ML20010C430
| ML20010C430 | |
| Person / Time | |
|---|---|
| Issue date: | 07/23/1981 |
| From: | NRC |
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1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
4 PUBLIC MEETING J
5 SAFETY GOAL WORKSHOP 6
PANEL C 7
ECONCHIC, ETHICAL AND SOCIO-POLITICAL CONSIEERATIONS 8
i 9
Parlor C 10 Cliffside Inn 11 Harpers Ferry, West Virginia 12 Thursday, July 23, 1981 13 The meeting was convened, pursuant to notice, at 14 10:50 a.m.
with P. Slovic, Decision Research, presiding.
15 PRESENT:
16 P. SLOVIC, Chairman 17 R.
BERNERO 18 H.
INGHAM 4
1 19 D. MacLEAN i
20 E. O'DONNELL 21 T.
PAGE 22 C. PERROW 23 A. ROMANO 24 C.
WHIPPLE 25 i
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MR. SLOVIC:
Good morning.
I welcome all of you 3 to Round 2 of Panel C.
Some of you missed Round 1 but there 4 is a report of it in the workshop report that has been 5 distributed.
6 I hope that we will go on to some additional 7 issues.
We have no set agenda.
The agenda is basically 8 wha t we make it here.
We have only about three hours in 9 contrast to about two days that we had at the previous to meeting.
So I think we will have to try to focus a bit more 11 and try to single out the key concerns and issues that we 12 vant to put on record here.
13 As before, if certain ideas are not dealt with to 14 your satisf action in this session er even in the plenary, 15 there is ample opportunity to write to the people at 16 Brookhaven, to Geo rge Seg y, af ter the meeting to add th ese 17 comments or anything taat occurs to you after we adjourn.
I 18 was impressed before with the openness of this whole process l
19 and the willingness of people preparing the reports to 20 consider all of the input that was offered.
21 I think we should go quickly around the table a nd 22 introduce ourselves and say where we are from and if there 23 is any particular issue that you would like to raise for 24 consideration on the agenda.
I pretty well discussed some 25 o f the concerns that I had earlier.
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I should add that my background is in the 2 psychology of judoment and decisionmaking so that I have 3 that perspective upon things.
4 Ed do you want to start?
5 MR. O'DONNELL:
I am Ed O'Donnell.
I am with 8 Ebasco Services.
I am a nuclear engineer.
I have been 7 involved in nuclear licensing and saf ety for 13 years or so.
8 With respect to the paper the couple of issues I 9 would like to delve into deal with the relative importence 10 o f the three elements that the NRC ' as included in this 1
11 quantitative safety goal.
That is tae individual risk, th e l
12 societal risk and the limit on the probability of a 13 large-scale fuel melt.
Are they equally im portant?
Is one i
14 more important than anothar?
Do we treat them all the same?
15 Ano'2er item is the se paration of accident 16 conditions from normal operation.
I am not sure where one 17 draws that line and whether it is even appropria tma tc draw 18 the line.
19 The discussion of risk aversion has been left 20 somewhat up in the air here and I think it is something we 21 o ugh t to get back into even though we did not manace to 22 resolve anything at our last session.
(
23 Finally, I think the treatment of the A173A, er as 24 low as reasonably achievable, concept it included here but 25 wit hout any attempt to quantitfy it.
I think that is ALDERSON REPORTING CCMPANY, INC, 400 VIRGINIA AVE., S.W WASHINGTON. O.C. 20024 (202) 554 2345 l
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i something we should discuss:
whether or not tha t cught to 2 be quantified or just kind of lef t very qualitative and 3 vague as it is here.
4 HR. SLOVIC:
Thank ycu.
5 Bob, would you proceed?
6 MR. BERNER04 I am Bob Bernero, director of the 1
7 Division of Risk Analysis a t NRC.
I am not technically a 8 member of your panel but I am here out of strong interest 9 and I offer whatever help I can.
10 I have a particular interest in the statement that 11 Paul singled out in the introductory remark s this morning.
12 That is the statement which is the culmination of the risk 13 aversion question.
I quote now from the draft paper that i
14 everyone has:
"However some radiological risks might be l
15 unacceptable regardless of benefit."
This is the 16 stakes-are-too-high syndrome or however you would describe 17 i t.
I have a very strong interest in that and have 18 reactions to it.
19 MR. SLOVICs Thank you.
20 MR. PAGE:
I am Toby Page from the Environmental I
21 Quality Laboratory at the California Institute of Technclogy.
22 I have two er three things.
One is in reading 23 over the xerox discussion paper, it seemed to r.e tha t there 24 was sort of a large gap.
That is there are some noble words 25 about qualitative goals that are sort of bland and ALDERSON AEPoRTING COMPANY. INC, 400 VIRGINIA AVE. S?# '#ASriiNGToN, D.C. 20024 (202) 554 2345
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1 acceptable because they are sort of bland.
Then there are 2 some numbers that come out at the end.
I am interested in a L
3 discussion of how do you go from here to there.
I think 4 there is a problem there.
l 5
MR. SLOVIC:
Excuse me.
Let ne make sure I j
6 understand you.
Do you mean the gap between the 7 introductory discussion of the difficulties in this whole 8 enterprise and th e base on qualitative goals and then the 9 sudden shif t to a few quantitative goals ?
10 MR. PAGE:
Yes.
An example of this is they say we 11 worry about these equity problems, future generations and so 12 on, but if we can make the number small enough then that 13 makes it all right.
The question is how do we get frcm this 14 very cursory discussion of what these noble words mean about 15 no risk to an individual should be significant.
16 MR. SLOVIC:
That reminds me of the cartoon I saw 17 of this mathematician proving this long theorem on the 18 blackboard and it is all covered with figures and he is down 19 a t the bottom and he says:
and then a miracle occurs.
20 (Laughter.)
21 NR. PAGE:
Then the second thing is sort of 22 related to the first which is we have been talkinc about 23 goals extracted f rom the verification and implementatien.
24 You first set the goal as one exercise.
Then in the second 25 exe rcise you worry about whether or not you are gettinq ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AV7., S.W WASHINGTON. D.C. 20024 (202) 554 2345
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6 1 close to it.
A third exercise is to worry about how you get 2 close to it.
3 One of the things that seems strange abcut 4 implementation to se is that the process of verification is 5 viewed sort of passively 11n the sense that we have discussed 6 very little on structures of incentives of how you get from 7 here to there and what happens when something goes wrong and 8 how do you tell when something goes wrong without knowing 9 what the rules of the game are, who gains and losos in the 10 sense of the operators, the NBC, that sort of thing.
I am 11 not sure tha t the goals have any operational meaning.
i 12 The third interest is one I broucht up the last
)
13 time but did not carry it very far.
It appears that we have i
14 looked at the problem of risk assessment in cerms of trying 15 to get qualitative numbers by some sort of frequency 16 notion.
If we are going to create structures and incen tives 17 and validation processes, we are going to be struck with 18 scoring ur.ique events as opposed to developing frequency 19 data on repeated events.
20 There are methodologies f or doing that.
But as 21 f ar as I know it is not being done.
If it is being done I 22 woulc like to know how it is being done.
My feeling is tha t i
23 if we are going to tak e these goals seriously and 24 quantitatively, then we need to think about scoring unique 25 events and predictions over many unique events in such a wa y 1
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7 1 that it is probably different f rom wha t we are doina now.
2 For example one of the obvious kinds of 2 predictions to make year by year is whether or not 4 particular accidents which will turn up the next year which 5 are unforeseen now will fit on the error tree or not.
If 6 they do, that is fine.
If they do not, we will have to do 7 something else.
So we can make predictions about how i
8 comprehensive our analysis is as well as particular small 9 chains.
to HR. S10VIC:
Helen.
11 5S. INGRAM:
Hi.
I am Helen Ingran.
I am from 12 the University of Arizona.
I am basically a water resources 13 specialist and I have spent a couple of years at Resources 14 for the Future.
I expect my interest here relates though to 15 my more general concerns as a political scientist.
18 I have for a long time been interested in the 17 question of how economic, environmental and other decision 18 analysis actually affect policymaking processes.
It is 19 probably an obvious statement to say that much analysis 20 simply justifies political decisions that are made and 21 rationalizes those decisions af ter the f act ratner than 22 breeds into the decisionmaking.
My interest long has been 23 to try to figure out an intellectual and analytical process 24 tha t actually helps decisionmaking instead of dresses it up.
75 One of my questions here, possibly because there 1
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8 1 is this gap between qualitative goals and these numbers, is 2 do these numbers serve to explain a process of 3 decisionmaking whereby the public and decisionmakers get 4 educated by the im plica tions of their decisions so they can 5 make sharper decisions?
Or is this just another example of 8 taking a number which is low enough so tha t everybcd y says 7 well, you don't have to do tha t weighing and balancing and 8 you don 't have to make those careful calculations?
9 Perhaps I should say that I may have prepared to myself too f actually for this meeting.
I began going 11 through all of the background documents including the kinds 12 of things you had f or the Palo Alto mee ting and the 13 interesting results of that Palo Alto meeting which was rich 14 in ideas and conten t.
It was very exciting stuff.
I began 15 thinking I should have had days to prepare because there are 16 a lot of interestints things inc2uded.
17 Then I read the discussion paper and I guess I was 18 surprised at how little of that thing really is reflected in 19 this discussion paper.
Perhaps if I had begun with the 20 discussion paper I would not have had that feeling that we 21 have labored and labored and produced this kind of knowledge 22 which is not that different.
4 23 Huch of what I am concerned about are questions of 24 how do you determine distribution of risk.
It seems to me 25 quite clear that some people are at greater risk in these ALDERSoN REPORTING COMPANY. INC.
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1 things than others.
Then there is the question of fairness 2 of that and compensation.
I wonder if that is adequately 3 dealt with simply by setting the number so low that it looks 4 like nobody suffers so much that you have to do that kind of 5 weighing and balancing.
8 Paul, you raised a number of other issues this 7 morning, many of which I have on my list and I hope we 8 discuss them.
9 ER. SLOVICa Thank you.
d 10 HR. ROMANO:
I am Tony Romano from Brookhaven.
I 11 am going to act as raconteur of this session so we can help 12 put together the final report.
13 MR. SLOVIC:
Thank you.
)
14 dR. WHIPPLE:
I am Chris Whipple from EPRI.
I am 15 an engineer and I have been working in the risk area for the 18 last four or five years, particularly as it pertains to 17 nuclear power.
18 I have some comments on the discussion paper.
My 19 basic commen t is that one of the issues I have heard raised 20 repeatedly and mentioned again at the beginning of the i
21 discussion paper is the need for some clear logic for 22 quantitative safety goals tha t the public und the Congress 23 can understand.
I am concerned because I still have nCt 24 seen it.
25 I see some waffling where there is indecision as tLDERSoN REPORTING COMPANY. iNC.
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o 90 1 to the logic on how safe nuclea r plants should be, should it 2 be part of an overall energy policy tha t lo'ok s a t resource 3 supply problems, foreign policy issues down to a more narrow 4 structure of problem that compares all nuclear or down to an 5 even narrower still view that says the engineering of the 6 plants should be done professionally.
7 I see a lot of bouncing back and forth between 8 these three levels of decision.
I do not think a single 9 logic has yet emerged.
I think that is essential to this 10 process because the numbers are going to change over time.
i 11 They have to have some logic to fall back on.
12 I too have an arrow by the line tha t some l
13 radiological risks might be unacceptable regardless of a
14 benefit.
Pragmatically I think it makes sense to have a 15 ceiling on new legal risks.
I think there are risks that 16 a re unacceptable for the general public, but trying to 17 define what those are is pretty tough.
I am not sure, at 18 least in light of the numbers that are in the safety goal 19 proposal, tha t it is very meaningful in this context.
20 I also am concerned about the issue of the 21 unverifiability of plant risk levels, what you and Bob 22 talked about this morning, and the general problems of high 23 degrees cf uncertainties when you get to low probability.
24 There is a line I copied out of the paper that sa ys :
25 because of lack of certainty th a t unforeseen events are ALCERSON REPORTING COMPANY, LNC, 400 VIRGINIA AVE., S.W., WASHiNGTCN. D.C. 20024(202) 554 4145
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1 adequate 17 provided for, an analytical demonstration that 2 quantitative goals are achieved would not be sufficient to 3 show that a nuclear plant is safe enough.
4 I understand the concern that went into that but I 5 quess the only other evidence that one :ould consider 8 besides that is the analytical treatment and observed events 7 and all the postulated events.
I almost think that 8 statement is a tautology because it could a pply to any risk 9 on which you do not have a large amount of historical data.
10 I do not quite understand what is meant by an extra margin 11 of safety except it is a vague reference to some sort 12 aversion to uncertainty.
13 If that is the case I think it should be addressed 14 as uncer tainty.
It is stressed somewhat.
There is a 15 statements where uncertainty regarding a radiological 16 hazard is sufficiently great, the hazard should not be 17 permitted.
18 Again I put that in mathematical terms.
I say if 19 the upper confidence level is excessively high, you might 20 not want to accept the risk.
I guess the question is do you 21 use best estimates or bounding arguments, in which cases of 4
22 analysis is the one I am in terested.
I do not think it has 23 been clearly treated in this report.
24 One other issue that came out, the one 25 quantitative criterion that I felt coming in was the most ALDERSON REPORTING COMPANY. INC.
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1 important was the definition of what is as low as reasonably 2 achievable.
That is what kind of money for what kind of 3 trade-of f to safety is judged to be r easo na ble, because the 4 absolute numbers themselves are, as we have heard frcm Rob, 5 f airly f uzzy and hard to determine if you are below them or 6around them.
That is the one number that did not come out 7 in th e report.
I can understand why there would be a 8 reluctance to put a number on it but I think if these 9 quan titative goals do start to be rolled into the regulatory 10 process, tha t A1 ARA goal will be tae critical one.
I think 11 that is important.
12 The other area that I wo uld like to see a little 13 more detail and I am sympathetic to the NRC staff that 14 prepared th e report. -- is I only have the vaguest idea of 15 how these safety goals would be applied.
The problem of 16 setting fairly low probability targets but then also 17 requiring ALARA, it was not clear to me whether the A1 ARA 18 applied most to backfitting old plants or whether it was 19 m ea n t to apply to new plants once they had met the numerical 20 targets.
21 Finally the issue in implementation that dees 22 concern me is that the goals as planned in the report seem l*
23 to be unacceptability criteria but not acceptability 24 c rit e ria.
That is an analytical demonstration of plan meets 25 one of the goals is not accepted, and I understand why, ALDERSoN REPOR *iNG COMPANY. iNC, 400 VIRGINIA AVJ., S.W., WASHINGTON. 0.C 20024 (202) 554 2345
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13 1 given the difficulties in taking apart probablistic analyses 2 and knowing whether they are right or wrong.
3 But by the same token the statement that 4 probablistic analysis of plants that come in at higher risks 5 than those of the goals will be bases to challenge seems to 6 me to provide a strong disincentive to do probablistic risk 7 analysis.
