 the first piece of this action has been done.

14 So that's what those, that's what those

-- 15 MEMBER BLEY: I've never seen anybody do 16 the steps and walk through it, if they walk through it.

17 I always had a vision of if w e're going to do this stuff, 18 especially if it was distributed, we're going to have 19 radios or headsets on or something. We're going to be 20 saying, Hey, John, go do this. Or, Charlie, go do that.

21 Susan, go over here and do that. Because then when he's 22 don e it and I can keep track of it all and make sure 23 he's sequenced right.

24 What you said is maybe not, maybe they all 25 175 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 just get sheets of paper and go out. And then those 1 numbers we saw earlier get even more

-- 2 DR. COOPER: Well, yeah, I mean I guess the 3 thing is that even though the actions might appear in 4 order in the procedure, the order in which you get the 5 communications may not be the same. So the point is 6 that you could be sending out operator A, B, and C to 7 do things and you're going to wait on B to g et D done, 8 and they're going to report back differently.

9 So that's the error, the kind of thing that 10 we're worried about. And then the sequencing error is 11 the ultimate problem.

12 CHAIR STETKAR: Let me try something for 13 you to think about. And that is

-- and Matt alluded 14 to it -- when I read through these things I don't

-- 15 I know that there are different issues as a human 16 reliability analyst that I need to be aware of in these 17 types of conditions compared to sitting in the main 18 contr ol room with whatever procedures I have, which is 19 difficult to know.

20 And I, I certainly endorse the notion that 21 the guidance should make analysts painfully aware of 22 that. 23 On the other hand, accounting for those 24 conditions now that I'm painfully aware of it, I don't 25 176 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 know why we need such prescriptive screening criteria 1 and prescriptive numerical values to plug in because 2 we don't do that, for example, when I'm in the main 3 control room under strange situations that may not 4 perfectly match a set of procedures.

I leave it up to 5 the analyst to evaluate performance

-shaping factors, 6 use whatever cognitive reliability model they're going 7 to use and whatever implementation slips and all that 8 kind of stuff.

9 Why do we need to be so prescriptive both 10 in terms of screening criteria and explicit numerical 11 values in this particular guidance? In other words, 12 why doesn't the guidance just simply, given the 13 expertise and the amount of time and effort that people 14 have put into thinking about this, this part of the 15 problem, why doesn't the guidance just simply make it 16 very, very clear, as an analyst you need to be 17 considering these factors in the context of your 18 scenario, in the context of your procedures, in the 19 context of your panels, and in the context of whatever 20 the fire damage is?

21 Because it strikes me that the human 22 reliability analysis, given all of that stuff and the 23 fact that communications might be more difficult than 24 standing in the control room, things might take more 25 177 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 time because I need to d o Step A clearly before Step 1 B, but I need to do that in the control room.

2 DR. COOPER: So, I guess I think I 3 understand what you're saying. And I think that the 4 thing is that we, maybe we tried to come up with a 5 distillation of wh at we understood from the experts to 6 try to come up with a simplified approach. And what 7 I think I hear you saying is that we should open it up 8 a little bit and provide the explanation that went 9 behind it so that an individual analyst can try to 10 better ma tch up to their specific thing.

11 CHAIR STETKAR: I'm just a bit 12 uncomfortable about the prescriptiveness of this and 13 its potential for being misused in ways that you hadn't 14 thought about by people who will say, well, this is the 15 NRC-approved -- I followed t he NRC-approved guidance 16 and, therefore, it is perfect.

17 You might not have thought about the ways 18 people, creative people can use guidance in very 19 creative ways if they don't want to do something.

20 MEMBER BALLINGER: I think given the 21 variability in all the plants and things like that that 22 you've described, if you're having a very bad hair day 23 in one of these plants they're going to do things that 24 are going to be different. And so being as 25 178 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 prescriptive as John is saying you're having, it seems 1 to me that it is too prescriptive. It's just too

-- 2 DR. COOPER: Yeah, I guess that the 3 intention was not so much to be prescriptive as to be 4 simple. And part of the thinking behind the going for 5 simple is because more so than with the decision to 6 abandon, I think our experts and their ability to 7 imagine something that's never been done was, it was 8 beyond their ability to imagine how things could go 9 differently or badly.

10 In other words it was sort of it was more 11 like so we've come to this point , we could

-- I mean 12 there are a number of other things that we conjectured 13 so far as errors of commission and doing this and that.

14 And after we came out of the expert panel we still sort 15 of debated some of those things. And we finally came 16 down to this.

17 And part of it was we didn't feel like there 18 was anything in the literature that could help us. And 19 certainly we were stretching to try to find other HRA 20 methods that we could use to develop any kind of HEP.

21 And I didn't think we could push our experts to give 22 us them. I think they were

-- they got to the issues 23 and that was as far as they could go.

24 And they realized that this is, this is, 25 179 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 I mean this is no longer in the control room. You know, 1 the point was made, yes, there are some remote shutdown 2 panels in the simulator. But as far as I know, the 3 only, only plant that I've heard that actually has been 4 doing integrated training on safe shutdown after the 5 main control room abandonment is Calvert Cliffs.

6 CHAIR STETKAR: Okay. So if I'm at 7 Calvert Cliffs, maybe, maybe my human error 8 probabilities are much smaller than if I'm at Plant X.

9 But I don't tailor my guidance for how to do human 10 reliability analysis based on those snippets of pieces 11 of information. I tailor my guidance so that if I'm 12 at Calvert Cliffs for a particular fire scenario I come 13 out with a human error probability of, you know, 3.7 14 times 10 to the minus 4.

15 And I'm at Plant X for the same fire 16 scenario I come out with .5.

17 DR. COOPER: Yeah, we, like I said, there 18 was a version of this where we were going to have

-- 19 I mean more five, five on compensatory measures. That 20 could be procedural, health, or training, or whatever.

21 There was some discussion about having different 22 values. 23 But the problem was that how to ma ke 24 distinctions between, you know, what, you know, how can 25 180 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 we make distinctions in the numbers? And what would 1 be the basis for it other than the fact that we just 2 intuitively know they ought to be different?

3 I mean, I guess if you go back to the 4 decision to abandon tree, I know you were hanging on 5 the best case probability.

6 CHAIR STETKAR: No, no.

7 DR. COOPER: But the main thing for me that 8 came out of that was that there was only a factor of 9 10 difference between the best case and the worst case 10 scenario. And to me that meant that they thought the 11 main thing was the reluctance to leave. And anything 12 that could help, like procedures, they didn't think 13 there was much of an impact.

