ML20006F560
| ML20006F560 | |
| Person / Time | |
|---|---|
| Issue date: | 10/04/1989 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-2666, NUDOCS 9002280165 | |
| Download: ML20006F560 (9) | |
Text
6 r
)
hdhddd[P 4 7, sq =] PP !
tu 34Wa J
p m
. h hp h
DATE ISSUED:
10/4/89 I071M f
ACRS Subcgmmittee Peeting Sumary/ Minutes For Safety Pailosophy, Technology, and Criteria September 26,-1989 Bethesda, Maryland Purpose The ACRS Subcommittee on Safety Philosophy, Technology and Criteria O
planned a meeting on September 26, 1989 in Bethesda, Maryland.
It is-recognire:i that a Subcommittee n:eeting may not begin until a quorum of at least two ACRS members is-present. Due to last minute cancellations, e cuorum was not available. Therefore, the-following is a summary of a discussion between D. Ward and some NRC Staff members on the concept of adeounte protection as it relates to the safety goals.
In a Staff RequirementsMenorandum(SRM)datedAugust 21,1989(copyattached),the Cornission requested the Staff and the' ACRS to prepare,a' joint paper identifying their positions on the concept of adequate protection. A copy of the meeting agenda and the list of questions-posed by W. Houston-(RES)are' attached. The meeting began at 1:30 p.m. and adjourned at-3:00p.m.andwasheldinopensession(reccrdedas, usual).
The:princi-pal attendees.were as follows:
ACRS NRC D. Ward, Chairman W. Houston (RES)
~
D. Houston, Staff W.Minners(RES)-
4 M. Taylor (RES)
Review Documents There were no specific documents to be reviewed at this meeting.
g Actions, Agreements, and Comm'tments
~
Q The Staff agreed to provide a draft document on the concept of adequate l
protection for consideration at the ACRS meeting on October 5, 1989.
I A1 9002280165 891004
)
DESIGNATED ORIGINAL
{
2I66 PDC h
certified By
L..
1 q
-]
j.-
SFTSC Meeting Ninutes September 26, 1989~
l p
Mr. Houston also indicated that the words adequate protection of the i
l safety and health of the public come right out of _ the Atomic Energy Act.
However, the words adequate protection only appear in the regulations in' i
10 CFR 50.109, "Backfitting." He indicated that the courts had been:
l petitiered to force the Commission to issue some kind of objective
(
standard or criteria in regard to adequate protection but the courts l
declined to do so.
l
- p. Ward indicated that the Committee position ras more clearly related; to the third portion of the policy statement cited above:
... Current.
reculatory practices---nuclear power plants....
- He stated-that the Committee had not intentionally set off to define
- adequate protection but that it had simply developed during the lengthy review of the Safety-Goal Policy. He further stated that the safety' goals with quantitative PRA measures should not be~used to test individual plants but rather to-judge the body of reguletions and classes of plants.
In respect to W. Houston's second~ question, D. kard indicated that'the ACRS position in SECY-89-102 was a fair characterization.
However, he felt that they Staff's opinion that this differed from the: policy ~
statement was incorrect.
As noted above, he referred to.that portion of-the policy statement that was relevant to the ACRS position and.indi-cated that he felt the position did not differ from the policy statement. Mr. Ward and R. Houston then discussed.the various ACRS ictters that addressed the concept of adequate protection.
In respect to-W. Houston's third question, Mr., Houston indicated that
. o there are few examples of instances in which new regulatory requirements have been imposed as backfits or that were justified on the basis of.
meeting adequate protection.
M. Taylor (ED0) pointed to one example, the station blackout rule.
D. Ward questioned, in respect to the backfit rule, what the Staff used as a gauge to make a finding of a
__.,,e 9
--ed,.
- l SPT&C lketing Minutes
-S-September 26,_1989 substantial safety improvement.