I think that is exactly the wrong thing because 8 despite the uncertainties in knowing what reactor risk 9 levels are, PRA has a lot to offer in terms of improving the 10 design and operation of the plant.
I worry about 11 disincentives.
12 I am a little concerned tha t there seem to me to 13 be some multiple sources of conservatism in the report.
14 Tha t is using high ALARA ra tes because the risks are to 15 health and safety.
It says somewhere in the report:
a 16 general aversion of uncertainty throughout.
I think that 17 h as to be broken down and looked at.
18 Finally, given that you cannot use the 19 probablistic targets as stated as actual goals to be 20 verified by probablistic analysis, or at least I do not see 21 any willingness to approach it that way and I agree with 22 tha t approach, I wonder about the whole idea of having 23 probabilistic goals being treated as standa rds.
I read the 24 discussion paper.
They were being treated as standa rds.
25 A nalysie shows if you do not meet them, you have to justify ALDERSON REPORTING COMPANL INC, 400 VIRGifHA AVE S.W WASHINGTCN. O C. 20024 (202) 554-2345 l
14 1 your plant on some other grounds.
Having standards you 2 cannot verify is the question.
3 Finally I do ha ve an interest, tying back to this 4 panel, in the whole question of risk aversion which was 5 treated very lightly and almost not at all in the discussion 6 paper, I guess in some pa rt because I had a role in the 7 development Of the 1.2 factor and I know the history of how 8 tha t came into being.
I guess I am a little concerned about 9 how far that is being carried on the basis of the pretty 10 quick and dirty analysis.
11 MH. SLOVICs Thank you.
12 ER. MacLEAN I am Doug acLean.
I am at the 4
13 Center f or P hilosophy and Public Policy Research Center at 14 the University of Maryland.
I am a philosopher by traininq 15 and for the last few years my research has focused on energy 1
16 policy and more recently on the general issues of risk 17 a ssessment, particularly the question of the nature of 18 justification of policies that require centralized decisions 19 tha t impose risks on health.
There is a number of basic 20 philosophical issues there.
21 My concerns here are best divided into some issues i
22 about the paper and some issues about this panel.
I will 23 talk about the panel first.
I was happy that Paul outlined 24 most of the central issues th a t emerged from the panel 25 discussion at the Palo Alto meeting.
It is
=y opinion that ALDERSON AEPORTING CCMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345 w
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15 1 the report does not deal with these very se riously, some not 5
2 at all.
I do not know quite wha t to say about that.
I do 3 not know what we should be aiming to do in this panel in 4 terms of refining that report.
Righ t now it looks like some 5 of the socio political, ethical and also the economic issues 6 have sort of been phased out in terms of this report.
I 7 guess that bothers me a bit.
8 About the report itself, I have a number of 9 particular questions and objections.
Most of them are 10 discussed in the discussion paper that was circulated so the 11 details are there.
But in general my concerns are these.
12 First of all one of the clearest messages that emerged from 13 the general discussion at the Palo Alto meeting is that 14 qualitative standards, qualitative goals were very important 15 and perhaps quantitative goals did not make a lot of sense 18 unless they were related fairly clearly to qualitative goals.
17 It seems that there was an attempt in this 18 discussion paper to take that seriously.
The claim here is 19 tha t we have some qualitative goals and then quantitative 20 goals based on those.
The execution, carry ing out that 21 claim, I find to be woef ully inadequa te.
First o f all the 22 qualitative goals I t' ink a re about as vacuous or as empty 23 a s they can be and I think they could be made very, very 24 specific and much more meaningful.
If they are not made 25 much scre meaningf ul, I think that might raise some ALCERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON. O.C. 20024 (202) 554-2345
16 1 socio-political problems about wha t these numbers are all 2 about.
3 Secondly, relating then the quantitative goals to 4 t he qualitative goals, I ag ree wi th Helen's comments that 5 af ter the statoment of the qualitative goals the 6 quantitative goals seem to be pulled out of the air.
About 7 the quantitative goals themselves I have a number of 8 particular problems in my own mind.
The main one I guess is 9 the one that has been mentioned, the problem of 10 verifica tion.
I think unle's that issue is addressed 11 seriously, it is hard to tell what the goals amount to.
12 So I have a lot of problems with the report, but I 13 do not know how they enter into the particular focus of this 14 panel.
15 MB. SLOVIC:
Thank you.
16 ME. PEHROWs I am Chick Perrow of the Department
!7 of Sociology at the State University of New York at Stony i
18 Brook.
I am interested in organizational theory and l
19 systems, failures and systems, accidents and systems and so 20 forth.
21 I think there are many issues concerned with the 4
22 d raf t report.
One of them has been stated at least twice so i
23 I will just second it, namely that I also do not find the 24 dilemmas and agonies of this panel reflacted in the draf t 25 sta temen t.
It is as if they said oh, th a t is a whole can of l
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17 1 worms that we are going to forget about and stay away from 2 because we are not either qualitative or quantitative in our 3 goal statement, they are just considerations.
4 So I was rather annoyed at that because I thought 5 we worked rather hard and plumbod some difficult issues last 6 time, and they do not seem to show up.
7 With the report I have three major criticises.
8 All of these
- t. ave been mentioned I think.
One of them is 9 that the current experience with nuclear plants demonstrates 10 that for several of the serious accidents or near accidents, 11 speaking of Fermi and THI and Browns Ferry, things like 12 tha t, th at they were the result of una n ticipa ted 13 interactions of f ailures, failures that normally you would 14 n o t expect to occur at the same time and have them interact 15 in the way that they did.
The pro ba b.411 ty for these kinds l
16 of interactions cannot be reasonably estimated.
The fault 17 tree analysis is not equipped to deal with these kinds of 18 cra zy accidents.
19 Therefore the probability of risk estimates I 20 think is not appropriate for systems tha t have certain 21 cha racteristics.
Namely we do not know much about what is 22 going on within them, there is high complexity, there are a 23 lot of pathways of interactions that are unexpected and 24 finally that they are very tough and uncomfortable systems.
25 Furthermore, even experience does not help us th a t i
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18 1 much.
The best example is that as a result of TMI ch ange s 2 were made in opera ting practices.
It was widely believed, 3 it is only people who have read the Carlyle Michelson memo 4 or observed the Davis Bessie transient more carefully that 5 TMI would not have happened.
It could have been prevented.
6 So they made these changes and then we had within 7 four months in at least two other plants experiences where 8 the new regulations made it mere dangerous'and more 9 difficult to handle the transients anc increased the 10 severity of the transients in terms of cost and downtime and 11 risk as the result of experience learned at TMI.
So whe.
12 you have very com plex systems, even experience is not a good 13 guide.
14 The second point is that the proposed goals 15 indicate that -- and I do not think anybody has raised this 16 one yet so this is kind of different -- even disclosed risks i
17 tha t would be judged unacceptable may be judged acceptable 18 because other unnamed f actors override them.
They are 19 unnamed by the report.
20 So they say, "we therefore propose that NRC should 21 not require demonstration of compliance with the goals in 22 individual licensing cases as a principal basis fer 23 licens3 ng."
There are a whole bunch of quote s but the best 24 o ne I guess ir, "if we have a safety goal a nd the risk 25 estimates indicate an unacceptable risk, it should be ALDERSCN REPORTING COMPANY. INC.
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19 1 necessary to show that other factors override this 2 finding. "
That is to say some unidentified other facters 3 would transform the unacceptable into acceptable.
4 I think the public should be made aware that 5 saf ety is only one of many goals.
There are some others.
6 This report does not specify.
I presume they include 7 excessive costs, prolonged outages, unavailable technical 8 means and so on.
But I am not sure because they have not 9 told us.
~
10 Finally, one that everybody has hit on is +.he 11 implementation.
I would point out that even after TMI and 4
12 with an invigorated NRC even more concerned with safety than l
13 they have always been, we have had several cases of rea lly 14 unacceptable performance by utilities.
The most notable T
15 tha t I la aware of is Indian Point.
So the ne wly 16 invigorated NBC has not had an appreciable impact upon the 17 performance of the industry.
That is one point.
And could 18 they do anything even if they had th e means, and it does not 19 seem to be in there.
20 The second point is that we do not know what they 21 wcald do.
It is totally unclear from the proposed safety l
22 goals ho w plants in operation would be affected by this or 23 even plan:.s coming onstream.
There is no concrete 24 demonstration of the etfect it might have upon plants or hcw 25 that affect is to be achieved.
So we ha ve a big gap between 1
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o 20 1 the goals and the implementation thing.
People have 2 mentioned that and I think it should continue to be 3 mentioned.
4 Those are th ree serious concerns beycnd the one 5 that I do not find delibera tions and problems of the last 6 time reflected in the document.
7 MR, SLOVIC I have counted about 18 concerns.
8 Some of them are overlapping.
All are relevant.
I have 9 done a quick and dirty classification of those and I can 10 pare them down to about ten agenda items.
I will restate 11 them very quickly.
12 First is the na ture of the qualitative goals and 13 the link between getting from qualitative to quantitative.
14 Actually this is really a subset of a broader concern that j
15 was raised about the general logic and coherence in the
]
16 control document that form a coherent, understandable, 17 convincing statement.
18 There seems to be a number of issues that are 19 related to the use and adequacy of probablistic risk 3
20 assessment and the treatment of uncertainty in this form of 21 analysis, questions about the use of the ALARA principle, 22 some concern about the specifics of the qua ntita tive goals 23 themselves, the problems in the verification of goals and 24 the implementation of them.
25 There is very general concern about the questions ALCERSON REPORTING COMPANY,INC.
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21 i
1 of social policy and how one integrates complex value 2 concerns into policymaking, whether it is done adequately 3 here.
This also relates to whether the concerns raised in 4 Panel C's diss.ssions last time really have been addressed 5 properly in the present report and what can be done about 6 that.
7 There is another general question about the 8 distinction between goals and standards and where this 9 report stands in that regard and more specific concern about to the nature of risk aversion and how that should be 11 incorporated.
12 I have just reeled off eight which I think include 13 most of these items.
I see all of these as relevant.
I 14 have the feeling we will touch upon all of th em.
I do not j
15 know how much we can do in the time we have except to try to 16 bounce these ideas around.
17 There will be an hour-and-a-half p.'.enary session 18 tomorrow that is designed to be focused on these social 19 issues.
As chairman of tha t session I will try to bring up 20 for general dircussion some of the things that we either 21 h ave discussed here or have not.
So I will keep this agenda t
l 22 in mind tomorrow as well.
Then in the other plenary 1
23 sessions I would imagine that there would be a lot of 24 o ve rla p.
Just as we are to uching upe n quan tita tive issues 25 this morning, social issues will emerge I think all through ALDERSON REPORTING COMPANY. INC, 400 V!RGINIA AVL, S.W., WASHINGTON, D.C. 20024 (202) 554 2345
22 1 the plenary sessions.
2 I would like to add a co mr.en t here.
Maybe we 3 should start with the question of probablistic risk 4 assessment.
The issues were highlighted really well by 5 Bob's talk this morning and I think tha t that ties in quite 6 closely with the concerns that Chick has about this.
Bob 7 had a very thorough compendium of the problems and 1
8 dif ficulties in doing probablistic risk assessment but 9 concicded on a rather optimistic or somewhat optimistic to note.
It is still let's say maybe the best thing we have 11 and we have to keep developing it and build on it.
12 I get the feeling tha t Chick shares there concerns 13 but interprets them differently, much more pessimistically.
14 I think we could say well, given all of these uncertainties I
15 the question is when does the tech'ique collapse under the 16 weight of all of these accumulated uncertainties.
Is it 17 still viable despite all of the se real problems?
Or do you 18 have to say that is really it; it is worthless; it should 19 not be used at all?
Or is there some middle ground such 4
20 t ha t it can be used in some situations but not in others?
21 I see the discussion paper as trying to take a 22 middle ground by acknowledging uncertain t:.es, saying it 23 should not be used in a probative
'.a I; there should not be 4
24 an attempt to verify compliance or noncompliance.
Perhaps 25 it can be used to set priorities for research or just as one i
l I
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23 1 of many considerationc.
2 One might objrct to the specific language in the e
3 document wi th regard to the technical limitation.
But I 4 think
't attempts to be kind of a soft implementation which 5 is really sensitive to these uncertainties.
It dces take 6 the position that despite the uncertainties there still is a 7 use to it.
I think maybe we could spend a little time 8 discussing that issue.
9 MR. PERROW:
I think that is well stated because I 10 certainly do not think that it should be thrown out by any 11 means.
It is extremely important for a lot of failures that 12 are predictable.
It is a sim ple thi ng.
In one sense you 13 v a n t to know how thick to make the walls of :he pipe.
So 14 you rely on operating experience.
It is going to experience 15 certain surges so you lea rn from tha t.
16 My objection is quite different.
It seems to me 17 tha t the discussion paper sends a signal -- and I think 18 Helen Ingram might agree with me on this just from listening 19 to her very brief remarks -- to the public that 4
20 probabilities have been taken into account in these 21 estisiates and they have been quantified and we have laid 22 them out as a standard and we expect plants to do that.
23 This is e great reassurance to the public that we have all 24 done oct herework and have done the best we can.
25 I would prefer a much different signal be sent out ALCERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTCN, O C. 2002 (202) 554 2345
2 84 1 to the public.
As a matter of fact I propcse a preamble 2 which would bea "These goals do not reflect current 3 operating experience."
That is we have had far more 4 accidents than would be predicted by the fault tree 5 analysis.
As a matter of fact somebody sat down and took a 6 f ew of them and calculated tha t the probabilities of these 7 things having occurred were almost ;nfinitesimal.
8 And the experience suggests that proba b ility risk j
9 assessments, the heart of the picoposed goals, may not be i
10 very relevant for current and planned plants.
We should 11 warn the people that the basis of these goals are not really 12 very appropriate.
What I am concerned about is the symbolic 13 message that we send.
14 MR. 310VIC Could I ask a question here?
When 1
15 you say these goals do nGt reflect current operating 16 experience, I am wondering about the distinction of goal 17 versus standard or whatever.
Does a goal have to reflect 18 operating experience ?
Can't a goal be something that is put 19 forth as an objective which defines what we believe, what is 20 importan t, what we want to achieve apart from operating 21 experience ?
I do not see the link there.
22 MR. PERROW s Ihat is a good point.
How about 23 changing it?
"The standards that these goals imply do not 24 reflect current operating experience."
25 MR. WHIPPLE4 I am not sure I agree with that ALDERSON REPORTING COMPANY,INC, 400 vtRGINIA AVE, SY'. WASHINGTCN. 0.C. 20024 (202) 554-2345
25 1 though.
2 MR. O'DONNELL.
What I did after Three Mile Island 3' was to take Rasmussen's estimate of tr a least serious 4 accident with outside consequences and see what it said 5 about the likelihood given 50 or 70 reactors.
And it said 6 that the probability is 50 percent tnat you would have seen 7 one by 1973 or 1974 and a
.8, you would see one by 1980.