14 And whether that's because they didn't, 15 couldn't imagine how that would work or what, that was 16 the result.

17 CHAIR STETKAR: And again, you say a 18 factor of 10. I say the difference between the 80 19 percent success and 98 percent success, which is a 20 really small difference. It means it's always really 21 success ful. 22 MEMBER SUNSERI: Well, I worry about the 23 1 in 5 chance it was not going to be successful. That 24 seems like pretty high failure rate to me.

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-3701 (202) 234-4433 DR. COOPER: Let's just arbitrarily move 1 it. So it was .5 and .4. I mean the point is that there 2 wasn't that m uch difference between

-- or a .5 and

-- 3 well, anyway.

4 CHAIR STETKAR: Let's see

-- 5 MEMBER SUNSERI: I want to add one comment 6 though regarding this slide that you have up here which 7 I mean I think the focus of this is on when is yo ur 8 command and control, say you have a failure there or 9 not a failure; right? And my earlier comment, well 10 this looks like, a lot like normal operations is, well, 11 did you think about going back to your criteria?

12 Because when I think about what a command and control 13 failure would look like in a control room abandonment 14 scenario I think about this; right?

15 So if I'm in the control room and I'm 16 dispatching an operator to start a pump he's going to 17 go down, he or she is going to go down there. I'm going 18 to be on the radio with them, or I'm going to be on the 19 telephone with them. And they say, I'm starting the 20 pump. Watch for the flow. I get a report back; right?

21 DR. COOPER: Right.

22 MEMBER SUNSERI: When there's a fire out 23 in the plant and I've left the cont rol room, my radios 24 may not be working, my telephones may not be working, 25 182 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 I may not be able to communicate with that person. So 1 that's when it becomes

-- so I would put criteria around 2 that to tell me whether or not I lost command and 3 control. 4 So I would look at these five things you 5 have on page 31 and maybe think about what screening 6 criteria would I wrap around those to tell me I had a 7 loss of command versus these human performance issues.

8 DR. COOPER: At least with r espect to the 9 communications that's a feasibility criteria. You 10 have to have the communications and the equipment and 11 all those sorts of things. So that that screen has 12 already been met. So you know that you can 13 communicate.

14 There may be some things abo ut the 15 communications that are not optimal. And we discuss 16 that as being part of the command and control.

17 The bottom line is that we're trying to 18 focus on when there is a need for command and control 19 such that it affects one of these actions in the field.

20 Because they're not doing anything at the remote 21 shutdown panel. At least that's not the situation 22 we're looking at. We're looking at a situation where 23 someone's doing something out in the field, and what 24 can we do to make that fail. And it's either

-- and 25 183 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 we're focusing on, I mean we have looked at delays.

1 That was one thing that we looked at. But that's not 2 where the experts led us to look.

3 So we're looking at things where you can 4 get things reversed such that you could fail something.

5 Because a delay is just simply going to change the 6 timing, which we can reflect directly in the rest of 7 our analysis and in communications.

8 MS. PRESLEY: So it's not so much that 9 these things can't happen in normal operations, but in 10 the normal command and control situation you have 11 certain bounds and you have people working together.

12 So this is, it's a bigger vulnerability when you're out 13 in the field because you have a different command and 14 control sector. So we're looking for things that a re 15 especially vulnerability now that your command and 16 control has changed.

17 MEMBER SUNSERI: Right. So I think about 18 this, so you know in your control room you've got your 19 shift manager and your supervisor right there. When 20 you go abandon the control room those two people may 21 not be in the same place.

22 MS. PRESLEY: They probably are not.

23 MEMBER SUNSERI: And your ability to make 24 timely decisions is now changed; right?

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-3701 (202) 234-4433 MS. PRESLEY: Right.

1 MEMBER SUNSERI: That's command and 2 control. 3 MS. PRESLEY: So the things on Slide 31, 4 we basically had to

-- so some of those, the timely 5 decision making, and the, like, the feasibility of 6 communications, the communications, the comms 7 equipment being available, those we've already 8 demonstrated throu gh a feasibility assessment.

9 So we're looking at the additional things 10 that can cause

-- that are harder to recover from and 11 become more impactful than they are normally because 12 you have that backup, you have that crew working 13 together the way they're used to. So I guess that's 14 how we got to those five criteria. So these are more 15 vulnerable than they would normally be in normal 16 operations because the command and control is not the 17 same level essentially.

18 DR. COOPER: So, for example, in the 19 control room y ou had a procedure, and if you're talking 20 about putting a pump into place there's probably one 21 step, one step or substeps that are all related to 22 putting that pump into service. And it will be gone 23 through in order, in sequence, read out loud by the 24 shift supervisor with the board operators responding 25 185 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 as they do things.

1 Now we don't have that. We have people in 2 the field reporting when things have gotten. And you 3 might have in a particular attachment, you might have 4 a note that says this needs, this is a whole point you 5 need to communicate with someone else. Or you need to 6 know that, you know, Step A has been performed before 7 you do what you're going to be doing.

8 But that usually, that's going to run 9 through the shift supervisor.

And he actually has to 10 do the job of making sure that they're done in the 11 correct order. So that's what we were focusing on.

12 And how is it possible that it could be, those steps 13 could be done out of order, or Step A never got 14 performed, and you tried to get that pump started or 15 you tried to start that diesel without having, without 16 having cooling water or something like that.

17 So that's the issue that we're, that's what 18 we're trying to get at, could that possibly occur or 19 how could that occur? And so the kinds of things that 20 we're thinking about, well, you know, we just lost track 21 of all the communications that are going, coming in.

22 Maybe he doesn't have place

-keeping aids. He doesn't 23 have a place or a good way to write things do wn. Too 24 many calls come in at once. And when he gets, when he 25 186 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 gets the call from the field operators, wants to start 1 the pump and he wants to know have you started this?

2 Has, you know, operator A started the section head?

3 Can I go ahead and start this thing, start this pump?

4 And the shift supervisor is thinking, well, there is 5 a whole bunch of phone calls that just came in, I've 6 got some scribbles here, I think they got a

-- I think 7 you're okay. Go ahead. Using the formal 8 communications.

9 So that's, that's one of the failure modes 10 that we imagined that could happen because of the 11 disconnect between, you know, the beginning of an 12 action and end of an action because they're being 13 performed in the field at different locations, running 14 through the shift su pervisor. 15 So that's how it's different is that 16 there's no longer control on the ordering of the steps.

17 Okay, so we

-- the first screen is, is there 18 coordination.

19 The second one is are there actions that 20 have to be sequenced, these coordinated actions.

21 The next screen is whether or not you can 22 detect whether or not there's something going on wrong 23 with your equipment.

