ML19338C240
| ML19338C240 | |
| Person / Time | |
|---|---|
| Issue date: | 08/06/1980 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T, NUDOCS 8008140236 | |
| Download: ML19338C240 (53) | |
Text
NCCLEAR REGULATORY COMMISSION
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'o ADVISORY COS'MITTEE ON REACTOR SAFEGUARDS SUBCOS'ltITTEE CN SAFETY CRITERIA AND PHILOSOPHY t
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August 6, 1980
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1 UNITED STATES OF AMFBICA
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2 NUCLEAR REGULATORY COMMISSION 3
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5
SU3 COMMITTEE ON SAFETY CRITERIA AND PHILOSOPHY o
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7 Nuclear Regulatory Commission 8
Room 762 1717 H Street, N.W.
9 Washington, D. C.
10 Wednesday, August 6, 1980 11 ihe Subcommittee en Safety Philosophy and Criteria 12 met, pursuant te notice, at 1:05 p.s.
13 MEMBERS FRESENT:
14 DAVID OKPENT, Presiding 15 JESSIE EBERSOLE 16 DESIGNATED FEDERAL REPRESENTATIVE:
17 RICHARD SAVIO 18 ALSO PRESENT:
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MR. OKRENT:
The meeting will Tow come to order.
3 This is a reeting of the Advisory Committee on 4 Reactor Safeguards, Subcommittee on Safety Philosophy and 5 Criteria.
6 I as " avid Okrent, the Subcommittee Chairman.
The 7 other ACRS member present today is Mr. Jessie Ebersole.
8 The purpose of this meeting is to discuss the 9 development of requirements for near-term construction 10 plants, or NTCP plants and to hear a presentation by the NRC 11 Office of Policy Evaluation on proposed work plan for 12 developing safety goals.
13 The meeting is being conducted in accordance with b
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14 the provisions of the Federal Advisory Committee Act, the 15 go ve rnm en t and the Sunshine Act.
16 Dr. Richard Savio is the designated federal 17 employee for the meeting.
18 The rules for participation in today's meeting 19 have been announced as part of the notice for this meeting 20 previously published in th e Federal Register on July 22, 21 1980.
A transcript of the meeting is being kept and will be 22 made available as ',tated in the Federal Register notice.
23 It is requested tha t each speaker first identify 24 himself and speak with sufficient clarity and volume so that 25 he can be readily heard.
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We have received a written statement from offshore 2 power systems.
Copies of the statement have been 3 distributed to the subcommittee and will be included in the 4 record of the meeting.
5 We will now proceed with the meeting and I call 6 upon Mr. William Kane of the NRC staff.
7 MR. KANE:
Thank you, Professor Ckrent.
Do you 8 mind if I sit.
9 3R. OKRENT:
As you wish.
10 MR. KANE:
I would like to give a brief status 11 report of where we stand on this program.
12 First, I an with the Division of Licensing in the 13 Cffice of Nuclear Reactor Regulations.
I have been involved O
14 in this program since the outset.
15 As you know, on March 17th of this year an NRR 16 task force was formed to propose TMI related requirements l'7 for the near-term construction permit in manuf acturing 18 license applications.
We used the action plan as the basis 19 for this.
20 In March and April of this year we held meeting 21 with the near-tern construction permit applicants, of which I
- 22 th ere are six and the ML applicant.
23 On April 4th we developed our initial set of 24 proposed requirements.
As you may recall, we broke down the 25 action plan items into five ca tego ries.
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1 The first one was not applicable, things that just 2 were not applicable to CP plants for one of a number of 3 reasons.
4 The second category were areas where we felt that 5 the applicants could simply provide commitments to do 6 something in
'4e operating license stage.
7 Th e third category was areas where studies would 8 be developed even after the construction permits were issued 9 in order to make modifications that would be isplemented in 10 reviewing the operating license stage.
11 The fourth category were requirements where we 12 felt we may need some explanation of just how they were 13 going to go about meeting the action plan.
This would be a O
14 general level of information and not equivalent to that 15 which was normally provided at the construction permit stage.
16 Then the last category were those things that we 17 felt we had to have a full amount of detail on in order to 18 give the construction permit.
19 On April 9th we met with your TMI-2 Implication 20 Subcommittee and we received feedback on our proposal.
21 On April 22nd we made revisions to these 22 requirements.
Cne of the notable revisions I think was in a 23 reliability engineering area where we used a number of the 24 comments that you had made a t the meeting.
25 On May 2nd we met with the full co=mittee.
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1 that time the near-term construction permit applicants had 2 indicated they had a number of problems with our proposal 1
3 and had proposed to meet with your subcommittee again, I i
4 believe it was in June or July, to provide alternates to the 5 staff proposal.
As you will recall, they had engaged two 6 co ns ul tan ts to develop th ese proposals.
7 On Mar 6th you issued an AC3S letter in which you 8 indicated that you had developed a subcommittee to work with 9 the staff and with the applicants as these requirements were 10 to be developed.
11 On July 15th the manudacturing license applicant 12 submitted responses to the proposed requirements that we had 13 developed back in April.
I think you may have a copy of O'
14 that.
i5 On July 23rd we eventually issued a paper to the 16 Commission outlining our specific proposal.
Originally we 17 ' tad intended to go forward to them with the complete package 18 of information to get their approval.
This proposal was 19 modified in July.
20 Our approach now is to isstle our requirements for 21 review and comment by the public.
Af te r th e receipt of n public comments we would then go back to the Commission for 23 approval of the requirements for the construction permits 24 and for the manufactirt19 license application.
25 On August 1st of this year the Commission approved O
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400 VIRGINIA AVE. S.W., WASHINGTON, O.C. 20024 (202)554-2345
6 Oy 1 that staff proposal.
2 Now, as far as the future activities ara 3 concerned, probably next week we will issue a Federal 4 Register notice inviting comments on the proposed 5 requirements.
I believe you have a copy of the July 23rd 6 Commission paper and the Federal Register notice that we 7 plan to issue is Enclosure 4 I believe to that package.
8 Mh. OKRENT:
Yes.
I received that last nicht.
I 9 don't know when Dr. Savio got it.
I am not sure whether I 10 have or have not seen the applicant's submission in July 11 that you men tioned.
12 MR. KANE:
The applicant has not made a submittal 13 to us as of this date.
(m's) 14 MR. OKRIN T :
What was it you mentioned that he had 15 done in July?
16 MR. KANE:
Well, as you recall, at the ACRS 17 meeting, the f ull committee meeting, they told us tha t ther 18 had a problem with a number of areas, the principal one 19 being the degraded core cooling area and reliability 20 engineering.
I believe those were the two major ones.
Also 21 citing.
22 What they claimed to have done was to engage two 23 consultan ts, Saul Levy and Levine from NUS, to look into 24 developing proposals, alternate proposals to that which had 25 been developed by the staff in these areas.
These were to O)
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1 culminate, as I understood it, in reports which would be 2 submitted to the staff for review and to the ACES and then 3 vould be the subject of an ACES meeting to be held about a 4 month thereafter.
5 As I understand it, these reports have been 6 developed but they are still under review by the utilities 7 and I know of no immediate plans for them to submit those 8 reports.
9 MR. OKRENT:
I thought you said the:y had submitted 10 something commenting on your proposal.
Perhaps I 11 misunderstood what you said.
12 MR. KANE:
We held several meetings with the 13 applicants back in March and April at the time we were
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- 4e did receive some 15 feedback from them, but we have not received a package of 16 comments, formal comments or alternate proposals to the ones 17 developed by us.
18 tR. OKRENT:
When you talk about a package of l
19 requirements, or wha tever it is, from the s+.aff, this 20 proposal as described in SECY 83-ua, this is not identical l
,21 with what you were talking about in March and April, is it?
ZZ 3R. KANEs No, it is not.
23 The Federal Register notice vill indicate that i
24 there is a NUREG document 0718 which outlines in more 1
25 detail, or in complete detail our pro posal.
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1 reports, how the requirements were de veloped and will 2 include each of the action plan items and assicn a specific 3 category to it, as I mentioned, the 1 through 5.
4 Then there will be a supplemental description for 5 each of the action plan items that require the delivery of 6 intsraation to us other than a commitment to explain exactly 7 what is required to be submitted and the level of detail 8 associated with that submittal.
This NUREG document will be 9 published next week similtaneously with the issuance of the 10 Federal Register notice.
11 The next activity that we think is important is we 12 would like to meet again with the ACRS, with your 13 subcommittee and eventually with the full commits e parallel 14 with the public comment period which is u5 days to receive 15 th e ACRS feedback from your teview of these requirements.