8 So I do not think that in absolut e terms the 9 operating experience has been ' hat we have far more 10 accidents than the first few PBAs we have had to date have 11 predicted.
12 MB. PERROWs I would disagree with that.
What 13 Rasmussen did was predict the probability of a failure of 14 emergency f eedwa ter coupled witr a s+op-open POR.
That was 15 par t of the Three Mile Island accident but there is no 16 estimate in there of the failure to recognize the zirconium 17 water reaction, no estimate in there of the f ailure of the I
18 operators to viola te standa rd ope ra ting procedures.
The 19 operators did what they were supposed to do.
We now wish 20 they had done what they were not supposed to do.
No 21 estimate is in th e re that they would have misunderstood the 22 accident, no estimate in there that there would he a whole 23 bunch of associated failures.
24 So that failure became a very expensive one, very 25 costly failure for reasons which the Rasmussen repCrt cou'ld ALDERSoM REPORTING COMPANY,INC.
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26 1 not possibly pred ic t.
So that is what I mean by viola tes 2 opera ting experience.
3 3R. WHIPPLE:
The mere fact that one particular 4 sequence, string of events occurred does not tell you much 5 a t all about its probability of priority.
That is the 6 difficulty.
If this happened in three reactors, I would 7 certainly agree tha t it was a high probability the event was 8 overlooked.
But you can do a little bit of crude averaging.
9 HR. PERROWs What I am saying is there are a great 10 number of interactions that can take place.
So there is a 11 high chance of a low probability accident.
Any one accident 12 by itself has a low probability.
But there is a let of 13 opportunities for any one of those low probability i
14 accidents.
Dropping a light bulb is a pretty good example.
15 It is an excellent one.
Another one is the Hanford pla nt 16 where a short circuit fused some adjacent wires.
The 4
17 adjacent wires contro? led the scram system and def ea ted the 18 scram system.
Fortunately there was a backup but there f
19 a ren ' t in commercial plants.
That vns a very low 20 probability event.
But there is a lot of occasions for it.
21 MR. SLOVIC:
I think we could discuss this all 22 d a y.
We are getting at the uncertainties and this is i
23 reflective of the problem.
t i
24 MR. O'DONNELL:
It seems to me th a t we are naking 25 too much of the link between the goals themselves and the ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
o 27 1 process by which you verify them.
Obviously it is very 1
2 important.
But they are really separable to a certain 3 extent.
One could set c o s.l s, that is this is what the NRC 4 should be striving for in terms of an acceptable level of 5 risk.
We should take those goals and chisel them on the 6 f ront of the NRC building as the sta tement of what is an 7 acceptable risk.
That could be in terms of the numbers here.
8 Now having established that, it could be in terms 9 of the two f atalities per 1,000 megawatts per year just as 10 you could set acceptable levels of risk f or the automobile 11 industry.
let's say if you wanted to limit the number of 12 traffic f atalities to 40,000 per year, that can certainly be 13 adopted as a goal.
Then the question of whether you will 1-4 ever be able to verify that you have met the goal is really 15 a separat? issue but one that is very important, cbviously.
f 16 If you have enough operating experience as you 17 would have in the automobile industry, it is directly 18 verifiable f rom experience that we are not meeting a goal i
19 such as 40,000 fatalities per year.
In a technclogy such as i
20 n uclear power, the question of whether you have met these 21 goals that are chiseled on the front of NRC then becomes one I
22 of do we have enough operating experience to see that we 23 h a ve met those goals.
The answer right now is obviously no, i
24 v e do no t have enough operating experience to verify 25 directly f rom experience th a t we have met those gcals.
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1 So one then has to say what is the next best way 2 of determining whether I have done that.
It appears that 3 using PR A with its uncertainties offers a t least some hope l
4 of determining whether or not we are in the range of that i
5 goal, whether we are two orders of magnitude lower or higher.
6 So I would, if we could, separate the discussion 7 into wha t a re the goals themselves and then what is the 8 means of verif ying them.
i
~
9 MR. S10VIC:
Helen.
10 MS. INGRANs I think tha t maybe it is not a good i
11 idea to think that we can separately discuss the goals and i
12 the means of verifying, par tly pbecause I am concerned about 1
13 this symbolic message that came through very clearly here t
i
]
14 which is we have this number and there is great faith in 15 this number and it is so low that we can be sort of assured 16 t ha t if th a t is met, we do not have to worry about risk.
j 17 It seems to me that this is an opportunity, a 18 public policy opportunity to say to the public:
we are in a 19 risk-laden world.
It is not just nuclear power but other i
20 industries have risk.
So when we make decisions, there is 21 no such thing as safety, that everything has a risk with a j
22 probability associa ted to it.
4 23 What I am concerned about here is that we have 24 these numbers and the chance to take probability analycis 25 and discuss those numbers about how certain are we that that i
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29 1 number can be verified, experience, what does that number 2 mean.
Th-is not taken up here.
I think that is related 3 to the question of the logic between the qualitative _ goals 4 and these numerical kinds of goals.
5 As a policy analyst, somebody who is interested in 6 how analysis is connected to decisionmaking, I saw this 7 whole exercise as an opportunity to be more sophisticated i
8 about public policymaking, to realire that you cannot oo 9 around continually reassuring people that it is a safe world 4
10 a nd then things happen for which they have not been warned, 11 they are not prepared, there is overreaction.
It is 12 enormously costly.
It th r s w.
the whole policymaking process 13 into an upheaval.
14 If the analysis therefore was a little closer to 15 events that happened, that after all this is an improbable I
16 event but it happened, it does not throw out everythfng, 17 tha t it was in the realm of possibility, we would be better l
18 o f f.
19 MR. MacLEAN:
I disagree slightly I think with the i
l 20 wa y Paul stated the issue.
If we want to look at the 21 problems of probablistic risk assessment, I think the 22 question is not th e uncertainties and wha tever is so great 23 t h a t this a pproach to setting goals is just hopeless and 24 therefore should not be used, but rather are they great l
25 enough that it might be the case that a different approach i
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l 30 1 would be better.
j j
2 In particula r I do not think it should be ruled 3 out in advance and that it should be clearly demonstrated 4 tha t goals stated probablistically, quantitative safety 5 goals are somehow better than the traditional defense-in-6 depth approach that it seems to look like is being 7 overturned here.
8 Secondly, I think it is important to link the
- 9. statement of the goal with verification.
Here is why.
Look 10 s t the statement of Goal 3 that takes a 1 in 10,000 per year 11 reactor operation.
How did we get this number 1 in 10,000?
12 As I recall it, that number came out of the Forum proposal, 13 the NUREG-0739 I guess.
It was stated there I think that 14 1 in 10,000 was about the lowest level that we could 15 meaningf ully verify.
I think th a t if that is the case, 16 obviously we should not be working with numbers that cannot 17 be verified.
However that number implies, as we have stated l
18 in our discussions of 'his, tha t with 200 plants, over 30 19 years there is a 60 percent chance of a large -ore melt.
20 If that is unacce ptable id if th a t is the lowest 21 number that can be verified, then we have a serious problem 22 with these quantitative goals and probablistic goals.
So I 23 do not think that the issue of the goals can be separated 24 f rom verification.
25 MR.
'4 HIP P LE :
Is wha t you a re saying that the only l
l l
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4 31 1
1 thias that the operating experience can do for you is verify 2 that the plants are not using goals?
In the foreseeable 3 future we will never be able to demonstrate the goals?
4 MR. MacLEAN:
I am saying here that the connecticn 5 with verification is this.
If there is some number that is 6 the lowest number we can meaningf uly verify and if using a
7 that number gives us an acceptable risk level that we might i
8 think is unacceptable like a 60 percent chance of core melt, 9 then you have a problem with using these numbers at all.
10 MR. WHIPPLE:
Whether or not that is an 11 unacceptable risk is a sepa ra te question.
J 12 MR. MacLEAN:
That is right.
P3 MR. SLOVIC:
It is a ma tter of consistency.
i 14 MR. O'DONNELL:
That is why if you set the goal 15 rou d._i;. first of all the bases of first principles of 16 wha t you think is acce ptable.
Then you turn to the questien 17 of whether or not you can verify that.
If in fact you 18 canno t e then you have no wa y of showing you have met the 19 g oa l.
But the goal is still there.
20
'R.
MacLEANs* Then the question is what is the 21 point of having a goal.
I 22 MB. O'DONNELL:
You are prejudging the second 23 question.
If you can set the goal, you have done tha t, then 24 you turn to the question of whether or not you can 25 demonstrate that you have met it.
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MR. Mac LE A N:
I would want to suggest that we 2 should not have a goal that cannot be verified.
3 MB. O'DONNELL:
I am not sure of that.
4 MR. SLOVICs Let me try to react to what has been 5 said so tur.
j 6
Is there not some value in making a sta tement of 7 goals which serve somewhat like the Constitution does, to I
8 define an ideal tha t we think is worthy, is logical, is fair
~
]
9 and so forth, to strive for without knowing exactly what it 10 is going to lead to in terms of procedures, to kind of set 11 it forth?
12 To me it seems that this is valuable because it 13 a ttempts to set forth openly and explicitly what the NRC 14 f eels is important in defining protection of public safety.
3 15 I think that is a big step in itself even thouch it leaves a 16 lot undefined.
As I read this document, there is an attempt 17 to cast it in the ligh t of something tha t is not fixed in 18 stone, is very much an evolving th in g which will be tried 19 out in a very loose way to begin with as experience is 20 gained.
21 I thini that people have said that we do not knov 22 exactly how it is noing to be implemented.
I think that is 23 the case.
You will never be ab1 ) to forecast the 24 implications of some of these statements until yoa actually 1
.I 25 live with it for a w h il e.
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So I think that if there is tha t provision that it is going to be not taken that seriously or in a binding way' 3 to begin with and we just set this forth, which to me seems 4 like a tremendous step, and live with it for a while and 5 criticize it and ba t it around and revise it, then maybe 6 some of these issues will take on a different light.
PRA is 7 an evolving methodology as well.
Maybe it will undoubtedly 8 improve and that might cast a somewhat different light on 9 things.
10 MB. PAGE:
I want to restate what you said and 11 change its meaning slightly.
12 It seems to me that operationally there are three 13 ways you can vorry about nuclear safety.
One is to require 14 def ense-in-depth concepts where you focus on redundant 15 systems and make that the way that plants are constructed 16 and operated.
17 Another way which is closer related is to 18 prescribe *h e technology in great detail.
In other words go 19 beyond a generic principle af ter that defense-in-depth 20 concept and tell people how to build their plants so you can 21 have sort of nitty-gritty petty regulations, lots of them.
22 The third is that you can have a performance 2:) standard tha t says as long as you can make your plant 24 perform with the probability of this kind of failure at this 25 number or below, then you are okay.
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34 1
What we have been talking about is goals.
The way 2 you f rame the impression of goals is not in that direction.
3 In other words you say here is a goal that is nice, it is 4 like the Constitution and we will vorry about implementation 1
5 later, but just to set up the goal will let us think through 6 the problem more carefully and then as we worry about 7 implemen ation more, then things become scre operational.
8 What I am sa ying and wha t I think Doug is 9 suggesting is if you take the notion of an overall aggregate 10 performance requirement such as the probability of core 11 meAtdown being less than some number, it can just by itself, 4
i 12 sort of sitting up there in a vacuum, be misleadino in the 13 sense that i is going to look like some sort of a teeny i
14 number to the public at large and it will have a scct of 15 reassurance value which is illusory because we have no way
]
16 o f knowing whether it is good or not.
i 17 I think part of what got us in trouble wi th the 18 Rasmussen report is that it was used in tha t wa y.
We got i
j 19 those teeny numbers and people said oh, we will be okay.
l 20 Then an accident comes along and people say gee, we can't 21 rely on anything.
So you have these vacillations back and J
j 22 f orth.
23 MP. SLOVIC:
Would it help not to have 1
24 quantita tive goals ?
25 MR. PAGE:
I think basically that you have to do f
f ALCERSCN AEPCRTING COMPANY,INC, 400 VIRGINIA AVE., S.W., W ASHINGTON, D.C. 20024 (202) 554-2345
35 1 all three.
You need to worry about redundant systems, 2 def ense-in-depth.
You need to worry about petty 3 regulations
- this valve rather than that valve.
And you 4 need to worry about cyerall performance requirements.
5 But in thinking about the overall perf rmance 6 requirements, I think it is empirically nonsense, in th e 7 technical sense of nonsense, to have a number sittir.o up 8 there all by itself without any notion of whether you are d
9 getting close to it or whether it is a good number or a bad 10 number.
Who gains if this happens; if that happens who 11 loses.
12 The idea tha t I am trying to push right new is 4
13 that quantitative goals become more meaningful and more a
14 useful to the degree which you can make them have some sort i
15 of empirical content.
That does not necessarily mean that 16 you have to have operating experience so that you can 17 de/elop frequency histograma on each one of these numbers.
)
18 I t may be that there are other ways of giving an operational j
19 content to these kinds of numbers.
i 20 ME. O'DONNELLa I think I agree with a lot of what I
21 you said.
From the industry's point of view I do not think i
22 t he industry is looking at using safety goals and risk 23 assessment to get ric of the defense-in-depth.
In fact it 24 is quite the opposite.
We alread y ha ve a g rea t deal of very 25 detailed regulations that peopla are kind of living with.
1 i
f I
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36 1 The concept of defense-in-depth is very important.
That is 2 what kind of saved everything at TMI.
That is the exicting 3 structure of regulation.
4 The idea behind the safety goals is to try to 4
5 establish from first principles first of all an accepta ble i
6 level of risk and then to look at this existing bcdy of 4
7 regulation including defense-in-depth to try to determine 8 somehow whetter or not designing plants to the current j
9 regula tions do in f act meet that determined level of l
10 a cceptability.
11 That gets into the process of verification.
So 12 all of these three things really come together but each is j
13 really an independent problem and subject that can be 1
14 addressed on its own merits.
15 MR. WHIPPLE:
There is an added benefit too which 16is the probablistic goals as we are talking about them here j
17 seem to ref e r to a n overall standard for licensing and a 18 number to give the public confidence in what you are doing.
19 But in addition a goal can be a design criteria and it can j
20bea regula tion criteria, a development of deterministic 21 c ri te ria.
i l
22 I think the NRC staff if they had a number to 23 backtrack to when they are working on this criteria, instead j
24 of working on the current entirely judgmental situa tion, it i
25 could be a valuable reference point.
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MR. SLOVIC4 As I understand, the succested use of 1
2 the goal here would be more along that line.
Specifically 1
3 it should not be used in licensing.
Of course one could 4 argue that inevitably those concerns will be brought up and 5 once you put it forth, people can start using this technique 6 in any way that they want and then bri1q it up as an issue 7 in litigation or wha tever.
8 MR. 0*DONNELL4 I think its most valuable use is q
9 in determining needs to change things.
In other words do we 10 need another valve here, another widget there.