24 And we give some examples of local 25 187 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 indications or, you know, it's possible the shift 1 supervisor might have a procedure step or note to ask 2 somebody the mod for the equipment from another 3 location if it's not the remote shutdown panel.

4 Then the fourth screen is whether or not 5 the shift supervisor is the one that has the 6 responsibility for all the communications. In other 7 words, he's the final point for all the phone calls.

8 He's not -- and then we have some examples of things 9 that would kick you out. Or, you know, if there's 10 nobody else that's helping them make these, fielding 11 these calls.

12 And then I guess the other thing is if there 13 was a specific set of steps that had to be coordinated, 14 you know, it's not like the shift supervisor is just 15 focusing on these steps. You know, he's got a larger 16 set of duties. So he's, he's the focus of all these 17 communications.

18 And then the fifth and final screening step 19 is any kind of compensatory measures that might help 20 the supervisor with coordination and you don't have 21 those. And we give a couple examples. And we're 22 focusing on procedures in these examples.

23 Things that could help that you don't have 24 that would keep you to model this would be if there's 25 188 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 like a hold point written into the procedure, or a 1 warning, or a caution, that sort of thing.

2 And then another thing would be good 3 place-keeping aids so that the supervisor can record 4 when support systems are being put into service so that 5 when he gets to those, those interactions with 6 operators that are putting front line systems into 7 place he does know that the supporting systems have 8 already been put into service and they can move ahead 9 with these final steps to get this equipment into 10 service. 11 So this is the set of screens that we put 12 together. Those are the concerns that we put together 13 and that have been informed by all the interactions that 14 we've had with e xperts in other discussions. And as 15 I indicated before, the simplified approach that we've 16 taken is to go ahead and assign a single value as you 17 come through these screens. And the basis for this 18 value is -- comes from three, four different places.

19 We did a review of various HRA methods or 20 guidance to see if it addressed some of the similar, 21 some of the issues that we thought were important.

22 NUREG--2114 which is the cognitive basis for HRA NUREG 23 has some discussion about workload and multi

-tasking. 24 The NUREG for IDHEAS At

-Power, NUREG

-2199, 25 189 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 has a decision tree that addresses workload that 1 includes consideration of distractions and 2 interruptions.

3 NARA, the publicly

-available paper has a 4 communications generic task type with some er ror 5 producing conditions that include that include 6 information overload, which we identify in the 7 instructions as a possible failure mode.

8 And then THERP Table 20

-8 also talks about 9 errors in recalling oral communications.

10 So, using these, these inputs, we looked 11 at each of these methods. And the range of HEPs from 12 these methods went 1E to the minus 2 to .1. And we 13 picked the middle of that arbitrarily. But those are 14 the -- you can see the range is not, not wide. But 15 that's what we got in

-- that's wher e we came out in 16 the end. 17 MEMBER BLEY: Susan.

18 DR. COOPER: Yes.

19 MEMBER BLEY: I'm still a little off 20 center on this stuff. But much of this kind of looks 21 reasonable to me. The screening steps 2 and 3 together 22 just feel a little funny to me.

23 DR. COOPER:

Okay. 24 MEMBER BLEY: This idea that step 3 is 25 190 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 saying, well, you don't protect things right away.

1 You're off trying to do something else. Which kind of 2 seems in conflict with this business of 15 minutes or 3 less. 4 And then 2 is the o ne bothers me. If in 5 fact you have a condition that would lead to failure 6 in 15 minutes or less, I guess if you don't have that 7 then we're screening from consideration. And that 8 just feels very optimistic to me.

9 CHAIR STETKAR: Everything is perfectly 10 d etectable given more than

-- 11 MEMBER BLEY: From then on.

12 CHAIR STETKAR:

-- given more than 15 13 minutes. 14 MEMBER BLEY: And then I get to the next 15 step and, Oh my gosh, I've run off doing other stuff.

16 DR. COOPER: Well, if you took the 15 17 minutes out does th at fix the problem?

18 MEMBER BLEY: You've still got to have 19 something that falls through the screening failure rate 20 at a minimum for me.

21 CHAIR STETKAR: Well, the worst it can be 22 is 95 percent success. Again, it's either 100 percent 23 success because it's screened out, or 95 percent 24 success if it's not screened out. So the worst it can 25 191 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 be according to their guidance is 95 percent success, 1 .05 for failure.

2 DR. COOPER: But the basis for this is the 3 role of command and control in the im plementation of 4 the safe shutdown strategy. And in the cases where you 5 don't have to coordinate anything, then there really 6 isn't a role except for the time for the communications.

7 There's no, for the strategies we're looking at there's 8 no deciding to us e something else. There's no calls 9 from the supervisor to a field operator to do something 10 else. 11 They all have their pieces of procedure.

12 They're implementing those. That's it. That's the 13 way the procedures are written right now.

14 So there isn't

-- you know, the shift 15 supervisor doesn't have to allocate resources. He 16 doesn't have to pick up the phone and say, hey you, field 17 operator, go do this. He's not assigning anybody 18 anything. The procedure doesn't, well, the procedure 19 doesn't have the supervisor making any choices so far 20 as going to another procedure, using a different piece 21 of equipment.

22 MEMBER BLEY: If you go back to number two, 23 if you got rid of the whole phrase after the comma.

24 DR. COOPER: "Such as"?

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-3701 (202) 234-4433 MEMBER BLEY: Yeah.

1 DR. COOPER: Yeah, t hat's -- exactly. 2 MEMBER BLEY: Then it says if there is no 3 thing that can fail without some kind of recovery, yeah, 4 then you could go on, I guess.

5 DR. COOPER: Okay. All right.

6 MEMBER BLEY: I'd have to think about that 7 some more.

But it just smells a little funny.

8 DR. COOPER: No, I mean it is

-- it was, 9 it was a place where I wanted input because I wasn't 10 sure. I didn't

-- we had some discussion about it among 11 the team and didn't have any other answers at the time.

12 So we can c ertainly take that feedback as

-- 13 MEMBER BLEY: If you don't

-- if you can't 14 have an irreversible failure of equipment

-- 15 DR. COOPER: That's, that's correct.

16 MEMBER BLEY: Fifteen minutes stuff is in 17 interfering with the next

-- 18 DR. COOPER: Okay. Fair e nough. 19 CHAIR STETKAR: Before we get to the

-- Is 20 there anything more on these screening and this topic?

21 DR. COOPER: No.

22 CHAIR STETKAR: I want to bring one more 23 thing up that I intentionally left to the end.

24 I really like the notions of the time lines 25 193 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 that you have. I think they're really good. It keeps 1 people focused on those times.