16 Finally in October we would expect to consider all l'7 of the comments, in cludin g those of ACRS, and make any 18 revisions to the requirements that need to be made, meet 19 with the Commission perhaps the same month, or November, 20 with a November 1980 being a likely date for Commission 21 approval of the requirements.
22 That is where we have been and wha t we plan to do.
23 MR. OKRENT:
Is there some reason why this was 24 brought up to the Commission the week before the ACRS 25 meeting instead of the week after?
I as just sert of i
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1 curious.
2 ER. KANE:
It just happened to work out that way.
3 This proposal had been in the mill since af ter we met with 4 ACRS.
It was changed slightly in July.
It was expedited as 5 best we could, and it just happened to come out on the 23rd 6 of July.
We had met with the committee, both your 7 subcommittee and with the full committee, and we had 8 received some feedback from you.
~4e had indicated at that 9 meeting that our next step was to go to the Commission with 10 this proposal and to get their reaction to it.
11 As I said, tae proposal had been changed from 12 rather than going to the Commission for their approval of 13 these requirements to go to the Commission and request their O
14 approval to issue these requirements for public corment.
15 MR. OKRINT:
My recollection of the proposal that 16 you have discussed with the ACRS subcommittee and full 17 committee back in April or May, whichever it was, was that 18 it didn't deal with any of what were called the policy 19 questions like reliability engineering or degraded : ore 20 cooling.
Is ny memory wrong?
~ 21 MR. KANE:
I believe it did.
I believe.:h e 22 question was whether the policy that we had developed was 23 ronristent w ith your own views.
~4 ell, with the exception of 24 reliability engineering.
I think I indicated at the outset 3 that as a result of our April meeting with your subcommittee x
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10 1 we h ad indicated to that subcomnittee that based on your 2 comments that we felt that the action plan should require, 3 or that we should require of the construction permit 4 applicants an e.vnansion of the work in the reliability 5 engineering area.
So we have modified our requirements to 6 hopef ully sa tisf y the comments that you made at that meeting.
7 Now, as you recall, on degraded core, we had 8 talked in terms of asking the applicants to demonstra te 9 before they got a construction permit that they could do 10 certain t: tings in the area of hydrogen control, in the area 11 of melted cores and the filtered containment venting.
That 12 was in the proposal I think which Harold Denton discussed 4
13 with you at the full committee meeting.
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.ow, in the Commission paper you will find those 15 two areas addressed directly.
They were discussed with the 16 Co m m issio n.
'4 e have specific proposals that we are making 1'7 in those two areas and tha t we are asking for public 18 comments on.
19 MR. OKRENT:
I guess my memory must be faulty.
I 20 will have to try to refresh it by looking at the minutes and 21 some of the other things.
I didn't think you were proposing 22 then to do more than to apply the action plan like you were 23 doing it for NTCLs.
I agree these items are in the action 24 plan, but they are in in a very general way.
My mencry is 25 probably wrong.
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1 MR. KANE:
let me correct what may be a 2 misimpression.
We are not applying the action plan in the 3 same way as we are doing for the near-team.
We are using 4 the action plan as the basis for establishing requirements 5 f or construction permit applicants.
In some cases an action 6 plan may sim ply defer staf f activity for some time, like 7 fiscal
'82.
In many of those instances we have actually 8 developed requirements based on the action plan to apply to 9 construction permit applicants to get some work done in 10 parallel with the staff 's activities.
That is what will be 11 described in this NUREG document that we will be issuing 12 next week.
13 MR. OKRENT:
What would you propose then from your 14 poin t of view as a good schedule for AC?S review?
15 MR. KANE:
Speaking only for the staff proposal 16 and not for the applicants?
1:7 MR. OKRENT:
Yes.
18 MR. KANE:
The NUREG document will be out at the 19 latest the middle of this month.
That would be in parallel 20 wi th the Fed eral Register no tice.
Now, th e Federal Register 21 notice calls for public comments with in 35 days of issuance 22 of that notice which would mean th a t all th e public comments 23 would be back in about October 1st.
24 It would seem to me that a subcommittee meeting in 25 la te September or early Cctober followed by a full committee ALDERSON REPORTING COMPANY, INC.
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'J e would th en take 2 the next month essentially to factor in all of the comments 3 received from the public, 'ncluding your own, and then 4 revise our proposal with r,ommission approval in November.
5 MR. OKRENT:
- 4ould we have :eceived the c omments 6 from the public by the beginning of October?
7 3R. KANE:
We can certainly make them available to 8 you.
I think there will be sort of's schedule problem 9 because I think most of the comments will be coming in 10 toward th'e end cf the comment period.
You may not have them 11 all, but we can certainly make available to you all that we 12 have at that poin t in time.
13 ER. OKRENT:
Do you know in fact what the date of 14 th e Federal Register notice is what the 45 -d a y 15 MR. KANEs No, I do not.
16 XR. OKRENT:- You don't know.
All right.
Maybe we l'7 better keep a little bit tentative on that since it may 18 relevant for the committee' as well as the staff to know what 19 th e public, including the JTCP utilities, and others have to 20 say.
We can ask Dr. Savio to try to keep ab reast as to what 21 are the actual timing points for different things to occur 22 and, if necesssey, then shif t a mon th o r whatever.
23 MR. KANEs Yes.
It may turn out that a November 24 ACRS would be appropriate.
25 MR. OKRENT It may be.
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1 In connection with trying to schedule this 2 meeting, we have been a little bit frustrated because we had 3 first thought we might have the NTCP utilities tell us what 4 they thought, but that is something they are not ready to do.
5 I thought we weren't going to.have anything f r'o m 6 the staff, that all they were going to tell us sort of was 7 something similar to what we hea rd in April.
In fact, that 8 is different.
You have represented us with something you 9 have already sent to the Commission which outlines the 10 position.
11 Than I asked if we could hear from appropriate 12 personnel and the staff concerning what you might call how 13 they are developing a philosophical approach to this kind of O
14 qu es tio n, to design Indian Point review, to future 15 construction permits. and I was told people weren't 16 available for that.
17 So it has been a little bit confusing situation.
18 I will put it that way.
I hope that we can have appropriate 19 discussions at f uture subcommittee meetings and that the 20 staff, if necessary, cancels other activities if that is 21 what it takes.
Z2 Could I ask one or two specific questions.
23 MR. KANE.
Sure.
24 MR. OKRENT:
I haven't had much time to look at 25 the SECY 23-57 or the SECY 83-ca.
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1 regard to degraded core cooling on page 3 it says "C7 and 31 2 applicants should describe the degree to which their designs 3 conform to the proposed interim rule."
4 Now, could you tell me which proposed interim rule 5 do you mean?
6 MR. KANE4 The one that is to be issued shortly.
7 I am told perhaps next week.
8 MR. OKRENT4 Do we know what is in it?
9 MR. KANEs Well, it is still being modified.
As 10 of this week I as told tha t. it will be issued next week.
I 11 think the nature of the interim rule war to put into effect 12 many of the requirements that had already been imposed on 13 operating plants that are described in the action plan.
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14 addition, to address the inerting question for the Mark I 15 and II and ice condenser plants and airo the Mark III plant.
16 MR. OKRENT:
But so far I haven't seen anything in 17 previous documents, issued docunents by the staff that 18 discusses more than Mark I's and II's.
So if there is some 19 other document would you tell me what it is?
20 M3. KANE:
When it is issued it will be called the
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21 proposed
-- it is a Commission paper and the subject will 22 be proposed interi amendments to 10 CF3 part 50 relating to l
23 hydrogen control and certain degraded core considerations.
24 It will address the Mark I and II plants, it will address 25 th e ice condenser plants and it will also address the Mark l
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Well, in f act, all containers.
2 ME. OKRENT:
When you say address, the staff had 3 some specific recessenda tions previously for Mark I's and 4 II's.
Does it have some specific positions on ice 5 condensers or Yark III?
6 M3. KANE:
Yes, it does.
7 3R. OKRENT:
That are different than what was 8 accepted in the past?
9 MR. KANE:
The current version I as looking at 10 calls for inerting the Mark I and II and for not inerting 11 the ice condenser plant and for doing studies by a date 12 certain on the Mark III plant.
I caution you that is what I 13 as reading in the current draft.
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14 MR. CK3ENT:
Fair enough.
15 Now, it says, again on page 3,
" Applicant should 16 also provide reasonable assurance to the extent practicable 17 and take into account the present state of the art of this 18 technology that issuance of CP 's and ML's will ot foreclose 19 or preclude the modification facilities to accommodate 20 po ten tial requiremen ts tha t may result from the rule-making 21 proceedings.
These potential requirements include such 22 features as filter vent containment and molten core 23 re tention and hydrogen con trol systems."