T 't e y would 11 be incremental changes, nc-to throw out the entire i.
12 structure and to determine whether or not we should do away 13 with remote signing or containment.
14 MR. PERROWs How would we do that?
i 15 MR. O'DONNELL:
How do we do it now?
16 MR. PERROWs We do it by regulations.
17 MR. O'DONNELLs But on what basis?
There is no i
la defined basis.
19 MR. PERROWs How could these calc,lations affect a i
1, 20 valve?
That, is really a very basic question, a decision i
j 21 about a valve.
i I
22 Paul is saying we cannot take the se things too 1
23 seriously, that we are jus: going to kind of play with 24 t he m.
So they are not really goals.
They are not going to 25 be implemented if something else more serious comes along i
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j 1 and you are saying that we are going to determine --
2 MR. O'DONNElla It will certainly be an element of 3 tha t decisionmaking process.
4 MR. PERROW4 I still have not heard anybody tell 5 me how.
6 M R. B ER N ERO :
I wonder if I could volunteer an 7 example on that.
I mentioned in the talk this morning that 8 we looked at Crystal River III power plant in Florida.
We 9 calculated the core melt probability for that plant.
We got to.s little bit over this goal like 2 or 3 times 10 to the 11 minus 4 per year probability of core melt.
12 If you looked at the analysis, it said that the 13 probability of core melt is principally tied up in a very 14 limited body of equipment.
The decay heat removal system 15 *;ich is called auxfeedwater is a two pump system in that 1b plant, one electric and one turbine-oriven.
And due to the 17 way it is wired up, it really depends on or derives power 18 from only one of the two DC buses and only one of the two AC 19 power buses.
20 That risk analysis then says, one can speculate, 21 her e is a goal 10 to the minus 4 per year for the 22 probability of core melt; your plar.t does not need it and 23 w ha t you have to fix is this valve or that DC battery or 24 t h a t AC power connection or some amalgam thereof.
l 25 In some instances it could be so simple as a l
l l
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39 1 single valve, that a very imprudent arrangement of valves 2 would cause a problem.
In this particuar case it was a 3 limited network of equipment.
4 4
MR. PERROW:
You mean there might be plants out 5 there that depend upon removing decay heat after some other 6 accident?
And sometime when you have to remove decay heat, 7 that would rely on a limited amount of power source by.iust 8 AC and where the probability might be 10 to the minus 1?
4 s
{
a MR. BERNER0s I doubt very much if you would find to one that high.
What you will find is a plant which is 11 substantially less reliable than some of its peers.
In this 12 particular case it is a redundant system.
It has a motor 13 d riven a uxf eed pump and a steam turbine-driven auxiliary t-14 feedwater pump.
i 15 But the way it is set up, it has only a limited 16 benefit of that redundancy because of the way it is wired in 17 the pipe.
There are two basic approaches that th e designer 18 o f that plan t could have used to a ch i.e ve sub s ta n tially 4
19 greater redundancy.
As many of the plants do, they put in 20 one turbine-driven pump and two motor-d riven pumps.
They 4
21 h av e a three pump system and they harvest 3 much greater 1
i 22 reliability in taking advantage of redundant electrical 23 power sources.
I 24 In this particular case there are swing electrical i
l 25 systems that could get you part way there.
l
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MR. PERROWs This to me is very i mporta nt.
Would 2 passing this or fl oa ting out, sending out this safety goal 3 by NRC cause anybcdy to go and look at their auxiliary 4 f eedwater system or removing decay heat and say gee, we 5 don 't need it?
P MR. BERNERO:
No, I doubt it.
7 3R. PERROWs What effect would it have tomorrow on j
8 the operation of plants like Crystal River if this were 9 passed in this present f o rm ?
Would anybody out there do 10 anything dif ferent from what they are doing now?
Would they i
11 go around and look at their decay heat removal system?
12 MR. BERNERO:
They are going around and looking at j
13 the system anyway.
That is going on.
14
.R.
PERROW:
I hope so, i
15 MR. BERNERO:
But what it would do is it would i
16 give a much better sense of urgency or importance to the i
17 result where in the Crystal River case the failure to remove 1
18 decay heat, reliability number or leading ccre melt, is 2 or 19 3 times 10 to the minus 4 per yea r, tha t probability of core 20 melt as against some other plant someone will do or is doing 21 a similar analysis and comes up with 2 times 10 to the minus 22 5.
23 Right now the regulatory process is such that the 24 NRC has a group of people looking at Crystal Eiver that sa y s 25 7 ee, you ought to fix 2 times 10 to the minus u.
In anothe r I
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1 room there is another group of people looking at scme other.
2 plant and saying gee, you really ought to fix 2 times 10 to 3 the minus 5.
4 The passage of the goal would in the one case say l
5 you very well should fix 2 times 10 to the minus u and in 6 the other case say you probably do not have to unless you 1
j 7 can do it very simply.
That is the effect it would have.
8 MR. PERROWs It kind of puts a ceiling en it.
It.
9 says this is a reasonable thing and if you are already 10 there, don 't worry about it.
11 MB. BERNERO:
Yes.
Of course the thing that Chris 12 raised about a standard of unacceptability and acceptability 13 is an important distinction.
14 MR. SLOVIC:
I think in this way these analyses 15 are used as aids to thinking and decisionmaking with regard 18 to problems that have to be decided upon some way.or 17 another, anyway.
If you do not have an explicit goal, then 18 it will be done in a variety of ways, perhaps incon sistently.
19 MR. WHIPPLE:
Have you seen cases, Bob, in which 20 you and the industry more or less agree on the probability 21 but do nct agree on the need for a fix?
If you are talking 22 about some pa rticular plan t, say in the future, and if you 23 had a background reference goal as opposed to the judoment 24 o f the regulatory staff, at least you have a fairly clean 25 way.
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1 HR. O'DONNELL:
It seems to me th a t the way the 2 staff is looking at risk assessment these days is tha t if 3 you come in with a risk assessment they do not look at the 4 level of risk.
They just say okay, these a re the worst 5 actors and you have to fix them.
There vill always be worst 6 actors.
You get to the point where you keep fixing things 7 and it is like lowering the water in a reservoir.
More 8 rocks start showing up the lower you go.
9 Without some basis for deciding whether or not you 10 have some threshold for which things become less important, 11 you have no basis for decisionmaking.
12 The way this is described now is kind of an upper 13 limit and it implies that if you are below that you are 14 oka y.
It brings in this ALARA principle without really i
15 quantifying it.
I think tha t is a very important item here 16 because I think no matter what level of safety you have gone 17 t o, if you can do things to reduce that level of sarety that 18 a re cost effective, once you do it the NRC should require it.
19 That is why I think it is important to have in 20 here always the principle that even though you have met the 21 ocal, yc i ha ve gotten below the ceiling, that if ycu can do 22 something that is in fact cost effective and allocates 23 resources wisely, you ought to do that.
That is why I would 24 like to see some q ua n tifica tion be given to the ALARA 25 principle.
Not everyone in the industry agrees with me on 1
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2 MR. PAGE4 So you look upon these quantitative 3 goals as a way of doing one of two things.
One is to 4 rationalize the process and the second is tha t it gives you 5 some sort of way of saying enough is enough.
6 HR. O'DONNELL4 If it is not a ra tional decision, 7 enough is enough.
8 MR. MacLEANs I have one further question on the 9 issue be tween you and Chick earlier.
I still do not see why 10 these quantitative goals or quantitative performance a
11 standards would f acilitate the implementation of further i
1 12 backup systems rather than hinder them.
That was the 4
13 question that you raised.
1-4 As it is now as I understa nd it, you look at 15 something and say here is a weakness in the system.
Maybe I
16 you say we don't want any more hydrogen bubbler so let's 17 replace the circonium cladding with standard steel 18 cladding.
It seems to me that a manufacturer can come back i
19 and say that even with the zirconium cladding, here is the 20 risk estima te ; it is not that high; we won't do it.
21 I do not know how the process actually works.
But 22 I can see no reason why you should not implement f urthe r 23 saf ety standards rather than hinder f urther saf ety standards 24 in the areas that have been targeted as problem areas.
25 MR. O'DONNELL:
I do not.tink we are prejudgine ALDERSoN REPCRTING COMPANY. INC, 400 VIRGINIA AVE., S.W.. WASHINGTON. D.C. 20024 (202) 554-2345
16 u 1 the issue.
We want rational decisionmaking.
If it leads to 2 more saf ety systems that are more ra tional, so be it.
3 MR. MacLEAN4 We do not know if it will lead to 4 further defense-in-depth or less.
5 MR. O 'DONNELL4 I suspect tha t it will lead to a 6 shif ting, a reallocation, looking at things that maybe in 7 the past ha ve not been considered th a t important, looking at l
8 the less catastrophic type events ar.d looking at things that 9 are more likely and that are determined through operating 10 experience and risk assessments such as putting position 11 cases on power relief valves which I think could be shown, 12 using PB A and saf ety goals, to be a very co st-ef f ective j
13 ch ange.
14 Let the cards f all where they may.
If ycu l
15 est ablish rational saf ety goals and have some means of 16 e valua ting things and making this part of your decision 17 process, it is a much better situation than we hav'e now.
i
~
18 MS. INGRAMs Just in terms of the purpose of the I
19 policy st1tement on page 3, we have talked about a number of I
20 t hings.
It says, "This may lead to more coherent and J.
21 con sis te.'.t regulation for nuclear power plans and a more 22 predictable licensing process."
l 23 It seems to me that this would be a more useful i
24 document if it reflects, Pa ul, some of the things you said 25 earlier about targets, ideals, constitutional kinds of i
i 1
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i 45 1 things and it related more closely to this business so the 2 industry knows when it has met the standards and can be sort 3 of secure.
If that is what the intent of this is, then it 4 would be much better if that were spelled out so we can i
5 decide ourselves.
6 MR. WHIPPLE:
I think a large part of the 4
7 incentive to develop quantitative goals is just what we have 8 been discussings to give industry a non-moving target and, 9 with a little luck, also have the effect of allecating the 10 analytical skills towa rds the high probability events and 4
11 away from the high concept events, towards the big problems 12 and away from the smaller problems.
13 MR. BERNERO:
I would like to ask for information 144 f ro m the panel.
The NBC through its various arms has done a 15 couple of things already.
It has notified through a 16 Commission rule-making action anyone who is designing a 17 plant now, a near-term construction permit and there are a 18 f ew still on the drawing board, that owner is required to do l
19 a probablistic risk analysis and show in some logical way 20 how the results of tha t analysis are reflected in his design 21 decision, clearly recognizing problems and dealing with 22 t he m.
There is no threshold given, just we know we are 23 going to want to do tha t; here, go do it and we will sort I
l 24 o u t later how we judge what you did.
l 25 In a similar vein the agency has told all of the l
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46 1 o pe ra ting plantsa by time certain every one of you is going 2 to have to do a probablistic risk analysis and show the 3 retrospective panel.
Once again we do not know how we are 4 going to judge the Crystal Rivers when they do show up.
5 MR. SLOVICa We have time for one last comment 6 aef ore we should adjourn.
7 MR. PERROWs Once again I do not know how you get 8 your 10 to the minus 4 versus 10 to the minus 5 with regard 9 to the Crystal River.
I have little confidence when looking 10 a t that stuff that anybody knows wha t they are doing, i
11 especially when Rasmussen comes out and says I predicted TMI A
12 by our probablistic risk assessment device.
That accident 13 and most of those accidents are full of incredible things.
14 I actually trust you -- it does not sound lik e it 15 -- but do you really believe that you can say a meaningful i
16 way is 10 to the minus 47 17 MR. BERNERO:
In the case of Crystal Biver I will 18 invoke what I said earlier this morning about se t-a side s.
19 In the case of Crystal River, when it was done I said I did I
20 n o t specifically include saf eguards so I ha ve that mental 21 reservation on the left side of my head, and we specifically 22 excluded seismic risk for analytical reasonc and that is on 23 the right side of my head, and on the top of my head I have 24 tha t great big completeness issue that I tried to spell out.
25 What it says is within tt.a limits of our ansiysis, ALDERSCN REPCRTING COMPANY. INC, 400 VIRGINIA AVE L N WASHINGTON. O C. 20024 (202) 554-2345
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a 47 i
1 the scope that ve did, the best available estimate that we 2 have for the probability of core melt from the causes 3 considered, and recognizing the myopia of the system, is 2 i
4 times 10 to the minus 4 probability of core melt due to the I
5 lack of decay heat removal.
6 I recall a few years back where one of our senior I
7 staff members, Victor Stello, challenged me.
I was doing a J
8 partial risk analysis on the fuel cycle f acility.
I was 1
i 9 only looking at a piece of the risk.
He said how can you 1
1 10 look at only a piece of the risk without looking at all of 11 it.
I said because I don't know how to look at all of it; I i
12 will at least look at the parts tha t I can look at and tha t 13 m a y moot the whole thing; I may shut the bugger down because l
14 of that; I will not se rve the public well or serve our 15 mission well if I sit and struggle and weit and try to j
16 analyze the whole thing before I analyze it at all.
17 So what the Crystal River result tells me is this 18 much I think I know with f air confidence, that the failure 19 to remove decay heat f rom those causes is that much.
I have 20 a separate issue which is an attendant problem just hcw j
j 21 m u ch does a malevolent person contribute to that.
I can 22 sho w you an incident in a plant where valves were l
l 23 misa11gned, associated with the same system in question.
24 You say well, de that what, 10 to the minus what?
I do not l
25 know how to q. '. cif y that.
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1 So that is really what you are doing.
It is that 2 partial scope.
3 MR. O 'DO NN EL L:
But then you deal with these 4 unquantifiables in a different way.
You use a conservative 5 approach to regulation.
4 6
MR. BERNERO:
Or at least I get the Crystal Fiver i
l 7 decay heat removal system taken care of rather than go down i
8 to Crystal River and do something else that is just vasting l
9 their time and the public's money in one way or ano ther.
10 Th a t is a non-problem.
There are many difficulties we have 1
11 pursued and still pursue that I think any fair analysis 12 would show border on the frivolous, that they are hobby 13 issues, that some guy has made a career in one safety issue 14 and he will chase it whether
- is a real issue or not.
15 If ye have a way to sort out part of the problem 16 and at least get a perspective on it, th a t is really what we 17 are saying.
I 18 MR. SLOVIC:
Thank you.
I 19 I think we shculd break for lunch.
We will be 20 back f airly soon.
Let's return at 1:00.
3 21 (Whereupon, at 12:10 p.m.,
the meeting recessed, 22 to reconvene at 1400 p.m.
this same day.)
23 24 25 t
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AFTERNOON SESSION i
2 (1415 p.n.)
3 MR. SLOVIC:
I received at least one comment to 4 the effect that the discussion this morning, although it may i
5 have been interesting, was not exactly a t the heart of l
4 6 socio political and ethical issues.
I do not agree.