2 Feasibility assessment. Why

-- and we've 3 had this discussion in the past

-- why do you not 4 quantify uncertainties in the time available, in the 5 tim e required and look at the overlaps and the 6 uncertainties as a contributor to the overall human 7 error probability, which we have in fact already in the 8 guidance for at

-power ideas?

9 And there's a notion that at least I 10 personally have been trying to instill in this 11 organization going forward is that are there 12 uncertainties? Yes, there are. If there's a 2 13 percent probability, given the uncertainties, that the 14 time required is longer than the time available, 15 there's a 2 percent probability that I'm not going to 16 make it. For the other 90 percent chance I'm now 17 looking at what fraction of that 98 percent chance do 18 I win and do I not win?

19 And that's sort of a conceptual thing that 20 is not -- you don't talk about uncertainties in the 21 times, and you certainly don' t talk about it on that 22 time dilution type thing.

23 DR. COOPER: Unfortunately, 24 uncertainties are overlapped, yeah.

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-3701 (202) 234-4433 CHAIR STETKAR: Well, it is. And that's 1 why I didn't want to start it but I'll just throw that 2 out there. It's on the record. We don't have time for 3 an in-depth discussion. We've had the discussions.

4 Mary can dredge up her notes. But it something that 5 there is -- it's in the IDHEAS methodology, or it has 6 been. 7 And that's a conceptual notion. It's not, 8 it's not focused on these particular scenarios or 9 anything, it just kind of a way of thinking of things.

10 And now you can go on with your path 11 forward. 12 MS. LINDEMAN: Okay. I'm going to give 13 Susan a break. She's done an excellent job thus far 14 explaining all the techni cal details.

15 So I think our next step and current 16 status. There's a bullet missing, and I just wrote it 17 down it says digest today's presentation and 18 discussion, so.

19 (Laughter.)

20 MS. LINDEMAN: I mean, personally, I think 21 the feedback is valuable and certainly can be, you know, 22 embraced. Having the discussion today, as you alluded 23 to, has anyone tried this out? So, you know, the next 24 step down the road is seeking peer review.

25 195 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 And Susan and I have been discussing peer 1 review. So I've solicited a number of volunteers.

2 And I know Susan has done the same. So we'll have a 3 good panel of both NRC expertise and industry and 4 practitioner expertise. So I think next step once we 5 digest this feedback is go to peer review and then go 6 throu gh our publication process.

7 CHAIR STETKAR: You don't have plans I 8 don't see here for a

-- I'm assuming

-- Well, let me 9 ask you. After you have the peer review of the guidance 10 you will now have Supplement 1 and Supplement 2 and the 11 original 1921. Is ther e any notion of a pilot 12 application, in particular for the main control room 13 abandonment guidance?

14 DR. COOPER: Susan Cooper. It wasn't our 15 original plans. I think that it's possible, you know.

16 Ashley, and Mary and I need to talk some more about the 17 peer review. Part of our public comment period for 18 1921, which was also part peer review, did

-- was 19 actually a pilot of I think it was the Westinghouse 20 Owners' Group. I think they did a pilot. So it might 21 be that some of our industry peer reviewers in 22 particular can take that to be more than just reading 23 the document and providing some feedback, but actually 24 trying to exercise it.

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-3701 (202) 234-4433 The other thing that we have discussed that 1 isn't in Supplement 2 are examples. And I think there 2 are places where some of the discussions we had today 3 could be better understood if there were some examples.

4 Some, you know, some of the things that we've talked 5 about today, and we've had some other discussions 6 internally coming up to this, this briefing today where 7 we thought that that probably would be, especially on 8 the timing discussions and the phases and how you 9 calculate time available for Phase II and stuff like 10 that, having some illustrative examples on that would 11 probably assist that.

12 But the curre nt schedule for publication, 13 as shown here in brief, does not have a specific 14 piloting phase. The original schedule did but we kind 15 of stretched out time to get to this point with this 16 document. 17 And I'd like to add that I think that 18 without this being a joint project with EPRI, I think 19 coming up with any kinds of guidance in this area that 20 is not supported by operational experience, by 21 plant-specific training or demonstration, and little 22 literature, I think it would be very, very difficult 23 to come up with anything. 24 CHAIR STETKAR: As Mark Henry said in the 25 197 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 introduction, I think that in these areas that that 1 process, the MOU process benefits both the agency and 2 the industry tremendously because it kept both entities 3 kind of grounded

-- 4 DR. COOPER: Yes. And I'd like

-- 5 CHAIR STETKAR:

-- in some concept of 6 reality anyway.

7 DR. COOPER: I'd like to, I mean, you know, 8 the, you know, we looked at existing methods in the 9 beginning, but the fact that our industry partners were 10 willing to put CBT aside and start with something new 11 because it technically matched what we thought were 12 concerns, I think is not something that probably would 13 have -- either one of us would independently have felt 14 like we could have done.

15 CHAIR STETKAR: Thank you. Thank you, 16 thank you. Let me take care of a couple of things here.

17 If there's anyone in the room here who'd 18 like to make a comment, come up to the microphone and 19 do so. 20 I'm assuming that there is still some 21 chance that there might be members of the public on the 22 phone line. If there is anyone out there who would like 23 to make a comment, I'm hoping that the system will work, 24 please speak up and identify yourself and make a 25 198 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 comment. 1 (No response.)

2 CHAIR STETKAR: I don't hear anything

. 3 I hate to do this because the system is 4 supposed to work. But is there anyone out there 5 listening who can just confirm.

6 MR. BROWN: The line's open.

7 CHAIR STETKAR: It is? Okay, thanks, 8 Theron. Thank you.

9 All right, having heard no comment

-- 10 MS. GUNTER: This is Kaydee Gunter. I've 11 been listening the whole time.

12 CHAIR STETKAR: Okay.

13 MS. GUNTER: I have no additional 14 comments. 15 CHAIR STETKAR: Great. Thank you.

16 Thank you, thank you. This time of the day and the 17 silence on the line made me a bit une asy. 18 So, no public comments.

19 I'd like to go around the table and get any 20 final comments or observations from the members. Dr.

21 Ballinger, sir.

22 MEMBER BALLINGER: No comments. Great 23 presentation.

24 CHAIR STETKAR: Dennis?

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-3701 (202) 234-4433 MEMBER BLEY:

It's been a good discussion.

1 I still have some things to think about. I guess if 2 you're doing revisions of this and you're getting 3 public comments then if we ever want to write a letter 4 it would be after they get these comments I think.