24 Then it goes on to say " Prior to issuance of a CP 25 or ZL applicants vill also be required to submit their O)
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<-( >n 1 evaluation of the additional features both preventative and 2 mitigative they propose to include at their facilities that 3 have the potential f or significant risk reduction."
4 I don't understand th a t statement because an 5 applicant could come in and say "Well, we don't propose to 6 include anything additional," and I think th ey would then 7 have met this statement.
Was that your interpretation?
8 MR. KANE:
Well, that is not an acceptable 9 response.
10 MR. OKEENT4 Well, what would constitute an 11 acceptable response?
12 MR. KANE:
That is a little bit difficult to 13 answer, but let me tell you what is involved.
One of the O
14 problems that the applicants have proposed to us is the 15 problem of the melted core and the whole idea of the core 16 catcher or whatever to handle a melted core.
17 They have proposed to us that they would like to 18 have available as an option the possibility of doing studies 19 to show that they can reduce the probability of core melt by 20 a factor of something, whatever that may be.
They would 21 like to have tha t option available to them up front if they 22 can demonstrate to us that they have made a significant 23 improvement in the plan as an alternative to making a design 2'
accommodation for a core ladle.
We haven't as yet put any 25 numhers on what that might be, for example, a factor of 10.
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1 If he could demonstrate a factor of 10 that might be an 2 acceptable alternative, but we really haven't settled on any 3 numbers at this point.
4 5R. OKRENT:
You know, at first reading one could S get the impression tney were asking for something specific, 6 but on a second reading it is a very carefully werded thing 7 that doesn't ask for anything specifically.
8 MR. KANE:
The original proposal was as described 9 above.
It was to show us how the design had the inherent 10 flexibility to handle these possible requirements that may 11 call out a rule-making.
That was the original proposal, but 12 we have in it left the flexibility for applicants who can 13 demonstrate a substantial improvement to their ;1 ant.
It 14 actually foreclosos some of these possible desicas.
15 MR. E3ERSOLE:
3r. Kane.
4 16 MR. KANE:
Yes.
17 MR. EBERSCLE4 Did the applicant in attempting to 18 do this attempt to sidestep the hydrogen generation problem 19 by decla ring he is not going to let the core melt?
20 MR. KANE:
That is the main problem.,
21 MR. ERERSOLE:
That is his main objective, I take 22 it.
Th a t is righ t.
24 MR. E3ERSCLE:
There is another phase of this, I 25 think, and that is consider a melted core from the primary k
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v 1 loop but ~ congealing it with a water cooling system within 2 the containment so you don't have a containment penetration 3 problem.
But that leaves the residual of the h yd rog e n 4 generation and the consequence of the.t.
Have the applicants 5 taken tha t view as a possible route?
6 MR. KANE:
Well, as I say, we haven't received the 7 specific proposal yet outlining exactly what they want to 8 do.
As I understand it, their studies have shown that they 9 are willing to make specific changes to provide 10 accommodation to handle the hydrogen and to provide 11 accommodation for the filter venting containment.
The 12 primary problem seems to be with the incorporation of a core 13 ladle or core catcher.
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14 MR. EEEBSGlE.
I should have thought hydrogen 15 would have been also a major problem as a by-product of the 16 core melt.
17 MR. OKRENT:
You do have a subject called the 18 liability en g ine erin g.
I had assumed tha t the thrust of 19 that section was to see whether there were steps that they 20 could tak e that would redace the probability of serious 21 damage to the core and that that was covered under item 3.
22 I didn't realize that it was covered under item 2.
23 MR. KANE It wasn't when you saw the proposal 24 befo re.
It is now.
Under reliability engineering I think 25 we have gene at that in a different way.
As you will I
ALDERSCN REPORTING COMPANY, INC.
400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202)554-2345
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2 MR. OKRENT:
'4 h a t I am getting at is if I just 3 read what you have written under item 2 under the heading 4 " Degraded Core Rulemaking" I would have assumed you were 5 only talking about things that related to degraded cores.
6 It is a little bit awkward to have to ask questions to find 7 out what an important sentence means.
8 MR. EBERSOLE:
I thought that was all mitigative.
9 MR. OKRENT:
So did I.
10 MR. ERERSOLEt In going down to item 3, liability
~11 engineering, I thought that had embodied all of the terrible 12 packaging in 660 in this assorted list of nuts and bolts and 13 major considerations and picture studies and physical 14 experimentation that is enclosure two.
15 I have great difficulty, by the way, in 16 packaging enclosure 2 into any reasonable integral I'7 packages.
In thinking to do I have to look at the bulk of 18 it as coming under liability engineering if it involves 19 enginering improvements to, for instance, reduce the 20 potential for core melt.
You will notice in those four 21 items there is no engineering improvements at all anywhere 22 in the prevent context unless it is in item 3.
I mean, it 23 is a by product of doing their liability engineering study, 24 isn't it?
Gr it would be a by-product if the study doesn't 25 come out well.
AL.DERSON REPORTING COMPANY, INC.
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1 MR. KANEs Let's see how I can repackage this.
2 Degraded core rule-making relates to a specific action plan 3 item.
4 MR. EPORSOLEs Well, it is presumptive of having a 5 degraded core to begin with.
6 MR. KANCs That is rig h t.
The whole thrust of 7 degraded core rule-making I believe in the action plan, as 8 you say, is sitigative.
9 MR. EBERSOLEs Yes.
10 MR. KANE:
What I am saying is that for the 11 construction permit applicants there is an option available 12 to them to satisfy that action plan for now.
For gaining 13 the CP they may develop a combination of preventive 14 mitigative fixes that would be acceptable to us.
15 MR. EEERSOLEs Well, if they have to go so far as 16 to put mitigative features in for a melted core they have 17 gone pretty far.
18 MR. KANEs Well, I guess that is the point.
They 19 do not want to put in mitiga tive f eatures f or a melted 20 core.
They want to go at that standpoint preventively.-
21 MR. ESERSOLEs W ell, is the basis for their 22 argument not to have to do this going to be under item 3, Zi liability engineering, and the things they are going to do 24 is an outgrow th of that?
25 MR. KANEs No.
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400 VIRGINIA AVE. S.W., WASHINGTON. 0.C. 20024 (202) 554-2345
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1 all the things in item 3.
2 MR. IBERSOLE:
That confuses me.
I thought that 3 was all mitigative.
4 MS. KANE:
It is.
5 MR. EBERSOLE:
Item 3 begins with a degraded core.
6 MR. KANEs Two and three are tied together, but I 7 think you could do item 3 without doing an integrated 8 probabilistic study.
'4 hen you go to satisfy the last 9 paragraph of item 2 I think you have to be able to 10 demonstrate tha t you have identified all of the dominate 11 sequences, that you are in fact making these preventive and 12 mitigative fixes and that you are achieving a certain 13 reduction in core melt probability.
O 14 MR. ESERSOLE:
Let me see if I can understand 15 better.
As I look at these four major topics, one is citing 16 an d we can part that.
Degraded core rulemaking is 17 presumptive of a degraded core and we have failed in our 18 mission to prevent it.
Liability engineering is a whole 19 host of studies that embody virtually all of this 20 complicated and detailed list from soup to nuts over here.
21 MR. OKRENT:
Some of which are intended to prevent 22 an accident from occuring and some of which are intended to 23 prevent the accident from leading to a degraded core.
24 MR. EBERSOLE:
Right.
If I take all that I have 25 to look at item 3 as having embodied all the thing s i
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22 1 associated with this vast list of little hits and pieces 2 right to whole philosophies.
This is a very random list.
3 It has no unified cha racteriration at all.
It jumps from 4 product ease to major installations in a very random 5 pattern.
6 I wish somebody would sit down and creak it up 7 into cohesive packages that we could talk about.sther than 8 vonder whether one minute piece of it is embodied in a major 9 topic somewhere else in tha t sane list.
You can't tell what 10 it is.
It is impossible to read that list and read it in 11 any integrated sense because I can take any one of a dozen 12 general topics and imagine that another dozen details are 13 embodied within those.
O v
14 MR. KANE:
Well, I think that is part of the way 15 we approached this.
We used the action plan.-
These are all 16 items taken from the action plan.
17 MR. ERERSOLE:
Well, that was the character of the 18 action plan which is still a problem.
19 3R. KANE:
That is right.
i 20 3R. CKRENT:
In connection with item 3 on page 3 21 of your SECY 83-48 after going through this listing of 22 various systems on which liability anaysis should be 23 performed it says "CP and 3L applicant should provide 24 sufficient information to describe the nature of the 25 studies, how they are to be conducted, the completion dates b) t ALCERSCN PEPORTING CCMPANY. INC.
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3 Could you tell me what it is that the staff thinks 4 is the right timing in construction f or completion of such 5 studies and what the staff things are the criteria by which 6 these applicants should decide whether or not changes should 7 he made af ter they have done such studies.'