1
}
7 It that seems to se that we were discussing 1
i 8 whether or not it is possible to put forth meaningful and i'
9 politically acceptable goal statements in an arena where the i
i 10 state of the art of probablistic assessment is still very J
l 11 undeveloped and there is a lot of uncertainty.
That is j
f 12 where I see that discussion as being relevant.
It seems 13 tha t what we were working around is the concept that one can 14 have goals that are still meaningful and yet do not depend 15 critically on the uncertainty level of PRA at this point.
1 16 However I do think that we should shift focus now j
17 a nd look a little more carefully at the kinds of value 18..ssues, e thical it. sues, political issues that one might more i
j 19 usually associate with the label that this panel has been 20 given.
21 I would like to make a comment to start things off 22 about this.
That is that I for example view myself in part i
23 a s a value analyst.
I think one can think of goal setting i
24 as having several components.
One is sort of the 25 probablistic side which we have discussed a lot and the i
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50 1 value side which I would like us to turn to now.
)
2 We can talk of VA as sort of on a parallel with 3 PB A.
And if we do that one would find tha t the state of the 4 art first of all is every bit as complex as PR A, if not more 5 so, and that the amount of effort and analysis that has gone 6 into V A just cannot even begin to compare with the decree of 7 effort and rtJources and analysis that have been put on the 8 PRA side.
But nevertheless with any a ttempt to state a goal 9 that is sort of a goal that is relevant to society and its to wishes, it is vital to look at the value side of things.
11 I think this is what we ought to turn to.
This in 12 my mind is a real serious problem with mutting forth any 13 specific goals at this time because it is so undeveloped.
14 We went around on this at the last workshop in terms of what 15 do you do about intertemporal equity, spatial equity 16 distribu tions, what kind of risk aversion models you should 17 u se.
I think that is a good example of risk aversion.
18 I think the end of the alpha model is a model of 19 the impact of an accident on society, the social costs of an 20 a cciden t.
I think one could work up value models, impact 21 models that rival in complexity the PRAs that are being done 22 a t great cost and effort.
Yet the state of the art that we 23 a re a t right now is that we simply put a little alpha factor 24 o n the number of lives lost in a single accident as our l
25 model.
I think we need to ge t a lot more sophisticated and ALDERSoN REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W.. WASHINGTCN. O C. 20024 (202) 554 2345
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1 that is going to take some time.
2 With tha t as an introduction I would like to open 3 discussion to any of the key value issues or others that we 4 have been discussing, risk aversion, equity and whatever 5 else you want to put into the discussion.
6 MR. PAGEs I do not think the yellow book, the i
j 7 ACRS proposal NUREG-0739, or the xerox copy reflect the 8 state of the art in terms of discussion, the language, 9 modEls and so un wi th respect to the equity issue.
i 10 MR. WHIPPLEs If I can carry on your comment, the 11 discussion haper seems to be almost a retreat from the ACES 12 proposals to treat the social 'ssues nonlinear, that is in i
13 early and latent f a talities, they backed away from risk l
14 aversion, they dropped out of genetic advances.
And by and 15 large they are going with almost expected values it seens, 16 expected values for catastrophic accidents and simple i
17 probability numbers for individual risk.
l 18 I guess the issue is the trade off between the l
19 values of the sophistication including those factors versus 20 the value of having a real simple, easy-to-understand set of i
21 cri te ria.
I have mixed emotions.
I would be interested to 22 hear other people's comments.
23 MR. PF3 ROW:
I have strong emotions on that.
I dc 24 not chink you can trade off at all.
A fairly simple thinc 25 i s a mystifica tion of the reality and a very serious one.
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52 1 So my option would be to inc1rde those other complicated 2 things and irascible and difficult and controversial things, 3 include them as fully as possible.
Otherwise we are 4 misleading that thing we call the public out there.
5 MB. SLOVICs I think one could argue that it is 6 fine to simplify it but you need to do some analysis that 7 would guide your simplification.
That is if you do an l
8 analysis and you understand the sensitivities of the outcome 9 of that analysis to the various aspects of the analysis, you j
10 might see that you can do away with some considerations 11 because they are like others.
You can me-e some things.
12 B ut in the absence of that analysis I think the 13 simplification is premature.
14 So it seems to me tha t we are doing a l
l l
15 simplification without analysis and maybe it is because we i
16 do not yet know quite how to do that analysis.
17 MR. WHIPPlE4 One of the premises of the way they 18 simplified it is essentially they use a rero discount rate.
19 Is that representa tive of prevailing social lives?
Toby 20 used the phrase state of the art and social science and 21 value assessment.
Is that state of the art?
22 MR. SLOVIC:
I do not know.
I am not sure I would 23 agree with IJby.
I would agree th a t the documents do not 24 reflect state of the art but I am not very impressed with 25 sta te of the art in some a reas, maybe certain aspects of l
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J 1 equity considera tions.
There have been some prorosals which j
2 a re useful.
3 Why don 't you elaborate on that, Toby?
4 MR. PAGE.
I think the comment that I made this 5 morning with respect to how do you go from here to there, in s
6 other words to the numerical goals, lies to such things as 7 treatment of risk aversion.
There are two paragraphs about 8 risk aversion with no transition, no a rgument.
I see this 9 same kind of gap in several other places.
10 I guess with respect to the discount ra te question 11 there is a long and complicated debate as to how you treat I
l 12 f uture generations.
It is fairly sophisticated to deal with
]
l 13 right now.
I do not think it is very productive for us to i
l 14 vet into it right here.
I am not sure ultimately 1.ow i
j 15 productive it would be for the NRC to go th ro ugh it at all.
i j
16 I have a feeling that they would be better off if they at
]
17 least acquain ted themselves with this debate.
I 18 The feeling I have from reading the document is 19 tha t the people who wrote the paragraphs are unaware cf the 20 literature, which is probably not a ve ry sa f e position to be 21 in.
The reservation I have is that I am not sure that the 22 proper manrJement of nuclear power safety issues really 23 turns on the kind of debate you get by reading through this 24 literature.
l I
25 MB. SLOVIC.
Why not?
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- 53. PAGE:
Because I think that where it really 2 turns is we are f aced with the problem of using, expanding 2
3 or contracting a technology that is complicated and has some 4 risk in it.
It seems to me the proximate problem we have to 5 deal with here now is a question of how you get the 1
6 institutions to work in the sense of the operators being 7 responsible, being skilled, the designers being skillful, 8 making good designs, the risk assessors doing a careful job, 9 discovering their mistakes and so on.
So the system 4
10 actually works.
i 11 MR. SLOVIC.
Wouldn't some argue that maybe those j
12 are the wrong questions?
that is sort of assuming that the 13 technology is safe enough and now let's get down tc the 14 management of it.
Maybe the questions of equity or risk 15 aversion could address the more fundamental issues.
I think 16 a lot of people when they think of the socio-political 17 problems are really quest.Aning whether the technology is 18 saf e enough given the public values.
19 MR. PAGE:
Let me say it this way.
It seems to me 20 the NRC's stra tegy in the discussion paper that we are 21 looking at is to argue that the problem of imposing an 22 unf air risk on the future by long-lived radioactive 23 contaminants will be solved as long as we get the 24 probabjlities down low enough and then we will not have to 25 Worry about it.
So then we try to do get it low enough.
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Given that strategy which may not be a good I
2 strategy, maybe we should debate it, but given that strategy 3 it seems to me there are two questions.
One is how do we 4 know that we are anywhere near this reassurance number.
5 think that is the less important of the two.
The second 6 question is how do we structure the consist of the j
7 establishment of institutions such that we actually upgrade 8 with low probabilities of accidents.
9 It is all very well and good to have a number that to is low, th a t is comfortingly low, but the problem is th a t we
]
11 may or may not have accidents that may not be very large but i
12 if they are very large, then we are in a whole lot of 13 trouble.
i
]
14 I am sorry to be rambling.
It is hard for me to i
15 put my finger on it.
An analogy of what I am talking about 16 is if you look at the way transistor chips are made in this 17 country versus Japan.
We have about a tenfold hicher 18 f ailure rate than the Japanese.
When you ask the Japanese 19 w h y that is true the say there are two philosophies.
One is 20 you worry a whole lot about quality assurance and physical 4
j 21 sampling and testing and projection rate and so on.
And the i
22 o th e r is yo u j ust make them well.
i 23 You can sort of choose which side is doing which.
24 So what I am saying is we need to worry about what the 25 structure of the incentives are so that we make them we ll.
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I 1 Then some of the those other questions will becone less 2 important.
3 MR. PERBOW:
It is beginning to sink in.
4 MR. PAGE4 That is wh y I am saying that whether we i
5 have a scphisicated arguement that leads to a 10 to the 6 minus 5 or 10 to the minus 6 is not nearly so important to 7 se as getting to how do you go from here to there.
4 8
!f I were really confident that it was 10 to the 9 minus 5, then that is better than waving at 10 to the minus I
^
10 6 a nd sa ying maybe you will get it.
I i
11 MR. WHIPPLE4 You are talking about the Pickover i
12 a pproach.
i 13 MS. INGRAM4 Without being at all sophisticated l
l 14 a bout this, Toby mentioned about things appearing too simple l
l 15 in this document, almost as if the dimensions of the problem i
j 16 were not understood, for example on pace 7:
We believe th a t i
i 17 the premises stated belo> a re generally self-evident.
18 Much stated below is not at all generally 19 self-eviden t, particularly thr question of distribotion of 20 risk, geographically as well as intertemporary in terms of 21 intergeneration.
That is taken care of in a footnote where f
22 i t says:
It is not possible to devise a system of 23 regulation whereby the distribution of risks and benefits is i
24 always equitable to each individual.
25 That is probably true.
Then the question ic how 1
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l 1 does one analyze the differences in risk and then if those 2 differences are great enough, what does one do about those 3 dif ferences politically?
Instead of asking those questions i
4 or even indicating that it is understood that those are real j
5 questions, the document then goes to sa y we d on ' t have to i
~
l 6 worry about this if the risk is small.
So if everybody 7 suf fers a little but, then the big difference is absent.
8 I do not know any basis on which to believe that i
9 is true.
Certainly it is not politically true.
If some to people politically feel at much greater risk than other I
11 people, they may not mind e ven if that is very small.
Our l
12 experience indicates that the people at TEI were not i
13 convinced tha t everyone said it was a very small ri s k.
They 14 had questions:
why us; why not somebody else; how did we I
15 get into this position ; what political process did we go 16 through th a t we got chosen.
17 MR. WHIPPlE:
I think the fact that the Nuclear j
18 Regulatory Commission is holding this meeting rather than 19 nuclear plants, like the EPA talking about coal plant 20 s a f e t y, suggests tha t there are enough q ua lita tive j
21 dif ferences.
22 MS. INGRAMs True, except I think that needs to be 23 relfected in the document.
i 24 MR. WHIPPLE:
They can say nuclear risks are 25 special.
l i
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1 RR. O'DONNELL It seems to me we spent a lot of 2 time in the last workshop discussing these subjects with 3 little or no consensus or agreement on how it should be 4 treated.
We recognize things like risk aversion, 5 intertemporal distributions.
There are two sides to those 6 coins, that if you try to account for protected future 7 generations by incorpo rating measures into the safety goals 1
8 that would do that, you may be putting a penalty on present 9 genera tions.
I 10 The same is true with risk aversion.
If you bias i
11 the results toward trying to take care of the biq 12 consequential probability accidents, you will be spending a
13 less resources on the more probable lower-consequences 14 acciden ts.
So we did not reach any conclusion.
j i
15 I think what the NRC has done in this paper is I
18 essentially to treat those things neutral.
That is use the j
17 risk aversion f actor of one essentially.
You could make l
18 arguments for 1.2 and you could make arguments for
.8.
It 19 is the same with the intertemporal phase.
They did not bias i
1
~
20it one way or another.
Given the state of the art I do not 21 know what else they could do.
i 22 MR. PERROW:
I would l',4 k e to see an argument on 23 tha t.
The point is not today.
24 MR. O'DONNELL:
I gave it last time.
25 MR. PERROW:
I did not understand it then either.
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1 I hope we do not get into one thing here.
If we j
2 do, then it is goina to tr.rn us aside.
I think it is not j
3 a ppropriate.
I think dams should be made safer and coal j
4 plants should be made safer and chewing gum should be made 5 saf er.
We are here to discuss n uclea r plan ts.
I think th e y 6 should be made saf er too.
7 As far as the limited resources that you say we f
8 are spending too much on ca tastrophic and tha t is going to l'
9 take away from spending more on the other, then get more J
10 money and put it in the rate base and charge more for 11 spending it on the smaller risk too.
Tha t is not at issue.
I 12 I do not think we should get into that type vi issue.
i 13 MR. O'DONNELL:
I disagree.
There is a limited 14 amount of resources available to protect the public from all 2
15 risks.
i j
16 MR. PERROWs I do not think so.
17 MR. O'DONNELL:
If we approach it that wa y, we are l
18 going to end up with somethig that is not servino the public 1
19 w ell.
20 MR. PERROW:
If you create resources, if the price i
1 j
21 of energy generated by coal needs to be doubled in order to j
)
22 p u t some f airly simple sarety devices in those mines and put
]
23 scrubbers on those plants so that coal is not as dangerous, 24 then we should recommend that it be doubled.
i 25 MR. O'DONNELL:
There should be a single criterion i
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1 for making those decisions an6 it should account for those 2 figures.
3 MR. PERROW You presume we have them.
4 MR. O'DONNELLs No, I do not.
We do not have 1
5 them.
That is what I am saying.
6 MR. PERROW:
I mean the pronuclear people have 7 them.
They tell us how many people are killed every year 8 f rom coal mine accidents and how many people are injured by 9 the smog and so forth.
That data is abundant.
It is 10 published in Science every year.
11 MR. SLOVIC:
There is no criteria though for where 1
12 you draw the line.
Do you double it?
13 MR. PERROWs Then we know the cost of putting up 14 scrubbers and you can go to the Bureau of Mines and the 15 Bureau of Mines will tell you rather closely how much it 16 would cost to make the mines safe so they do not kill 1,200 17 miners a year or something like th a t.
It is possible to do.
18 But that is not our issue I do not think.
19 MR. O'DONNELL:
We have simila r interests.
l 20 Doesn ' t that issue apply here as well?
21 MR. SLOVIC:
What is the issue?
22 MR. ? ERROW :
Our issue is not to control either 23 coal with nuclear or to compare catastrophic with 24 noncata.s trop hic risk.
I assume we want to eliminate both.
25 If we cannot eliminate both, then the power generated is 4
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61 1 going to be too expensive to even buy.
2 NR. O'DONNELL:
Let's stipulate we can eliminate 3 both.
4 MR. PERROWs We have ALABA.
5 3o then don't tgli me tha t we have a problem that 6 ve are emphasiring catastrophic risks and ignoring the less 7 serious accidents.
We should be looking at both.
8 MR. O'DONNELL:
I agree, but we should not bias 9 results to put an inordinate amodnt of resources on one at to the expense of the other.
They should be treated, in the 11 absence of overwhelming evidence to do otherwise, en an 12 equal basis.