5 But nothing more to question I don't think.

6 CHAIR STETKAR: Matt.

7 MEMBER SUNSERI: It's days like this where 8 I'm glad I sit on this side of the table instead of that 9 side of the table.

10 You guys did a great job of fielding all 11 the questions we asked. And I appreciate all the hard 12 work that goes into this. I know it's a tremendously 13 difficult task trying to figure out how people would 14 act in every situation. So, thank you for your work.

15 CHAIR STETKAR: Jose.

16 MEMBER MARCH

-LEUBA: Nothing for me.

17 CHAIR STETKAR: Walt.

18 MEMB ER KIRCHNER: No, thank you.

19 CHAIR STETKAR: Joy.

20 MEMBER REMPE: No comments.

21 CHAIR STETKAR: Vesna.

22 MEMBER DIMITRIJEVIC: Well, I was silent.

23 Usually I'm silent when I don't have a question. So 24 I have a comment.

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-3701 (202) 234-4433 This was the second reason because I really 1 didn't have a chance to carefully looking at the report, 2 so that's why I was so withholding on the questions.

3 So I noticed that sometimes in this, 4 because it's such a complex problem, and we really 5 admire what you guys are trying to do as such a complex 6 problems by always so many issues. And sometimes I had 7 the feeling that we were discussing not completely the 8 same thing because it wasn't clear exactly what HEP for 9 Phase II, if it's actually abandonment of the control 10 room in the sense that they decide to do that and they 11 do whatever they have to do, turn this switch or not.

12 And in some case this habitability issue 13 comes ten to decide to leave, but it may be worse for 14 them to perform actions they have to perform. So we 15 are often discussing things on different levels.

16 So this is why I was thinking that we should 17 actually, it will really help if you guys have examples.

18 Now these examples can be coming, obviously doesn't 19 have to be specific plan, you just see the remote 20 shutdown panel or procedure, but it could be some 21 different scenarios because a lot of different 22 scenarios will leave completely different responses.

23 And it seems to me that there is a danger 24 we don't identify, but right now we are in the sit uation 25 201 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 if you have a scenario where we lost any controls, you 1 know, could be component cooling system, could be 2 offset power, could be whatever, any control from main 3 control room, that we have to, you know, make decision 4 to abandon the control, that, it c ould be for different 5 scenarios, you may see this number. Right now the 6 number is 3 minus 1 in the worst case and 5 minus 2 for 7 CMC, so this is 2.5E minus 1; right? So we have a 25 8 percent status to pay for any scenario which requires 9 to abandon the cont rol room. 10 And if this is how the plants are going to 11 interpret that, then there is certain dangers there, 12 so. You know, so some examples I think may benefit.

13 A couple scenarios go down and see, you know, what's 14 happening. So that's about it.

15 CHAIR STETKAR: Thank you. And I'm not 16 going to say it. Thank you for all the work. And I 17 really appreciate your stamina. I think, I think we 18 had a good discussion.

19 With that, we are adjourned.

20 (Whereupon, at 5:41 p.m., the meeting was 21 adjourned.)

22 23 A Collaboration of the Electric Power Research Institute (EPRI) & U.S. NRC Office of Nuclear Regulatory Research (RES)Susan E. Cooper (NRC/RES)Ashley Lindeman & Mary Presley (EPRI)ACRS PRA Subcommittee MeetingApril 4, 2018Rockville, MDSupplement 2, NUREG-1921 Quantitative HRA for Main Control Room Abandonment 2A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Status of Fire HRA Modeling for Main Control Room Abandonment (MCRA)Today's presentation:

-Provides updated information for joint EPRI/NRC-RES HRA research project-Addresses second product of this research which:Builds on previous research products

-NUREG-1921 / EPRI 1023001, which established guidance for the conduct of fire HRA

-NUREG-1921, Supplement 1 / EPRI 3002009215, which established guidance for the conduct of qualitative HRA for MCRAUses the experience developing NUREG

-1921 & supporting NFPA 805 submittalsWill provide the last piece of the MCRA research, i.e., guidance for the quantification of MCRA HFEs 3A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Today's AgendaReview project history and background

-Project teamReview of Supplement 1 (Qualitative Analysis)-Summary of responses to commentsSupplement 2 (HRA Quantification Guidance)

-Overview-HRA quantification guidance:Before the fire creates conditions for abandonment (minimal guidance so not discussed today)For the decision to abandon the MCR on loss of control For implementation of MCRA shutdown strategyStatus and future workClosing 4A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Project History and Background 5A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Project History and BackgroundObjective of research is to provide HRA guidance for scenarios involving abandonment of main control room due to fire generated conditions

-Loss of habitability (LOH) -Loss of control (LOC)Identified as an area of future research in EPRI 1023001 / NUREG-1921Complex topic and plant specific considerations

-Wide range of remote shutdown panel (RSDP) capabilities of and associated procedures

-Therefore, difficultto develop generic guidance 6A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Project TeamNRC/RES-Susan E. Cooper, NRC

-Stacey Hendrickson, Sandia National Laboratory

-John Wreathall, John Wreathall& Co., Inc.

-Tammie Rivera, NRCEPRI-Ashley Lindeman, EPRI

-Mary Presley, EPRI

-Erin Collins, Jensen Hughes

-Paul Amico, Jensen Hughes

-Jeff Julius, Jensen Hughes

-KaydeeGunter, Jensen Hughes 7A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Supplement 1 (Qualitative Analysis) 8A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Qualitative Analysis(NUREG-1921 Supplement 1 / EPRI 3002009215)Presented to ACRS PRA Subcommittee in May 2016Held peer review in Summer 2016

-ObjectivesReview for technical itemsDoes it meet needs of intended users?-Peer review compositionPRA practitioners (industry and NRC), Human reliability analysts (industry and NRC), and Cognitive and behavioral science analysts (consultants)EPRI published joint report in August 2017 9A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Qualitative Analysis(NUREG-1921 Supplement 1 / EPRI 3002009215)Summary of revision since May 2016

-Edits and clarifications associated with ACRS and peer review comments-Added analytical process diagram (Section 2.4.1)

-Added dual unit timeline example (Section 7.6.3)

-New section in Appendix A addressing variability in capability of RSDP design (Section A.3)

-Provided additional development on Appendix B

-Command and Control -Added Appendix D

-insights from operator interviews 10A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Three Phases of MCRAPhase I -associated with actions taken before the decision to abandon

-Actions directed from MCR using EOPsPhase II -the decision to abandon is plant

-specific and requires agreement between plant operations, fire PRA modeling and fire HRA