W. Minners (RES) felt that as a practii cal matter, cost-benefit considerations would be the_ overriding issue; D. Ward indicated that one problem with anything likesthe safety goal is i
the threshold problem._ He suggested'that the backfit rule and its cost benefit argument could be a tool for dealing with the threshold problem.
This threshold, either a specific value or a fuzzy band of values, would esteblish how safe is' safe enough.
D. Ward also indicated that there should be no " cliff effect" implied with the thresh'old.
At the conclusien of the meeting, D. Ward and W. Houston discussed.
proposed ways to satisfy the SRM with either a joint paper or:with separate letters from the ACRS and Staff. 'This matter was. left open for i
discussion at the Committee meeting,on October 5,1989.
s i
i s..
L NCTE:
Additional meeting details can be obtained:from a transcript-i
~ ~ ~ ~
of this meeting available'in the NRC Public-Docunent Room, 2120 L Street, N.W., Washington, D.C.- 20006,(202)634-3273, or can be' purchased from Heritage Reporting Corporation, 1220 L Street, N.W., Suite 600, Washington, D.C. 20005,-(202) 628-4888.
l l
t 1
'k t
4 1
a 4
/.;
/// / * *
.j {
g C,. '
j*
UNITED STATES IN RESPONSE,IPLEA f
NUCLE AR REGULATORY COMMIS$10N REFER To:
M89072- ;
{
,]
w ash 4NGToN D.C. 30608 ~
')
j August. 21, 1989
+
1 oreacs or THe SECRETARY e
. i MEMORANDUM FOR:
James M. Taylor-Acting Executive: Director for operations-'
E Raymond F. Fraley, Executive Director
-Advisory Committee on Reactor Safeguards FROM:
Samuel J. Chilk,-Secreta h
SUBJECT:
STAFF REQUIREMENTS - BRIE (G ON-3 INTEGRATION OF POLICY ST KENTS FOR SEVERE ACCIDENTS, ADVANCED REACTORS,, SAFETY GOALS, AND STANDARDIZATION,-'10:00 A.M;, WEDNESDAY,-
JULY 26, 1989,-COMMISSIONERS' CONFERENCE' ROOM, ONE WHITE' FLINT NORTH, ROCKVILLE, MARYLAND (OPEN To PUBLIC-ATTENDANCE) l The Commission was briefed by the staff on the integration of-the Commission's policy statements for severe accidents, advanced reactors, safety goals, and standardization.
q The Commission requested the staff to prepara a paper ~'
outlining:=
1.
When'information will be:available to make-decisions-on 1
the key licensing. issues ~ for the: advanced reactor designs, and policy questions associated with the review of~the-evolutionary and advanced light water reactors; 2.
When these decisions are needed; and u
3.
The decision-making process that ensures the-integration of necessary itiformation for making timely decisions.,
(EDO)
(SECY Suspense:: 10/15/89)-
1 subsequent to the meeting, the Commission requested the staff and the ACRS to prepare a joint' paper which clearly' identifies their differing positions on-the concept of: adequate:
protection, as it relates to the safety goal.
(EDO/ACRS)
'(SECY-Suspense: - 10/15/89) f&.
i
,,,,.,....... ~ -.
- - ~ +
6-4 o-
-e--%
w<m.--*e..,,m+meve,e
,e w
w r
=
{
p;/ !
j Commissioner Rogers requested the staff to provide confidance that the Commission's policy statements are being integrated
-/
effectively.
He. requested the staff to'be on the lookout'for contradictions,-gaps, and new policy issues emerging from its-implementation of the Commission's policy statements, and to j
bring its findings to the attention' of the Commission in a timely-manner.
cc:
Chairman Carr t
Commissioner Roberts e
Commissioner Rogers
+
Commissioner Curtiss' OGC GPA PDR - Advance DCS - P1-24
- s
.L i
j.
1.
?
(
i i
l.
G j --
8 a
f 3
i i
+
c, --
r i
ACRS Safety. Philosophy Technology, and Criteria Subcommittee Meeting September 26, 1989 Bethesda. Maryland i
E L
- Tentative Agenda -
A.
