ML20011A096
| ML20011A096 | |
| Person / Time | |
|---|---|
| Issue date: | 09/24/1981 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML20011A097 | List: |
| References | |
| REF-10CFR9.7 NUDOCS 8110070190 | |
| Download: ML20011A096 (63) | |
Text
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u 9P Attached are the PDR copies of a Commission meeting transcript /s/ and related meeting document /s/.
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other distribution is requested or required.
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Transcript of:
Briefing by American Nuclear Society F
on Current Activities, September 24, 1981. ( l copy) a.
Letter to Chairman Palladino from Corwin L.
- Rickard, ANS, July 31,~1981.
(1 copy) b.
Above-entitled meeting Agenda.
(1 copy)
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1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY C0 EMISSION 3
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BRIEFING BY AMERICAN NUCLEAR SOCIETY 6
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ON CURRENT ACTIVITIES 7
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11 Room 1130 1717 H Street, N.W.
12 Washington, D.C.
13 Thursday, September 24, 1981
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14 The Commission met at 3:07 p.m.,
pursuant to
- notice, 15 BEFORE:
16 NUNZIO PALLADINO, Chairman 17 PETER BRADFORD, Commissioner 18 JOHN AHEARNE, Commissioner 19 ALSO PRESENT:
20 L.
BICKWIT, General Counsel 21 S.
CHILK, Secretarf 22 P. REMICK 23 24 25 ALCERSCN REPCRTING CCMPANY, lNC, 400 VIRGINI A AVE., S.W., WASHINGTON, O C. 20024 (202) 554 2345
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CHAIRMAN PAllADINO:
The meeting vill please come 3 to order.
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The subject of*this afternoon is a briefing by the O, '
5 representatives of the American Nuclear Socie ty.
They are 6 going to bring us up to date on the current activities.
7 We are very delighted to have you here this 8 afternoon.
I understand that you have a number of colleagus 9 here with you, Mr. Rickard, and you will be the spokesman at 10 least for the start.
If I may, I will turn the meeting over 11 to you.
12 MR. RICKARDs Thank you very much.
13 It's t real pleasure for the American Nuclear s
14 Society to have a chance to talk with the Commission and 15 present you with a briefing.
I don't need to tell you and, 16 I 'm sure, o ther members of the Commission, but I will repea t 17 it anyway, just a little bit about the American Nuclear 1
18 Socie ty because we are proud of our efforts and our members.
19 As you know very well, we are basically a 20 scientific and technical society.
We are 1u,000 members 21 strong now and still growing.
That 1u,000 membership 22 represents, I am sure, the trix of the scientific and 23 engineering and technical knowledge in the nuclear 24 technology field in this country.
25 Our membership also includes members overseas.
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t 1 have sections.of the American Nuclear Society overseas that l
2 opera te in Europe, Asia and Africa, so we are both --
3 NR. DU TEMPLE:
And South America and in Japan.
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4 HR. RICKARD4 Some in Latin America and Japan, 5 right.
So we are both an international as well as a very 6 strong membership here in the U.S.
7 We are purely scientific and technical and our 8 membership is made up of scientists and engineers from 9 universities, industries, many members from the NRC.
10 COMMISSIGNER AHEARNE:
A few lawyers.
11 HR. RICKARD:
And a few lawyers.
We are all 12 p rofessionals.
13 (Laughter.)
14 HR. MUNTZING:
It only takes a few.
15 COMMISSIONER AHEARNE:
To do what?
16 MR. RICKARD:
And here with me today is the Vice 17 President of the American Nuclear Society and 18 Presiden t-Elect, Manning Muntzing.
19 We have Bon Stinson, who is Chairman of the Power 20 Division of the American Nuclear Society and has been 21 involved in many other divisions in the Society.
22 John Graham on my right, also an officer of the J
23 Society and the Treasurer, and beyond that htving p1syed a 24 very important role in the Safety Division of the Society.