-Typically the HRA/PRA team will need to define conditions which require abandonment and the time at which these conditions will exist. Good example of FPRA feedback to training and/or procedures.Phase III

-models actions after the leaving the MCR, similar to NUREG-1921 ex-MCR actions

-Also addresses command & control, coordination and communications 11A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Three Time Phases of MCRAPhase I -Time period before abandonment decisionPhase II -Time period for the decision to abandonPhase III

-Time period after abandon has been made 12A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Example of integrated timeline for multiple HFEs 13A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Example of Timeline For Phase III (Dual Unit Abandonment) 14A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Supplement 2 (HRA Quantification Guidance) 15A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Overview of Supplement 2Supplement 2 developed to be a companion document to NUREG-1921 and NUREG

-1921, Supplement 1High-level development approach 1.Focused development on Phase II & Phase IIIDecision to abandon on loss of control (LOC) (Phase II)Implementation of MCRA safe shutdown strategy (Phase III) 2.Insights from Supplement 1 were used to identify key issues that should be represented in quantification 3.List of issues were compared to existing HRA methods 4.Authors developed "strawman" quantification approachesPhase II -developed candidate decision treesPhase III

-list of issues only 5.Expert inputs were used to confirm and/or modify each "strawman" and complete quantification methods 16A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Role and Use of Expert PanelPanel composed of:

-Two NRC staff with knowledge of operations and training, including fire

-related expertiseHarry Barrett (retired; formerly NRR NFPA

-805 reviewer)Jim Kellum(NRO)-Two HRA/PRA analysts experienced with plant fire

-risk studiesJeff Julius, JENSEN HUGHESErin Collins, JENSEN HUGHESExperts needed to have experience and understanding of a wide range of HRA/PRA and operations issues, especially with respect to MCRA scenarios-Experience/understanding across a range of NPPs (not just plant

-specific for 1

-2 NPPs)Experts used differently for Phase II and Phase III

-Phase II: Confirmed key issues, pruned/modified strawman decision trees using prioritized uses, provided HEPs for "best," "worst," & a few immediate

-case contexts, pair

-wise comparison inputs for other decision tree branches-Phase III: Confirmed/pruned key issues, identified main priorities & associated contexts 17A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Overview of Supplement 2 (continued) How to use Supplement 2-Supplement 2 provides quantification guidance on MCRA scenarios that were beyond the scope of NUREG

-1921-Certain types of operator actions & human failure events (HFEs) in MCRA scenarios should be addressed with NUREG

-1921 -NUREG-1921, Supplement 1 qualitative analysis guidanceIs needed to apply HRA quantification guidance in Supplement 2 (and is repeated, if needed)Introduced, defined, and illustrated (via event analyses) the key concept of "command and control" (C&C)

-Supplement 2 expands upon this concept 18A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Phase II -Decision to Abandon 19A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Phase II -Decision to Abandon (LOC only)High Level ApproachStep 1: Developed list of factors important to the quantification of the decision to abandon Step 2: Consideration of existing HRA methodsStep 3: Adaptation of existing HRA methods against factors important to quantificationStep 4: Development of new decision trees specific for decision to abandonStep 5: Obtained subject matter expert (SME) feedback on decision trees and human error probability (HEP) valuesStep 6: Document findings and provide guidance to analyst 20A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Step 1: Factors important to decision to abandon (team consensus)IssueDifferentiationPoints ProcedureContent-Best case: Explicit statement of severe conditions (such as extensive MCR instrumentation failure or equipment failure consistent with fire PRA modeling) due to fire that require abandonment

-Worst case: SS/SM discretion only

-Intermediate case: Procedure provides fire locations that, when identified and confirmed, indicate likelihood of needing to abandon, but still leave it up to SS/SM decisionTime available (versus time required)-Best case: Long (~20

-25 mins)-Worst case: Short (~5 mins)

-Intermediate case: Moderate (15 mins)Training-Best case: "Realistic" training in simulator

-Worst case: Classroom only training at minimum level

-Intermediate case: Detailed classroom training coupled with explicit MCRA criteria provided in procedures 21A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Step 1: Factors important to decision to abandon (team consensus) (continued)IssueDifferentiationPoints Cues and indications

-Best case: SS/SM has procedural guidance and training on cues that clearly and quickly identify that:(a) fire has been detected in a location relevant to the abandonment criteria,(b) the MCR is no longer reliable as a source of system/component information and control

-Worst case: No consistent or coherent way of seeing that LOC is occurring using the displays in the MCR.

-Intermediate case: Multiple cues but simulator and classroom training has prepared operators on what to look for and how to make decision ReluctanceThis is related to the: a) capability of the RSDP, b) operator comfort & familiarity with the MCR, c) inability of operators to conceive of such a desperate situation.

-Best case: Capable RSDP, explicit MCRA criteria & "realistic" training

-Worst case: Very limited capability RSDP, no explicit MCRA criteria, & minimum classroom training

-Intermediate case: Most major systems on RSDP, some MCRA criteria; some training 22A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Step 1: Factors important to decision to abandon (team consensus) (continued)IssueDifferentiationPoints Staffing and Communications

-Best case: SS/SM aided in decision

-making by STA or other crew who are monitoring clear abandonment criteria as would be done with Critical Safety Function Trees

-Worst case: SS/SM discretion only

-Intermediate case: SS/SM receives timely input from ex

-MCR operator on severity of fire OR from other in

-MCR crew on status of MCR boards and key equipmentTransfer to procedure with MCRA criteria

-Best case: Clear transfer to necessary procedure steps (or STA is assigned to monitor MCRA criteria and MCR indications in order to achieve quick transfer to procedural steps for MCRA)

-Worst case: No specific transfer steps.

-Intermediate case: Transfer is not distinct.

23A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Step 1: Timing associated with decision to abandon on LOCTiming not as "clear cut" as typical internal events actions

-Time available: left over time (after Phase III)

-Time required: gradually unfolding cue, highly dependent on procedures/training 24A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Step 2: Existing HRA Quantification MethodsConsidered several HRA quantification approaches:

-Cause-Based Decision Tree (CBDTM)

-Human Cognitive Reliability/Operator Reliability Experiment (HCR/ORE)-Integrated Human Event Analysis System (IDHEAS) At

-Power-Standardized Plant Analysis Risk Human Reliability Analysis (SPAR

-H)-Nuclear Action Reliability Assessment (NARA)

-Cognitive Reliability and Error Analysis (CREAM) 25A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Step 3: Adaptation of Existing HRA Quantification MethodsInitial quantification discussion centered around re

-interpreting the CBDTM decision treesReview asked:-Is the failure mode of the tree still applicable?