8 MR. KANE:
Well, I think what we are asking for is 9 sicilar to what we did in the auxiliary feedwater system 10 liability studies.
We are asking them to use these 11 techniques that were used in the AFW studies, to go back and 12 see if they can't make improvements that will take into 13 account the potential for human error problems, common g-
'uj 1-4 causes, single-poin't vulnerabilities in a way of upgrading 15 the systems.,
16 I know that in fact we have on the operating 17 plants using these techniques uncovered sany areas that have 18 enhanced the overall reliability of the auxilia ry f eedwater 19 system.
I think we are doing that now on the operating 20 license applications and I think the thrust of this activity 21 should be to look a t other systems in the same way that we 22 looked at the auxiliary feedvater system.
23 MR. OKRENT4 Now, when a plan t is built or neaqly 24 built your flexibility to make changes without major
.i 3 distruption is clearly much less than f or a plant that may (O
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24 1 have been designed but for which there is actually no 2 construction.
3 Ace you proposing to have the same criteria sed 4 in deciding whether or not a change should be made for NTCPs 5 as you are for operating plants, or that there should be 6 some modified criterion of j udgment and, if so, what?
7 MR. KANEs I think it would be a modified 8 judgment.
I think there is more flexibility.
Obviously 9 there is more flexibility in the construction permit 10 application.
I think these studies could be undertaken and 11 completed, not necessarily before the CP, we are not asking 12 th a t tha t be done, but the thrust of this sa ying what can 13 you do, how soon can you do it, and can you do it in c way 14 th a t you can make changes to that system and you won't 15 impact the overall schedule?
16 MR. OKRENT:
I don't know what the term " impact 17 the overall schedule" mean these days and in what context 18 the NRC thinks it should be factored into this decision.
I 19 see many things impact the overall schedule for plants.
I 20 see plants in the middle of construction delayed for one, 21 two or th ree years and so forth.
I see plants delayed for 22 longer periods after they have cps and so forth.
23 How does the NRC factor this question of impacting 24 the schedule into its decision-making?
25 ER. KANE:
Perhaps I misspoke.
We want th e O
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1 studies done, all of these studies.
We want all these 2 systems examined and we want them examined early.
It is up 3 to the utility to get the studies done and to show us hov 4 these changes can be made and f actored into the final design 5 of the plant.
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6 We are not suggesting that you show us a 7 completion date which is here and a study which will take 8 this long and say, well, you can't complete the study in 9 time so we are not going to do that one.
We are not 10 suggesting that that is a way out.
11 MR. OKRENT:
I have no idea from reading this what 12 kind of a timing in f act you think is the proper one, and of 13 course I don 't know whe ther that timing can be met.
I can't 14 tell from this, if I were the utility, what level of 15 reliability or safety or whatever it is you think ther 16 should be looking for.
Should they still stay with the 17 single single-failure criterion?
If not, in what way should 18 th ey deviate f cm it?
Should they look at what the Germans 19 require and consider whether they should do that on their 20 plan ts even if they have already exanined it and don't find 21 any obvious weak points?
What is it that is the measure at ZZ least of good enough if you can do it?
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1 larger and it would be completely different, or something, 2 and they may be able to convince you.
3 Eight now it seems to me ill-defined unless one 4 just says, well, we will do whatever we were going ta do on 5 the operating plans which I thought you said was not what 6 the in tent is.
7 MB. KANEs
'de are not doing this on the operating 8 plans.
Again, our criteria reliability goals are not 9 established, no more than they were for the auxiliary 10 feedwater system on an individual system.
11
- 33. OK3ENT:
~4 ha t I am trying to do is indicate 12 some areas that I hope when ve have a subcommittee meeting 13 the staff will be prepared to present further thoughts on f-(
14 the matter.
Let me put it that way.
Also I hope that all 15 of the NTCP utilities vill also be prepared to present their 16 individual thoughts since they may not have a single thought l'7 because I think that would be useful.
Then hopefully those 18 other people wh'o have either previously or at that time 19 proposed tha t they would like to would comment on the thing.
20 Let ma just make one other brief note.
At the 21 last subcommittee meeting we talked about some items that 22 sight conceivably relate to NTCP plants like single-failure 23 criteria and so forth.
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7-Nod 1 through soma specific items.
I don 't know whether we should 2 consider that necessarily a complete list, but they were 3 indicative of some kinds of things that one migh t at least 4 think about which are perhaps partly covered by your 5 liability engineering but not necessarily the same.
6 I would think if it is not mentioned there, it 7 would be relevant to hear what the seismic design basis is, 8 what is thought to be the seismic contribution to risk f rom 9 these plants, how well it is known, if they are less than 10 0.2G, for example, is there merit in considering at this 11 stage a change, and this sort of thing.
12 We vill try to schedule the subcommittee at an 13 appropriate tine, and please keep Dr. Favio posted on your 3
J 1<4 best estimate of timing so we can not delay things 15 unnecessarily.
In other words, if we can fit it in in the 16 right way ve vill try very much.
I'7 5R. KANE Well, I think the issuance of the 18 Federal Register notice vill be the event that trigger the 19 remaining schedule.
20 MR. OKEENT:
I hope the JTCP people vill tell us 21 What their consultants recommended and wh ether they agree 22 with their consultants or not.
I enink we would be 1
23 interested in learning what were their recommendations or 24 suggestions or what-have-you since these are certainly 25 experienced people in the business that they hired as (v3 ALDERSON REPCRTING COMPANY, INC.
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1 consultants and we vould like to have the benefit of their 2 thinking.
3 MR. KANE:
'4e also would he interested.
4 HR. CKRENT:
Anything thing else you want to pull 5 out?
6 MR. E3ERSOLE:
You say you have not yet developed 7 criteria for tability of such things as auxiliary feedvater 8 systems, et ceters.
It is typical of the industry to trail 9 the regulatory process and then scream to high heaven when 10 they are caught and have delays which cost them untold 11 millions, or rather cost their customers, I should sore 12 accurately say, for picking up behind a regulatory 13 requirement.
O 14 Do you see any evidence that industry in fact is 15 going to take some substantive leads to improve or advance 16 themselves improvements in plants not now required by the 1'7 regulatery process?
18 MR. KANE4 I have not seen any evidence of that.
19
- 33. ESERSOLEs In short, you do not see any 20 outward evidence that they are going to make some offerings 21 of significant improvements in their liability engineering 22 or anything else.
They are still going to go through the 23 trailing process as they always have.
24 HR. KANE:
I had thought th a t these two studies 3 may make some proposals in that area.
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1 MR. EBERSOLEs As long as they maintain themselves 2 in a trailing cosition then they are always going to have l
3 incremental costs due to regulatory improvements.
l 4
MR. KANE:
That is correct.
5 MR. EPERSOLE:
They could save millions by leading 6 but the tendency is never to do that.
I had thought perhaps 7 the new era would be that they would advance some new 8 criteria for safety and engineering inprovements, among 9 those including such things as integral shutdown systems, 10 et cetera, those things whAch are ahead of the mitigative 11 process of core ladies.
12 3R OKRENT:
I think we would be interested in 13 hearing f rom the staff as well as the utilities what they
(
14 think about, for example, dedicated shutdown heat removal 15 systems or some of the German redundancy requirements, and 16 so f orth.
In other words, it would be, I think, helpful to 17 have some of these specific items discussed.
Also how they 18 expect to address this really complicated question of 19 non-safety systems and control systems and their eff ect on 20 saf ety and is the current situation and design okay.
21 Well, I think we are behind the cchedule by quite 22 a bi t.
We had better go on to the next iten unless there 23 are any other things now.
If we have time later we can come 1
24 b a ck.
25 I think next is Mr. Sege who will talk about their O
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1 proposed work plan for developing quantitative safety 2 criteria.
3 Thank you.
4 MR. KANEs Do you want me to stay here?
5 MR. OKRENT:
It is up to you I think.
It is not 6 necessary.
7 You have the floor, Mr. Sege.
8 (Slide) 9 MR. SEGE:
Th5nk you, Mr. Chairman.
10 The Commission has, as you know, request?d CPE and 11 CGC to prepare for the Commission's censideration a plan f or 12 developing a policy statement of what constitutes adequate 13 safety.
More generally it would be sort of safety goals the 144 Commission wishes to pursue.
That plan is due in a couple 15 of days.
16 The next phase of it is, by Commission request, a' 17 preliminary safety policy statement for Commission 18 consideration and public comment.
It will be due to the 19 Commission in December.
20 The prepartion of that draft statement has been 21 assigned to CPE to develop in conjunction with the a
n utiliration of inputs from the various other staff 23 activities as well as the ACRS advice which is expected to 24 be received in October.
