ML20003C741
| ML20003C741 | |
| Person / Time | |
|---|---|
| Issue date: | 02/12/1981 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML20003C742 | List: |
| References | |
| FRN-45FR65474, REF-10CFR9.7, RULE-PR-50, RULE-PRM-50-29, TASK-OS, TASK-RS-220-5, TASK-SG-029-3 NUDOCS 8103180178 | |
| Download: ML20003C741 (86) | |
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NUCLEAR REGULATORY COMMISSICN
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In the.h af:
l COm1ISSION MEETING - DISCUSSION OF ATWS POLICY i
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l DATE: February 12, 1981 PAGES: 1 thru 84 l
n: - ' Washington, D. C.
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1 1
UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY CCMMISSION 3
4 CCMMISSION MEETING 5
DISCUSSION OF ATWS POLICY 6
Nuclear Regulatory Commission 7
Room 1130 1717 H Street, N.W.
8 Washington, D. C.
9 Thursday, February 12, 1981 10 The Commission met, pursuant to notice, at 10 :00 p.m.
11 BEFORE:
12 JOHN F. AHEARNE, Chairman 13 JOSEPH M. HENDRIE, Commissioner 14 Vit:: tor Gilinsky, Commissioner
.15 Peter A. Bradford, Commissioner 13 STAFF PRESENT:
Samuel J. Childs, Secretary 18 Leonard Bickwit, 19 Marty Malsh 20 21 22 23 i
24 25 AJERSON REPORTINS COMPANY. INC, L
400 VIRGIN 4A AVE, S.W. WASHINGTON. D.C. 20024 (201'; 354-2345
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2f9EI5EIEGE 2
CHAIEMAN AHEABNE:
It is very hard to think of 3
appropriate remarks to make to reopen the subject of 2.T W S.
4 We don't have time thic mornin; to review the history.
5 C0!3ISSIONER HENDE!E:
Why don't you tell you note 6
that my hair was completely dark on the occasion-of my first 7
meeting on that subject in 1903.
8 CHAIEMAN AREARNE:
At the recent 250th meeting of 9
the ACES, I was urged by the members to get an AT*JS 10 resolution before they fade away permanently.
11 CCM3ISSIONEE HE.iDEIE:
They were telline se the 12 sar.e thing in 1972.
13 CHAIEEAN AHEARNE:
We have met on this many 14 times.
I sa sure the staff involved is probably much more l
15 veary than we are with the issue, but it is a fundamental 16 question that have very far reaching effects in desien, in i
17 economics, and_potentially in safety.
As a result, we are i
18 compelled to sddress it again.
19 We have a revised rule in front of us.
'J e also 20 have the draf t environmental impact assessment.
21
~4ho is the chief spokesman?
22
- 33. '1INSEES:
hy thought is that ! vould quickly 23 review the January 29th memorandum, and transmittal.
24 think what the staff still recommends is that the Federal 25 Register Notice be published fo r public comment, and then ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE. S.W. WASHINGTON. D.C. 20024 (202) 554-2346
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developed into a final rule.
2 In the January 29 th m emorandum, enclosure A 3
revised that was attached to that, we. e c o.::a nd tha t' '.he 4
chances in the discussion be put into that revision and 5
published tha t way.
These are the things that have the 6
vertical lines in the margin.
7 However, the succestions of Chairman Ahearne, the 8
changes to the rule, the staff vc2id recommend that those 9
not be changed, that the proposed rule remain the way it was 10 first proposed and go cut for oublic comment that way.
11 COM.MISSIGNER GIIINSKY:
How did the version we 12 have get to be where it is?
Is it basically your version, 13 John?
14 CHAIRMAN AHEARNF:
I sent a letter, which all of 15 You had copies of, on December 10th.
All I caid was, 16
" Plea se be prepared to dircuss the attached al te rna tive 17 form."
18 C0!MISSICNER GIIINSKY:
Then somehow this got l
19 translated into the alterna.tive form.
20 CHAI3?AN A HE A R'I E:
You have just heard.
It has 21 not turned into the form that they now recommend.
22 TR. M.IN N E R S :
Thore were some subtleties in 23 draft _ag the rule that we thought that we could get so that 24 we could have a specific thing to discuss as an alternative, 1
25 since that wa s the thing that was beinc proposed.
l ALDERSoN REPORTING COMPANY. INC.
@ Ver.CetNIA AVE, S.W., WASHINGTON. D.C. 20024 (202) 554
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In the discussion section, on page 9 cf the 2
revised en losure A, in the middle paragraph, in the last 3
line wa s a revision in response to Conniasicner Hendrie's 4
request to address the adequacy of th e reliability of the 5
protection systems.
6 We believe that there is general agreement on the 7
first part of the sectica, that th e reactor protection 8
systen reliability has not been demonstrated, and people 9
vill agree to that, but I think the staff's best judgnent is to that the ra11 ability also is not adequate.
11 Healizing that there is some uncertainty in making 12 that judgnent, and that the data is consistent with the 13 contrary view, you can nake statistical calculating, which 14 depending on how you make your assunptions, they can give 1
15 you different probabiliti+0.
Eased on our judcment that 16 there have been one full failure of the protection system, l
17 and one ptreial failure of the protection cystem in about l
18 900 reactor years of experience, leads the staff to 19 enclude that the reliability probably is not adequate, 20 considerin g that adequate is a vary high standard.
i l
21 CHAIEMAN AHEARNE.
Warren, since you are cpen to 22 page 9, and this is part of the problen I alluded to l
l 23 earlier, forgetting the cycles th re ugh, renind ne of what is 24 the one common sode failure th:t you are talkinc about at l
25 the top of page 9?
i
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ALDER 8CM REPORTING COMPANY,INC.
400 VIRGINIA AVE., $1* WASHl'iGToN, D.C. 20024 (202) 554 2345
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MR. MINNERS:
Tha t is the commen failura in which 2
all the square relays would not open if they had been 3
challenged.
4 CHAIRMAN ASEARNE:
That was not an American 5
reactor.
6 ME. MINNERS:
Ihat was not an American reactor, 7
but. it was an American design and American equipment.
The 8
same failure occurred in pre-operational tests in an 9
American reactor.
10 CHAIRMAN AREARNE:
But'the 700-reactor years that 11 you refer to cover what reactors?
12 MR. ? INNERS:
The 700-reactor years cover only 13 commercial nuclear power reactors in this country.
/
14 CHAIRMAN AHE ARNE:
But the failure you are talking 15 about doesn't refer to a commercial nuclear reactor in this 16 country?
17 MR. :iINNEES:
No, it doesn't.
l 18 COMMISSIONER GIl!NSKY:
I think John has a good 19 point.
l 20 MR. MINNERS:
Ycu could add in that.
21 COMM!SSIONER GILINSKY:
I dcn't know that the l
22 numbers would change very r.u ch, but certainly one ought to 23 be looking at the whole population, when you are drawing a 24 sample from outside the U.S.
l 25 MR. IHADANI
'4arren mentioned 900-reactor years ALDERSON REPORTING COMPANY,INC,
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with lightwater rasetors, that includes experience not just 2
in this country, but throughout the world, excluding the 3
Soviet Union.
So it does include experience with lightwater 4
reactors in other countries also.
5 CHAI2 MAS AMEARNE:
So it would be 900.
6 MR. THADANI:
Ihat is correct.
7 CHAIR 5AN AHEARNE:
Ihe page says 700.
8 3R. 3 INNERS:
I think that it is an error.
It 9
probably should say 900.
to CHAIRMAN AHEARNE:
I don't have any sans.e that 11 Your points would be in any way changed, I am not tryino to 12 make that case.
It is Just I think it ought to be written 13 clearly to sa y th a t there was one reactor trip portion in 14 900 reactor years, and it is worldwide.
Just make it clear, 15 tha t is all.
to MR. MINNERS:
That was one thing I wanted to focus 17 your attention on. because I think that was a point of 18 importance, whether you considered there was just lack of 19 demonstration, or whether it really was inadequate.
20 -
The othat point is on page 9 --
21 CHAIEMAN )HEARNE:
Fince that was Jea's point, 22 Joe, do you want to sa y romething?
23 CCZ2ISSIONER HENDRIE:
Ihe staff is entitled to 24 its view.
Mine would continue to be that I think it 25 continues to be an inability to show, rather than, frem my I
ALDER $oN REPORTING COMPANY,INC, 400 VIRGIN.A AVE., S.W., WASNINGTON. D.C. 20024 (202) 564-2346
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standpoint at lea st, any judged inadequacy.
2 CHAIRMAN AHEARNE.
So you would put a period after 3
the first "adecuate."
4 00MMICSIONER dENO3II:
I am not enormously upset 5
by it.
6 COMMISSIONER GIIINSKY:
There wculd have to te at 7
least a concern because of our inability t0 calculate that 8
it may not be adcquate,at a minisum.
9 OC3YISSIGNEE HENDE!Es Ic be cure.
10 Thara is at least t h:- Cowle situation, and there 11 are a couple of other circumstances where you can argue 12 whether or not they oucht to te added in as equivalent 13 system failures in the appropriata experience base.
The 14 staff has chosen act to here, and tha t is all right.
15 CHAI3 MAN AHEARNE:
So you could live with that.
16 COM2:SSIONEE HENORIE4 I will have te decide 17 whether I f eel the need to say anything for myself about it 18 eventually or not.
19 3R. MINNEES:
The other point I would like to 20 direct your attention to is on page 14, in lines 5 through I don 't know whether it is 21 14 This is a statement which 22 a legal term or not -- it excludes Part 100 from ATWS.
23 Ihe staff's opinion would be that the purpose of 24 the rule is to citigate'ATNS events, and that is limit core s
25 damage.
The curpose of the ATWS fix is not to allow care ALDERSoN REPORTING COMPANY.1NC.
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400 VIRGINIA AVE,5.W WASHINGTON. D.C. 20024 (202) 55 & 2346
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damage, and then limit the consequences of core danage, 2
which is really what Part 100 is directed to.
3 If you do Part 100 type doce calculations, you 4
would go back and put filters on the containment, and things 5
like that.
The staff's technical intent is not to do that, 6
but is to prevent damage to the core in actual avents.
7 Therefore, we don't think that Part 100 is really relevant 8
to ATWS.
9 CHAI?. MAN AMEARNE:
I am not really completely 10 following the argument.
11 Are you saying that if you use the test estinate 12 ralculations, you would enc up gettine off-site doses that 13 would be unacceptably high for Part 100 purposes?
14 MR. MINNFRS:
No, ycu would not.
If the ATWS fix 15 is as ao propose, our best judgment, cur best estimate 16 calcultiens would say, no, you would ta within Part 100 17 doses.
In fast, there is a criterion in there which is put 18 in there to do that generical'ly.
If you neet that criterion 19 it is the staff's estimate that you would'not exceed Fart 20 100 doses.
21 Put tha t is rather different frc: what is done in 22 past accidents in which each accident has a dose calculation 23 associated with it for a scecific plant.
Ne don 't think 24 that that is'really worthwhile.
You are doine a lot of 25 of f-site dose calculations, it is costing time and money, if ALDERSON REPORTING COMPANY. INC.
400 VNIGANIA AW S.W, WASNINGTON. D.C. 20024 (202) 564-2346
9 1
You vent above Part 100, what would be the solution?
You 2
would go back and put filters en the centainment, but that 3
is not the intend of the staff's ATWS fix.
4 COMMISSICNER GIIINSKY:
Where would Part 100 come 5
up, if you were not excluding it?
8 MR. *IadERSs Ycu wculd hava to calculate the 7
number of fuel failures, the amount of activity releared to 8
the cooiant, the amount of activity released in a ?WR 9
primarily through leaking iteam generater tubes, out of the 10 steas generator relief valvec, and then to th+ environm ent.
11 COMMISSICNER GIL!NSKY:
This would be in addition 12 to everything else that is being done under the rule?
13 CHAIRMAN AHr ;EN E:
Yec.
14 MR. MINMZ?S:
That is what is done in all other 15 accidents.
18' COM'ISSIONER GIIINSKYz In cther words, you would 17 be relieving the licensee of the f urther obliga tion to make 18 a Part 100 calculaticn.
19 ME. MI3NYES:
Correct.
l 20 C0!!MISSIONER GILINSKY Would there also be the 21 possibility, if you somehow kept the relationrhip to Eart 22 100, to relieve the licensee of certain requirements under 23 the rule, if he could show that without them he could s till 24 meet the Part 100 dose limits; or is that not an issue?
25 Y3. "INNEES:
I
- 2. 3 ccrry, I did ne t understand the ALDERSON REPORTING COMPANY,INC, Mrs VIRGINIA AVE., S.W. WASNINGTON, D.C. 20024 (202) 554-U45
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question.
2 C H AI3 MA N AHEARNE:
That is wha t I was trying to 3
get right.
4 COMMISSIONER HENDE!E Because ?a rt 50 says, "Dc 5
A, B, C, and D," and the fact that Part 1CO without some 6
other instruction says, " Include ATWS as one of the 7
accider.ts you calculate, Chapter 15 of the Safety Analysis 8
Report, and do the Part 100 calculations," none of that 9
says, "You don't have to do A, 3, C, and 0."
to In fact, you co=e out of the Part 100 calculations 11 ufscovering that there is negative radioactivity rut into 12 the atmosphere, and enhancement of the health, and you have 13 to do A, 3, C,
and D, and E, because those are specified
(
14.under Part 50.
15 CHAIEMAN AHEASNE:
And it wouldn't lead to a 16 legally defensible challenge of the rule?
17 COMMISSIONER HEFDRIE:
Of the A, 5, C, D, and E, 18 no.
Cf course, I am speakin7 on behalf of the General 19 Counsel here.
i 20 MR. SICKWIT:
We said that in our TMI Hydrogen l
21 Con trol Statement.
l l
22 CH AIRM A N AHEARNE:
So the sole purpose of removing
'23 the Part 100 issue is to --
24 CCMMISSIONE3 HENDEIE:
Keep from havinc to do a 25 set of specific accident calculations for each specific L
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plant.
2 CHAIRMAN AHEAENE:
In the absence, then, of 3
putting thst statenent in, by puttine this rule in place, 4
you would also pick up the need to do the ATWS calculation 5
under Part 100 type analysis?
Is that a direct link?
6 MR. N.INNE3S:
If you didn't have this :tatement 7
in?