-Are there dominant failure modes or mechanisms missing from the set that should be accounted for?Review yielded:

-CBDTs intended for one main cue. For LOC, the "cue" is more vague (fire alarm, verification of fire, and verification of LOC)

-Both abandonment procedural step and transfer to abandonment were supposed to be covered and this presented some confusion in re-interpretation

-Decision trees were binary decisions, but the procedure quality range was too large to fit within binary structure 26A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Step 4: -Draft decision treesDeveloped three new decision trees for decision to abandon

-Failure to transfer to MCRA procedure

-Failure to understand the MCRA criteria have been met

-Reluctance / delayDecision trees formed the skeleton for discussion with SMEs

-Failure to transfer to MCRA procedure

-removed from consideration by the SMEs who concluded it was not a significant contributor to failure. -Failure to understand the MCRA criteria have been met

-expanded to address reluctance and timing

-Reluctance / delay

-subsumed into criteria tree 27A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Step 5: Summary of Expert FeedbackPrimary driving factors from expert discussion

-Reluctance to abandon, key driving factor, across all response

-Timing (as discussed earlier)

-General training of crew to integrate information and look forward to "what is coming" (judgment and understanding

)These considerations are built into the base HEP estimates in the final decision treeHEP estimates and key drivers based on current U.S. fleet

-HRA guidance for MCRA would be substantially different for a new NPP design that uses a substantially different MCRA safe shutdown strategy, including re

-constitution of the entire MCR operating crew at essentially a backup MCR 28A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Steps 5 & 6: Final Decision TreeAbandonment logic explicit in the proceduresSimulator or talk through training on the decision to abandonAwareness of urgency "time pressure"HEP when Tavail decision is less than or equal to 5 minutesHEP when Tavail decision is between 5 and 25 minutesHEP when Tavail decision is greater than 25 minutesYes1E-016E-022E-02(a)Talk- through/ simulator observations No1E-018E-023E-02(b)Criteria documented in procedureYes1E-017E-023E-02( c)Classroom only No1E-019E-025E-02(d)Yes1E-019E-025E-02(e)Talk-through / simulator observations No2E-011E-018E-02(f)JudgementYes2E-011E-016E-02(g)Classroom only No2E-012E-011E-01(h) 29A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Phase III 30A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Phase III: Implementation of MCRA Safe Shutdown StrategySupplement 2, Section 4 provides guidance on HRA quantification for all HFEs in Phase II I-Section 4.3 provides process for identifying, modeling, and assigning HEPs to HFEs (including feasibility assessment and analysis of timing)Most of Phase III HFEs are associated with execution of MCRA procedure steps at local plant stations

-NUREG-1921 guidance for quantification should be used with Supplement 2Most of the research effort for Supplement 2 focused on when/if additional HFEs (or failure modes for existing HFEs) should be added to represent failures in C&C

-Section 4.1 and 4.2 summarize concerns with respect to C&C

-Section 4.3.3.3 addresses C&C failures

-Appendix B provides additional information regarding C&C research 31A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Phase III: Definition of C&CSupplement 1 to NUREG

-1921 (qualitative analysis for main control room abandonment [MCRA]) is based on military definitions but is focused on the following as key functions related to C&C at nuclear power plants (NPPs):

-Maintaining a coherent understanding of the plant state (situational awareness)

-Timely decision

-making-Allocating resources as needed

-Coordination of actions

-Managing communications between team members such that they are timely and effective 32A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Phase III

-High-Level Approach to Address Command & Control ImpactsExpanded upon Supplement 1 regarding understanding of C&C for implementation of MCRA safe shutdown scenarioDeveloped a consensus on likely relevant issuesUsed input from experts to:

-confirm key issues

-focus on a specific C&C failure mode and associated contextDeveloped a set of screening rules for analyst to identify contexts when a C&C failure should be modeledReviewed existing HRA methods to identify those that addressed issues "similar" to C&C issuesA human error probability (HEP) was selected from range of HRA methods with similar issues 33A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Supp 1: C&C differences between Normal Operations and MCRA OperationsDuring in-MCR, Normal Operations (typical plant)During MCRA Operations (typical plant)Control room team, acting as a single centralized "cognitive entity"*Coordination with fire brigade and some plant area staffControl room team distributed in plant areas*Supervisor may be alone at RSDP, buttypically also has one RO*Coordination with fire brigade and plant areasShared visual cuesSingle views of plant information by individualsWell-rehearsed and tested plans and actions

  • Resources anticipated & available
  • Limited need for flexibility in response
  • Recognition

-primed decision

-makingMCRA phase III is one of the most frequently exercised fire PRA scenarios, however it is not sure if C&C is exercised. The concern is that C&C portions of the plans and actions occasionally rehearsed, rarely tested (but this is plantdependent).*Some resources anticipated & available but complete range untested*Potential need for flexibility in responseCommunications (mostly) face

-to-face, voiceCommunications mostly audio via radios, phones;so few confirmatory indications such as annunciators & alarmsRestricted interruptions during response periodUnknown potential for interruptions 34A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Phase III: Expert Input on Key Issues/Concerns for C

&CBecause of how the MCRA safe shutdown strategy is implemented, C&C is different for MCRA operations, such as:

-While the role of shift supervisor (SS) or shift manager (SM) who has the primary responsibility for C&C in main control room (MCR) is the same following MCRA, the capabilities for indications and controls at the remote shutdown panel (RSDP) are different

-Communications are different, and impacts time required for response-Most likely no alarms, and few indications at the RSDP so need to closely monitor parameters and may be more susceptible to distractions

-Coordination of actions may be required & is complicated by operators being in different locations & any associated communications issuesFocus on C&C failures to coordinate actions, especially irreversible damage 35A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Changes in Role of Supervisor and CommunicationsRole of SS/SM in MCRA operationsSS/SM continues to drive operations but for most actions cannot directly observe the action

-Monitors some actions, and coordinates some actionsOperators have different rolesAllocation of resources mostly done via assignments of various procedure attachments to operator (ROs & field operators)Communications are different for MCRA operationsTypically NOT face

-to-faceMay be only "reports" that actions are completedCommunications equipment & associated problems can be a concern 36A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Phase III: Screening Rules for When to Model a C&C FailureScreening StepDescription of Screening StepIf 'No'If 'Yes'1.C&C coordination is required for placing equipment into service, e.g., successful pump operation requires adequate suction head from supporting equipment/system.Screened from considerationGo to screening step 2.2.Failure to properly sequence operator actions for placing equipment into service would result in an irreversible failure of the equipment, such as either condition below leading to SSC failure within 15 minutes or less.Screened from considerationGo to screening step 3. 3.Operators can not immediately detect improper functioning of equipment (in order to immediately shut down equipment), due to, for example, i. A lack of local indications (including a lack of equipment or flow noises that are recognizable from training or experience); orii. The field operator moving to a different location without checking for proper functioningScreened from considerationGo to screening step 4.