25 The status of the plan itself is that it is in a
. ~N draf t stage.
It is in the process of internal review,
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k-1 particularly within CGC and CPE and we expect to put it to 2 bed in a couple of days.
3 The proposed objectives cad scope of the plan are 4 to develop an explicit articulation of policy with respect 5 to fundamental issues of public health and safety and
~6 whatever protection the Commission believes is adequate.
7 In terms of scope, we expect that the articulation 8 to be developed will include some general approach to 9 Commission acce ptability and some policy statement 10 concerning safety cost tradeoffs, and, to the extent that it 11 is practical, to articulate these quantitative saf ety goals 12 statements with respect to cafety improvement goals and I 13 think we would almost certainly expect to include some sort fSO 14 of standard for review of past actions in single item new 15 rules and improved practices.
The work is going to 16 concentrate primarily on reactors, although not exclusively.
17 (Slida) 18 The me thod of approach that we are proposing means 19 that in the course of review of the paper there may well be 20 changes in what I am reporting now.
We would, however, i'
- 21 appreciate any thoughts that the subcommittee might care to 22 share with us concerning the general structure of the plan, 23 no t the specific details but the general structure itself 24 (inaudible).
25 The emphases of the method of approach are to (s) utilire the results of other activities which have been i
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1 ongoing for some time.
That of course no table includes the 2 ACES advice expected within two months.
3 Then we vill take into account the viewpoints of 4 groups with an irtarest at stake and considered views of 5 groups such as AIF, EPRI, others in industry, critics of the 6 nuclear industry and others.
7 Then the performance of background and studies.
8 That would, to a quite limited extent, add to and round out 9 where necessary the work that is already in progress 10 pa rticula rly with respect to past practices of hP.C and its 11 predecessor agency, practices of other agencies, approaches 12 to safety goals in other industrial countries and theories 13 and facts of risk acceptance.
I's V) 14 We expect to have workshers for discussion among 15 invited knowledgeable ;ersons of various viewpoints and from 16 the standpoint of the various disciplines that ate germane 17 to the subject.
18
'4e expect to have a vigorous solicitation and 19 consideration of public comments at various stages of the 20 process.
21 As I sentioned, we plan to submit a preliminary 22 staf f paper for Tozmission consideration in December to be 23 followed by a second staff paper which the plan schedules 24 for August.
There will of course be inter =ediate 25 milestones, b ut this series of two papers is the series of
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2 In terms of dyna:ics of the project, we plan to 3 develop a broad range of approaches that have been developed 4 and suggested and tha t have significant advocacies.
- First, 5 without trying to narrow down too early, but by December we 6 expect to have gone a long way in a narrowing process to 7 help identif y for the Commission a small number of options 8 th a t reasonably represent the range of alternatives 9 presented.
10 Our program plan involves opportunities at va riou s 11 stages for Commission guidance as the work progresses.
12 MR. OK3ENT:
If you could leave that on for a 13 minute.
uow do you have.in mind soliciting comments from O
14 nuclear critic groups, that is your item 2, and also I guess 15 what I would call chird party groups?
16 MR. SEGE Maybe the best way to answer that would 17 be for me to take the schedule and chart out of order and 18 talk about
-hedule first and show you various places where 19 that sort of situation occurs.
20 MR. OKRENT4 Do it in however way you were 21 planning, but if you could pick that up and also indicate 22 where you would try to get Congressional input if you were Z) going to.
24 ME. SEGE:
Certainly.
Maybe I should cover the 25 task descriptions first and then get to that point and then tO V
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1 wc will keep the order in which the handouts have presented 2 the information.
3 MR. OKRENT Fine.
4 (Slide) 5 MR. SEGE:
The principal tasks of the program are 6 listed on this slide.
I listed the liaison activity first 7 because of the significance that we attribute to the work 8 that is already in progress.
A number of the additional 9 studies will make only limited ad.iitions to it.
I don't 10 vant to develop that because the subcommittee is well 11 familiar with the various activity in progress.
12 Then we planned a series of background studies in 13 the five categories listed.
O 14
~4ith respect to the statutes and practices with 15 respect to th se statutes there has been an analysis 16 prepared by t e general counsel's office who was principally I'7 responsible i sr tha t paper last October tha t analyzes vhat 18 the lav requares and how that requirement has been 19 interpreted in regulations and decisions in the past by N3C 20 and its predecessor agencies.
Of course, as we are all 21 aware, the law is not definitive enough to satisfy the 22 present Comr ission, but definitive enough without f urth e r 23 articulation by the Commission.
That is not the basis for i
24 for the actions that th e Commission has now set in sotion in 25 this regard.
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We plan to do some more in that area.
We expect 2 to have an hinterian look over what interpretation has been 3 given to the safety goals, how the safety goals hava been 4 applied and how that interpretation has developed over the 5 decades of nuclear regulation.
6 MR. OKRENTs If I can offer a comment there.
If 7 he is going to look at history it might be interesting for 8 him to look at what the staff's thinkinc was at the 9 beginning of the 1970's concerning the probability of a 10 serious accident and what their thinking is at the end of 11 the 1970's and count the orders of magnitude.
12 MR. SEGE.
Th e ne x t ta sk tha t I ha ve listed there 13 is a very brief review of the statutes and practices of
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1<4 other agencies such as the production reactors and 15 (inaudible) parts of DOE, NASA, the Food and Drug 16 Administration, EPA, the Consumer Products Safety 17 Commission, FAA and perhaps one or two others.
It vill be a 18 matter of selecting a limited number of agencies whose 19 statutes and practices may perhaps hold some lessen for us 20 to make a brief study and try to discern to what extent we 21 can learn from them, if at all.
22 MR. ENGERSOLE:
May I ask, where in there, if any 23 place, is there a study of the relative risks in electrical 24 energy generation and the association with the need for 25 th a t ?
Is it included in that batch some place?
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- 33. SEGE:
Yes.
We have that covered in item "B"
s 2 I will come to it in just a fev moments.
3 MR. OKRENT:
Excuse me.
Under item B I would 4 encourage you to try to figure out EPA's practices, what is 5 the magnitude of the risks that EPA is trying to regulate 6 and get some kind of a ball-park handle on that.
I think, 7 although vague, they don 't deal with large accidents.
They 8 do deal with large amounts of things.
9 MR. SEGEs One of the other subcommittees I 10 believe of ACRS under the same chairman has done some 11 looking into the approaches of other industrial countries 12 with the same laws in the nuclear area and our research 13 people have done something in-that area.
We expect to have 14 some summary report in an attengt to see to what extent 15 those practices hold any lessons for the United States.
16 The social acceptance of risks is a task in which I'7 we expect to learn something of the way risks are accepted 18 or the extent to which there is aversion to risks in other 19 sorts of endeavors.
This is where the alternative means of 20 energy generation would come in versus nuclear studies, but 21 not only alternative means of energy generation but also 22 other sorts of endeavors in which people are exposed to risk 23 such as transportation, tobacco, alcohol, consumer products, 24 industry, construction, dams, sports and natural harards.
i 25 We may not do all of that.
It would be a matter of looking
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1 at these candidate contexts and selectino some that might 2 hold meaning.
3 But closer to homa it comes to alternatives to 4 nuclear generation of electricity.
We would clearly want to 5 take cognizance of what is actually happening and what sort 6 of alternatives exist, the acceptance of risks, the nature 7 of the risk as well as its magnitude and consequences and 8 consideration of economics and bene:its.
9 Ih the task we concentrate not on what is actrilly 10 happening in terms of the facts of risk acceptance in 11 different contexts, but rather the theories (inaudible) and 12 acceptance, including considerations such as relation to 13 other risks, whether the exposure is voluntary or 14 involuntary, the nature of the hazard, the specificity of 15 the victim, the number of persons at risk, the relation to 16 benefits generally and uncertainty as to the nature and 17 magnitude of the risk.
18 There is a considerably amount of work along these 19 lines, that is the progress of the research with sponsorship 20 notably through the Erookhaven (inaudible) research contract 21 (inaudible).
We expect to u till:e th at work as such as 22 possible.
That is still running further to a lisited extent.
23 The next group of tasks is the policy development 24 itself.
"ere ve expect to develop some so:t of working 25 hypotheses first about how we judge the adequacy or the
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1 desirability of a particular type of safety core statement, 2 the quality in the sort of approaches that are possible.
3 Then in December there is a preliminary policy 4 paper in which a limited number of approaches, together with 5 decision criteria and rationale that supports the particular 6 options presented to the Commission would be presented 7 befo re the Commissicn for consideration.
8 from here after with some iterations, advice from 9 the ACES, works *sps, public comment and well as Commission 10 guidance and completion of additional studies we vill be 11 proceeding to a policy paper for further Commission action.