8 COMMISSIONER HENDRIIs Not directly.
It does not 9
flow from explicit sta tements a nywhere in the regulations or to the law, but if you have got an accident ATWS, which is now 11 classified as one of t.se dasion basis accidents because it 12 has a whole'section of Part 50 that talks about it, I think 13 You are going to have a lot of trouble naking the case that 14 your accident analysis in the safety report is conplete 15 unless it talks about the results of that accident.
It 16 would be like coming in with an SAE in which you don 't have 17 a set of dose calculations from ICCA.
18 CHAI3 MAN AHEA2HE:
Fine.
19 Now, Warren, tell ne again what the logic is 20 behind this?
If we think this is serious enough to place 21 these requirements on, why then isn't it serious enough to 22 have to do the accident analysis?
23 MR. MINNERSa The intent of the ATWS is to make 24 changes to the reactor systeo to prevent core danage.
In j
25 many of the other accidents, ycu are allowed to put ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE.,3.W., WASHINGTON. D.C. 20024 (202) 554 2348
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engineered safety features on the containment that would 2
mitigate ths conseq*2ences of core damage.
I den't feel that 3
this is th e purpose of the ATWS fix.
4 CHAIE:As AHEAR3E:
The ATWS fixes in the 5
description are both preventien and mitigation.
6 M3. MIN 3EPS:
Provention and mitigation of what?
7 Some of the fixes are to prevent any ATWS events at all.
8 hitigation really means prevention of core damage in the 9
sense that it is used in the rule.
We want to do, by havine 10 these backup systems of boron injection and pump trips, and 11 such things, to prevent core damace.
That is what is meant 12 by mitigation of ATWS events.
13 But there is also mitigation of core damage.
You
/
14 could let the core be damaged, and depend on the containment 15 to mitigate the consequencer of that damage.
That would be l
16 to have a tighter containment, to have filters, to have a l
17 double containment, and thines like tha t.
I don't think it 18 is the intent of the requirement to try to mitigate core J
l 19 damage.
I think the intent is to prevent core damage.
l 20 COMMISSIONER GILI? SKY Could you compare shis to 21 Appendix X.
l 22 CHAIRMAN AHEARNE:
Eefore you do that, let me ask 23 one question.
24 The centainment isolation feature that you are 25 requiring is not relatad, assuming that' there is some core i
ALDERSON REPORTING COMPANY,INC,
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damace?
2 MR. MINNERSs Nc, it is.
But we have put those 3
specific things in the rule, ra ther tnan ha ving semebcdy de 4
a dose calculation.
5 CHAIRMAN AHEARNEs Eut that is related to it?
8 MR. MINNERSs Yes, it is.
7 We have things in the rule which mitigate core 8
damage, and I am not trying to sa y we don't.
But they are 9
rather specific things, and you don't have te go through a 10 dose calculation, and then the licensee or applicant would 11 then have to make a decision of what things to put on to 12 mitigate core damage.
We have already specified those.
13 COMMISSIONER GIIINSKYa let me ask you, are you
(
14 saying that our past r?quirements for Part 1CO calculations 15 hasn't added all that e.uch, or is not useful, therefore, you 18 have changed your mind?
17 MR. NINNERSs Particularly in Appendix X.
18 COMMIS5!CNER GIIINSKYs I= there romething really 19 different about this rule?
i l
I-20 MR. MINNEESs Appendix K is unique.. In Appendix I
21 K,
if you do that, you do hava minct core damace, and you do 22 have some activity release.
But the dose calcultion that is 23 done which correlates with that accident is based on a core l
24 damage which is much, sucn beyond what you wculd allow under s.
l 25 the Part 50 requirements, ss Coamissioner Hendrie said.
i C
ALDERSON REPORTING COMPANY,INC, 400 VIRGINEA AVL S.W., WASHINGTON, D.C. 20024 (202) 554-2346
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If you go to the ECCS Appendix K criterion of 2200 2
degrees and 1 percent, you get some activity release, but it 3
will be a few percent of what is in the core.
But the dose 4
calculation is done on almost 100 percent of what is in the 5
core, and it is distributed around.
6 CCMMISSIGNER GIl!NSKYs
! den't follow you.
7 There is a Part 100 csiculation that is done with 8
a substantial release of the fission inventory.
Now is that' 9
related to the specific requirement of Appendix K or 10 anything else?
11 4R. ' INNERS:
It is not, and that is why I said it 12 is unique.
It is not, it is kind of divorced from it.
The 13 Appendix K calculation which says you get this consequence, 14 and then you lonore that consequence and you presume that it 15 is much larger than that, and do a dose calcula tion.
16 COMMISSIONE3 GILINSKY But that dose calculation 17 isn't tied to any specific rule?
18 MS. MINNE3S Yes, to Part 100.
19 COMMISSIONER GILINSKY:
'Jh at I mean is that it is 20 the Part 100 calculation that one does, but it is not tied 21 to any specific requirement on safety equipment within the 22 reactor in the sense that you are laying en certain 23 requirements.
(
24 MR. "IN:lERS4 It is, because that defines what the 25 leak rate of the containment could be, the kind of filters r
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AI.DERSoM REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W. WASNINGTON. D.C. 20024 (202) 554-2345
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rou can have on the containnent, whethe r you need core 2
sprays.
There is a whole lot of engineered safety feature d
3 designs that are affected by the Fart 100 dose 4
calculations.
5 CO3MISSIGNEE GILI55XY:
That is right.
6
- 53. MINNEES:
It affects the cont ainment design.
7 It does not affect the sycten systen.
It does not affect 8
how bic pumps you have.
9 00!MISSICNE3 GILINSKY:
Tes.
10 M3. YINNERS:
I quess what I as trying to say is, 11 I think the purpose of the ATVS fix is not te fix up 12 containments to ttAe care of ATVS, it is to fix up reactor 13 coolant systems.
14 You do have to recognize some of the off-site dose 15 possibilities f ron ATUS events, and we have done that.
We 16 don 't, at least ! don't think it is wo rthwhile to ;o th rough 17 a whole bunch of off-site dose calculations which would at 18 best fix um the con tainment, which is no t the intent.
19 SOMMISSIONIE G!LINSKY:
Supposa ycu zorry about 20 something like dropping the f uel element.
A calculation is 21 performed on the radioactivity releare associsted with that 22 accident, and then you see whtt sort of a dose you get 23 outside.
That is specifically tied to that scenario.
24 ER. 2IJNERSt Host accidents are differant than 25 _the Appendix T.-
In moct *ccidants, the dose calculation, s
ALDER $oM REPORTING COMPANY.INC.
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the Part 100 type calculatien is much more closely 2
correlated to the accident itself.
3 COMMISSIONER GILINSKY:
That sort cf calculation, 4
you are saying, doesn't need tc get ;erformed here.
5 ZE. ?. INFERS:
Right.
6 COMMISSIONEB GILINSKY:
I don't really see why you 7
tie the other one to Appendix K, since it was performed long 8
before Appendix K.
It has been going on for 20 years.
9
%R. MINNERS:
In ATWS you have to.
10 COMMISSIONER HENDRIE:
It is intrinsically a LOCA 11 calculation.
I was trying to think of where the fact that 12 it is a LOCA enters in the Part 100 calculatien, and right 13 off-hand nothing comes to mind except that you assume you i'
14 have a containment with a lot of water sicshing around in 15 the primary system, and a lot of fission products, all the 16 noble ga ses, and 1 percent of the rest.
17 COMMIS2IONER GILINSKY:
Ultimataly, in an ATWS ycu i
i 18 are also worried about a LOCA of some sort.
At some point 19 something is going to break, and that is what you are l
l 20 worried about.
It is just that we distinguish what we call l
21 a LOCA stemming from a pipe hreak, or a LCCA stemming from a 22 f ailure in the reactor protection system.
So in some sense t
23 they are all LOCAs.
(.
24
- 23. iINilIEC :
But in the ATWS event we are not 25 permitting by our criteria the extent of core damage ve i
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\\s ALDERSoN REPORTING COMPANY. INC.
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permit in the LOCA Appendix K calculation.
We are 2
essentially peb=ittin; only slight cladd rupture, which lets 3
out a little of that qap activity, which when ccmpared to 4
melting the core l'.d oxidiring the cladd is a minor event.
GNER 'ENDRIE You don't mean Appendix K.
5 CG3.1IS3:
d 6
You mean Psrt 100.
7 COMMI53ICNE3 GIIINSKYs I would'have said this 8
differently.
There is a Part 100 calculation that covers a 9
variety of possibilities, and we are ready to do a 10 calculation wnich assu:es a suhstantial fission pteduct 11 release, snd you regard that ac sufficient for coverina this 12 r ul e.
13 3E. MINNIES:
My opinion is that the criqinal Part 14 100 was to consider a corenelt type accident, and then do a 15 dose calculation and see what kind of a containment you 16 needed.
Then it got used so that every accident that was 17 proposed wa s specifically --
18 COMMISSIONER GILINSKY:
'i h y do we do that since 19 those involve lasser releases than the classic Part 100 20 release?
21
- 13. MINNERS:
Yost of them are pretty useful 22 because doing the Part 100 things defines what you have to 23 do for the accident.
In you example of the fuel drawbacks,
(,-
24 it tells you what kind of filters you have to have in your 25 fuel area to take care of that accident.
So there is a ALDERSoN REPORTING COMPANY. INC.
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direct relation between the accident calculation and the 2
design requirements on the engineered safety fea tures, in 3
that case filter *,.
4 CC3MISSICN 3 GILINSKY:
So this vould be 1 5
requirement outside of containment?
6
'E. MINNE3S:
It vould depend on the plant.
7 COMMISSIONER HENDRIE:
It is separate frem 8
containment.
9 COMMISSIONEE GIIINCKY:
I can understand that one to because the Part 100 csiculation, barically, is always in 11 the containment, isn't it?
12 CCMVISSIONE3 HINDE!E:
The Part 100 tells you how 13 tight it has got to be.
14 COMMISSIONER GIII3 SKY:
I think we are 15 sufficiently close here that I understand wha t you are 16 saying.
17 OHAISMAN AHEARNE:
I am still not there.
18 If you kept this in, cr if you didn 't put in the 19 Part 100. issue in your rule, the envelope of releases that 20 are examined in the maximum release case under the Pa rt 100 21 calculation vould or would not cover what you perceive to be 22 the cesult of doing the accident analysj i inherent in the 23 ATWS?
(_.
24 ME. M!NNIES:
It dould not.
25 CHAIRMAN AHE.43NE:
'Jh y ?
ALDERSON E40RTING COMPANY,INC,
. G VIRG4NBA Q S.W wAS6m1TCN. D.C. 20024 (202) 554-:345 l 9
19 1
ES. ' INNERS:
Because the releare acde is 2
different.
The steam line break accident is very similar to 3
it because that is where you get the outward pressure 4
differential on the stear generator tubes, and that is what 5
happens in an P.TWS event.
6 In the LCCA, which'is the large source term, the 7
primary system is depressurirad and the steam generator 8
tends to stay pressurized, so the leakage tends to be in the 9
primary system through the leaky steam generator.
10 In an ATWS event, the leakage is the other way.
11 The primary system is pressurized, and the secondary system 12 is blowing onc, so it is at a lower pressure.
So you get 13 the leakage out, which is rim 31ar to the steam line break 14 accident.
l 15 So if the steam line break accident produces about l
16 the same core damage as ATWS, it covers it in that sense.
l i
17 To the degree that it doesn't produce the same core damage, l
18 it doesn't.
So there is some, but it is not l
l 19 COMMISSIONER GILINSXYs You are saying that the i
l 20 path that the reactor material might take is diff erent; is 21 that the point?
r i
22 MR. 2IN3FRS:
Correct.
23 OCMMISSIONER GILINSXY:
Could you say a little 24 more about that?
I understand the pressure differentials, f
l 25.but what does that mean, that you Go out the steam line?
l
~
l ALDERSON REMRTING COMPANY. INC.
400 \\1RGINIA AVL S.W, WASHINGTON. D.C. 20024 (2GD 554-2346
20 1
ME. MINNEES In an ATWS event, you ar= isola ted 2
f rom your normal heat sync, which means that the relief and 3
safety valves, and atsorpheric dump valves on the steam 4
generators are open, and you are discharging steam to the 5
atmosphere from the steam cenerators.
Primary water which 6
has fission products in it, if you have fuel damage, is 7
leaking into the steam generaton.
So you are getting a more 8
direct path from the reactor to the environment.
9 CHAI3 MAN AHEARNEs That goes back to your earlier 10 statement and conclusion that if you were to do the Part 100 11 calculation you could end up with requirements of additional 12 filters tha t you wouldn't have.
13 MR. MINNERS:
Yes, you could.
h 14 CCMY!SSIONER GIIIFSKYa
'ihy does the steaa 1;-
generator have to be open to the atmosphere?
16 M3. MINNE3Sa Because th e presumption of an ATWS 17 event is that you are isolated froc your normal heat synes.
18 That is the initiating e ven t.
You have a turbine trip, or a 19 loss of feedwater somewhere, so you don't have the condensor 20 to discharge to.
The only way the heat can get out of the 21 system is through the ar=osphare dump valves directly into 22 the atmosphere.
23 In a BW3 it is different.
The steam is released 24 through the pressure core, which is inside the containment.
25 The problem is tha t there is a less direct path in a *WE ALDERSON REPORTING COMPANY. INC, 400 VJ4GNelA AVE S.W. WASHINGTON. D.C. 20024 (202) 564 2346 7
21 1
than in a prescurired water reactor.
2 I think the off-site dose consequences have to be 3
considered, and I think the way the rule ir written does 4
that.
The way I had icoked at it is, if fuel damace and 5
steam generator tube leakage were the only consequences of 6
an AIWS event, I don't think the Commisrion would be looking 7
at it because considering any probability of it, and the 8
ancertainty of the probability of it, the consequences are 9
relatively sincr.
I don' t think that it would be a big to issue.
11 The big issue is that you severely damage the core 12 and/or the primary system, and get a cocemelt kind of 13 accident.
ATW3 was re-lly one of the first thince where 14 people started lookinc,
the risks due to ceremelt 15 accidents.
16 MR. 3ICKWIT: ' Is your view that under existing i
17 law you do not have to do a Ps. - 100 calculation with i
18-respect to ATW5 eve nt= ?
l 19 23, /INilERSs Yes, that my view because I don 't 20 think the NRC has decided yet that Aldi '. : an event you have l
21 to consider.