Subconcittee Chairman D._ Ward, ACRS
'1:30lpm Remerks D. Ward /-
1:45 pm-i B.
Joir.t Ciscussion of the Concept of Adequate W houston'(RES),
Protecticr.
-l C.
Concluding Remarks end D. Ward 4:15 pm' Plans for October ACRS i
Meetinc P.
Adjourn 4:30 pm-t-
1 t
1 t
i l-v -
y
,t
.)
y
. i s
c ADE0VATE PROTECTION AND SAFETY G0AL POLICY
- 1.
Is the Safety Goal Policy Statement itself clear on the -
meaning of safety goals as they may relate to the adequate protection issue?
2.
In SECY-89-102, Implementation of Safety Goal Policy, dated March 30,1989, has the staff correctly characterized the ACRS view?
~
3.
Should there be a relationship bet' ween' Safety Goal-Policy and the Commission's Backfit Policy as set.forth in the Backfiti Rule,10 CFR 50.1097 Questions for discussion with ACRS Sub-Committee, Sept. 26,.1989 9
e
O
{.'
SPT&C Meeting Minutes September 26, 1989 h
q
]
Discussion In his opening corr:ents, D. Ward reviewed those areas of the proposed j
implementation plan for the safety goal where the Committee has ex-l pressed a difference of opinion from that of the Staff, namely, the, concept of adequate protection, ' definition of large release, containment performance guidance and human / organizational performance..He also f
asked for Staff comments on the workability of preparing a joint paper P
as requested in the SRM.
- 11. Houston (RES) discussed the three questions in his handout (at-q tached). He read portions of the Safety Goal. Policy Statement to illustrate the Staff's position that there.are statements in it which could be regarded as some what ambiguous on the concept of adequate protection. These statements are as follows:
...Its objective is to establish goals.that broadly define an' acceptable level of radiological risk....
E i
...In its response to the recommendations' of the President's.
j Comission on the Accident at Threi Mile Island, the Nuclear I
Regulatory Commission (NRC) stated that it was " prepared to move-J forward with an explicit policy statement on safety' philosophy and the role of safety-cost tradeoffs in the.NRC safety decisions."...
... Current regulatory practices.are believed to ensure that the-basic statutory requirement, adequate protection of the public, is met. Nevertheless, current practices could be improved to provide-
-I a better means for testing the adequacy of and need for current and-proposed regulatory requirements. The Comission believes that such improvement could lead to a more coherent and-consistent regulation of nuclear power plants, a more predictable regulatory process, a public understanding of the regulatory criteria that'the NRC applies, and public confidence in the safety of operating-4
)
o-SPTf.C Neeting liinutes September 26. 1989 plants.
This stater 4tt of'NRC safety policy expresses the Com-mission's views on the level of risks to public health and safety-that the industry should strive for in its nuclear _ power plants....
...The objective of the Comission's policy statement is to estab-lish scals that brot.dly define an acceptable level of radiological risk that might be imposed on the public as a result of-nuclear j
power plant operation....
l
...The Commission believes.that this ratio of 0.1 percent appropri-ately reflects both of the outlitative goals--to provide that-individuals and society bear no significant additional risk.
hcwever, this does not necessarily mean that an additional risk
(
that exceeds 0.1 percent would by itself constitute = a significant additional risk. The 0.1 percent ratio to other risks:is low; enough to support an expectation that people living or working near~
nuclear power plants would have no special concern-due to the plant's proximity....
t
...The Commissior has adopted the use of mean estimates for pur -
poses of_ implementing the quantitative objectives of this safety l
l goal policy (i.e., the mortality risk objectives).
Use of the mean
[
estimates comports with the customary practices for cost-benefit analyses and it is-the correct usage for purposes of'the mortality risk comparisons....
i
...To provide-adequate protection of the public health:and safety, current NRC regulations require conservatism in-design, construc-tion, testing, operation end maintenance of nuclear power plants....
d n
W 4+
w e
y w.--r-4 4