13 MB. PEB50W They should both get all of the 14 resources they need.
If the consequences --
15 MR. O'DONNELL:
Or forget the alternative, 16 wha tever that is.
17 MR. MacLEAN It might be that a more 18 sophisticated analysis of the value issues we receive would 19 lead us tcward some determination of what the society 20 demands in terms of the saf ety requirement and that demana 21 might be such that it is stated independently of the costs.
22 Tha t might lead us to establish a minimum safety requirement.
23 I can see a virtue in stating tha t without looking 24 a t costs, at least on the part of the agency that is 25 supposed to regulate the safety of this.
Then if the costs ALDERSoN REPORTING COMPANY,INC, j
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d 1 are too great, you go back to the drawing board or you get 2 rid of the technology tha t is not essential.
Beyond tha t 3.evel of social acceptability, then the balance of trade-off 4 of costs come in.
5 But I am a little concerned in setting up a goal 6 for the NBC of balancing safety against costs from the very 7 beginning.
8 MR. O'DONNELL:
I did not mean to imply that.
The j
9 way I envision the goal structure is that there are these 10 limits below which one must get without considering costs.
i 11 If you cannot get below them without having a 12 cost-competitive system, then the system will not survive.
j 13 MR. SLOVICs How do you determine those limits?
1 j
14 Would that be the level of risk above which it is 1
4 15 intolerable to have the technology?
16 MR. O'DONNELL4 I think th e se would be the types 17 of individual and population goals we are looking at here.
l 18 MR. WHIPPLEs I do not think that is w.h t these 19 a re.
I think these are surrogates for what they think you j
{
20 wound up with af ter you go through an ALARA process.
4 21 MR. C'DONNELLs That is the problem I have with 1
22 t hi s.
I do not understand how these things relate to each 23 other and to the ALARA principle.
24 MR. PAGE:
I think it migh t be useful to have a 25 short discussion on how we think these numerical goals fit j
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i 1 in with
"'e ALARA principle.
Maybe the NRC could tell us.
{
2 Tell me if I am wrong.
My understanding of this i
3 is that the way they fit together is this.
We have a i
I 4 particular kind of risk structure with nuclar power that i
i 5 disturbs a lot of people because of the large accident
]
6 potential and because of t'e irreversability of the r
7 rad 3 ation.
So the equity problems are particularly 8 troublesome.
9 So the way of sort of finessing thi ; problem l
10 without getting to the nitty-gritty of the literature is to j
11 say let's make th e numbers small and when the numbers are j
1 l
12 small, then the equity problems fade evay.
That seems to be i
j 13 the strategy.
There is the operat il side which as you 1
]
14 mentioned says that if the.' u m b -
2 not small, then the 15 technology is not likely to sutvare.
You probably could 1
]
16 stand maybe one more Three Mile Island.
i i
17 MR. O'DONNELL:
I do not know about that.
18 MR. PAGE4 So that is the strategy with respect to
)
19 the goals.
But then the question is where does ALABA fit
]
l 20 in.
My impression is that ALARA is just the opposite of a l
21 cost-ef f ective approach.
A cost-effective approach is you 4
}
j 22 set a goal and then ysq
.f to meet it with a minimum of I
23 cos t.
With ALARA you have a certain sort of reasonable cost l
24 tha t you are willing to add on safety and then you try to l
25 buy as much safety as you can wi th that of course to equal A
h ALDERSoN REPORT;NG COMPANY. INC, 400 VIRGINIA AVE, S.W WASHINGTON. D.C. 20024 (202) 554 2345 1
64 1 the cost.
It is the flip side of the coin.
2 The thing that puzzles me and I would like to get 3 some feed.back is how NRC and industry think these two 4 concepts fit together or should fit together or if they are 5 different f rom wha t I suggested.
8 MR. O'DONNELL I can give you the industry's 4
7 view.
The goal structure tha t we proposed on the Industrial 8 Forum basically consists of two primary elements.
That is a 9 limit on individual risk to the maximum per individual and 4
10 also a limit on the population risk per 1,000 megawatts of I
l 11 power.
Those have to be met.
That is before one gets into 12 cost-benefit balance rate.
You have to demonstra te tha t you 13 have met those goals.
)
14 MR. PAGE:
For basically the reasons that I 15 outlined ?
They are a way of satisfying the equity issue?
l 16 MR. O'DONNELLs Yes.
I think the argument that a
17 you can deal with the equity issue by limiting the maximum 1
18 risk going to the individual to a small number I think is a t
)
19 valid approach.
It may not be as sophisticated as one would i
20 lik e.
21 MR. PAGE:
-- and other motivations for it l
22 MR. O ' DO N N EL L :
No.
For any technology there 23 should be a number that on an individual basis ensures that 24 this technology which is really there fo r the benefit of 25 society as a whole is not imposing an undue risk on any one J
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65 1 member of the public out there.
2 MR. PAGE:
We do not have it like autcmobile 3 saf ety.
4 MB. O'DONNELL4 We should.
There is no reason we 5 should not.
6 MR. PAGE4 Se you think there should be minim um 7 levels of risk for various technologies?
i i
8 MR. O 'DONNELL4 Yes, sure, ideally.
i 9
MR. PAGEs But on what grounds?
i 10 MR. WHIPPLEs The FDA is using 10 to the minus 6 J
11 as a background level.
i 12 MR. O'DONNELL:
It is an individual risk.
Let's a
j 13 limit it to industries that voluntarily impose risk to the i
14 public.
I think there should be a limit for all l
15 technologies on how much society imposes on any individual i
16 involuntarily, beca use society has the tech nolo gy that is i
17 benefiting society as a whole.
I thin k equity demands that.
I 18 MR. PAGE:
So you basically think it is an equity 19 argument.
I 20 MR. O'DONNELL4 Yes, I think that is an equity 21 argument.
j j
22 MR. PAGE:
How does it fit together with the ALAPA 23 principle?
24 MR. O'DONNELL4 The ALARA is something that one, 25 having met the individual and the population number, has 4
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1 therefore sa tisfied the equity a rgumen t.
We are looking at 2 investing the public's money in protecting the public.
We 3 shold then try to allocate those resources in the most 4 cost-effective manner to get down any further below that 5 limit.
And that is essentially a matter of balancing the 6 benefits in terms of risk reduction against the costs.
It i
7 is the public's money being spent for public benefits.
That l
8 is a resource allocation out there.
9 MR. MacLEAN:
Can you give me one further bit of to information?
How do you determine that first number?
11 MR. O'DONNELL:
The way we have approached it is l
12 tha t you look at existing levels of risk and you make it a 13 small fraction of that.
You look at competing technologies, 14 for nuclear if coal is going to be the alte rna tive.
15 MR. MacLEAN:
So you balance it against com pe ting 16 technologies and existing levels of risk.
17 MR. O'DONNELL:
That is right.
18 MR. MacLEAN:
This is righ t where I want to raise 19 the question Is that socially acceptable?
If we are 20 ask ing where the value comes in, I think it comes in right 21 h er e.
22 MR. WHIPPLE:
I think the question is4 Is the 23 logic sound?
24 MR. MacLEAN4 I understand the me thod.
I 25 understand the principles that work here.
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1 MR. O'DONNELL We fee.1 it is a rational approach.
2 MR. MacLEANs It is rational in what sense?
So 3 tha t if large numbers of the public object to the standards j
4 for nuclear power being set in this way, even after you have I
t 5 convinced them tha t this is consisten t with other background i
6 risks and risks of other technology, then would you say that 7 these are rational?
I 8
NR. O 'DONNELL:
In the political arena ve 1
9 recognize that this is a tuo phased process.
The industry 10 or NRC or any group could come up with a proposal.
Now that 11 has to be presented to the public and has to stand or fall I
12 in the public arena, in particula r Congress.
I think 13 ideally it should be the Congress that should decides
- yes, 14 N BC, these are good numbers or not.
Congress is in effect 15 the representative of the public.
16 MR. MacLEAN4 Ideally that migh t be right.
17 Congress does not always choose wisely in these situations.
18 They pass Delaney Amendments and the OSHA Act and other l
19 things like that.
They do not always act wisely.
But also 20 they f all short of f ulfilling their goal.
They establish an 21 agency and say you go ahead and do it.
That is basically 22 what we have here.
So we cannot just say that Congress 23 oucht to do it.
Congress did not do it.
24 MR. SLOVIC:
Any method has in it a lot of 25 underlying assumptions.
I think here this comparison of ALDERSON REPORTING COMPANY. INC.
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1 other technologies does have the assumption that there is 2 something optimal or reasonable about these technologies, 3 that over time they have evolved into some acceptable level 4 of risk so tha t we can make these comparisons in a 5 meaningf ul way.
6 Yet we have to recognize that these different 7 technologies have different distributions or risk, both in 8 terms of catastrophic potential and equity and other 9 characteristics Second, one could turn this argument 10 around and say if we could look around us to determine what 11 is acceptable, why do we even have to bother doing anything 12 about nuclear power; why don't we just say it is acceptable 13 because it is; the procedures have evolved over time and we l
14 have them and why even go through this exercise.
There is I
]
15 sort of a circularity there.
16 MR. O'DONNELL:
If it is acceptable, then why is 17 there a need to change any of the regulations we have?
18 MR. PAGE:
The point is if you are going to use 19 benchmarks in order to define acceptability, why not use 20 nuclear power as a benchmark?
That is a very short 21 circularity.
It makes you wonder why you want to do a 22 search f or benchmarks in the first place.
23 MR. O'DONNELL:
I am not propo sin g tha t nuclear 24 power be used as a sort of benchma rk.
25 MR. PAGE:
That is one of the three pregesed ALCERSON REPORTING COMPANY. lNC.
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1 sources for a technical risk concept.
It is called 2 bootstrapping in here.
But it is essentially you look for 3 comparisons as to what other technologies were accepted at 4 the time.
1 5
MR. SLOVIC:
You are comparing with coal or 6 whatever.
7 MR. PERROW:
I think that brings up another 8 argument that Todd LaPorte, if he were here, would want i
9 brought up.
It has not been brought up but I think it ties 10 in very nicely.
In one sense the industry is saying look, l
11 nobody has dropped dead directly f rom a radiological 12 accident and coal is worse and present levels of risk j
13 indicate that people will take a much higher risk with 14 smoking and so forth, therefore it is not a very serious 1
15 case.
}
16 Todd I think wo uld sa y or a t least I would say 17 that we have not tested it yet.
What worries some of us is 18 n o t the reco rd to da te but the record that is likely to 19 occur even by some of industry's estimates if we have 200 1
20 reacters operating at 30 years each.
Then our estimates i
21 really have erratically changed, especially where the public 4
l 22 is involved.
Somebody said one more Three Mile Island will 23 do you in and Ed said no, I do not think so.
i i
24 MR. O'DONNELL:
I said it pr:obably would, 4
25 politically.
i l
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MR. PEBROW:
In that case if you get 200 reactors 2 operating 30 years each, you are goine to have a Three Mile 3 Island what, every four years, every five years ?
And one of 4 those is not going to come just within a half hcur of a 5 complete core melt like Three Mile Island was supposed to 6 have, according to some experts, but it is coing to happen, 7 maybe the second one or the third one.
8 What I am trying to point out about the factors of 9 scale is there is a difference between having a highly risky to technology or industry out there tha t is small and having 11 one that is large, because when they get the headlines 12 coming much more frequently, then the perception of risk 13 rightly or wrongly -- and I think it is probably wrongly I
14 according to Paul's work and others' work -- but rightly or 15 wrongly the perception of risk is going to change ma rkedly 16 a nd we are going to see this as much more risky, even though l
17 the level of safety may have increased because you have more 18 events out there.
j l
i 19 It is a base rate phenomenon.
You have more l
20 things to go wrong.
Then you are going to have a serious 21 political problem on your hands and a serious emetional 22 problem f or pe ople who do not do good risk analysis in their 23 heads and in technical terms do not do Bayesian analysis 24 instead of correlation analysis.
25 So you are going to have people out there who will ALDERSON RE?oRTING COMPANY,INC, 400 VIRGINIA AVE S?N, WASHINGTCN. D.C. 20024 (202) 554-2345
7 '1 1 be f righ tened by this kind of event.
Furthermore you are 2 going to have the nuclear waste problem going on.
I don
1 j
3 remember Todd 's figures new but it runs something like 4 this.
With that man y plants you are going to have 30 trucks j
5 on the highway every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the day hauling nuclear 4
6 waste.
You are going to have a truckful of nuclear vaste in 7 the Eisenhower Tunnel every four hours, which is a very 8 risky tunnel.
You are going to get these kinds of 9 associated risks going on with the increase in scale.
10 So there is a point at which a safe industry nay 11 be safe if it is small but may paradoxically become unsafe 12 if it gets larger, because when we start trucking that stuff 13 around we ha ve more chance of their getting inte accidents.
14 With 500 plants on any day there will be 200 trucks i
15 unloading if there is one waste site in Nevada er something i
16 lik e that.
j 17 That is going to change society's whole perception l
18of nuclear power.
I do not think it is going to change for 19 the better.
It is going to have a scale effect that this 20 study of saf ety goals is not taking into account.
And if we 21 are talking about value, ethical and political issues, then 22 I think we should.
1 23 MR. S10VICs Let me just react to that.
I think 24 it is an extremely interesting point.
I can see things t
j 25 going both ways.
First of all the scale will not change i
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1 o vernigh t.
We are talking about a system of guiding goals 2 which are flexible and can react to change.
However it 3 probably is the case that as we increase the scale the 4 technology will become more dependent on it and in that 5 sense we probably will be forced to tolerate a greater level 6 o f risk.
7 I can see that there could be adaptations.
8 Society will adapt.
So it may not be necessa rily the case 9 that Three Mile Island will have the same impact down the 10 road that it has today.
Again there is a lot of uncertainty 11 about what will ha ppen.
12 But the scenario that you are putting forth is 13 also a scenario in which society is deriving a much higher 14 level of benefit from the technology and may be willing 4
15 this is the value issue again -- to tolerate that increased i
16 ris k.
So I do not think we can prej udge wi thou t a lot of 17 analysis just what the effects of scale are going to be.
18 MR. PERROWs We are getting the benefit from this 19 technology rather than another one.
We are not getting the 20 higher level of benefit.
21 MR. O'DONNELL:
They are becoming more familiar 22 with the technology.
23 MR. PERROW:
That may be the case.
And that may i
24 be the worst case too.
People started out pronuclear power.
I 25 You guys blev it, to put it bluntly.
You started j
1 1
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1 out with 71, 75 percent people f or nuclea r power when the 2 first polls came in in the ea rly '70s.
Tha t stayed very 2
3 high.
Then it took a big dip around the first t+rious i
4 accident at Browns Ferry and at Fermi.
Then it kind of went 1
5 back up, not all the way.
}
6 The public's acceptability of nuclear risk has i
7 gone down directly with the publicized accidents, and Browns i
8 Ferry was not even very publicized when it went down.
It is 9 the accidents that are doing this, not the intervenors I 10 think or the secondary effects of the various protesting 1
)
11 groups from the '70s.