If we did do that, and didn't have something 22 which did not exclude Part 100, then I would presume --
23 1E. 3!CKWIT It is et a credible accident within 24 the meaning.
25 4R. 'I!!NERS:
It his not been decided that it i= a ALDERSON REPORTING COMPANY,INC, 400 VIRGMA AVE.,5.W. WASNtNGTON. O.C. 20024 (202) 564-2345
22 1
credible accident.
2 XR. BICV.WI2:
Ihat is your reference to an 3
inadequate frameverk from a legal perspective.
That is why 4
you put those words in the statement of considerations.
I 5
assume that is also the reason why you do not deal with the 6
Part 100 issue in the rule itself, because in your view it 7
is unnecessary to deal with it.
8 MR. MINNIFSs It is unnecessary and undesirable, I 9
think.
10 COMMISSIONEE GIIINSTY4 Eecause it is onerous, it 11 is a lot of work?
12 XE. MINNERSs It is a ninor side icrua to the real 13 probles.
You could do that calculation and put some scre 14 filters on, but I think the change in risk would be very 15 small.
16 MR. EICKWIT:
So your view is that even if this i
l 17 languace were not contained in the statement of 18 considerations, there would be no Part 100 calculation 19 requirement?
t l
20 -
dR. 'INNIES:
No.
My opinion would he that based 1
21 on past precedents that ~if you adopted ATWS as an accident, l
22 and did not have these words on pace 13, the precedent would I
23 say, yes, you will have to do an off-site dcce calculation, 24 a Part 100 type calculation for AIWS ovents.
25 From the aralyses that we have had, ycu can meet ALDERSON REPORTING COMP!J4Y,INC, 400 VIRGINGA AVL 3,W., WASNINGTON, D.C. 20024 (202) $64-23.5
23 1
Part 100 derec with no partirular problem.
It is not s 2
limited thing en the plants that I have seen analyred.
3 There may be a' plant out there which has a tad side, or some 4
unusual f eatures, but as a peneral ctatement, if you do your 5
ATW5 csicilations, there are not many fuel failures, and you 6
can meet the Part 100 dose limits.
7 CHAIRMAN AHEARNE:
Guy, feel free to jus; in.
8 MR. CUNNINGHAM:
I am listening, ready to jump in 9
when I have sc =e thi ng to ca y.
10 CHAIRMA9 AHEARN2s len, do you and
a r t y want to 11 make more a rgument on that?
12 tR. BICXWIT:
We will follow the eld prictice.
13
( Gen =rsi laughter)
(
14 COMMISSIONER HENDRII:
Your problem with this was 15 that it is a rela xa tie n of Pa rt 100.
16 1R. ZALSCH:
In the interim in particular, un til 17 the rule-comes into the effect, that is wha t we are 18 concerned shout.
19 MR. BICK'.'IT If your conclusion is wrong that the 20 fact that the Commission has not spoken to this accident and 21 defined it as a credible accident, doec not mean that it is 22 not a credible accident within the terts' of Part 100, then 23 you have the possibility Of a relaxation reculting f rom this 24 rule.
25
~C0hhISSIGNER G!l!NSZY:
Does Psrt 100 talk about ALDERSO*d REPORTING COMPANY. INC.
400 VHtGNW WE., S.W., WASHINGTON. D.C. 20024 (202) 554-2346
24
~
1 credible accident =?
2 MR. M!NNEPS:
Yer.
MP. MALECH:
That is a f actual determination 3
4 usually made in each crse, or generically, as to whether a 5
particular acciden t is or is not credible.
6 COMMISCIONER GIl!NSKY:
Part 100 assumes the very 7
substantial relesse of radioactivity.
8 UK. 3ALECH:
It is supposed to.
The assumption 9
was that the credible accident you would postulate would be 10 one, in fact, which would produce a substantial release of 11 fission products, at least into the containmant.
As the 12 safety features improved, the staff crntinued to postulate a 13 substantial release of fission products, even though under f'
14 other regulations that release, under most people's 15 thinking, would not be a credible relesse.
But it continued 16 as a matter of staff practice.
17 CH AIRMAN AHE ARNE:
That is the two part 18 calculation.
'ihere one cet of calculations you do to see 19 what kind of release you get into the containment, and the l
l 20 second set you assume a large amount.
21 MR. MALSCH:
One of the problems was that the l
22 release to containment is just ;ostulated.
!t is a l
l 23 so-called non-nechanistic assumption, and there ic really no
(,
24 credibility-associated with it.
It is just automatically l
i 25 done.
It produces a certain amount of ficsion ;reducts, and i
ALDERSON REPO3 TING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASNINGToN, D.C. 20024 (202) 564-2346
25 1
then the calculations carry through in terms of cc.tainment 2
leak rate, and things of that rort.
3 F.3. MINNEES:
If you :st the other r=quirements of 4
Part 50, we would say you would not get those kinds of 5
releasas, Or auch, such less.
6 CHAI? MAN AREARNE My point is that the credible 7
ev9nt issue only refers to the other part of that 8
calculation, not how did you get all that stuff into th e 9
containment, because you just assume that stuff is in the 10 containment.
11
- 33. MALSCH4 That is the practice.
12 CHAIEMAN ARIABNE:
That is the practice.
13 MS. FALSCH:
Credibility can refer, I think, to
(
14 any poin t in the accident sequence.
It could be the 15 initiating event, or the subsequent operational safety 16 features, the filters.
17 MR. MINNERS:
It is a very artificial calculation 18 because it considers the radiation activity, the fission 19 products that vould result from an event which is coremolt.
20 But it does not consider the other consequences of that.
If 21 you have a coremelt, you are coing to have proble:s with gas-22 production f rom concrete, and possible hydrocan production, 23 and all those other things that go with coremelt sceidents.
24 All that the Part 100 calculations have dona is to 25 have this big source of radiation f rom a ceremelt, and this ALDERSoN REPORTING COMPANY,INC.
400 VWNhMBA AVE., S.W., WA
- vlNGToN. D.C. '4024 (202) 564-2346
26 1
is what the dose would be.
It has not considered any of the 2
other consequences that would have come fron a ceremelt.
3 CHAI3 MAN AHEARNE:
That is right.
4 Your concern on the ATWS issue, Marty, you have 5
said was because there would be a relaxation in the 6
interim?
7 MR. MALSCH:
The concern that I had was that it 8
has not been established by any rule whether or not ATNS is 9
or is not a credible accident.
Therefore, under the present 10 scenario, anyone who wants to say, "I think this plant oucht 11 to be designed to withstand ATWS," would be allowed to raise 12 that issue under Part 100, and maybe also under GDC but I am 13 not sure.
(
14 The problem if that is the case, what would he the 15 result of doing a Part 100 calcula tion in each case.
I 16 don 't know what th e re sult would be.
But if, for purposes 17 of argument, you say, ATWS is a credible accident, and if, l
18 for purposes of argument, you do the calculation, and in 19 some cases in results in laying down sone requirenents, the 20 effect of saying that Part 100 does not apply is to relieve 21 the licensee er the applicant from complying with those l
22 requirements.
23 I don't know whether those requirements made any 24 sense or not.-
Our issue wa s, if you make tha t arcument, 25 there.is a difference tetween the present regulations and l
ALDERSON REPORTING CQWPANY,INC, 400 VIRGINIA AVE., S.W., WASMNGToN, D.C. 20324 (202) 554 2346
27 1
wha t these ' regulations require, and the dif ference ought to 2
be, addressed.
If the difference does not make any sense, or 3
is not significant, that is fine.
4 C O?.F.ISSIONER ' GIIINS KY :
Py the way, just as a 5
historical noto, Part 100 does say that a coremelt accident it qualifies it a little bit, but it says that a coremelt 6
7 accident is a. credible accident.
It sa ys, "Such accidents i
8 have generally been assumed to result in substantial melt 9
down of the core, with subsequent release of appreciable i
10 quantities of fission products."
11-MP. BICKWIT:
In view of where you are headed, I 12 think it would be pref erable in the rule to say that this i
13 accident is not a credible accident from the standpoint of
( ~',
l s'
14 Part 100.
l 15 You have nothing in the rule at this point that-i 15 deals with the Part 100 question.
You have a statement in 17 the statement of considerations that rays that Part 100 is 18 an inadequate legal framework.
19 MR. MINNERS:
I was hoping he would step in 20 because that was advice we got.
21 MR. CUNNINGHA!:
I am just not sure that it is 22 necessary.
It is determined to keep this eat of Part 100, 23 or to keep Part 100 out of this.
Certainly we can say that 2t.
with additional languace in the rule.
(j 25 ZE. "INNERSs I would presume tha t the requia tions v-6 ALDERSoN REPoMTING COMPANY,!NC.
400 VIRGANIA AVE, S.W. WA84414GToN. D.C. 20024 (202) 554 2346
28 1
could say somewhere elre that for this particular event you 2
don't have to do a Fact 100 calculation.
Are you proposing 3
that the rule should to de it?
4 4R. RICKWIT:
! think tha rule should flatly say l
5 tha t.
6 MR. CUNNINGHAM:
Lai se back up.
I scree with the 7
lawyers' analysis of the problem.
Once the Com. mission 8
decides whether or not to spply Part 100 here, we can make 9
the specific statement in Part 100 that ATWS doesn't apply.
10 XR. MINNERS:
The words on the criterion for core 11 damaqa could have some words, "In lieu of ? art 100, do 12 this.*
Is that what you are succesting?
13 MR. ?ICKWI!4 Yes, and I thought that was the
('-
14 Conr;ission's view as expressed at the last neeting.
15 COMMISSIONEE GILINEXY Are we then qcing to be in 16 the position of laying on all these requirements to deal 17' with accidents tha t we don ' t regard as credible?
18 ER. *lINNIRS:
I would not say it the way he said 19 it.
He would say that it is not credible, and I wouldn 't 20 vant to make that statement.
If you have in the rule, 21 obviously you - believe that it is credible.
22 I would just say, "In lieu of doing a Part 100 23 calculation, or meeting Part 100, do this," which would be-(.
24 to meet the fuel failure criterion we have in there.
The 25 initial recoerendation was that. we put the distinction.
s_-
ALDERSON REPORTING COMPANY, INC, 400 VWIG4NIA AVL S.W., WASHINGTON, D.C. 20024 (202) 554-2346
29 1
MR. BICKWITs But you see ceing beyond tha t.
You 2
e.re saying that at this point it is ycur understandino tha t 3
the Comm.ission does not regard this as a credible accident 4
under current law for purposes of Part 100.
5 MR. MINNEES:
I would presune there would have tc 6
he some procedure by which people would decide.
7 CHAI22AN AHEARNE:
What he is saying is that th e 8
staff's judgment is that the correct approach to do the 9
treatment of the ATWS is throuch the proposed rula.
10 Therefore, it is not necessary to put it in the Part 100.
11 He is not saying whether or not it should be included in a 12 bin called " credible," or "not credible."
13 ME. BICK'4ITs I think you are also saying that
(
14 under current law, until the rule becones effective, that it 15 is the Commission's posture in your view tnat these kinds of 16 accidents are not credible accidents within the meanine of 17 Part 100.
18 ER. XINNE3Sa I would not interpret it that way.
l 19 COMMISSIONE3 HENDRIE:
Does anybody recall the l
20 current practice, or the practice of the last few years?
21 ATWS comes up periodically at hearings, and there has to be 22 some treatment of it.
Because it has been for some time one 23 of the so-called generic safety issues, I expect the staff's
(
24 argument in hearings is that it is not nececsary to address l
25 in the context of this particular proceeding because it is F
l ALDERSoN REPORTING COMPANY,INC, 400 VIRINNIA AVE S.W WASHINGTON. O.C. 20024 (202) 554-2346
30 1
being considered on a generic basis by the Co?nission, and 2
SO On.
3 I don't know how all that verks out.
I don't 4
recall any specific ATWS connected requirenent: in a case.
5 MR. MAISCH In CP cases, it is liticated in the i
var you have described, namely, the position of the sta ff 7
would be that this is a matter that can b9 taken care of 8
before the plant goes into operation.
9 CHAIRMAN AHEARNIs What if it is a renevel case?
10 MR. MALSCHs Then they have to decice if something 11 needs to be done now.
I am not sure what the rationale 12 would be, either that the accident is not credible, or that 13 it is in a doubtful category and it can wait a few years 14 until the generic resolution takes hold.
I as not sure what 15 approach it sculd be.
16 MR. MINNERSa We are requiring licenrees to have 17 procedures that deal with ATWS, and maybe that weakens our 18 argument a little bit that we in some way rec =gnire that it 19 is crecicle.
20 I think the staff would cay, in licht of the TMI, 21 ve have procedures to take care of ceremelt accidents, which 22 ve don't think are credible either.
It is just prudent to 23 do a relatively simple thing, to have pagar proceduras which 24 vill take care of things which are beyond " credible."
x 25 MR. 91CXWIT:
But you have a design criterion O
ALDER 4 SON REPORTING CoWPANY,INC, 400 VIRGINIA AVE. S.W. WASNWeGTON. D.C. 20024 (202) 564-2346
39 1
under which ycu can impose AT"S requirements, quite apart 2
from Fart 100.
3
- 52. MINNERS:
In the rules now?
4 MR. BICXVIT:
Yes.
5 YR. ' INNERS:
What would you quote for thst?
8 MR. RICKWITs Criterion 29.
7
- 13. DINNERS:
I guess it has not been.
8 COMMISSIONER HENDRIE:
What is 297 9
MR. ?!CKWIT:
Protection acainst anticipated 10 oparational occurrences.
11
- 33. 3 INNERS:
That would be a very literal 12 interpretation of that criterion, I think.
13 COMOISSIONER HENDRIE:
We have not plucced %TWS 14 under that.
15
- 13. SICKWIT You hsve to have some basis for the 16 requirements that you impose.
It either has to be the 17 design criteria, or the Part 100.
I don 't know how you 18 impose them otherwise.
~
19 MR. tINFERS:
The staff has gone thrcunh in 20 exercise, which it has not come down yet on, which tries to 21 say which of the T3! requirements are based on the rules, 22 and which 3ra not.