25 And a Board member and Executive Committee member ALCERSCN REPCRT;NG COMPANY,INC, 400 VIRGINTA A%E S.W WASHINGTON. O C. 20024 (202) 554 2345
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4 1 of the Scciety, Angie Giambusso.
2 So we have a good cross-section of both the
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- 3 officers and the Board and the division chairmen.
He always says I never need an 5 introduction.
6 (Laughter.)
7 MR. RICKARDs And I can't miss Octave here because 8 he is Mr. ANS, as you know, an executive director of the 9 Society and has kept it g.,ing well all these years.
10 And Harry Lavrosky has also joined us, who was 11 just immediate past president of the Society, and we can 12 call on him if we get in trouble here or if I get in 13 t rouble.
I am getting all the problems this year that he 14 had last year.
15 CHAIRMAN PALLADINO:
- 'ou mean he didn't solve any 16 of them?
17
( La ugh te r. )
18 MR. RICKARD:
We feel basically that our Society 19 has the same goals and aspirations that your NRC has, that 20 your Commission ha s.
We are all prof essionals.
One of our 21 preeminent cesponsibilities is towards the health and safety 22 of the public, and each of us feel that responsibility in 23 the day-to-iay activities that we are in, and tha t is I
24 partially what we are doing in being banded tocether in the 25 American Nuclear Society.
So we f eel a very great kinship ALCERSoN REPCRTING CCMPANY,INC, 400 VIAGINI A AVE., S.W., WASNNGTON, D.C, 20024 (2C2) 554 2345
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- de have very many activities in the Society that 3 bear scientifically and technically upon the industry that 4 you are regulating.
Almost all of our divisions -- and 5 there are some 1,8 separate divisions now of the American 6 Nuclear Society, spanning a range from the Power Division --
to the Division of 7 and Ron is the Chairman of that 8 Biology and Medicine.
But certainly the Power Division, the 9 Reactor Operations Division, the Safety Division are three to major divisions that bear directly upon the interest that 11 you have n the Commission.
It Our very largest single activity in the Society
'eand the activity that commands the largest number of
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14 volunteers of our membership is in standards making, which 15 is an ef fort that bears directly with you, and our present 16 standards activities are consuming the efforts of about 1300 17 of our members that meet on a regular basis and work very 18 hard to produce good standards for the nuclear techno1Cgy 19 fiteld.
20 Beyond that we also thought that wo would try to 21 convey to you here just briefly some of our other activities 22 and our thoughts, and we would look forward to any 23 suggestions you have where we might better direct the 24 efforts of our society that could be of benefit to problems 25 tha t you may have or scientific and technical input or peer ALCERSON REPCRTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHNGTCN. O.C. 20024 (202) 554 2345
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6 1 review could facilitate and help you in your job in the NRC.
2 So we have an agenda here which we're are l '
3 modifying it's already modified slightly.
Ron Stinson 4 was going to make a statement next on the p rogram.
5 NR. STINSON:
Thank you very much.
6 Again, my name is Ron Stinson.
I am President of 7 the Management Analysis Company and Chairman c f the Power 8 Division, and past Chairman of the the Reactor Operation 9 Division Society.
10 When I found out I had the opportunity to poll the 11 members of the Executive Committee of the Power Division 12 about the reconciliation of major rulemaking hearings, I,did 13 not realize the degree of frustration that I stirred up.
It i
14 is enormous at this time.
15 The Power Divisien endorses the concept of 16 utilizing Safety Goal, Criteria as a basis for stabilizing 17 the licensing process and hopefully ending the historical 18 ratcheting problems that have plagued the nuclear power 19 industry.
It is a total unanimous consensus that the recent 20 proliferation of regulations that has been coming cut of the 21 Commission are indeed not adding to the safety but are 22 degrading the safety in the plants today in the overall 23 ope rability and main taiaability and the complexity of the 24 plant.