Now the confidence in nuclear power i
12 is being eroded by this.
]
13 You may say as we get more dependent on it that 14 the confidence is going to go up, but I doubt it.
I think 15 as we become more dependent on it, we get more accidents and 16 then confidence is going to go down.
By then we are going 17 to have solar sheets on mylar that can do it.
18 MR. SLOVIC:
What you are talking about is an 19 issue on the modeling of the consequences of scale.
I think 20 i t is a legitimate issue which deserves analysis in its own i
21 right and apparently that analysis has not been done to my 1
22 knowledge.
i 23 l' R WHIPPLE:
You are suggesting also though that 24 the industry cannot tolerate another accident.
The industry 25 cannot promise tha t of course.
It absolutely cannot.
But !
i l
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l 74 I think my analogy say of commercial aviation which has had a 2 lot of catastrophic accidents in history but survives, g
3 thrives, that what will happen with nuclear power dependu on 4
4 the perception of the alternatives at the time.
5 We cite Browns Ferry and TMI as cases for public 1
j 6 disillusionment where really the public consequences were a
i 7 pretty minimal from those accidents.
I can suggest an 8 alterna tive hypothesis where the public say well, it looks 1
9 like those big containment buildings they put on reactors 10 really do work and those things ha ve accidents all the time J
j 11 but fortunately we are pretty well protected.
That is an j
12 alternative.
j 13 The public may well become sa tu ra ted with stories l
.l 14 every time a reactor has a turbine trip that it makes the i
j-15 f ront page of half a dozen newspapers.
There may be a i
i 16 boredom setting in just like the announcement of a new i
j 17 carcinogen is tre.ated with boredom by and large by the i
18 public today.
So to predict public response is pretty i
19 trick y.
l 20 MR. PERROWs Ye s, but the evidence so far is my 1
j 21 scena rio, not yours.
It may occur.
People got bored with i
j 22 campus riots in the '70s and they dropped out of th e I
23 newspapers.
But I do think that nuclear powec is different 24 and it is diff erent from airline accidents and it is i
.i 25 dif ferent from saccharin controversies.
But we do not l
4 l
l 4
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We will see.
l 2
MB. PAGE It seems to me tha t there are two sides i
3 to this.
One is the empirical side, how the public is going 4 to react, which has a lot to sa y a bo ut how much it is worth 5 to the extent tha t the nuclear industry is hurt by i
j 6 accidents.
In some sense this self-interest of the industry
(
l 7 should be used to f urther safety goals by setting up l
8 liability rules like this insurance pool that is being set i
9 up in the af termath of Three Mile Island and all th a t sort 10 o f stuff.
11 I would like to see more a ttention on these kinds 12 of empirical issues which are not in this draft document.
I l
13 think it would be strengthened if we were concerned more 14 with it.
j 15 But the other side of the coin is how much should i
l 16 in-principle safety goals change or not change when we look j
j 17 a t the difference between one small plant and a whole 18 ongoing system of many plants.
I think tha t is the point 1
19 that Todd was really worried about last time.
This issue a
j 20 also has not been addressed.
I think it would be 21 strengthened if we would, i
22 MR. SLOVIC:
I think it has not been addressed j
23 directly becasue the analysis has not been done.
Put I
]
24 thio it has been treated implicitly in the notion that 25 scale changes will evolve over time and so will these i
1 i
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1 goals.
I thx.1k tha t is where I see it as having been 2 addressed.
You may say that is not adeq' tate or should be 3 resta ted.
4 MR. O'DONNELL:
It seems to me that last time the 5 real impact with any of these numbers is not very great 4
4 6 unless we are talking about scale changes on a factor of 10 l
7 or 100, that is 100 times more reactors than we have now.
I 8 do not think it is really significant because I do not think 9 we are going to see scale changes like that.
10 It has been something tha t is going to happen over 11 a long period of time.
These things as I said earlier are 12 not going to be chisaled into concrete.
I view them as i
13 something laterim that de ought to try to use and if they i
i 14 need changing, then change them.
I 15 MR. PERROW:
If the plants onstream come onstream, i
j 18 ve will have an enormous scale change in terms of the n'2mber 1
17 o f 1,000-megawatt plants compared to what we have had l
18 before.
When Three Mile Island went up we only had about j
19 170 or 160 years of experisnce, operating reacter years of l
20 experience with that kind of plant, very little.
)
21 Now we are going to get more and larger.
That is 22 going to be a scale change.
The number of plants may not be 23 m uch greater but the type and size of plant probably will be 24 s uch greater.
We do have historical evidence that the 25 larger plants are down more of the time and have more ALCERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W, WASHINGTON, D.C. 20024 (202) 554-2345
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1 preblems.
l l
2 MR. WHIPPLE4 In the first few years that occurs l
3 with any plant 4
MR. PERROWs All plan ts, yes, but them more than 5 the smaller ones.
A recent Science article on that shows 6 that.
I do not know how good it was.
7 MR. SLOVIC:
There was the feeling I believe 8 expressed this morning that the present document does not.
9 adequately incorpo ra te these various socio-political 10 concerns.
Are there any specific suggestions as to, given 11 the state of the art of value analysis, what could be said 12 a t this time in a goal statement ?
13 MS. INGRAMs Without specific language I would 14 prefer that this document reflected more of the recognition 15 that it is an interim document aimed at evolution as we 18 learn more f rom experience and as systems grow.
I am 17 especially bothered by this sort of dismissal cf a number of 18 questions because of:
the risk is so low we need not worry 19 about it.
20 It would seem to me that it could be said that we 21 cannot set a standard or we cannot set a goal perhaps.
That 22 is all righ t because not enough is known or it is no t clear 23 eno ugh, there is not consensus, but some notion that as l
l 24 time goes on or should there be an absolute shif t of scale, i
25 these questions again become relevant and they must be kept AwDERSON REPORTING COMPANY. INC.
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78 1 in mind.
2 As it is now the document almost reads es if 3 because we have this number we need not worry about all of 4 these quetions.
It would be a lot better I think if there 5 were more of a sense of a these are things that we need to I
6 continue to worry about and gather inf ormation about and 1
1
)
7 keep dis cussing and that this goal-setting should not be a l
l 8 number but instead a process and tha t this is a kind of i
9 interim number, the best we can do right now.
10 Ha. iiHIPP LE:
It talks about catastrophical risk 4
11 events but nothing else.
12 MB. O'DONNELL:
I would agree with that.
This is 4
13 in f act the first attempt that anyone has made to do 14 anything like this tha t I am aware of.
It certainly cannot 15 be viewed as a final product.
i 16
- 33. WHIPPLE:
to that extent I think the emphasis 17 is a goal over a standard.
This read to me like they were 18 talking about a standard.
They need to be emphasized.
1 19 MB. SLOVICs So if I understand this, we are 20 suggesting that the statement is put on the agenda as valid 1
i 1
21 relevant csacerns tha t need to be worked on further towards 2 incorporation, things such as these equity considerations of 23 genetic defects or transgenerational effects or a whole list 24 of some of these really hard-to-deal-with social value 25 issues.
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MS. INGRAMs In the back it talks about how are we 2 going to evolve a methodology for assessing risk, risk 3 assessment.
You have talked about a value assessment, how 4 ve understand values and how that too might evolve.
Could 5 we use more of a similar kind of language in relation to 6 these hard social issues?
7 HR. BERNERO:
I wanted to ask a question because i
8 there is a thread that comes through a i t of the comments.
9 This document purports to be an address of only 10 one aspect of nuclear risk.
That is accident risk.
It 11 moots the question of intertemporal, the long-lived waste 12 disposal, the other parts of the transportation risk that 13 you alluded to, Chick.
Is it being said that that is not a 14 f easible approach, that one can not parse the problem and 15 attack accident risk alone in a narrow perspective?
That is i
16 one question.
17 The other is a question that I think may be 18 related to that.
Although I agree that the document does
]
19 n o t make a clear tie to a n acceptable probability of death 20 given the statement that the probability of nuclear-21 accident-caused death should not be all that high compared 22to che background risk, is it legitimate to have a so cial 23 standard which asserts that today's scale of accidental 24 dea th is on the whole acceptable?
25 Or to put it another way, given the general scale ALDERSON REPORTING COMPANY. !NC, 400 VIRGIN!A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 l
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l 1 of accidental death, can you assert that an individual 1
2 contributor to accidental death is on the whole acceptable i
j 3 if it is at some fractional percent in that, 1 percent or 4 something like that?
Is that not a socially acce ptable 5 ba:-is ?
6 MS. INGRAM:
But the notion of social 7 acceptability comes in the context of whe ther or not that 8 risk. is understood, the extent to which the individuals feel l
9 they can impose it on themselves, the extent to which they 10 f ee! they are in control.
None of that theory is really 11 reflected in sort of a general statement about well, you 12 might die in an automobile accident or coal also has a risk 13 f actor.
14 MR. BERNER0s I agree with you and with what Chick 15 sa ys in the cosmetic sense.
It could be explained more.
16 B u t I am concerned about the substance of it.
I am thinking 17 in terms of if the probability of death to an individual 18 anywhere in the United States is on the order of 10 to the 19 minus 5 for, what is it, the white hea]:hy 12-year-old girl, 20 the heal thiest people and safest people in the country.
21 If one seeks just this background risk perspective 22 and says an individual risk that is down at some level, at 23 o r below that is self-evidently acce ptable because it is 24 just a lora on the --
25 MR. SLOVIC:
Bob, let me respond.
You..sked twc ALCERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. 0.C. 20024 (202) 554 2345
81 1 questions.
On the second one I think there is a sense in 2 which we would have to say that we really do not know i
3 whether it is acceptable.
On the surface it sounds good.
4 It is only 1 percent of the accident risk that we tolerate 5 altogether.
6 But that presumes that this other risk is somehow 7 acceptable.
It alsc presumes that there is someone who is 8 kind of minding the overall risk to society.
You could sa y 9 this about this technology.
Then you have another 10 technology.
That group is setting goals and they want to 11 have a 1 percent.
There are all kinds of questions about 12 how you divide it.
13 You could say the same thing about the waste 14 disposal aspect, the percent.
Pretty soon you have 1,000 15 dif f e ren t technologies, each contributing 1 percent, and 16 your overall level of risk to society has ballooned.
17 I think it a start but it is just a start.
It 3
i 18 needs more analysis.
19
!! R. iiHIPPLEs Let me take a shot at something 20 h er e.
It seems to me tha t there are two separate levels of 21 risk that are at issue.
One is what Cyril Comer called a 22 de minimus level, a true noise level of risk, one that if 23 risks are below that you can ignore them.
It is like the 24 airplane flying over your house.
It could certainly crash 25 into your roof and ideally you might deserve some ALDEASCN REPORTING COMPANY,INC.
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i 1 compensation for that but in practice you saf foroet it, the 3
2 risk is really small.
3 The second is the risk above which it is j
4 inequitable to expose something.
On an individual basis it 5 is the I-won 't -pla y-Russia n -ro ule tte -f o r-a n y-a moun t-o f-mone y 6 theory.
It is just too high.
I think that we are assuming I
7 tha t this one target r*sk level will serve both of those 8 f unctions.
If it is one number it is too high to be above, 9 and it it is below it we can ignore all of the equity 10 issues.
I 11 In fact what we are really talking about is an 1
12 upper bound on risk, probably quite a bit higher than are in 4
13 these reports, which says it is an absolute, tha t you cannot 14 go abc'e it, and then a range from which you are going to 15 make your cost trade-offs and then a noise le vel tha t you i
16 need for management purposes that says yes, it is a risk but 17 i t is not worth putting resources into.
i i
18 Do you think that is part of the confusion?
19 MR. MacLEAN:
I think ve should not be assuming 20 t h a t.
We can talk about risk across the bo ard here.
We a re 21 talking about safety requirements f or opera ting nuclear I
i 22 power plants.
It may be that the risks that society is or 23 o ug h t to be willino to tolerate from nuclear power plants is l
25 the same as the risk across the board.
It may be that this 25 is a very special technology.
We cannot prejudge that issue.
9 i
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1 It is the issue of social acceptability that led j
2 me to my initial comments this morning that you have to have 3 better stated qualitative goals and a much better 4 explanation of how the quantitative goals are based on the 5 qualitative goals.
The reason is because I think that our l
6 values, social values, the notion of accpetability, these 7 are basically qualitative notions.
This is the way I think 8 most people think and this is what the public understands.
9 And to show that these quantita tive goals are satisfying th e 1
10 public, you have to do all of the steps backwards.
11 Otherwise you do not have the justification here.
1 12 The other thing is that, thinking on Ed 's comments 1
13 and comparing, this is sort of Richard Wilson's approach to i
14 it, that you get to a certain level of natural risk and it 15 is acceptable.
I have always questioned that.
'4 h a t is at 18 issue here is that the concept of social acceptability can 17 itself be thought of as an empirical notion or a normative 18 notion.
As an empirical notion, you go out and ask society 19 w ha t it will accept in terms of safety requiremen ts f or 20 nuclear power.
It may be the same as other things; it may 21 be higher; it may be lover.
i 22 If you start out saying if we control it down to 23 all of the other natural background risks and everythno 24 else, that is good enough, that is to take a sort of a 25 normative approach to social acceptability.
That is saying i
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l e4 1 that is the way a rational person should approach nuc 9ar 1
2 risks the same as any other technology.
3 Where we want to interpret cocial acceptability in 4a basically empirical way or basically normative way, that 5 raises a whole separate set of issues.
But it should be j
6 made clear when we are stating these goals what we are 7 operating from.
Are we going to do surveys, very f
j 8 complicated Slovic-type surveys to give us very refined 9 measures of what general public attitudes a re and wha t sort 10 of scales they go along and wha t sort of dimensions they are 11 concerned about and go with tha t empirical data?
Or are we 12 going to have a basically normative approach to this?
13 MR. O'DONNELL:
I think we should sta te very i
14 clearly tha t if this is a normative approach, this is a 15 normative approach.
Again I view the thing as two-phased.
i 18 You set down what you think is a rational set of criteria, 17 which means normative, and then you go out and you present i
18 tha t to the public, to the Congress, and if they say no, we l
19 d o no t want the risk of nuclear, we want something ten tines 4
20 s a f er, that is a political question.
21 MR. MacLEAN We could also debate whether setting 22 the risks of nuclear is the same as other risks.
23 MR. O'DONNELL:
That is what I mean, whether that 24 is a valid approach.
25 MR. PERROW Rationally we can set it different.
i 1
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85 1 I can make a rational argument but they are not the same.
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2 MR. O'DONNELL:
We can disagree on that, you see.
3 MR. PERROW:
We would still be within the 4 normative, the way you are using it.
5 MR. O'DONNELL:
If there is a rational basis for 6 tha t, sure.
l 7
MR. WHIPPLE:
To that extent that is why risk 8 aversion has come up.
It is an attempt to put that in a 9 normative approach.