23 CHAIRMAN AHEARNE:
I guess, if the Commission does 24 agree with this spproach, you would then put in some 25 language embedded directly into the rule which would sa y ALDGtSome REPofmpeG COMPANY.1NC, 400 VWIGaseA Avt. S.W. WASMefeGToN. D.C. 20024 1202) 554-2346
32 1
that Part 100 calculations need not be done.
2 MR. MINUEES:
If that is a better way of doing, 3
that is whst we will do.
It is.
5 COMMIS" TONER GIIINSKY:
I guess ! am still 6
surprised that the basic Pa rt 100 calculation dcesn't cover 7
the possibilities that may come up in an AT*45, or that it 8
cannot be modified in sone way in a relatively simple way to 9
include them, as opposed to attaching the Part 100 to calculation specifically to this requirement in the way you 11 would with a rod drop accident, or somethinc..
12 MR. NINNESS:
It could be modified.
fou have to 13 reinterpret Part 100, and then when you ask people to do i
14 Part 100 calculations, you would have to say, " Consider 15 ATWS, and then do your calculation."
1 presume that the 16 procedure would be then that you would put out another Reo 17 Guide which gave a source term and all the other assumptions 18 that went along with a Part 100 calculation.
i 19 COMY!SSIONER GILINSKYa In the basic document, the j
20 technical document whose number I forget, what assumptions l
l 21 go along with that beyond simply. the amount of radioactive L
22 aaterial that is released.
Are there assumptions about i
23 pressure differentials, and so on.
We presume how the pressure stays 25 up, how the pressure stayr up, what the leak rate of the i
i l
ALDERSoN REPORTING COMPANY,INC, 400 VIROWBA AVE., S.W., WASHINGTON. D.C. 20024 (202) 564-2346
.~.
j 33 1
con tainm en t is, whether the ccre sprays are en cr off, how 2
much of the activity is absorbed in the water, things like 3
tha t.
It is a partial list.
I am not sure that it is a 4
complete list.
5 3ut there are quite a few other assumptions, it is 6
not just the source ters.
You have a let of assumptions 7
about meteorology.
8 COMMISSIGNER HENDRII:
Fission product forn.
9 "R.
MINNERS:
Yes, and whether you get any aerosol 10 or not.
11 COMMISSIONER GILINSKY:
That isn't changed by the 12 accident arising out of an ATWS or something else, doer it?
13 MR. MINNERS:
I an not that much of an expert.
14 COMM!SSIONER GILINSKY4 The me teorology is 15 meteorology and whatever comes out is' fed into whatever 16 meteorology you are using.
17 MR. MINNERS:
It would depend on what chemical 18 form it would he in.
It depends on the chemical i
19 environment.
If it is in a reducing, exidizing in the l
20 atmosphere, you are. going to get different iodines, and 1
21 things like that.
22 I am not sure if an ATWS environment is different 23 than a LOCA environment.
I have not icoked at it.
You are 24 certainly going to have different temperatures that things 25 are going to happen in.
ALDERSON REPORTING COMPANY. INC.
400 VIRCHA AVE., S.W., WASHINGTON. O.C. 20024 (202) 554-2346
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COMMISSIONES GIIINSKY:
You think an ATWS 2
initiated seltdown is substantially less likely than a LOCA 3
initiated meltdown, a pipe break initiated neltdown?
4
- 53. ZINNERS:
An AT"5 meltdown?
5 C0!MISSIONER GIIINSX Y:
In other verds, resulting 8
in the kind of radioactivity release that is spcken of in 7
TID, or whatever the number is.
8 COMMISSICNER HENDRIE:
Before or after 9
implementation of some array of fixes?
to COM5ISSIONER GILINSKY:
I guess I would say 11 after.
12
- 33. 3 INNERS:
Our purpose is to make the 13 probability of an ATWS seltdown about the same as the other i
14 significant sequences from transients and from small LOCAs.
15 COMMISSIONEE GIIINSKY.
Eight, but I mean the i
. purpose of Apoendix Y is to substantially reduce the 18 r
i 17 probability of fission product releases resultino from an 18-accident that started with a pipe break.
' ~
19 MR. MINNERS:
That probability ir on the order of I
20 10 to the minus 5 per reactor year, and tha t is what we 21 would like to make the ATWS probsbility being about, 10 to i
22 the m inus 5.
l I
23 COMMISSIONER _GI1!NSK!:
Suppose that they are both i
24 comparable, uhy shou 2cn't the umbrella calculation, which is 25 the basic Part 100 calculation, deal with both cf them?
ALDERSON REPORTING COMPANY. INC, 400 vinGNA AVE. SJ#, WASHINGTON, D.C. 20024 (202) 554-2346
35 1
.T E. YINNERS:
Because I don't nee what purpose it 2
accomplishes.
You can do rhe calculation and find out that 3
you got a dose off-site, and my answer to that is, "So what?
4 How does that affect the design of the plan t?"
5 MR. YURLEY:
I don't know if I can clear rhe 8
confusion, but perhaps I can.
7 Most of the risk analyses that I have seen, going 8
back to WASH-1u00, show that ATWS is a significant 9
contributor to risk due to coremelt.
So there are a nu mber 10 of sequences not only of LOCA but va rious kinds of LCCAs, as 11 vell ac ATWS, as well as accidents that bypass the 12 containment altogether like if someone leaves some valves 13 open, the so-called, system interfacing LCCA.
14 Ncw, not all of these accidents that you can 15 imagine are covered by a Part 100 calculation.
The Part 100 16 s really a decign basis for the containment, if you will.
l 17 So it dumps out molten core into containment, and then says, i
18 carry out the calculation f rom then on, and hold the doses 19 down to certain levels.
Those doses, then, you back l
20 calculate to find o..t what hardware you have to put on the 21 containment.
l 22 fy understandin4 is that it was never meant to 1
23 cover all classes of ceremelt accidents that lead to 24 off-site doses.
l 25 COMHISSIONER GIIINSKY:
I think that is richt, but l
l l
l.
N.DERSON REPORTING COMPNff,INC,
36 1
it does say that the fission product release should not be accident that is I am paraphrasing 2
exceeded by any 4
3 considered credible.
4 MR. MURiEY:
Conmissioner Gilinsky, the notion of 5
credibility, I don ' t k now, but I think stems from the old 6
WASH-7u0 calculation back in 1957, and its update in the 7
mid-50s where it was assumed that the containmant was lost 8
altogether.
There was no c6ntainment integrity at all.
9 Therefore, at least in the Part 100 calculation, one is 10 allowed to assume the integrity of the containment and the 11 engineered safety features, and that could be what is meant 12 by credibility and non-credibility.
13 CO!MISSIONE3 GIIINSKY:
I don't much like.the term 14
" credible," but just using it as a term of art for the 15 moment i
16 M3. EICKWIT:
I think you are stuck with it.
as defining those 17 COEMISSIONER GILINSKY:
18 accidents we take into account seriaqsly ja licensing
~
i 19 reactors, what Part 100 seems to be saying is, when ycu i
20 impose this requiremen t on the containment, you have a 21 fission product release which is no less than that from any 22 of the events that you take account of.
What ycu seem to te j
23 tellina me is that when we are all through with this, we 24 vill have an ATWS to the Ocint where it is under control to 25 the same extent as other sericus events.
ALDERSoN REPORTING CCMPANY. INC.
400 VIRGNA AVE S.W WASl44NGToN. D.C. 20024 (202) 554-2345
37 1
So ! vender why we shculdn't tr?at that On the 2
same basis as we de others.
- ust say I a: a little 3
surprised still that the basic Fart 100 calculatien dcesn't 4
cover it.
.. su 4..4
..w..
5 C, v..v. e. u-- a s r =..
u.r i. * :... r
.v. ~ o 7.. e.
s._
u.
6 following sense:
Er the time you assu:e a fission prcduct 7
release to the containment, with all the noble cases, half 8
of the radioicdinn, and 1 percent of the solid fission 9
products, you hava inferred a core datage situa tien which is 10 essentially a.ccre =elt down with regard :: the releare 11 fractions, which is all the rule talks abcut.
12 The rule dcesn't say anythin; ahout that het stuff 13 then verking its var any place elre, but just the release cf 14 fission products.
Fron that standpoint, the classic 15 calculation f cr containment tightness ;ur;cses, and seeing 16 whether it meets the site guideline deses probably pretty 17 vell ccvery everything.
18-37 the ti=e you seit devn a core, and get all of 19 the gases out of it, and to on, with regard to release cf 20 fission products, you have gene a pretty long way.
Yaybe 21 not everything is physically ;cssible, but you have pretty 22 vell covered all of these things.
23
'Jhat Warren is pointing out, however, is that when 24 you get'down to tas details fros.that point en, you have the 25 fission. products in the centainment, now we assune tha ALDERSON REPORTING COMPANY. INC, 400 VWIGMA AVE, S.W. WASHINGTON. o.C. 20024 (20 2 554-2346
38 1
con tainnent pressure, the leak rate at that pressure, etc.
2 Is the prisary and secondary leakage in er out cf the 3
secondary, etc.
Then there cet to be differences between 4
the classic calrulation, and particular accident routes like 5
this one.
6 COMMISSIONEE GIIINS Y:
There you are talking 7
about the TID dccu=ent, and the prescriptions that one gets 8
f or calcula ting releases out of the centainnent..
9 CC3MISS!ONEE HENDRIE:
Yes.
10 005MISSICNER GIIINSKY:
Those details are net in 11 the rule so far as I can tell.
12 I guess what I am saying here is that if --
13 CGM!!SSIGNIE HENDRIE:
Rut the lan;uage of the
/
14 rule just is, if there is another accident that has got a 15 bigger release of fission production than the one you had in l
16 mind, use the other one.
17 COMMISSIONER GILINSKY.
Right.
l 18 COMFISSIGNIR HENDRIE:
All I am-saying is that the l
l 19 release of fission products in the classic, I think that is 20 a reasonable one.
21 CCEMISSIONER GILINSKY:
If that is the case, I r
22 think it would be preferable to trea t all thase va ricus t
23 accidents more or less en a comparable basis.
24 CHAIEMAN AHEARNE:
I thought you were raying 25 earlier tha t due to sc e features you could get releares ALDERSoN REPORTING COMPANY,INC, a vW4G##A AVE, S.W., WASM? ton, D.C. 20024 (202) 554-2345
39 1
outside con tainment.
2 COMMISSIONER HENDEII:
I am not talking about 3
releases outside containment.
This is just from the fuel.
4 COMMISSIONER CILINSKY:
Yes.
5 COMMISSIGNER HENDPIEs The rule dces not say 6
releases from the containnent, it just says releases.
7 COMMISSIONER GILINSK!:
I think it would be 8
preferable to treat these various accidents on a comparable 9
basis, since they are of comparable importance.
If, in 10
. fact, as I suspect the Part 100 release covers it, it would 11 sake se feel better, let's put it that wa y.
12 MR. MINNERS:
The rule does not ignore off-site 13 doses.
It'just does it generically.
It says, the staff has 14 done a calculation which it has confidence covers the 15 reactor's generic leak if you limit fuel damage to this 16 certain prescribed anount.
In lieu of doing a specific 17 individual calculation for each plant, va vill tak e that 18 generic calculation and say tha t it applies.
19 COMMISSICNER GIIINSKY:
Are you saying then that 20 you have ssde a :siculation which tells you that Part 100, 21 in fact, covers this contingency, and therefers nothing 22 further is required ?
23 ME. MINNEBS:
If you mean by " covers this N
24 con tingency" that'vith the fuel damage ~scecified in the 25 proposed rule, the staff generic calculations are less than ALDERSoN REPOfmMG COMPANY.INC.
400 VW4GaNLA AVE. S.W. WASNINGToN, D.C. 20024 (20 D 554-2345
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the Part 100 dose guidelines.
2 00EMISSIONE3 GILINSKY:
Why do you need any 3
further exemption from Part 1007 4
- 35. MINNERS:
Why do it twice?
5 C0d5ISSICNEE GIIINSKY:
What I an sayinc is, why 6
would an additional calcula tion be necessary without an 7
exemption?
8 COE5ISSIONEE HENDE!E:
His feeling is, and I agree 9
with him, that once you identify this ATWS as something to 10 be protectad aqsinst, you have added it to the list of 11 accidents to be considered, and poople are going to want to 12 see a dose calculation in the sceident analysis part of the 13 safety report.
14 COMYISSICNE3 GIIINSKY:
But doesn't their generic 15 calculation take care of that?
16 C035ISSIONER HE8DEII:
The classic ceneric 17 calculation, the classic Part 100 big release, in effect, 18 because it gives biqqer doses outside, also covers a whole 19 variety of other accidents for which in fact specific 20 analyses are nevertheless required just to see how they come 21 out.
22 What Warren is saying is that he has confidence 23 that.3 ch the fixes they are proposing for A!WS, it will
(_ -
24 come out in all esses to be within those Fart 100 25 guidelines, anii he is proposing to offer relief to licensees ALDER $cM REPoRUNG COMPANY,INC, 400 VIRGINGA AVE S.W. WASHINGTON. D.C. 20024 (20D 554-2346
41 1
from having to make specific calculations for each plant.
2 COMMISSIONER GIIINE!Cf:
It seems to me that an 3
important part of that argument is a display of the 4
calculation that with these requirements you will not exceed 5
named. releases that are taken account of under Part 100 6
routinely.
7 CHAIRMAN AHEAENE:
I would interject at this point 8
that I think we have spent 40 minutes on this issue.
I am 9
not saying we have reached resolution, because I don't think 10 we have, but I would put that aside for a minute because I 11 think
.e will probably end having to have the staff come 12 back with something on that point.
I don't see us closing 13 on that.
t <4 fR. MINNEES4 As to the suggested changes to the l
l 15 rule, on page 20 one or the suggested changes was to change l
16 the criterion from the AEME Code Service Linit C to AEME l
l 17 Code Service Limit D.
This is discussed in some detail in 18 enclosure 1, which iz attached to the Janua ry 29 memo.
19 Ihe primary point of tha t enclosure is that 20 although there is some functional relationship between the 21 probability of an accident and what acceptance criteria you 22 use, there is no clear precedent.
When you go back and look i
23 at th em, they are all over the place.
24 We have some very stringent criteria for low 25 probability accidents, and I think vice versa.
i ALDERSON REPORTING COMPANY,INC, 400 VIRONA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2346
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Once again, if you go talk to a stress analyst, he 2
cannot give you any good quantitative or even gcod 3
qualitative relationship between the probability of failure 4
and the pressure stress.