25 We believe that the safety goal criteria should be ALDER 5oN REPORTING COMPANY. INC, 400 VIRGINTA AVE, S.W., WASHINGTON. O O. 20024 (202) 554 2345
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1 predicated on the following general principles:
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The goal should provide a level of protection for 3 members of the public such that no' single individual bears 4 an inordinate risk.
Essentially, a maximum acceptable risk 5 criterion should be established which will not subject an 6 individual -- The annual mo rtality risk should not increase.
7 Second,.the safety goals for nuclear power plants 8 should be established in a manner consistent with other 9 societal risks applicable to other technologies and should 10 consider the benefits as well as the risks inherent to the 11 technologies.
12 We do not feel that there have been adequate 13 tradeoff s in the cost-benefit analysis.
The formulaticn of 14 such safety coals would assure the public living in the 15 vicinity of a nuclear power plant that they are not being to subjected to any greater risk than members of the public at 17 large and should therefore enhance the public support for 18 nuclear power.
Such an improvement will include the
- 9 elimination of ra tcheting that does not improve safety.
20 While'we support the use of safety goals and 21 encourage the formulation of. safety goals consistent with 22 the principles stated above, se caution the Commission to 23 prcceed carefully in establishing these goals.
24 In our opinion there are four problem areas, and 25 these are somewhat arbitrary groupings that must be ALDERS 0n REPCRTING COMPANY. INC.
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8 1 caref ully assessed, cogently debated and clearly understood 2 if the safety goals concept is to truly improve the safety 3 and111 censing process applicable to nuclear power plants.
4 In the jargon of the industry, we talk about definitional 5 uncertainty.
Should a point be used, and should a hierarchy 6 of probabilistic criteria be used, things of this na ture.
7 Another difficulty is in value assessmants.
Do we 8 try to incorporate a scrietal utility f unct'on?
If so, how 9 does one determine society's risk aversion?
10 Third, difficulties in fact assessment, in 11 methodoloolcal validity such as post-core-meltdown phenomena 12 phenomena are not understood and those calculational models
- 13 need to be improved.
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14 And fourth, clarification.of adequacy and use.
15.There is a need for better answers to questions such as how y'
16 will saf ety criteria be used in.the licensing process and in 117 plant operation.
18 CHAIRMAN PAllADINC4 What was your I'irst one?
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The definitional uncertainty.
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20 that we mean the point value on a risk curve: should a point
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Should we have a hierarchy 22 of probabilistic curves for dif f eren t types of accidents or l
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24xp The assessment of hese problem a reas should
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25 incorporate the expertise of a wide cross-section of
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9 1 individuals who are familiar with nuclear power p3 ants, its 2 benefits and risks.
3 The Powar Division of th e ANS certainly contains 4-such an individual and is fully supportive and willing to 5 support in any mannor the Commission activities towards 6 establishing these safety goals.
7 In this regard we intend to firmly discuss with 8 other industry organizations such as the ASME IEEE what 9 initiatives we can take in this area and anticipate some 10 kind of a coordina ted eff ort on trying to address it.
11 CHAIRMAN PALLADINO:
Have you not been interacting 12 with the NRC -staff on saf ety goal development?
It is our perception that the i
14 Socie ty, the Power Division Society has not is COMMISSIONER AHEARNE:
I don't think there has 16 been any interaction as ANS per se.
There are individual 17 members.
That is right.
But as a committee 19 or study group made up of a consensus of th e Society, there 20 has not been interaction.
21 CHAIRMAN PALLADINO:
There have been workshops on 22 this subject.
23 MR. RICKARD:
7es.
With respect to the FRA there 24 is a very effective interaction under way, but that is just 25 one piece.
ALOERSON REPoPTING CCMPANY, INC, 400 VIAG1NIA AVE S.W.. WASHINGTCN. O 0, 20024 (202) 554 2345
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COMMISSIONER AHEARNE:
T' tere have been two 2 workshops on the safety goals and we have received -- f or 3 example, the AIF is sending in a submission.
We do not have 4 any formal interaction with the ANS.