10 MR. PAGE:
The point is that most of what we have i
11 been discussing has both a normative side and an empirical
)
12 side and how we would cla rify the argument in this paper if 13 they we re b o th treated explicitly.
What we are sayinq 14 really is that both sides are weak and what.maybe is the 15 first order of business is to straighten out the normative 16 a rg ument.
17 ^
MR. MacLEAN:
I am saying -- I do not know who l
18 else agrees with me -- that all that sort of discussion 19 should center around the qualitative goals.
20 MR. PAGE:
So Doug is saying one thing a little 21 more strictly than what I said.
Not only should you 22 separa te the norma tive issues f rom the empirical issues a 23 bit and do something about the issues instead of waving your i
24 hand a t it, but also Doug is saying th a t the proper l
25 structuring of the argument is to start with qualitative i
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86 1 principles to go beyond the bland principles that we have to 2 make them sharp enough so we can get some thing out of them 3 and then to try to get something out of them, to try to make 4 an argument with the issues, discuss some operational 5 content which would be quantitative.
6 MS. INGRA5:
It is clear that the normative theory 7 is there.
It is just not explicit.
For example this extra 8 margin in safety for unforeseen events sort of says tha t 9 nuclear power is dif ferent; you have to meet this extra 10 margin of safety and that may have something to do with the 11 theory of it being one unknown technology or something that 12 is hard to back up on, those kinds of things.
And as long 13 as it is there, it just is not more powerful but tha t is 14 explained.
15 I have a feeling, at least my own theoretical set 16 about all of this is that if we were to collect a lot of i
17 empirical da ta about how people feel about nuclear energy, 1
18 t h a t is changing over time as they have more experience, as 19 they are able to compare it with a lot of o ther things.
T 20 see this as a very transien t ma tter.
And even if one had a 21 lot of data about the levels on which people pref erred 22 things, I do not know that that data would be very good very 23 long because it is profoundly changed by events.
24 MR. MacLEAN:
Is that right?
Cces anybcdy knov 25 that?
Has anybody followed that?
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MR. PERROWs Yes.
i 2
MR. SLOVIC:
I do not think so.
3 MR. WHIPPLE:
I did not accept Chick's i
4 interpretation though tha t the public acceptance has been in 5 direct response to reported accidents.
j 6
MR. O'DONNELL:
But it no doubt has been changing.
)
7 MR. WHIPPLE:
Oh, yes.
j 8
MR. SLOVIC:
At a superficial level the public 9 attitudes toward the techn olog y bounce around somewhat, 1
1 l
10 although if you look at polls they are surprisingly stable, 1
11 more stable than you think.
But I think that tha t is likely l
12 to change over tine.
But questions about the public view 13 towards risk aversion or equity, do those concepts really 14 change over longer periods of time?
I do not know that that 15 has really been studied.
16 MR. PERROWs I do not know about that.
But I I
17 disagree on the nuclear.
It stared out with about 18 75 percent approval and is now down to just a little over
]
19 51 percent.
It went way down with TMI; it came back some 20 but lost a lot of it.
If you just smooth out that trend, it j
21 has been pretty steady and the dips are with the accidents j
22 tha t bring it down.
i 23 MR. SLOVIC:
I want to touch on sonething else l
24 before we leave the no rma tive descriptive, because I think 25 this is an important issue.
What I hear being put forth is 3
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88 1 the notion that we should really start with the normative 2 f ocus and try to work through the se things logically, then 3 put it forth and test it politically.
What happens if the 4 best normative approach to goal setting does not #avor well 5 politically ?
What do you do then, compromise?
8 MR. O'DONNELL:
You try to educate, explain.
7 Ultimately it is a political decision.
8 MR. SLOVIC4 Maybe this should be viewed a little 9 more interactively.
That is what was said.
Maybe starting 10 descriptively can at least help you identify a set of 11 concerns that people have that then could be subjected to 12 normative analysis.
So it does not have to be that you 13 purely have a group of logicians or philosophers starting 14 off but you kind of go to the public for their concerns and 15 then work with them in a normative setting, go back again.
16 MR. MacLEAN:
These two need not be incompatible.
17 There are some philosophers -- I number myself among them --
18 w ho think that our normative standards logically have to be 19 very close to people 's beliefs.
20 MR. WHIPPLE4 Also the empirical side sort of 21 takes care of itself; that is, the nuclear is enough of an 22 i ss ue.
I think that the choice of a safety goal made b y NEC 23 will only be tolerable based on feedback from the public 24 a ttitude.
25 MR. PAGE:
I think you can say it strongly that ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE.. S.W., WASH!NGTON, D.C. 20024 (202) 554 2345
4 89 1 the reason why we are here toda y is beca use of the current 2 situation which has forced the issue.
An undercurrent of 3 wha t is going on to me is that given the political f act tha t 4 there is political pressure on NBC to rationalire the 5 standard-setting process and have some sort of justifica tion 6 for goals or talk about goals or whatever, this is an 7 opportunity so that we might improve the processes as j
8 opposed to having windowCressing.
It could go either way.
9 It could become a charade.
You could say a few words and 10 you could forget about it.
Or it could become a part of the 11 process and you would get a better system.
12 An example of the non-normative analysis which 4
13 could be strengthened here is I think tha t when fou sort of 14 read between the lines, what is going on is the basic j
15 principle upon which these numerical goals are set up to 16 look at what can be done at "a reasonable cost," sort of 17 ra t1onalizing the ALARA principle.
You want to get a number I
18 tha t is low enough so tha t you can forget about the equity 19 issues and yet is high enough so it is achievable without 20 enormous cost.
If you can find the number, if there is a 21 number that can pass both of those tests, then you breathe a 22 big sigh of relief and tha t becomes your sa fety goal.
Then 4
23 if you can do better, that becomes the ALARA principle.
l 24 One thing that really surprises me when I read the
(
25 document is that -- I should not say this because I betray
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90 1 my origins here -- in the back of the document there are q
2 seven f rameworks f or approaching risk.
Three are i
3 essentially cost-beneilt analyses:
- 1) cost effectiveness,
- 42) risk benefit and 3) cost benefit.
Pasically all three 5 are the same.
6 Now the interesting thing is that the approach j
7 that I just men tio ned is diametrically o p po sed to those 8 three approaches in the following sense, that if you are 9 going to take a cost-benefit approach what you do is you 10 separate all of the normative issues except one on one side 11 of the ledger and you look at one no rma tive issue that is 12 going to drive your cost-benefit analysis which is a 13 doctrine of potential rate of improvement, which basically 14 means something to economists but maybe not too much to 15 other people.
16 It is a very well formulated kind of approach.
If 17 you are thinking of ALARA as a cost-ef fectiveness kind of 18 a pproach, then it should underlie.
Yet here we have this i
19 sort of quibble approach, goal-setting and ALAPA together 20 which is driven by a whole different perspective.
I would
~
21 find it much more comfortable if there were some sort of 22 justification that says this is why we do not wa n t to follow 23 a cost-benefit kind of approach in the main body of our text 24 which if we are doing this other approach -- I do not knov 25 how to characterire it and this is why we might want to ALDERSCN REPORTING CCMPANY. INC, 400 VIRGINIA AVE., S.W WASHINGTON. O.C. 20024 (202) 554 2345
91 1 use the cost-benefit a pproach f or A1 ARA, this is why we are 2 not going to use cost-benefit for something else.
3 3
But there is no such discussion.
4 MR. WHIPPLEs The ALARA itself is a cost-effective a
5 procedure.
t 6
MR. PAGEs So what I am saying is that we have l
7 these seven frameworks in the back.
8 MP. O'DONNELLs Are you referring to another 9 document?
l 10 MR. PAGEs I am referring to NUREG-0763, Toward a l
11 Safety GCals Discussion of Preliminary Policy I
i 12 Con siderations.
i 13 MR. PERROWs I remember that discussion.
I do not 14 get your point.
Can anybody else restate his point?
15 MR. PAGE:
Let me try to say this more succinctly.
16 The point is that if you are going to take a cost-benefit 17 approach, you take an approach that will be fundamentally 18 dif ferent from the main body of th e xeroxed discussion paper 19 and also the Toward a Safety Goal paper.
20 In the Toward a Safety Goal paper we have seven 21 f rameworks a t the end which are tacked on which are 22 f undamentally different philosophies.
The question is why 23 o ne h e re, why another there.
What is the argumen t that 2t. allows you to set one in one place and another in another 25 place, especially when in the main body we have two i
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1 competing?
We have this choice of safety goals Lased on one 2 perspective along with ALARA and thens ch, by the way with s
3 ALARA comes cost benefit in the back window.
4 I would be happier if we had some sort of reasoned 5 basis for developing the argumen t that this paper wants to 6 cubmit.
7 HR. WHIPPLE:
When you get through the formalities i
8 are they not operationally equivalent?
9 MR. PAGE:
I think they are operationally quite to dif ferent.
11 HR. WHIPPLE:
Once you know the metric you are 12 using, don't you end up with the same plant if you design it 4
13 according to one approach as compared to another approach?
t 14 MR. PAGEs No, because I think the spirit in which 15 the safety goal is written is:
here we have a nuclear 16 industry and we have to live with it.
So we will say we can 17 spend a reasonable number of hours setting safety goals.
1 I
18 That means that you are going to have some industry in some i
19 f o r m.
But under a generic cost-benefit approach you may end i
20up with no industry a t all.
1 2
MR. O'DONNELL:
I think we tend to look at these 22 c..ings in a very global sense.
But really wha t we are 1
23 talking about is NRC's mission which is not to decide i
24 whether or not we should have nuclear industry.
Their 25 mission is if there is going to be a nuclear power plant how ALDERSCN REPoRnNG COMPANY,INC, 400 VIRGINIA AVE., S.W. WASHINGTON. D C. 20024 CO2) 554 2345 6
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1 should it be regulated.
The Congress is the one whc has to 2 decide whether we are going to have an industry.
f 3
3R. PAGE:
If that is true, then that is the 4 f undamental difference between the cost-benefit approach and 5 the one that is in here.
It is well worth articulating.
6 3R. WHIPPLEs NRC has a problem in tha t they have 7 been told that we are going to have a nuclear industry, your 8 job is to see that the engineering is done right.
And you l
9 cannot really figure out what they mean by "doing the l
10 engineering right" without looking at competing risks, 11 competing energy technologies and so on.
I think that is 12 part of the problem.
13 MR. O'DONNELLs In the Atomic Energy Act it says 14 tha t the branch tha t you license should not pose undue 15 ris k.
The whole idea of the safety goal is to define what 16 that phrase of the Atomic Energy Act means in practice.
17 MR. PAGE4 One approach is to say we will make 18 nuclear power safer than coal.
Compare it to coal.
Another 19 a pproach is tc say forget about coal, we are going to spend 20 dolla rs on saf ety up to the point where the next margin of 21 saf ety will just buy one dollar's worth of safety.
They can 22 lead in very different directions because there is no 23 guarantee that coal is the upper benchmack that leads to l
24 this marginal condition.
25 MR. WHIPPLE:
But like the discussion paper, it l
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1 says to be acceptable it has to be safer than coal.
But J
2 that will not apply to ALARA.
Then we will look at the 3 marginal ef fectiveness of the issue of dollars.
4 MR. O'DONNELL4 The coal argument was only used in 5 setting this upper limit.
6 MR. FacLEAN:
You are saying something very close 7 to what Ed says.
You set this level and then below that 8
MR. SLOVIC It is a sequential process which 9 involves different rules, different logics and different i
10 times and I sense tha t you are uneasy about that.
l 11 MR. PAGE:
I think it is a very clever approach u but I would like to see it justified.
1 13 MR. O'DONNELL:
Setting the limit for the i
14 individual risk is f rom equity considera tions.
Tha t stands i
i 15 on its own merits, having nothing to do with ccst benefits i
16 which Ls really allocating society 's resources fo r society 's J
17 benefi n.
You still have to protect the individual.
18 MR. PAGE:
I understand what you are saying.
I 19 think the discussion we are having here goes further tcwards 20 j ustif ying this two-stage approach than what was in the 4
i 21 document.
22 MR. O'DONNELL:
I agree.
The document is kind of 23 licht on explanation, justification, rationale which I think 4
l 24 is there.
The other thing, I think the ALARA as presented i
a 25 here is extremely fuzzy and unquan tita tive and that shculd i
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95 1 be somehow brought within the framework of the quantitative 2 goals.
3 MR. MacLEAN:
Maybe as it stands now it might be 4 incompatible.
That is to say you might have met the 5 quantitative standard and further safety might still be the 6 ALARA principle, cost effective, easy to do.
7 MR. WHIPPLE4 The repo rt says tha t, I think.
It 8 is f uzzy.
9 MR. O'DONNELLs It says that but it does not 10 provide any quantitative measures of that.
11 NR. WHIPPLEs Or the alterna tive would be ALARA, 12 that you may have to spend more money than you were 13 justified by an ALARA condition to meet those quantitative 14 goals.
15 MR. PAGE:
Than you are in trouble.
16 HR. WHIPPLE:
Your marginal costs might be higher 17 but your absolute costs will still be lower.
18 MR. MacLEAN ALARA is used in other technologies 19 also and " reasonably achievable" is not always interpreted 20 to mean cost effective.
It is sometimes interpreted to mean 21 technologically effective.
22 MR. O'DONNELL:
It is interpreted in a qualitative 23 sense.
24 MR. MacLEAN:
That is not allowed?
25 MR. BERNERO:
There has to be a little control i
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1 technology.
EPA uses it.
It is quite different 2 philosophically.
3 MR. MacLEAN4 Is ALARA explicitly economic?
Yes, socio-economic.
5 MR. PERROW:
The fact that it has " reasonable" in 6 it implies break-offs.
7 MR. O'DONNELL:
Why not be explicit?
If you mean i
8 cost benefit why not say cost benefit?
Why use this fuzzy a
9 tern ALARA?
It is tied directly to a specific cost-benefit 10 number.
11 MR. SLOVICs To w ra p this up, now we have to reach l
12 a conclusion.
13 (Laughter.)
14 Thank you.
It is 2:30 and we have a break.
We 15 vill reconvene at 3 s00 for the beginning of several rounds 16 of plenary sessions, so your summaries will come up again.
i 17 I will try to summarize this.
18 (Thereupon at 2:35 p.m.
th e meeting was concluded.)
i I
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NUCLEAR REGULATORY CO.ARISSICN This is to certify that the attached proceedings before the v'
in the ::ta:Oer o f:
SAFETY GOAL WORKSHP - PANEL C - ECONOMIC, ETHICAL AND SOCIO-POLITICAL CONSIDERATIONS Date of Proceeding: July 23, 1981 Docket !! umber:
? lace of ?rcceeding:
Harpers Ferry, West Virginia were held as here.* n ap pear s, and that th'is is the original transcrip:
thereo f for the-file of the Cc= mission.,
Judith F.
Richard Official Repceter (Typed) 11 8 A
ficial Reporter (Signature) ed 9