It is mostly just qualitative 5
talk.
6 CHAISMAN AHEARNE:
Say that again.
7
- 23. dINN"ES:
If you go talk to a stress analyst, 8
and ask his what the probability of failure is versus 9
pressure, I don't think you will get a quantitative 10 relationship.
11 CHAIEMA:I AHEARNE:
If it is a simple structure, 12 you will.
You will ask him what he means by failure, and he 13 will describe it instead in percentage deformation, and how 14 auch deformation is a function of what stress.
15
- 22. YIN::ERSs I think c?tastrophic failure is what 16 we-mean.
If you ask his what is the probability of
. 17 catastrophic failure at the design pressure versus the 18 probability of catastrophic failure at twice the design 19 pressure, the people I have talked to say that there isn't 20 such difference.
They can't tell you whether the 21 probability changes by a f acter of two or wha tever.
22-There aren't any good data which ;ive yeu a 23 quantitative relationship between strass and failure.
24 CHAIRMAN AHE)RNE:
Part of the difficulty when you 25 are adcremsing what you are really andressine here is the ALDERSGN REPORTING COMPANY. INC.
4 400 VIRGINIA AVE., S.W WASHINGTON. 0.C. 20024 (202) 554-2346
43 1
complexity of the structure that you tre acv talkinc about 2
failing to the f ailure modes t:.ec selves w'hich are extremely 3
hard to calculate.
4 M2. MINNERS:
That is part of it, yes.
5 CHAIRMAN AFEARNE:
The mest complex the structura, 6
the more uncertain ycu are of the way the pressure is going 7
to be applied, then certainly the level of uncertainty you 8
are talking about br. gins to increase, that is true.
9 MR. MINNE35:
Sur I think they would say that the 10 probability of f ailure at design pressure is zero, and the 11 probability of failure at ultimate strength is one, and how 12 it varies between those points nobody can tell you.
13 CHAIRMAN AHEARNE:
Particularly Af they can say 14 what they mean by design pressure and ultimate strength, 15 becausa then they will define it to be those two.
13 fR. MINNESS:
All I was trying to point out is 17 that there is no direc: relationship.
There is some kind of 18 a qualitative indica tion t..at as you get the icwer 19 probability events, you can have a little less conservative 20 criteria, but it is very hard to quantify.
21 I don't see much difference in that respect 22 between level C and level 0.
23 CHAIEMAN AHE.;EN E:
There is in respect to the 24 final requiremente you_have laid on the equipment.
25 ME. %INNEES.
Obviously, level 0 would allow you ALDERSON REPORTING COMPANY,INC, 400 VIRGi?ilA AVE., S.W WASHINGTON. D.C. 20024 (202) 564-2348
un 1
to co to highar pressures than level C.
2 CHAIEMAN AHEA3SE:
That is true.
3' M3. MINNE35:
Which is a :
- uction in 4
con serva tism, which is perfectly all right.
It is just 5
defining how safe is safe enough.
8 CHAIEXAN AHEA3HE:
That ic true.
7
- 33. MINNEES:
I think you can gain that reduction 8
in conservatis: easier by changes in the evaluation if yon 9
vant to do that, without having to ic
'o the level D.
10 My objection to level 7 would be that it would be 11 very difficult criterien to adsinister because you Jould
~
12 have to do a lot of sta-if revie w and snalysis cf plastic 13 stresses in vessels that we vculd need in the level D.
It 14 would be a lot of work for the staff to review all this, and 15 a lot of work for the licensees to demonstrate that they had 18 set level D.
17 CHAI3EAN AHEARNE:
let me pick up on your second 18 point.
If the licensee looked at the requirement to neet 19 level D and concluded tha t that is really an awful lot of 20 work, he can certainly come in and say "I have met level 21 C,
and ! will show you," and thereby waive all the work th a t 22 he would have to do to show lev el D.
If his level C is 23 -stricter than level 7,
that would be then acceptable, 24 right?
25 M3. MINNE35:
It would be, tut it wculd not
. ALDERSON REPORTING CoMPAN't,IMC, 400 VIRGINIA AVE, S.W. WASHINGTON. O.C. 20024 C.T2) 554 2346
45 1
accomplish your purpose.
2 CHAIRMAN AHEARNE:
Wait.
You said two things a
3 lot of 11:ansee work, and a lot of staff review.
I an just 4
pointing out that if the licensee really felt that showinc 5
to level D is too such work, he is perfec'cly allowed to do 6
level C.
7 COMMISSIONER G:lINSKY:
You sound pretty attached 8
to level D, John.
9 (General laughter.)
10 3R. MINNERS:
But if that is what the licensee is 11 going to do, bring in level C, why put level D in the rule 12 if nobody is going to ao to it.
Why not put level.C in.
13 CHAIREAN AHE*.RNEs Because I would suspect that we 14 ought to be trying to do the best as we can to write 15 regulations that are reasonable.
If as part of that 16 rea sonableness we say, it is too much work for the licensee 17 to do this less conservative approach, it 10 clearly his 18 option to do th at more work, or do the less work.
-19 I wanted to go back to that first part, but I will 20 di it later because Vic has a question.
21 COMMISSIONER GILINSKY:
Could you give some 22 examples of engineering practice where level D is what is 23 written-in+o :he rules or standards?
24 dR. TINNERS:
Level D, in my understandine, is for 25 things like thermal loads and short-term loadc that are not
/
' ALDt E3oN REPCAtTING COMPANY. INC.
400 vlRGINIA AVE. L'.W., WASHWGToN. D.C. 20024 (202) 554-2345
46 1
at pervasive pressure loa d.
Ihat is what the level D is 2
meant for.
3 CHAIRMAN AREARNE:
'Eo w often do you argue with the 4
applica tion of levels C and D?
5
- 53. MINNERS:
I am not a stress analyst.
6 COMMISSIONER GILINSKY:
I just would lik e a 7
feeling for the kinds of places where level D is accepted.
8 CHAIRMAN AHEARNE:
Does anybody want to vol un tee r 9
as a stress analyst expert?
10 00M3ISSIONER HEN,DRIE:
There used to be a set of 11 things called " faulted conditions."
12 MR. MINNERS:
Ihey wanted to get away from that, 13 and they called them level C and D, so there was not i
14 association with probability.
15 COEMISSIONER HENDRIE:
Now we have normal, upset, 18 emergency.=
17 MR. LIAW:
To answer Commissioner Gilinsky's l
18 question of examples of places allowed to level D for 19 pressure in determining the failure criteria or with 20 d eg rada tion.
Infaty emergency and breaker component four.
l l
21 COMMISSIONER GILINSKYs Would you explain that a 22 little more?
23 MR. IIAW:
When we determine the maximum amount of 24 degradation or the minlaua coefficients required over time, s
25 we allow up to Level D.
~
ALDEA5cN REPORTING COMPANY,INC, 400 VIRGNA AVE S.W WASHINGTON, D.C. 20024 (202) 554-2346
l 47 1
1 COMMISSIONER HENDRIE:
On the stresses?
2 ME. LIAW:
Yes, stresses.
l 3
COMMISSIONEE HENDRIE; You still have a f actor of j
4 1.4 nargin.
5 MR. MI?NEES:
That is in the enclosure.
In the 6
steam break accident, you get the same pressure differential 7
as in AIWS.
If you have a failed tube with a crack in it, 8
ve do allow that to do ecsentially level I.
I don't think 9
it is specifically level D, but they do a lot of tests, and 10 based on the test data ve say whether the two will fail.
11 ER. LIAW:
If they can come and show us that they 12 have met the ASME code level D, they don't need to do a 13 test.
Anything above that, we allow then to do the t=st to 14 quantify the safety f actor 3 over the normal operation and 15 pressure.
One more example is the LOCA analysis with 16 essentially f aulty design condition, ve are then up to level 17 D.
18 Even though Warren says the pressure is somewhat 19 different 20 C0!XISSIGNIS GILINSKY:
Just where is level C 21 accepted?
22 ME. LIAW:
Fcr the condition design?
23 COMEISSIONER GILINSKY:
Is the pipe still expected 24 to maintain pressure?
25
- 33. LIAW Yes.
ALDERSON REPoRTINo COMPANY,INC.
400 VIRGMA AVE., S.W. WASHeMGToN. D.C. 20024 (202) 554-2346
u8 1
- 33. EI5NEES:
You mean f or earthquake loading ?
2
- 33. LIAW:
Just for a combination of LOCA loading 3
and earthquake loading.
'Te require some kind of appropriate 4
combination of it.
But in the ASME Code basically is this, 5
level D gives you some quarantee of integrity, and what the 8
proposed alternate level, in addition to that, requires some 7
demonstration of not excessive defornation -- There is a 8
combination of two of them.
9 OGMMISSIONER HINDEII:
That ir level C plus to o pe rability.
11 5R. LIAW :
That is what is stated in the rule.
12 ER. MINNERS:
So for piping, which is a 13 ceabination of earthquake and local loads, which is an 14 extremely impossible event, it is an artifact of the way we 15 do business, which I think we have tried to change.
I don't 16 think that chat really represents an accident.
We don't 17 analyze an accident of earthquake and a LCCA.
It is not an 18 analyzed accident.
l r
19 ME. LIAW:
T h'a t 1.s right.
20 1R. MINNERS:
We analyze the piping fer that load j
21 because it is a convenien t thing to do.
22 CO3MISSIONER HINERIIt In those structuras.
23 MR. MINNEES:
You m e r.n t what the Commission's 24 applica tions were ?
ss 25 COMMISSIONES GILINSKY:
I was actually thinking of
(..
ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.w, wAsweNGToN. O.C. 20024 (202) 554-2345
4@
1 the generic practice more generally, but it dces give me 2
sen. 10;a.
r 3
MR. MINNERS4 The other point I would like te make 4
is that I am not sure that by having a level D that you 5
would change the allowable pressures very much because there 8
are other factors that may limit you, se:h as the 7
requirement for operability of ve.Ives and pumps.
8 We are going to have probles; with bbited 9
conditions, primarily the head, you will get the bolt to 10 stretch, and you vill lose integrity, and you will have 11 water beina shot out of the bolted connections, which is 12 really not too well analyced.
I would think that you would 13 vant to preclude having bolted connections open during an 14 ATWS event.
15 COMFISSIONER GILINSKY4 Certainly, it would be a 18 great boon to the consultants and experts en plastic 17 deformation.
18 MR. MINNE35:
Chairman Ahearne, on the point of 19 rea so na bleness, I think we should have reasonable l
20 regulations, but the reasonableness is a combination of the 21 acceptance criteria and the evaluation model.
Ve have to 22 look at them both tocather because they are meaningless 23 separately.
I 24 7e think that combining level C with a certain s
25 conservatives in the evaluation model can give you the s
ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
50 1
reasonableness you want at a lot less cost and trouble to 2
the industry and the staff than by going to level D.
3 CH AIRM A'J AHEARNE:
When you say a lot less trouble 4
to the staff, would you expand on that a little bit?
5
- 33. MINNERS:
It is mostly analysis.
If people 6
come in with level D analyses, we would have to analyze them 7
and review them.
It is a plastic analysis, and it is jrst a 8
more difficult thing to look at and te do.
9 In the past our staff has accepted a level C based 10 on a pressure ratio from the design stresses because it is 11 wtthin the elastic range.
In some cases, they have looked 12 at particular components in more details.
But because it is an elastic analysis they are willing to take,.it is a very 13 i' -
14 simple thing to do.
15 CEAIRMAN AHEARNE:
Dc you have any sense of what 18 the impact gs far as industry equipment is concerned, coinc 17 f rom a level D to a level C,,or vice versa?
18 MR. MIM5ERS:
Impact on equipment in what way?
19 CHAIRMAN AHEARNE:
How wide, how many items would 20 not be able to meet che C but could meet D?
21 MR. MINNERS:
The one example is the steam 22 generator tube that ha ve flaws in them.
That is the primary 23 example.
n 24 The way the rule was written, we did not limit it 25 to steam generator tubes.
If there are particular n,
ALDERSoN REPORTING COMPANY,INC*
400 VIRGINIA AVE, S.W. WASNINGTON. D.C. 20024 (202) 554-2345
t 51 1
components that people want to q>
beyond level C, we said,
-2 fine, if you do some tests and give us a little more 3
demonstration, we will accept it.
4 I think generally there are critical points.
I 5
think one of the critical points is the control rod housing 6
has been placed where you would reach the hichest stresses, 7
and the body of the vessel may be well within the level C 8
limits, but the control rod housing would be below the 9 ' point, and we would allow them to do some tests on such a 10 local component, and accept essentially a quarantee.
11 CHAIRMAN AHEARNE:
Since you were really convinced 12 that level C is the appropriate place to be, you are not 13 really sure what the impact is if you relax that to D as far 14 as the difference in the difficulty in meeting as far as 15 equipment design, available equipment?
16 MR. MINNERSa I would presume, considering that 17 B&W calculation get up to quite high pressures, that at l
18 those pressures everything would be at level D.
People l
l 19 would be sayinc, look at a vessel at level D.
There is a L
20 theoretical possibility that somebody will say, " Accept a i
l 21 vessel that is at level D stresses."
l 22 "0MMISSIONER GIIINSKYs We were talking earlier 23 about the probability of f ailure f rom rero des' Nn pressure 24 to ultimate stress.
It seems to me that the uncertainties 25 go up quite a bit as you yield.
Just a lot less is known, ALDER $oN REPORTING CoMPANV,IN%
400 VW4G##A AVE, S.W. WASHWGToN. D.C. 20024 (202) 554-2345
52 1
and we are a lot less comfortable with the results once you 2
pass the elastic range.
3 MR. MINNERS:
If th9t is a point of interest here, 4
ve could probably get -- I am not sure that it would be an 5
absolute, 100 percent complete list, but I could ask the 6
people who have done the re view in the past to give me a 7
list of the components that are limiting in order to have a a
limit and come back to that, if that is what you would 9
like.
10 CHAIRMAN AHEARNE:
Clcarly it is of interest.
11 MR. MINNERS:
Oka y.
12 Ihe other suggestions had to do with, first of 13 all, with plants.
14 CHAIRMAN AHEARNE:
I didn't disagree with your 15 interpretations that you put into your letter.