37A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Phase III: Screening Rules for When to Model a C&C FailureScreening StepDescription of Screening StepIf 'No'If 'Yes'4.Supervisor in C&C role has responsibility for all (or the bulk) of communications to/from field operators, e.g., i. No one else is providing significant help to take or make calls to field operators implementing MCRA safe shutdown strategy and call from other plant staff (e.g., fire brigade, health physics), or ii. C&C is NOT solely (or mostly) focused on the communications associated with the equipment of concern and its supporting equipment/systems such as due to lack of help from other staff in taking/making these communications. iii. Communications are "segregated" such that supervisor and multiple field operators whose actions must be coordinated are NOT on a common loop such that all parties hear all communications (e.g., operator controlling cooling water to a pump does not hear the command to start the front-line system pump and therefore cannot alert the supervisor that there is no cooling water in service).Screened from considerationGo to screening step 4.

38A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Phase III: Screening Rules for When to Model a C&C FailureScreening StepDescription of Screening StepIf 'No'If 'Yes'5.There are NO compensatory measures to assist the supervisor with coordination. Example cases where compensatory measures are NOT present are

i. The MCRA procedure does NOT include a written step, or Hold Point, or Warning (Caution) that prerequisite SSC alignment is needed prior to operation. For example, if an MCRA procedure includes a caution about putting in supporting equipment/system into service before putting into service the equipment in question. ii. The MCRA procedure does NOT include place

-keeping aids such that the supervisor can record when support systems are in service, allowing the start of front

-line systems.Screened from considerationInclude C&C-related coordination failure.

39A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Phase III: HEP to Assign to C&C FailureIf screening rules result in "C&C failure should be modeled", then an HEP of 5E

-2 is recommendedBasis for HEP:

-Focused on sequencing failures and how they might occur

-Review of literature for other technologies turned our focus to "distractions" and "interruptions"Focused on "interruptions" as a good description of many types of communications that could compete for supervisor's attention

-Searchfor HRA methods that addressed similar issues:NUREG-2114 considers workload and multi

-taskingNUREG-2199 (IDHEAS at

-power) has workload decision tree that includes distractions/interruptionsNARA has a communications generic task type with error producing conditions such as information overloadTHERP, Table 20

-8 addresses errors in recalling oral communications

-Range of HEPs from these sources: 1E

-2 to 0.1 40A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Status and Future Work 41A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Current StatusSupplement 2, Quantitative HRA Guidance for MCRA scenarios:

-Draft report provided to ACRS PRA SC will be starting point for peer review -Peer Review:Scheduled to begin April 2018

-Final publication is planned for end of 2018 42A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921ClosingRemarks from EPRI and NRC/RES managementQuestions?

43A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921 44A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Supplement 2Backup Slides 45A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Phase I -Time Period Before Abandonment DecisionOperator actions directed from MCR, similar to other fire scenario-Tripping reactor

-Starting emergency diesel generator (EDG)

-Starting a system that failed to auto startQuantification guidance:

-Use NUREG-1921 to evaluate and quantify Phase I actions 46A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921ATHEANA expert elicitation process (NUREG

-1800) used in expert panelFacilitator guided feedback from experts (& controlled bias)Experts were already familiar with MCRA context & concept of probabilitiesImportant details of contexts were discussed:

-Decision to abandon on LOCDiscussed HRA team's list of key issuesConfirmed, clarified, & focused list of issues"Pruned" initial three decision trees => one decision tree with fewer branches

-Role of C&C after MCRA Discussed HRA team's candidate issuesConfirmed & focused issues (e.g., priority of C&C sequencing that results in catastrophic equipment failure)Facilitator guided experts through quantification process (decision to abandon only)-"Best case," "worst case," & intermediate case for each expert, then consensus reached-Pair-wise comparisons used to determine other branch points 47A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Supplement 1Backup Slides 48A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Qualitative Analysis(NUREG-1921 Supplement 1 / EPRI 3002009215)Provides foundational material required to support quantificationContent:-Mindset shift from internal events and fire HRA to MCRA HRA

-PRA modeling of MCRA scenarios

-Analysis of the decision to abandon

-Identification and definition of MCRA HFEs

-Feasibility assessment for MCRA scenarios

-Time and timelines for MCRA scenarios

-Performance shaping factors

-Recovery/dependency/uncertainty

-Appendices (Historical events review of MCRA scenarios, Command and control, and Guidance and tips for MCRA information collections) 49A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Qualitative AnalysisACRS Organizational CommentsPRA and HRA people should read everything, not just pertinent sections

-Removed Section 1.2, Intended Audience, which encouraged selective reading of material

-Toned down degree of interface between HRA/PRA throughoutAdd more in Appendix A about capabilities of RSDP

-Added new Section A.3, Alternative and Remote Shutdown Panel Variations 50A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Qualitative AnalysisACRS Reference CommentsReferences to IDHEAS (specifically Appendix B / PSF)

-Report acknowledges IDHEAS

-G in Section 2

-IDHEAS also referenced in Supplement 2 (both for decision to abandon and command and control)Discuss NUREG

-2114 influence on PSF / C&C

-More explicated references in Section 8 (PSF) & Appendix B (C&C) 51A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Qualitative AnalysisACRS Approach/Scope CommentsSISBO strategy should be addressed in the report

-ACRS version: SISBO not addressed

-Final: Added Section 3.5.6 Self-Induced Station Blackout (SISBO) and Other Recoverable Pre

-Emptive ActionsWhy is LOH fundamentally different from LOC?

-Greatly expanded on discussion on LOH (Section 4.1), including revisiting the technical basis

-Silent on discussion between too early and too late.

52A Collaboration of U.S. NRC Office of Nuclear Regulatory Research (RES) & Electric Power Research Institute (EPRI)ACRS PRA Subcommittee

-April 4, 2018Supplement 2, NUREG

-1921Qualitative AnalysisACRS Timing CommentsTiming-Time = 0 Clarified T=0 assumption in Section 2.4.3, General Assumptions

-Recovery actions called out in Phase III as separate items (10 minute recovery artificially constraining timeline)Removed recovery actions in timeline discussion

-Time uncertainty Time remains source of uncertaintyIn interviews generally look for a rangeUse point estimate in development of timelineIf key source of uncertainty, should do sensitivity study