5 CHAIRMAN PALLADINO:
Was the AIF input at their 6 initiative?
7 COMMISSIONER AHEARNE:
Yes.
8 CHAIRMAN PALLADINO:
We would like the input, and 9 I want to take sure that the evidence available is being 10 u se d.
The next point was one that was 12 somewhat contreversial in the group.
There are some people
'13 who feel tha formal rulemaking initiative should be deferred
(
14 until these issues have been f ully addressed, and I think I
15 tha t is too extreme.
There are certain rulemakings that 16 make sense to go ahead and proceed with, but I think we in 17 the Scciety and the Power Division would strongly urge the 18 Commissioners to back off and be very caref ul in which one,s 19 bef ore we f ully address the goals relative to establishing 20 th e levels of protection for society a t large.
21 CHAIRMAN PALLADINO:
Is there any particular area 22 of rulemaking that you are referring to?
23 MR. RICKARD:
We had some time back earlier or 24 las t year, really, given a letter to the Commission l
25 recommending that siting and degraded core rulemaking is te ALDERSON REPoATING COMP ANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTCN, O.C. 200:4 (202) 554 2345
11 1 certainly follow setting some kind of a goal, safety goal 2 establishment.
3 ER. STINSON:
I remember a point, if I could 4 digress a moment, about a calf's path where a calf stumbles 5 along and finds its way and nibbles here and there, and then 6 a cow follows it and then pretty soon a person "follows it, 7 and pretty soon a village builds up around it, and it 8 becomes the main pa!th of the village.
I feel we have 9 followed the calve's path, if you will, if we go back to the 10 China syndrome.
- de are not looking at where we are trying 11 to go with our overall goals.
12
.And the proliferation of these have been added on 13 and there are people that have an honest religious zeal on 14 their own individual things they are trying to put out here.
15 They are'not looking at tEeir overall goals, and tha t is a 16 major concern to the Power Division.
What is it doino to 57 the available resources and the ability to keep track of?
18 I think it would be worthwhile -- recently, if we 19 could take jus t a minute, I saw a slide presentation 20 prepared fo r the Boa rd of Directors of Texas Utilities, and 21 it had slides of some of the original hangers and restraints 22 for piping that was installed on Comanche Peak, and then it 23 h ad the evolution of these changes based on the '76 and 24 later criteria and wha t is goine on today.
25 It showed the hundreds of engineers, literally, in ALCERSON REPCRTING CCMPANY, INC, 400 VIRG;NIA AVE., S.W., WASHINGTCN, D.C. 20024 (202) 554 2345
i 11-A 1 trailers with computer terminals trying to do updated 2 as-built analysis, and the new large blocks of steel that 3 are installed in Unit 2.
They are trying to be responsive 4 to the standards and criteria.
And later, because it was 5 so drama tic, it was shown to the Texas Public Utilities 6 Commission in a rate case, it was very dramatic.
I don't 7 think anybody who understands the consequences of some of 8 these things and sees it in the field really believes we are 9 substantially adding to the safety of the >ublic.
10 MR. MUNTZING:
Mr. Chairman, in f urther answer to 11 your question, we tend to believe that the proper sequence 12 is to establish the safety goal, or goals, as the case may, 13 as a first step so people know where they are headed.
14 Thereaf ter would come an evaluation of source term problems, 15 of which there have been some interesting studies recently.
16 And thereafter then it would be appropriate to determine 17 wha t sort of engineered saf ety features, such as a degraded 18 core rulemaking proceeding or siting requirements, or 19 emergency planning responses, would be appropriate.
20 But these would be the mechanisms that would be 21 used to meet the goal or goals and reduce the risk that we 22 all want to reduce.
But I think that is the tyre of 23 sequence tha t we would feel from a technical point of view 24 -would be the appropria te sequence to pursue.
25 ALDERSCN REPCRTING CCMPANY,INC.
400 VIRGINIA AVE., S.W WASHINGTCN. 3 C. 20024 (202) 554 2345
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I want to thank you very much.