16 MR. MINNERS:
We will leave the rule that we would 17 be villing to look at this stuff, but it has to be justified 18 by the licensees before we would accept it.
l 19 CHAIRMAN AHEARNE:
All right.
i l
20 MR. MINSERS:
For current plants, I believe your l
21 suggestion was the same as the staff's which was to have a 22 prevention system for the scram system and to mitigate most 23 -of the accidents.
It is about the same.
There is not much 24 difference between the two.
25 The only thing that was not quite clear is your ALDER $oN REPORTING COMPANY. INC.
400 VIRGINGA AVE., S.W., WASHINGTON. D.C. 20024 (202) 564-2346
~
53 1
exception of Westinghouse.
We did it on a slightly 2
different ba.-is than I think I understood you.
3 CHAIRMAN AHEARYE I have no probles with your 4
approach.
j 5
NR. MINNERS:
'?he utilities in their petition 6
would suggest that current plants have prevention only, in 7
fact even less than what the staff vould suggest in 8
alternative 2(a).
Other people have made similar l
l 9
suggestions.
10 We would think that if the rule were published now l
11 all of these variations should be considered in adopting the 12 final rule, and would be treated as comments on the proposed l
l 13 rule.
14 The last iten was future plants, and I think 15 Chairman Ahearne's suggestica was that future plants be 16 treated the same as current plants.
17 CHAIR 5AN AHEARNE:
Yes.
That was the point.
18 3R. KINNEES:
I think the industry would say th a t 19 future plants might have some more requirements, that those 20 would be determine in an overview, a big-picture type thing 21 by the degraded cere rulemaking or the safety coal 22 rulemaking, or some form like that.
You would look at the 23 overall safety effects before you went to any more 24 requirements for ATWS.
s, 25 I think the staff still would recommend that we l
l-As.onRsON REPoRTWG COMPANY. INC,
~
400 VmGNAA AVE., S.W, WASHMGTON. D.C. 20024 (202) $64 2346
Su 1
have more sitigation features on the never plants just on 2
two things.
Cne thing we probably have in the btck of our 3
mind a safety goal, and we think that to attain that 4
reanonable assurance that new plants can do it and therefore 5
should do it, and therefore the total safety of all of the 6
reactors would neet.What we have in sind for a safety goal.
7 CHAI3EAN AEEA33E:
If I can address that point 8
first.
That will be a laudible connection.
However, that 9
is sufficiently icplicitly that I had difficulty with it.
10 So my arquzent obviously is tha t, given the grea t debate on 11 the uncertainty with respect to the developnent of the AT*JS, 12 it appeared to se that our case was sound on reaching 13 certain levels of requirements, and it was hard enough to t
14 fira up and to take position.
15 Maving taken that position, I had great difficulty 16 seeing how I could then say, however, in the future, 17 additional requirements have to be laid on.
That is where I 18 stopped.
19 The argument is that we have a sense that in the 20 future we are going to tigh ten up all across the board based 21 upon an evolution of a safety goal.
I guess we ought to say 21 that explicitly.
I, myself, couldn't support it because I 23 don't know where that evolutionary safety goal vill be.
But 24 at least with haven't stated it explicitly.
s.
25
- 33. MINNEES:
The other thing I would like to m
ALDERSON REPORTING CoMPMeY. INC, 400 VIReseA AVE S.W. WASHeeGTON. O.C. 20024 (202 554-2346
55 1
address a little bit is, although the staff has not used it 2
completely in its recommendation, it has looked at the value 3
impact.
There have been comments on the value impact that 4
that does not justify going to the post-8u requirenents, and 5
that the incremental analysis would show that.
6 I would just like to point out that if you include 7
the Browns Ferry event, presume it was a full failure and it 8
applies only to GE BWRs, that would increase our estimate of 9
the probability by about a factor of 5 in going to the fix 10 for current plants to the fix f or f uture plan ts.
On that 11 basis, I think you would get a positive incremental value 12 impact by doing that.
13 CHAIRMAN AHEARNEs Eut I would think that the rest 14 of the argument would then be that you would have to flow 15 back into current plants, too.
You can either take the 16 event or not.
17 MR. MINNERS:
The probability associated with 18 that, I think that is the point is trying to be made.
It 19 would show that there was even a greater incremental benefit 20 in going from 2(a) to 3(a), but it would show that there 21 would still be a positive incremental benefit of going from 22 3(a) to 4(a), which the present analysis 1f you only show 23 one failure doesn't show.
24 I think that was some of the a rgument, primarily 25 by industry, that if_you did an incremental analysis it ALDERSoN REPORTING C'sMPANY,INC.
400 VWNNNIA AVE., S.W, WASH 4NGToN. O.C. 20024 (202) 564-2345
56 1
showed that you weren't getting any more safety for your 2
dollar.
Most safety was by going to alternative 3(a), and 3
when you vent to an alternative 4(a) you were not getting 4
the value for your dollar.
5 I as trying to say that this just depends on how 6
you view how sany failures have occurred, and what ther 7
apply to.
8 9
10 l
11 i
12 13 14 15 16' 17 18 19 20 21 22 23 24 25 ALDERSON REPofmMG COMPANY. INC.
400 VmGINIA AVE S.W. WASHueG70N. O.C. 20024 (202) $64-2346
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- 13. ZINNERS:
The last thing I would like to 2
discuss, you asked a questien about high population 3
population sites.
The letter just said that the staff 4
thought what we would do would be apply essentially the 5
post '84 requirements to the high population sites.
ACRS 8
had some very specific suqqestions.
j l
7 CHA!RMAN AHEARNEs I guess, in a way what your 8
letter says that you believe that the treatment is i
9 appropriate.
Wha t it says is that additional requirements 10 may be appropriate in those existing power plants that are 11 considered high risk site or for a comoination of population l
12 density, etc., identification subject to another Commission 13 action, and. any additional ATWS requirements would be 14 subsequently considered. that is the way you treated that, i
15 and at the moment I would be villing to pass on that.
l i
18 ER. MINNERSs I would direct you to look at the 17 ACES specific comments.
Th ey have some specific things to 18 suggest.
19 This is all ! had to discuss.
20 CHAIEMAN AHEARNE:
Let me turn -- who will speak 21 for the lawyers on the issue that they have proposed, 22 namely, the inadequate environmental impact statement?
23 COMMISSIONER GILINSKY:
Could I go back to an 24 earlier point f or a second?
Ha ve. we discussed the Level C, 2d u ev el D with anybody on the ACES, because I think when it l
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passed by them it was a Level C rule?
2 CHAIRMAN AHEARNE:
No, I have not.
3 COMMISSIONER GIIINSKY:
Does it have their 4
blessing?
5 3R. MINNERS:
I don't think they directly said 6
that they agree with the Level C.
I can infer from their l
7 letter and from what we have discussed with them that they 8
accept Level C.
I have never asked them directly what they 9
think.
10 CHAIRMAN AHEARNE:
I had raised it with the staff l
11 back on December 10th but have not raised it with the ACRS.
l 12 MR. MINNERS:
In fact, in the ACES letter, in one l
13 of the specific recommendations, it says a certain reactors 14 should be held to the Level C limits, so they de have a l
I 15 specific reference to th a t, but it doesn't mean that all l
l-16 reactors should be Level C.
17 CHAIRMAN AHEARNE:
Who will speak to --
18 MR. CUNNIK3 HAM:
You have a joint memo from both 19 legal offices in which we noth conclude tha t the draf t 20 environmental imp.ct appraisal is insufficient for us to 21 form a conclusion th at the environmental impacts are 22 insignificant and, therefore, don't require an environmental l
23 impact statement.
24 CHAIRMAN AHEARNE:
Let me, cut of curiosity, since 25 it is a joint memo -- I guess, are you saying that this is l
l l
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in response, that the assessment is inadequat'e and requires 2
an EIS, or are you saying that the assersnent is inadequate 3
and ought to be redone on the basis of --
4 MR. CUNNINGHAM:
Our conclusion was you could go 5
either of two ways, that presently the assessment is 6
intdequate but might be able, after reworking, to fill the 7
bill and lead you the conclusion that the environmental 8
impacts are insignificant.
9 CHAIRMAN AHEARNE:
You did not have a chance to 10 review the assessment prior to being sent up?
11 MR. CUNNINGHAM:
Yes, we did.
Jim Herze on my 12 staff has been working closely with the staff.
13 CHAIRMAN AHEARNE:
So that on being sent out your 14 staff knew that in your view it was inadequate?
.15 MR,. CUMNINGHAM:
I am not sure that we 16 communicated that on the last prior draft which we had seen, 17 but 'they knew that our view was that it was inadequate.
We 1
18 gave them a suqqestion as to what further could be done.I 19 quess it is fair to say that they were not surprised.
20-COMMISSIONER GILINSKY:
Is the principal impact 21 the occupational dose involved in reworkino some'cf the 22 plants?
23 MR. CUNNINGHAM:
Yes.
24 CHAIRMAN AHEARNE:
That's your ma jor concern.
l l
25 MR. CUNNINGHAM:
yes.
ALDER 8oN REPORTING COMPANY. INC.
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C0%3ISSIONER GILINSKY :
It is a very difficult 2
thing to describe an analyre.
3
- 53. CUNNINGHAM:
they have s described the 4
principal impact as being occupational expo sure.
Our 5
concern is that they have not adequately made the case that 6
the anount of occupational exposure is insignificant.
7 COMMISSIONER GILINSKY:
Suppose you said it was 8
significant, and you just described it with the benefits, 9
would thst be a very ccaplicated thing to lay out?
10 CHAIRMAN AHEARNE:
It is insignificant, isn't it?
11
- 32. CUNNINGHAM:
I don't think the case has been 12 made.
If you add it all up, it is several thcusand man-rem.
13 CHAIEMAN AHEARNE:
Th at is insignficant.
(x 14 MR. CUNNINGHAss In the Surry case, it said that 15 ve are not satisfied that exposure in that range was l
16 insignificant and they requested an FIS.
l 17 CHAIBMAN AHEARNE:
Erroneously.
18 MR. CUNNINGHAM:
That was the staff's view at the 19 time.
20 That is one of the problems we have, we are 21 eorking now with a framework where there is that precedent.
22 CHAIBMAN AHEARNEj The point is that consistent 23 with the Surry decision.
The Connission has indicated that 24 they view that as significant
.s 25 ME. CUNNINGHAM:
Their language in the Curry ALDER $oN REPORTING COMPANY. 6NC, 400 vlRGINLA AVd., S.W, WASHtNGToN. D.C. 20024 (202) 564-2346
61 1
decision was, again, the case had not been made that it was 2
insignificast.
Perhaps 3
CHAIREAN AHEARNE:
let me rephrase it.
Ycur point 4
is that consistent with the Commission's Surry decision, 5
they have not indica ted an acceptance of that level as being 6
insignificant, is that correct?
7 MR. CUNNINGHAHs That's right.
8 CHAIRMAN AHEARNE:
Could you go on to say 9
consistent with their acceptance of the final environmental t
10 impact statement, that they have reached the conclusion that 11 it is insignificant.
12 COMMISSIONER GIIINSKY:
Who is they ?
l 13 CHA! BEAN AHEARNEs The Commission.
(
[
14 MR. CUNNINGHAE:
No, because the EIS was prepared 15 to show tha t the benefits outweighed the costs.
I am not l
18 familiar with the final EIS.
It doesn't necessarily reach a l
- 17. conclusion of insignificance.
All it had to do was show 18 that the banefits outweighed the costs 19
- 13. TRUBATCH:
There are two levels.
The first 20 level is the significance level.
If you conclude that 21 something is insignificant, then you are done.
If you l
22 conclude tha t it is significant, then you ao on to see 23 whether the benefits outweigh the costs.
24 MB..BICKWIT:
If you can't conclude 25 insignificance, then you go on.
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CHAIBEAN AHEARNE:
Ycu say that your judgment was 2
that the Surry EIS --
3 3R. TRUBATCH:
I don't know remember what the 4
language in the Surry EIS.
5 CHAIREAN AREABXEa You would agree that Point No.
6 1 was tied inextricably to the Commission's position in the 7
beginning and, th e ref o re, I assume at the end, on the Surry 8
issue.
9 COMEISSIONES GILINSKY You sound like you voted 10 against it.
11 (General laughter.)
12
- 52. CUNNINGHAN:
I would.
I am not sure whether 13 OGC would.
~
14 CHAIREAN AHEARNE:
Len.
15 MR. BICKWIIs I don't think it is tied.
For one, 16 we were not clesr, as a f actual matter, exactly where these' 17 exposures stood as compared to the exposures in Surry.
It 18 is not clear to us exactly what the exposures are here.
1 19 CHAIREAN AHEARNE:
Are you saying that the reeson 20 it is not clear is because of the other plants that are not 21 mentioned?
22 MR. BICK'JIT:
That's right.
25 If the exposures sre greater than Surry, then it l
(.,
24 follows that Surry would dispose of the matter if the 25 Commission vanted to stay with Surry.
If the exposures are ALDERSoN REPORTING COMPANY. INC.
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greater than Surry, then it follovs the.t Surry would dispose 2
of the matter if the Commission wanted to stay with Surry.
3 If the esposures are less, then the Comnission can make the 1
4 distinction, or the Commission can obliterate.
5 CH3IRMAN AHEARNE:
Wait.
But from ELD's point, it 6
was it was the Surry issue.
From your point, it really is, 7
here is an uncertain level of exposure and there is no case 8
made that it was insignificant.
9 Is that correct?
10 MR. BICKWITs Basically, I think what both offices 11 are attempting to do is to raise an issue, to elevate an 12 issue for Commission consideration and have the Commission 13 decide whether it regards these exposures are significant or k-14 insignificant.
15 NR. CUNNINGHAEa It al=n appeared to me that the 16 exposures here nave been very, very conservatively estimated.
17 CHAIRMAN AHEARNEa Conservatively, defined as?
18 3R. CUNNINGHANs Overestimated.
So that with a 19 refining of the calculation, the case for insignificance 20 becomes easier to make.
21
-COMMISSIONER GILINSKYa Eut isn 't it just as easy 22 to lay out-what these will be, indicate what the renefits 23 'ars and do the whole thing in ten pages?
^
24 HR. CUNNINGHA32 I think so, and that is why our s _,,
25 meno says you can go either of two ways.
k _..
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COMMISSICNER GILINSKY:
Y0u don't have to be 2
defensive in answering that question.