12 The next task if workshops, as I mentioned.
- d e 13 are thinking in terms of two workshops, one that would gg O
1<4 concentrate on the decision critiera ap; roaches and the 15 second that would discuss one tentatively proposed approach 18 if possible or perhaps a very limited number of alternatives l'7 in preparation for the policy paper that is going to be the 18 eventual product of this work, of course, or lay foundations 19 for particular efforts beyond that.
20 (Slide.)
21 The overall schedule of the project looks ZZ something like this.
The management of the work is going to 23 be handled or guided by an interoffice steering group in 24 which we expect to have the various offices who hava a 25 contribution to make to be represented.
That includes O
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1 Research, NRF., Standards, NM.SS as well as OGC and CPS.
We 2 also also hope that the ACRS will assign a member to 3 participate in the steering group.
4 The steering group will have broadly two 5 functions.
One is to apply general guidance to the work.
6 The second is to act as a focal point for channeling of work 7 requests and contributions to and from the organirations 8 that are represented on the steering group.
9 The initial set of Commission inputs we envisage 10 as a series of structured interviews 11th each of the 11 Commisrioners to get the benefit of that preliminary focus 12 on the subject tha t will be used in guiding the sort of 13 questions that we raise and the sort of investigations that
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14 ve make.
15 Then to answer Chairman Okrent's question, or to 16 begin to answer Chairman CXrent's question about the 17 participation of the various public that are interested, 18 quite early in the program we expect to hold an exploratory 19 meeting on approaches and decision criteria with 20 representatives of recognired and developed viewpoints of 21 certainly the NRC, industry and the public interest groups.
22 That would be followed by completion of three 23 items of staf f work, a working paper on decision criteria 24 for choosing among alternative. possible approaches to saf ety 3 core formulation, development of detailed plans and i
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(~)2 1 schedules for the various background studies and completion 2 of a working paper on +.he alternative f rameworks that would 3 then be used as a basis for narrowing into the relatively 4 few options that would be presented to the Commission later.
5 Finally, the preliminary policy paper will be L
6 submitted to the Commission by the date described to us by 7 the Commission which is September 29.
After the 8 Commission's release of tha t paper, not approval of the 9 paper but approval for release, that paper will be sent out 10 for public commett, with an indication for public comment.
11 The two workshops will deal with the results of that paper.
12 The second workshop will deal also with the results of the 13 first workshop.
14 Incidentally, the plan itself is going to be 15 released for public comment af ter Commission approval for 16 release so that will allow an additional opportunity for 17 public inputs.
At all these stages of public release we 18 expect our Congressional Affairs Cffice to solicit inputs 19 from the Congress and committees.
We expect to have general
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20 contacts with Commir71on staff by committee staff s that is 21 desired by the Congress as appropriate to the stage of the 22 work.
23 We expect to have started completion dates for the 24 various background studies, but we do want to see them all 3 completed at some reasonable time bef ore the submission of ALDERSON REPCRTING COMPANY, INC.
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1 the eventual policy paper to the Commissen.
That doesn't 2 sean that there will not be occasion and need for further 3 studies later as the policy statement is made in the coming 4 years to be further refined and improved.
5 We are suggesting a one-year overall time cycle 6 for this effort to the point where something is presented to 7 the Commission for action.
We are of course aware that 8 there has been legislation introduced that would call for 9 the Commission to promulgate a safety code af ter an 10 opportunity for a hearing by the end of next June.
Ve 11 thought it was premature at this point to rely on the 12 specifics of that legislation, or the proposed legislation, 13 in cl uding the specifics as to the schedule.
However, should 14 such legislation pass, we would of course want to adjust the 15 schedule in such a way as to be responsive to whatever 16 provisions actually have developed in the la w.
I'7 This completes the prepared parts of my remarks, 18 Mr. Chairman.
I will be availa ble fo r questions.
I see a 19 representative of General Councel's Office is present.
20 (Inaudible.)
21 (Laughter.)
22 5E. OKRENT:
If I could pursue a little bit the 23 question I raised earlier.
We have tried in the past and 24 again recently to see if we could get input from people like 25 the head of the Office of Science and Technology or the f^)
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1 Chairman of the Council on Environmen tal Quality or f rom 2 Senators or Congressmen who are active 'in this area without 3 success I think to this date unless something has developed 4 in the last day or two while I was traveling, but I didn't 5 hear from Mr. Cuikschriver who handles that part of the 6 effort.
7 It seems to me it would be potentially of 8 considerable interest to see what people like this think, as 9 voll as I suppose what I would call a fairly considerable 10 number of Governors who actually end up being in a position 11 of considerable responsibility as we have seen in various 12 vays with regard to safety, not only nuclear plant safety 13 but certainly nuclear plant safety and things related to it.
O 1<4 I don't know whether it is possible to get this 15 input, but it would seem to me to be useful.
In a sense 16 certainly the Senators and Congressmen and Governors are the 17 representatives of the public.
To me they are the most 18 representative members of the public aside from the 19 President himself, more so than either public interest 20 groups or people who say they a re neutral, you know.
21 If you can think of a mechanism of getting such 22 input I would encourage you to do it.
Let me put it that 23 vay.
24 3R. SEGE:
I appreciate the suqqestion.
There are 25 mechanisms for getting such inputs which have some limited O
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1 or great value depending on circumstances.
I should have 2 mentioned that we are civing thought to some additional 3 public meetings besides the ones that appeared on the 4 schedule slide.
5 We may very well add to even the master schedule a 6 provision for a public meeting sometime around the vockshop 7 time when members of the public, including spokesmen for 8 various State Governors, would have an opportunity to voice i
9 views as distinguished from public presence at meetings that 10 ve are intending to have with participation by invited 11 discussants.
In those cases the members of the public may 12 vell be given some opportunity to express views at some 13 point in the proceedings, but not to actively participate.
O 14 I am also acqua3nted with steps in that direction 15 on another project some years ago, the nuclear energy site 16 survey, in which workshops were arranged for representatives 17 of state and local governments.
Those representatives were 18 occasiona'lly in a position to speak for the heads of their 19 states.
' 20 MR. ENGE3 Soles May I ask a question.
Back when I 21 used to work for TVA there was a sort of principle which was 22 almost never mentioned but which existed.
It was called the 23 principle of individual initiative which was supposed to 24 sort have the theses in it that everybody did his test 25 toward a common goal from the janitor to the chairman of the O
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()s 1 board, and he acted in that way in the a'sence of any a
2 leadership to the contrary or with the assistance thereof.
3 Your effort represents an effort of about a year, 4 doens't it, before there is a policy?
5 MR. S EGE 4 Yes, that is correct.
6 MR. E3ERSOLEs Things will be going on in that 7 year.
On momentus or on the basis of the existence of f
8 perhaps a unstated policy of some sort do you intend to 9 state what appears to be the current policy and the basis 10 for actions in the interim period before you get your policy 11 out, because things are not going to be stan ding still in 12 that year?
13
- 33. SEGE4 I understand what 'cu are saying.
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14 expect to approach the subject with what I hope is a 15 reasonable balance of both (inaudible ) and intellectual 16 modesty.
There are wide divergencies of views as to how 17 much success is possible on what time scale with respect to 18 fo rm ula tion of all-embrasive saf ety goals that would govern 19 all G2fety decisions in safety goals that are laboriously 20 conceived as governing some types of safety decisions or at 21 least providing some limited guidance to those decisions.
22
'4e expect to present to the Commission options for 23 clear-cut and decisive action in those areas where it seems 24 to us that the issue is ripe for such action, but not for i
25 decisions which are too (inaudible).
I may be talking in
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1 45 2 riddles (Inaudible).
3 MR. E3ERSOLE:
I was really asking about the 4 interim period of about a year.
5 MR. SEGE:
By December perhaps there will be sone 6 items of policy where options can be presented to the 7 Commission in such a way that decisions are possible.
I 8 expect those to be rather limited.
In the meantime, of 9 course, the decisions will be made about retroactive 10 application of standards or grandf athering.
Decisions will 11 he made on the way costs and benei'its are taken into account 12 in safety decisions with or without articulating the 13 standard applied, just like they have been in the past.
14 ME. EEERSCLE Well, one could synthesire a policy 15 from what you are doing now, I guess.
16 MR. SEGEs Ferhaps.
Whether it would cohere into 17 something that is recognizable as a fashion to uphold, that 18 is a very different question, and it is also a question of systematicarticulationisgoi.kg to be 19 whether an a ttempt at 20 precise enough to be helpful or simplified enough to 21 constrain decisions tha t might more reasonably be made l
22 without an artificial simplification articulation.