3 CHAIRMAN AHEARNE:
Since the current one is 18 4
pages or something, it is obviously --
5 COMMISSIONER HENDRIE:
How long is the Surry EIS?
6 MR. MALSH:
Not very long.
I think it is about 20 7
pagus.
I am not certain.
8 COMMISSIONER HENDRIE:
The argument you have to 9
make here is a much more complex one.
That is, the Surry to EIS represents certainly a probable underestimate of the lov 11 estimates of an EIS on this because you are going to have to 12 deal here with not just a particular plant and not just a 13 particular component in a particular plant, or a k
14 well-laid-out program, stick to it and so on, but you 15 consider the alternatives, how many alternatives are there 16 with steam generator at Surry, whether you repair, or if you 17 pull the whole thing out, you shut the plant down and that 18 is about it.
t 19 Here they are all going to be -- there are going l
20 to be four vendors, or five, if you include Fort 3t. Vrain, 21 and each vendor will have several models of plant, and you 22 may be talking about different propositions f or two-loop l
23 Westinghonses, vintage of '67; three-loop plants, vintage of 24
'73 ; and fnur-loop plants, etc.
l 25 And the cures are going to be substantial -- there
- C ALDERSON REPOfmMG COMPANY. INC.
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is going to be a substantial variability in cures.
The 2
staff has picked out one particular cure of putting 3
additional pressure relief valves on CE and BEWs -- I guess 4
tha t is where the 50 came f rom -- not on Westinghouse, and 5
not on the PWBs.
6 But there must be sany other alternatives to that 7
that one is going to have to consider, and it is going to 8
get to be a fairly decent job.
9 MB. BICKWIT I guess our feeling is that the work to is essentially done and it would be --
11 CHAIRMAN AHEARNEs How do you know that?
12 MR. BICKWIT:
Just from the value imract 13 statement, the Commission papers, and the environnental 1-4 assessment.
15 But let me make a nother point.
You obviously were 16 skepticn1 about that conclusion, but even if you veren't and 17 it was just a paper --
18 CHAIRMAN AHEARNE:
I viewed it as another item of 19 information.
i 20 NE. BICKWITs Eveu if you regard it as simply a 21 paper-shuffling exercise, you ought to take into account the 22 precedent-setting factor of these decisions on what is 23 significant and what is insignificant, what can't be f
24 determined.
25 CHAIENAN AHEARNE:
In the previous Surry, the
(
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Commission said tha t they were unable to reach a conclusion 2
that it wasn't significant on the basis of the information 3
presented.
I would hope that having then finally seen the 4
information presented in the Surry EIS, that the Commission 5
might then have been more informed and hase resched a 6
conclusion that that was truly insignificani 7
Ihe Surry case, in addition, the total number of 8
people-rem involved were of the same order of magnitude as 9
here, but to a much more restricted set of people.
10 MR. MALSH:
But this whole point of doing EIS at 11 Sorry was to svoid having to reach that issue, the 12 significance issue.
13 CHAIRMAN AHEARNE:
That's a whole other issue, 14 Marty.
15 You have another argument in here also that you 16 take exception to 'the way they treat costs.
17 MB. BICKWIT:
I think it should be pointed out 18 that there is no requirement to treat costs in the 19 environmental assessment and where that wiped out.
20 I guess our problems there were just the validity 21 of some of the statements, but if those statements had not 22 been made, there is no legal defect.
23 COMMISSIONER GIIINSKY:
Where would you draw the 24 line of significance, John?
25 CHAIRMAN AHEARMEs I certainly would have in the ALDERSoN REPORTING CohPANY,INC, QQQ S.Wc WASHINGTON. D.C. 20024 (202) 564 2346
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Surry case drawn ir substantially above the couple of 2
thousand peopla-rem distributed across the work force that 3
was doing the Surry steam generate _,
I would draw th e 4
significance, if we are talking about 200 p eople-ren r,a r 5
plant for the opera ting plants, given the total pecpla-rom 6
that occurs at each operating plant every year.
! vould 7
also dr2w that below the level of significance.
8 Con trary to the statement that is in here, I tend l
9 to believe that a comparison of natural background is l
l 10 something that has to be taken into consideration.
11
- 58. BICKWIT:
I don't believe that it can never be 12 a f actor, and we are not te rribly helpf ul about prescribinq 13 what would be the best way to estinate insignificance.
l 14 CHAIENAN AHEARNEs It is very difficult.
I 15 MB. BICKWIT:
But the fact of the matter is that 16 ve were not persuadad on the basis of what we sa w.
We are 17 not the ones who have to be persuaded.
I think the 18 Commission ought to focus on that.
19 CHAIRMAN AHEARNE:
Yes.
20 I think it is certainly something we have to take 21 very seriously because there vill undoubtedly be a legal 22 challenge to the rule, I would guess, and if there is a weak 23 point on which the cha11ange can be focused, we ought to be l
24 aware of it, and at least have gone forth understanuino it.
25 H3. BICKWIT From the legal standpcint, there is s
l l
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no doubt that the easiest thing to do -- let me not say 2
easiest thing to do, but the conservative thing to do would 3
be to cranspose auch of what we have into an EIS but take 4
into account the precedent-: setting nature of these decisions 5
in future decisions on these matters where it may not be as 6
easy as we conceive it to be.
7 CHAIRMAN AHEARNE:
We are already seeing that C
because of the precedents on the Surry.
9 CHAIRBAN BRADFORD:
The precedent in this context, 10 what does it really mean?
11 MR. BICKWITs It means that the next time this 12 issue is considered, if you said in a case like this you 13 cannot
.'i,nd tha t it is insignificant, that argument will be 14 made at this table the next time.
15 CHAIREAN BRADFORD:
At this table, so that future 16 Commissions will be only marginally embarrassed by what we 17 have done.
16 CHAIRMAN AHEARNE:
No. 2, you say on your paper, 19 is not a critical point.
20 3R. BICXWITs It is not a critical point, but !
l l
21 personally was troubled by some of the statements, but not 22 in a way that I regard them as legally defective.
23 ER. CUNNINGHANs We are in agreement that there is i
24 no need to discuss the ecccc ic cests at all?
25 CHAIRMAN AHEARNE:
I would ceirtainly agree with ALDERSON REPORTING COMPANY. INC.
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the statement that 3 percent of $1 billion is significant.
2 It is certainly significant.
3 MR. BICKWIT There, by saying it is 4
insignificant, you don 't add to the legal difficulties 5
associated with this problem.
I just don't think the 6
Commission ought to make that statenent.
7 CHAIRMAN AHEARNE:
I would agree with that.
8 COMMISSIONER GILINSKY:
It depends on the 9
context.
10 11 CHAIRMAN AHEARNE:
If we end up going in the 12 direction of Part 100 that we previously discussed, then I 13 would conclude you would argue that that does have to be 14 addressed.
15 MR. EICKWIT I would like to get a slightly l
16 better.sensa of the staff's legal position as to what is 17 associated with their interpretation of Part 100.
18 CHAIRMAN AHEARNE:
All right.
1 19 Well, where I as at the present time, then, is I 20 would like to see something back from the staff explaininci l
21 this rule with respect to Part 100.
Maybe everybody else is 22 really clear, but I am still not.
23 If we waive Part 100, what t oes that end up 1
l 24 doing?
If we keep Part 100, what does that end up doin g?
s.
l 25 I think Commissioner Gilinsky 's view is that we ALDERSoN REPORTING COMPANY. INC.
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ought to be able to have a rule which everything fits under.
2 COMMISSIONER GILINSKY:
Is there a way of keeping 3
Part 100 without requir.ing a separate calculation tied to 4
this ATWS and to some'. tov fold it into the overall Part 100 5
calculation either by finding that it is already included or 6
modifying that in some way?
7 CHAIRMAN AHEARNE I would l'xe to see some 8
explanation of that is sue.
It might be the best way to just 9
come back down and talk to us, or those of us who are 10 interested, rather than trying to write a lot of stuff down.
11 XR. MINNERS:
Does that include Marty's issue of 12 what to do in the interim until you make a decision, and 13 then waiting to make a decision until it is finally 14 im plemen ted ?
Do you want a discussion of that also?
15 CHAI2 MAN AHEARNE:
Yes, I would look for that.
16 ELD will have to get together with OGC on the legal 17 interpretation of of Part 100.
l 18 COMMISSIONER HENDRIE If we are going to do t
i 19 something different in hearings with ATWS than is being done 20 nov, in whatever interia period there may be, we probably 21 ought to figure out what it is, and we might even hint to l
22 people what we have in mind is a statement of
(
i 23 consideration.
24 That is, if moving forward on the rule changed the 25 status and he'gan to pull ATWS out of being stuffed into a ALDERSoN REPoRTW8G CoWPANY. INC.
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generic category, we will deal with that sometime in the 2
future proposition, I think we ought to decide what the new 3
sta tus is going to be and try to figure out something 4
rational that doesn't leave the system any more constipated 5
than it already is.
6 CHAIRMAN ARE ARNE:.
Len, I guess that would have to 7
come f rom you.
8 MR. BICKWIT:
I think the interpretation we were 9
moving toward would have us do something different in to hearings, and as I understand, I think a clarification of 11 legal interpretation is necessary.
12 COMMISSIONER HENDRIEs The interir period is not 13 between now and an eff ective date of the rule, but between 14 the effective date of the rule and the time you get 15 everything implemented on the last plant, whichever the last 16 plant is that may be in the hearing.
17 MR. BICKWIT:
That is right.
18 MR. MINNERSa Was there something requested 19 relative to the environmental assessment, changes to be made 20 there?
21 COMMISSIONEB HENDRIE:
There are two problems.
22 There may be assorted problems, but wi th regard to the dose 23 thing and the environmental. assessment, there are sort of 2 24 problems that counsel raises.
_The first one is that by 25 sticking to 15 plants that might nead relief va lve s, laying ALDFJtSoN REPORTING OoMPANY,INC, 400 VIRGINIA AVE., S.W., WASNINGToN. D.C. 20024 (202) 554 2346
72 1
on a 100 person-tem per installation and so on, the legal 2
types are telling you, Gee, that is probably pretty thin l
3 since you don 't talk about what is going to be done on other 4
plants and what the exposures migh t be.
That is erobably 5
pretty thin as an estimate of the radiation exposure.
That 6
is Part A.
7 Part B they say it is already comparable to the 1
8 Surry, couple of thousand person rem, and if you take Surry 9
as a precedent, then it is not so clear that it is to insignificant.
11 Now I would like to separate Part A from Part B.
12 Ihe stafi~ =an help with Part A.
You will have to talk to 13 lawyers to see how f ar,you have to go for other plants.
But 14 on Part 15 CHAIRMAN AHEARNE:
On Part B, look at where Surry 16 ended up.
Not just where Surry sta rted.
17 COMMISSIONER HENDRIE It seems to me that Part B 18 is a Commission dacision.
I am ready to go-back --
19 CHAIRMAN AHEARNE:
You were at the time also.
20 COMMISSIONER HENDRIIs We lost all saf e ty a t all 21 cost, that is what happened.
22 MR. MINNERS:
One clarification.
You said 23 comparable to Surry.
I don 't understand that.
Our estimate 24 is that it is 100 man rems, and Surry was 2000.
How does 25 that compare?
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CHAIRMAN AHEARNE:
Total person-rem. So you have 2
100 times 15.
3' COMMISSIONER GILINSKY:
On the other hand, th i
4 benefit is multiplied ty the number of reactors.
5 MB. MINNERS:
I should multiply Surry by all the 6
reactors that change their steam generators?
7 COMMISSIONER HENDRIEs No.
The action at Surry 8
was specifically with regard to the single steam generator 9
at Surry.
This action is with regard to all plants.
10 CHAIR 3AN AHEARNE:
The Cossission said that they 11 could not come to a conclusion that a couple of thousand 12 rems was insignificant.
13 COMMISSIONER GILINSKY:
No.
14 CHAIRMAN AHEARNE:
That is what they said.
15 COMMISSIONER GIIINSKY:
You are dealing with a l
16 large number of reactors.
l 17 CHAIRMAN AHEARNE:
I realize that.
l 16 COMMISSIONER GIl!NSKY:
It does make sense to 1
19 compare the exposure per reactor, and you also have to i
l 20 com pare the benefits per reactor.
21 CHAIRMAN AHEARNE:
They did a study.
22 COMMISSICNER HENDRIE:
At this point we are just 23 deciding whether the environmental impact of this rule is 24 significant or insignificant.
That means we have to 25 consider the impacts of the total rule.
That means 3.11 the ALDERSON REPORTING COMPANY. IRC.
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74 1
reactors.
2 So that gives you the sue cf all of this stuff, 3
and it is radiation exposure that is the particular impact 4
we want to ta1X about at the moment, and it is the sum of 5
all exposure.
6 What you can argue is '.he point that John made.
7 If one felt a need to make a listinction from Surry, to come 8
away from that precedent, for instance, one could point out 9
that in fact the worker population over which the total to man-rem was spread here was very much larger.
There 90 11 plants involved, ultimately or something like that, versus 12 once in a previous case, and quite a limited work force.
13 So there are bases for coming down differently if 14 one wanted to.
My owb viev is that an environmental im pact 15 which can at best be rated as between rero and 4 potential 16 cancers in the next 30 years is an inconsequential 17 environmental impact, but that is a personal judgment, and i
18 others would have to reach their own.
19 But the point here is that we are trying to decide 20 is it significant or insignificant, 21 COMMISSIONER GILINSKY:
On an absolute basis.
22 XR. BICKWITs Yes, not whether you should do it, 23 whether any action flows from tht. determination.
24 COMMISSIONER HENDRIE:
Balancing the costs and the 25 benefits is what happens when you decide if it is ALDERSoN REPORTING COMPANY,INC, 400 VIRGMA AVE, S.W., WASHINGTord, D.C. 20024 (202) 554-2346
75 1
significtnt enough.
If it is significant, I have to see how 2
the costs and the benefits stack up in an EIS, and then 3
ir deed you have a batch of reactors, so whatever the gain is A
in safety for reactors is multiplied by the number of 5
rec.ctors.
6 3R. MINNERS:
May I bring another thcucht for 7
occupational exposure for consideration, maybe to put it in 6
somewhat of a perspective, and this is the var we looked at 9
it when we were trying to do this and why we said we didn't 10 feel it was significant.