23 I don't want to cound too pessimistic on that.
I 24 as trying to walk s middle course between the very strongly 25 felt need to systematise and rationalire decision-makin; by t'~
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1 explicit articulation of policy and the obvious 2 complications with which such attenpts are surrounded and 3 the care that is necessary to have good statements when i.
4 possible but avoid making bad ones in the interest of being S able to check off when we have not a r ticula ted that such 6 (inaudible.)
7 I as reasonably confident that we should be able 8 to do something better than we have done in the past on t
9 safety cost trends on retroactive application of 10 regulations.
Fernaps on some aspects of dealing with 11 uncertainty, as for example in the proposed citing rule 12 where there is one particula r response proposed to 13 uncertainties that could be re:sponded to by isolating citing Ci 14 or whatever else there is.
15 There may be 3me isolated areas in which one can 16 do a somewhat more complete job than in the overall issue.
I'7 But even in the overall issue if it no possible to have an 18 articulation which is such that regulations and case 19 decisions flov from it by a rigid Aristotelian (inaudible) 20 logic, even if it is not possible to do that, it may be 21 possible to articulate codes in ways that nev e rt heless sill 22 be helpf ul in systematic guidelines.
23 I don 't know how much can be achieved in one year.
'4e vill 24 try hard to achieve a lot.
25 MR. ESEESOLE:
Thank you.
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1 MR. OXRENT:
I don't have any other questions or 2 comments myself at this time.
3 Do you have any, Jessie?
4 3R. EBERSOLE:
No.
I guess I am mentally trying 5 to synthesize what I will have as a policy a year from now, 6 and then I am saying to myself, what will we do with it.
7 Can we in fact interpret it and implement it and will it be 8 cf that character?
MR. SEGE:
It is not going to be aseful unless it 9
10 is of some large or at least little help in makino rules, in 11 making (inaudinle) standards and in making case decisions.
12 If it is stated in terms such that the interpretation in 13 terms of what will be required of applicant to do in steel 14 and concrete and (inaudible) operation, if it is couched in 15 terms that cannot be at least to some extent reasonably 16 interpreted in such terms, it is not going to be a very good 17 goals statement.
We want to have something that would meet 18 the criterion of operation use (ina udible ) wi th some degree 19 of clarity and interpretability.
20 MR. E3ERSOLE:
I am aware of the eternal battle 21 between being completely nebulous and completely 22 prescriptive and where do you define th e lin e.
Z3 MR. SEGE:
Yes.
Well, we will be. struggling with 24 that for a year.
We expect to be contacting the ACES and 25 perhaps the committee can be of help to us (inaudible.)
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(_,fm) 1 MR. EEERSOLE:
I guess to the extent that energy 2 migh t be responding in that interval the tendency would be 3 to become more and more prescriptive.
Industry in 4 responding to the current safety need, if it vill respond, E
't reduces the prospect of prescriptiveness.
If it does 6 not, then it invites prescriptiveness if it intends to keep 7 building these plants.
Every tine you approach 8 prescriptiveness thare is a hue and cry that is what you are 9 doing, but when one goes back to generalities then you are 10 more often than not don't get a very good job against the 11 broad base of the general criteria.
12 MB. SEGE:
Predictability is very useful for 13 industry.
Cf course, predictability necessarily excludes O_,
14 something but it is predictable what is going to be excluded.
15 MR. OKRENT:
We were "arlier in the subcommittee 16 meeting in connection with the licensing staff and NTC?s 17 talking about a matter that represents a policy issue and 18 might or might not appear in some formulation of safety 19 policy or safety goals.
It related to what the staff was 20 saying in SECY 83-u8 on page 3 with regard to wha t they were 21 going to ask the NTCP applicants to do in the area of Z2 degraded core rule-making.
In fact, it ended up with a 23 question of needing to ask them to explain the words before 24 you really understood.
25 Apparently in the area of degraded core O's /
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1 rule-nakin; they curren tly envisage tha t an acceptable 2 approach would be for an applicant to come in and say we 3 have already achieved a plant whose risk is less than your 4 average plant with regard to the risk of let's say, a 5 degraded core or by adding some features to what they had
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6 proposed.
They will have gotten it down to some risk level 7 below the average plant or whatever it is, and that they 8 anticipate that this say be an acceptable approach for the 9 NTC?s.
10 Now, that raises a kind of policy question.
Do 11 you continue as in the past where I would say with regard to 12 degraded cores and melted cores the regulatory approach is 13 to prevent these, only perhaps try to do it better, but 14 still prevent, or do you say we are going to try to prevent 15 these and do it better as we know how, but we will also 16 assume that as,of now we can't be sure that the level 17 achieved in this regard is adequate.
18 It may prove to be so in the f uture, but there is 19 little reason or whatever to know you have enough confidence 20 and enough knowledge at this point to do that, so we will 21 also take a second step and provide some level of protection 22 with regard to degraded cores and melted cores.
Then, of 23 course, that brings in site and how sany people there are 24 around then and features to deal with degraded cores in some 3 combination.
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1 Now, that is a kind of policy question that in
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i 2 fact you can think about and arrive at a decision without 3 having numerical criteria.
You can also do it in terms of 4 some numerical f ramework, depending on how you choose your 5 numbers.
If I were to take a rather acceptable risk to the 6 individual at a not too high a confidence level and say 7 however this is met then it could be met by a combination of 8 ways.
9 On the other hand, if one takes a lower risk to 10 the individual and says you want to know this with a high 11 degree of confidence, then you might be forced to use both 12 design approaches, not the one or the other, because neither 13 one would by itself get you the necessary confidence.
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14 So what I am saying is that you can arrive ar 15 either a position which has the same general policy in terms 16 of numbers or without them.
Hight now it is my impression l'7 the staff doesn 't know what the policy is.
The 18 Commissioners as far as I can tell at least in anything that 19 I have read haven't told them what the policy perhaps should 20 be in general terms.
21
! think in a sense maybe Mr. Ebersole was saying 22 there are certain kinds of policy things that one can think a about and even arrive at without specific quantitative 24 safety goals or frameworks to put them in and so forth.
25 MR. E2ERSOLEs In fact, one can synthesire an 1
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1 existing policy, deduce it from what we are doing er have 2 done.
Then having done that examine it for good and had 3 points and see what a new one Uill look like against it.
4 MR. OKRENT4 Thank you for providing us with this 5 description of what you are going to do.
I guess Or. Savio
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6 vill make sure the ACRS is somehow notified tha t you have 7 invited them to supply a member be a participant.
8 MR. SEGE:
We are about to recommend to the 9 Co mm issio n.
If the Commission approves our plan then the 10 Chairman of the ACES would be approached on behalf of th e 11 Commission.
12 MR. OKRENT4 Thank you for correcting me.
13 I think we would e.ppreciate receiving as early as G
14 practical background studies or whatever information you 15 develop along the way since it might help our thinking as 16 Well.
17 I think with rega rd to Friday at the moment, if we 18 handed out this four-page reproduction of your slides the 19 members could pretty much see wh a t is planned and I suspect 20 might fill that need.
What do you think?
21 MR. SEGE:
There is some difficulty with that, Mr.
22 Chairman.
This is in a state of flux and I dca't know to 23 what extent this handout vill still be in line with current 24 thinking on Friday.
We are very close to submitting a paper l
3 to the Commission.
If that is agreeable tc the subcommittee
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I and the committee, I would feel a lot better if the 2 committee would wait I guess a few days for the mail to 3 reach them and receive the plan as submitted to the 4 Commission and then react to something that is current and 5 at least at that time somewhat (inaudibla.)
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6 MR. OKRENT:
So we could tell them what is in the 7 works and say that the details vill be forthcoming very 8 soon.
'Je could outline it generally, what we heard today; 9 is that what you are saying?
10 MR. SEGE:
Yer, that would be in order and I trust 11 you will report to the committee the caveats that I brought 12 before you.
You are seeing parts of a draft that is in the 13 final stage of review.
It is moving but there vill be items O
14 that will undergo change before it is submitted to the 15 Commission.
16 MR. OKRENT:
Okay.
Your estimate again for when l'7 you might submit this to the Commission was ---
18
- 53. SEGEs About donday.
19 3R. OKRENT:
About Monday.
Fine.
Thank you very l
20 much.
21 MR. SEGE:
Thank you very much, fr. Chairman.
22 MR. CKRENTt Is there any further business that we 23 have?
24 Dr. Savio?
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- 53. C KR E.N T :
I thought that you had noted already 4 that we had received an Oral state =ent from CPE.
!n any 5 event, it is duly noted.
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ACRS/ SAFETY PHILOS. AND CRITERIA Docke: Nt=b er el
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.s were held as herein appears, and tha: this is the original transcript therecf fc; the file cf the Cc=issicn.
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SCHEDULE FOR AUGUST 6, 1980
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SAFETY PHILOSOPHY AND CRITERIA MEETING 1:00 - 1:30 (1)
STATUS REPORT ON THE DEVELOPMENT OF REQUIREMENTS FOR NTCP PLANTS - 30 Minutes (NRC AND NTCP OWNERS GROUP) 1:30 - 2:15 (2)
PRESENTATION ON PROPOSED WORK PLAN FOR DEVELOPING SAFETY GOALS - 45 MINUTES (NRC-0PE) 0FFSHORE POWER ~ SYSTEMS-HAS SOEMlTTED THE ATTACHED WRITTEN STATEMENT, O
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I her (L.bk ara 4 WM STATEMENT BY OFFSHORE POWER SYSTEMS TO ADVISORY C0f011TTEE OF REACTOR SAFEGUARDS SUBCOMMITTEE ON SAFETY CRITERIA AND PHILOSOPHY t
AUGUST 6. 1980 l'
Subject:
Status of Offshore Power Systems' Responses to TMI-2 Action Plan items and Completion of Manufacturing License Review i
The purpose of this statement is to sunnerize the current status of the Offshore Power Systems (OPS) Manufacturing License application and provide the subcommittee an update regarding OPS response to TMI-2 Action Plan.
e The NRC Staff has issued an SER and three Supplements, and they have been reviewed g
by ACRS. The need for one final SER Supplement following Staff review of the
()
OPS' responses to the TMI Action Plan, NUREG-0660, is anticipated. The public hearings are complete except for TM1 matters. All existing contentions have been With heard and partial findings have been filed by both OPS and the llRC Staff.
the exception of review of TMI matters, the Floating Nuclear Plant (FNP) licensing process is essentially complete.
With respect to THI-2 related action items. OPS met with the NRC Staff on l
?
, April 30 to discuss items in the draf t action plan and to reach agreement with the Staff regarding which of the items would need to be addressed prior to issuance of the Manufacturing License and the level of information detail that The outcoce would be required for those items for which responses were necessas;.
of this neeting was agreement between OPS and the NRC Staff regarding both the applicability of the action items and the extent of information necessary to support issuance of a Manufacturing License. OPS has prevared responses to the applicable action items (in accordance with the agreement with the NRC Staff) and these responses were submitted to NRC as a topical report on July 15, 1980.
Copies of this topical report have been provided to the ACRS. The only item not addressed in the topical report is the degraded core rutemaking (Item II.B.8 of NUREG-0660). We will provide responses to this item as soon as possible It is worthwhile following publication of the proposed interim rule by NRC.
to note that the FHP has already undergone substantial review with regard to
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degraded core conditions by both the NRC Staff and the ACRS and that a refractory ladle for delaying melt-through of a molten core has been incorporated into the plant design. The inherent flexibtlity in the FNP design for incorporating design features to cope with degraded core conditions was demonstrated by the addition of the core ladle to the design. This flexibility a~.d the attention already given to degraded accidents provides reasonable assurance of our en t i s t.y to incorpor s. rutur. 4.s s on requirements.
On August 1, the Comision approved for publication for public consnent a policy statement i pending Construction Pemit and Manufacturing License applications.
i This policy would require Applicants address applicable requirements from NUREG-0660 and also require additional measures or cemitments in selected areas. As identified above. applicable requirements from NUREG-0660 have been addressed by OPS. submitted to NRC and are awaiting Staf f review. Two of the four other selected areas identifiec' by the Comission are applicable to the Manufacturing License review, they being Degraded Core Rulemaking and Reliability Engineering. Reliability Engineering was addressed in our responses to NUREG-0660 and further detail will be provided if required by the Staff. Degraded core rulemaking was discussed above and further information will be provided to NRC as soon as possible after publication of the interim ule.
In conclusion. OPS has provided all the necessary information needed to permit rapid completion of the review of our application except possibly for infomation with respect to degraded core rulemaking.
Such information will be provided as soon as possible af ter publication of the proposed interim rule. We urge a.
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the Staff and ACRS to complete this review as exo dttioustar O
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PROPOSED PLAN FOR DEVELOPING A SAFETY GOAL OBJECTIVE To develop an explicit articulation of policy with respect to the fundamental
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issues of public health and safety and the level of protection the Commission believes is adequate.
SCOPE The policy articulation to be developed will include scme general approach to risk acceptability and cafety-cost tradeoffs, and, to the extent that O
these reasonably lend themselves to articulation, quantitative safety goals, safety improvement goals, and standards for review of past acticns in light of new rules and improved practices.
The work will deal primary -- but not exclusively -- with reactors.
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METHOD OF APPROACH Utilization of results and interim results of ongoing NRC efforts (ACRS, RE5,NRR).
Consideration (and, as approcriate, solicitation) of inputs from outside groups with considered views (AIF, EPRI, other industry groups; nuclear-critic groups).
Performance of background studies (past AEC/NRC practices, practices of other agencies, approaches in other industrial countries, theories and facts of risk acceptance).
Workshops, for discussion among knowledgeable persons of varied viewpoints.
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Solicitation and consideration of public ccmments.
A series of staff papers for Commission consideration at critical stages j
of policy analysis.
' Reception and development of a broad range of alternatives before narrcwing l
to a limited number of significant options (and ultimately perhaps a single reccamended appreach).
l Opportunities for Commission guidance as the work progresses.
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TASKS I.
LIAISON ACRS, RES, NRR, industry, public interest groups, NSF/NAS, foreign II. BACKGROUND STUDIES A.
Nuclear Regulatory Statutes and Practices B.
Ststutes and Practices of other Agencies C.
Approaches of Other Industrialized Countries to Safety Goals D.
Social Acceptance of Risks E.
Theories of Risk Acceptance
( ])
III. ?OLICY DEVELOPMENT A.
Criteria B.
Frameworks C.
Preliminary Policy Paper D.
Policy Paper IV. WORKSHOPS A.
Workshop on Frameworks and Philosophies of Approach B.
Workshop on Proposed Approach V.
MANAGEMENT O
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PROGRAM MILESTONES Task No.
Event Date V
Establish Inter-Office Steering Group 9/8(a)
III.A Complete Comissioner interviews 9/19 I
Hold exploratory meeting on Approaches with 10/22 NRC/ Industry /Public Interest Groups III.A Complete working paper on Criteria 10/31 II Submit information paper on detailed plans and 10/31(b) schedule for Background Studies III.B Complete working paper on Alternative Frameworks 11/24 III.C Submit PRELIMINARY POLICY PAPER 12/29(c)
IV.A Hold Workshop on Frameworks 2/17 III.C Receive public coment on Preliminary Policy Paper 3/16 II Complete Sackground Studies 4/30 III.D Complete preliminary draft of Proposed Approach 5/20 IV.B Hold Workshop on Proposed Approach 6/23 III.D Submit POLICY PAPER 8/7(c) d (a) ce two-week arter Lomission approval of plan.
(b)
Scme background studies may be initiated before that date.
(c)
Issue for public comment 10 days later, after Comission approval for release.
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PAST ACTIVITIES O
MARCH 17,1980 NRR TASK FORCE FORMED TG PROPOSE TMI-RELATED REQUIREMENTS FOR NTC? AND ML APPLICATIONS MARCH / APRIL 1980 MEETINGS WITH NTCP AND ML APPLICANTS APRIL 4, 1980 INITIAL SET OF PROPOSED REQUIREMENTS APRIL 9,1980 MEETING WITH TMI-2 IMPLICATIONS SUBCOMMITTEE APRIL 22, 1980 REVISION TO PROPCSED REQUIREMENTS MAY 2, 1980 FULL COMMITTEE MEETING MAY 6, 1980 ACRS LETTER JULY 15,1980 ML APPLICANT SUBMITTED RESPONSES TO ?ROPOSED REQUIREMENTS JULY 23, 1980 STAFF ISSUED PROPOSAL TO COPMISSION TO ISSUE PROPOSED REQUIREMENTS FOR PUBLIC COMMENT AUGUST 1, 1980 COMMISSION APER 0 VAL OF STAFF PROPOSAL O
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AUGUST 1980 ISSUE FEDERAL REGISTER NOTICE INVITING COMMENTS ON PROPOSED REQUIREMENTS AUGUST 1980 ISSUE NUREG-0718 WHICH CONTAINS THE PROPOSED REQUIREMENTS SEPTEMBER /0CTOBER 1980 ACRS MEETINGS OCTOBER 1980 CONSIDER COMMENTS, REVISE REQUIREMENTS OCTOBER 1980 MEET WITH COMMISSION NOVEMBER 1980 COMMISSION APPROVAL 0F REQUIREMENTS E
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