11 We did, as you said, we took one plant and we took 12 what we considered to be probably the most harardous piece 13 of this thing in terms of occupational exposure, and that 14 was to veli the vsives on the primary system.
We did look 15 into this plant enough to know what it would take.
16 Ve vent to the Calvert Cliffs plant, and we had 17 people there telling us what the rsdiation levels were, how 18 long it would take to veld one of these valves up, based on 19 their professional opinion.
This is where we ca:e fovn, 20 with this ten-mac--rem for velding these three valves on the 21 steam generator at Calvert Cliffs Unit No.
1.
22 We then just assumed that since that was the worst 23 case, we would bound this thing by saying, oksy, everything i
24 else, there may be 10 other types of opccations, and we vill 25 just multiply it by ten and say all of the rest of the s
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76 i
1 things should run under our 100 nan rem for the plant.
2 We did not go into any detail to lock all of the 3
things that were involved.
This is a big job 'f you want to 4
go into it and really see hev you are going to do these 5
modifications.
There are all kinds of things involved.
We 6
di$n't f eel that that was the thing we were trying to do.
7 We were trying to bound the case.
8 We then multiplied the this by th e 15 plants tha t 9
ve feel night have to have steam relief valves put on thes.
to We took the Calvert Cliffs case because ve realired it was 11 the one'that would require the most valves, so we bounded it 12 again in a second way.
13 Ve did not look at all the other plants that 14 didn't have to do this, but we assumed that they would be 15 less than 100 man-rens per plant because they didn't have to 1
16 put the valves on, and ve considered that that was probably 17 one of the most significant places.
18 If you look at this thing ~ in terms of the nan-ress 19 per plant instead of multiplying the total man-ress by the 20 total numbec of plants, and then look at what each plant 21 does in terms of normal operation, in terns of just the r
22 normal operating exposures -- we tried to brine this out in 23 the table we gave you -- this thing va ries. -
(
24 3n the average over the six years, it was 500 nan 25 rems per plant per year, and this varies all the way from ALDER $oM REPORTING COMPANY. INC, 400 VaRG#elA A4. S.W. WASHINGTON. D.C. 20024 (202) 564-2346
77 1
400 to almost 600 between years.
So the variation between 2
yea rs is what we are talking about here in this particular 3
job, which is by the way a one-shot job.
We are talking 4
about doing these things once and not every year.
5 If you take on the average 500 man rems per plant 6
per year times the lifetime of the plant, you a e talking 7
about 20000 aan rems just f or normal operation of this plant 8
over its lifetime, which we were talking about increa sing 9
100 man rems for putting on these ATWS modifications.
10 We are talking about an impact of something less 11 than a half of 1 percent of the total occupational exposure 12 ve are talking about in the operation of this plant, doing 13 the ATWS rodel, assuming once you have it, then you don't 14 have to do anything more. But that is not quite true, i
13 COMMISSIONER OIIINSKY; It seems to me --
l 16
(;0MMISSIONER HENDRIE:
Well, that is a better 17 explana tion than you have written down here in the paper, 18 and that is what Counsel is telling you.
19 ER. MINNERSs You are right.
20 COMMISSIONER HENDRIE Write that all down and 21 they will give you Part A of my two parts.
22 COMMISSIONER GILINSKY:
You wouldn't say that if 23 someone got -- one person got several thousand man rems, 24 tha t was inconsequential.
- 25 COMMISSIONER HENDRIE:
One person, 2000 rem is s _
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ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVL 3,W., WASHINGTON, D.C. 20024 (202) 564-2346
78 1
2000 person rem, and I will say that is not inconsequential
~
2 because I can now identify that there is a very hich 3
likelihood tha t that person will die in th' near term.
He 4
is an identifiable either certain fatalit-or essentially 5
certain fatality as a direct and close result.
But when we 6
get to these auch lower doses --
7 COMMISSIONER GILINSKY :
I am not arguing with your 8
conclusion.
I as saying that it seems to me that the number 9
of persons involved is an essential element in deciding 10 whether or not the exposure is significant, and it is not 11 unreasonable to limit the exposure per a plant.
12 COMMISSIONER HENDRIE:
I think it is certainly an 13 important element, and it has the following things that 14 could usefully be said as a footnote to that comment.
15 First, for any given individual, if a greater 16 numbe; of people are receiving the same c sulative dose, any i
17 one of the group in the larger group has the lower personal 18 risk.
19 Second, if you assume the linear theory of l
l 20 radiation theory aff ects, then the integrated number of l
21 health effects from 2000 perscn ces are going to be the same i
l 22 whether you have 2000 people that get one rem or 200 people 23 that get 10 rems.
By the tite you get to 1000 or 2000, you l
(
24 have quite a didderent situation, but as long as you stay in 25 doses that are bel'ow 5 to 10 rems in a year or something ALDEF40N REPoRnNG CoedPANY,INC, 400 VIP 14NIA AVE. S.W., WASHINGTON. O.C. 20024 (202) 564-2345
79 1
lik e th a t, what I say is true.
The. linear theory will tell 2
you tha t you get the same number of health effects.
3 But in fact we have substant.lal expert opinien 4
which believes that the linear theory does not hold at these 5
dose levels, and that it is quadratic or falling more 6
rapidly, and that lower doses have progress?.vely lower 7
effects.
If that is true, tnen in fact there is a 8
suchtantial difference in the total health effects from 2000 9
person res if it is applied to a group of 2000 people or a to group of 200 people, a f actor of about 100 difference in the 11 health effects, in fact, the square of the dose.
12 Since from the data I see, and as best I can 13 judge, our better experts evaluated and so on, the quadratic 14 or similar theories of low dose response are at least as 15 valid scientifically as the linear theory where you have a 16 risk distribution, so that if that is correct, then more 17 people at lower dose is a substantially lower absolute 18 number of health offects; all of which confirm, in a rather
~
19 wi_ndy footnote, the shortcomings.
20 COREISSIONER GILINSKY:
I war, commentinc on len l
21 having said that it was the absolute limit.
If that is an l
22 issue here, i am not sure it is.
f 23 CHAIRMAN AHEARNE:
I would not want the staff's i
l 24 revision to go all the way that Commisstoner Hendrie just 25 did because I don't think you would the n. end up givinq
~
ALDERSON REPORTING COMPANY,INC.
~
400 VIRGINSA AVE S.W. WASMNGToN. D.C. 200 4 (202) 564-2346
80 1
suppcet to the Commission.
2 MR. MINNERS:
So we should submit another draft of 3
the EIS.
4 CHAIENAN AHEARNE:
Yes.
The quadratic form of the 5
lov threshold is not something that as a body we agreed to 6
endorse for all of our EISs, but the basic points were made.
7 COMMISSIONEB HENDRIE:
In particular, somewhere 8
give indication that you have taken account of not just the 9
15 plants that might have to put on safety valves or more 10 relief valves, but the whole group of plantr affected by the 11 rule.
If your conclusion is that for all intents and 12 purposes the exposure from ATWS cures and those other 13
- plants, however many there are 75 or whatever it is -- is 14 zero, say that.
l 15 The lawyers' complaint is not that you are wrong 16 but that you have not said it.
17 CHAIRMAN AHEARNE:
I'm going to disappear in a
(
18 minute, so let me make another point on the economic 19 impacts.
I am not sure whether you need to have that in 1
20 there, bqt if you do, would you please modify the words.
As 21 Commissioner Gilinsky pointed out, 3 percent $1 billion is 22 not insignificant.
It is relatively, in comparison to the 23 capital cost of the plant, that is a very small amount, but 24 a very small' amount of $1 billion is very significant.
You 25 eliminate the cost.
The comparison was strictly with $1 4
I g
f 400 VIRC%A AVE., S.W., WASHINGTON, D.C. 20024 (20D 564 2348 g
81 1
billion.
2 COMMISSIONER HENDRII:
Ihree percent is a lot.
3 Three percent means that if you can find 33 items of 4
comparable importance at cost in the fixing to ATWS, you can 5
double the capital cost of the plant.
I don't know how many 6
3 percent items one adds on before one concludes that once 7
trivial additions have become non-trivial, but at 3 percent, 8
it doesn't take long.
9 CHAIRMAN AHEARNE:
And also, somewhere in your 10 discussion of the economic impact, you don't put in any 11 account for the engineering of the equipment.
12 MR. NORBERG:
That was included as one of the 13 so-called indirect costs.
14 CHAIRNAN AHEARNEs But you don't say so.
Indirect 15 costs are licensing costs, operating and maintenance, 16 financing, installation, taxes and insurance contingency 17 funds, and equivalents of radiation exposure.
18 3R. NOBBERGa It should have been in there.
We 19 ande a mistake.
20 CHAI3 NAN AHEARNE:
I recall in. a couple of cases l
21 we have gone through, such as the plant shutdown engineering l
22 costs turn out to be quite a substantial.
I myself share 23 OGC's or ELD's concern of throwing in the equivalents of l
24 radiation exposures, that is just a whole other area that we 25 have tried to stay out of.
l l
l l
l ALDERsoN AEPoRTWG COMPANY. WC.
400 VIRGINtA AVE. S.W., WASHWGToN. o.C. 20024 (20 2 564 2346
02 1
3R. 9ICKWIT:
Since this is giving the Commission 2
some problems, I think you ought to give serious 3
consideration of dropping that section on economic impact.
4 3R. HINNERS:
Well, I will be happy to.
5 COMMISSIONER HENDRIEs We are committed by 6
internal practices to some sort of value impact analysis 7
which appears elsewhere.
8 CHAIRMAN AREARNE:
It is fairly lengthy.
9 COMMISSIONER HENDRIE4 I am not sure that chucking to this stuff in here 11 CHAIRMAN AHEARNE '
It is not needed.
12
- 38. BICKWITs That is right.
13 CHAIRMAN AHEARNE:
The essential issue is is there 14 a significant environmental effect?
If your conclusions are 15 that there aren't, which is your conclusion, there is a 16 reason for vaiving the EIS.
17 MR. NORBERGa We vill take the economic piece out f
18 of it.
19 -
NR. MINNERS Could we have'a schedule?
20
- Chuck, and I will get together with you at the l
21 end of the meeting.
22 COMMISSIONER HENDRIE Are you about to gavel this 23 thing?
24 CHAIPHAN AHEARNE:
The balance of the staff 25 resources, please keep in mind -- at least, forget time.
I ALDERSON REPORTING COMPANY. INC.
400 VWIGW4A AVE, S.W., WASH 6MGTON. 0.0. 20024 (202) 554-2348
83 1
forget time but I tend to begin to forget time.
2 CHAIRMAN BRADFORD:
Two weeks.
3 COMMISSIONER HENDRIEs Could you poke around some 4
among reigning experts on that Level D, Level C business for
[
5 me?
6 MR. MINNERSa
'4 ha t would you likei j
7 COMMISSIONER HENDRIE:
I would like te know what t
8 Siess and Bender think.
9 CHAIRMAN AHEARNE:
I think it would be better for l
10 us to contact the ACHS.
And I think we will make a further 11 request.
12 COMMISSIONER HENDRIE4 As a result of my query, is l
l 13 an ACRS letter of the classic mold the kind I have written l
14 myself to the Commission on many occasions, maybe I will 15 just have to make some telephone calls.
16 CHAIRMAN AHEARNE:
I don't really know how to 17 interpret that.
18 CHAIRMAN BRACFORD:
Is it a fair summary of your 19 comment on Bob Minogue's memo that you have no issue with it 20 at this time, that it is not a matter that you take up 21 between now and publication of the rule for comment?
22 ER. MINNERS:
Yes, I would say I will consider 23 that as another comment, e.nother alternative to be l
24 considered and be addressed when you finally come up with a 25 final rule, saying I am not doing this, I am doing that ALDEASoM REPORTING COMPANY,INC, 400 VlMG4NLA AVE, S.W. WASHINGTON, D.C. 20024 (202) 514-2346
84 1
because.
In fact, I would say all of these revisions could 2
also be treated the same way.
3 Exactly how Part 100 should be treated, whether it 4
is adequate. or inadequate relibility are also questions tha t 5
can be decided af ter the final rule, and may be decided 6
after some public co.mments on the way it was written.
7 CHAIBEAW AHEARNE:
Any other?
8 We are adjourned.
9 (Whereupon, at 12:10 o' clock p.m.,.the meeting of to the Commission adjourned.)
11 12 13 14 15 16 17 16 19 20 21 22 23 24 25 ALDERSoN REPORTING COMPANY,INC.
400 VIRGINIA AVE., S W., WASHINGTON, D.C. 20024 (202) 564-2348
I NUCLEAR REGULATORY CO.W4ISSION
[
This is tc certify tha: the attachec proceecings bef re -he l
in the matter Of:
COMMISSION MEETING Date of Prcceeding:
Februarv 12, 19o.
Decket Nu=ber:
Place of ?receeding:
Washington, D.
C.
sere held as herein a;;eers, anc ha: this is the criginal transcri;;
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Patricia A. Minson Official Reporter (Typed)
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$W W Cfficial Reporter (Signature) l l
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UNITED STATES OF AMERICA 7
[c NUCLEAR REGULATORY COMMISSION g
g COMMISSIONERS.
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s John F. Ahearne Victor Gilinsky Joseph M. Hendrie p88 7J Peter A. Bradford tj In the Matter of Application No. XR-135 Docket No. 11001075 GENERAL ELECTRIC COMPANY
)
Application No. XSNM-01662 (Exports to Taiwan)
)
Docket No. 11001076
)
In the Matter of Application No. XR-136 1
Docket No. 11002058 MFSTINGHOUSE ELECTRIC COMPANY
)
Application No. XSNM-01719 (Exports to Taiwan)
)
Docket No. 11002175
)
)
AppTication No. XR-137 In the Matter of
)
Docket No. 11002252 COMBUSTION ENGINEERING, INC.
Application No. XSNM-01753 l
Docket No. 11002253 (Exports to Taiwan)
Application No. XSNM-01754 Docket No. 11002254 I
MEMORANDUM AND ORDER CLI-81-2 W >
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Background
P.t" l
',r C' 9 ON The Taiwan Power Company seeks to purchase two nuclear powe'r rea~c'toFs 0 k
[W[h h
which will be sited in Yenliao, about 50 kilometers east of Taipei.
In W
soliciting bids, the utility stated that the contract-would not be awarded to x
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a supplier unless that company had already received authorization from its
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