2 M3. RICKARD.
John Graham is going to talk about 3 some of the management use of standards and some of our 4 standards efforts within the Society.
5 MR. GRAHAM:
Mr. Chairman, my name is Jchn 6 Graham.
I am Treasurer of the Society and past Chairman of 7 the Safety Division.
I am not the John Graham who is the 8 Washington representative of the ANS.
I don't mind taking 9 credit f or a lot of what he writes.
I don 't wa n t to take to any debits for any difficulties you may have.
11 CHAIRMAN PALLADIN04 There is a picture in th e 12 Nuclear News, but it's not good enough to --
13 (Laughter.)
Thank you.
15 What we have been discussing and what we wanted to 16 discuss here was the reestablishment of the viability of the 17 nuclear option, in particular in having a cooperative 18 licensing f ramework, and in particular in establishing 19 confidence in the regulatory process through an orderly 20 process which is based on a set of safety requirements which 21 is recc?". zed as proper and adequate throughout the industry 22 and throughout the technical community, and we really would 23 lik e to see this spirit of ccoperation pervade the licensing 24 process.
25 I wa nted to talk about three things to do this:
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13 1 First of all, the standardization of plants; secondly, 2 standards; and thirdly, the PRA activity, and perhaps 3 indicate in each of these areas where the technical and 4 scientific ' assistance of the Society might be of assistance 5 to you in establishing those recognized goals.
6 The standardiza tion, first of all, of nuclear 7 power plants, has been a topic that we have pushed around
- 8. for some years now, for some 10 years, in fact, but the 9 concept has had really a very limited degree of success.
We 10 have had some projects that have benefited by the effort, 11 but the overall hdvantage is marginal.
But we still think 12 that the overall advantage could be a lot g rea ter.
13 One of the major problems, as we see it, is the 14 apparent reluctant acceptance of the principle by the NRC in 15 its licensing activity, and we would encourage you to employ 16 the ideas of standardization to the fullest extent that you 17 can, because it is only by encouragement of the concept tha t 18 you will get the acceptance of the industry, in fact, to go 19 along with standardization.
20 There was a report recently published this spring 21 by the Office cf Technical Assessment regarding 22 standardization, and it had four possible approaches and 23 something like a dozen findings.
Some of those findings we 24 think reflect valid principles, and I will just read one or 25 two of titem.
ALCERSON REPORTING CCMPANY,INC, 400 VIRGINIA ANE S.W-. W ASHINGT ON. O.C. 20024 (202) 554-2345
19 14 1
Standardization can be an essential element in 2 maintaining a safe program for nuclear energy.
3 Secondly, it has the clear potential for time and 9
4 cost reductions and gains in saf ety for nuclear plants.
5 Thirdly, the quality of implementation for 6 standardization is just as important as the concept itself 7 in reaping the benefits.
i 8
Fourthly, the present trends of the industry 9 towards greater standardization would be encouraged by the 10 implementation. of a single-stage licensing.
11 And finally, fifthly, the enhanced sta nda rdiza tio n 12 would increase the likelihood of accurate risk a ssessment.
g 13 I think that is a most important one.
And so the 14 cooperation between NRC and the technical community and the 15 industry on these concepts, and others, I believe, would 16 h a ve a g rea t safe ty benefit.
17 That is especially true on the FRA issue and also 18 on the quality of the implementation of standardization.
It 19 is not only concucive to enhanced safety and efficient 20 saf ety assessment if you have standard plants one after the 4
21 o th e r, but it also will clearly lead to a slowdown in 22 spiraling costs of designing and building nuclear plants if 23 the re is some benefit going the same way as before.
24 And the continual escala tion of requirements,- of 25 'cou rse, is leading to an unnecessary situation where the ALDER $oN AEPOATING CCMPANY, INC.
400 vtRGINIA AVE., S 'N WASHINGTON. O.C. 20024 (202) 554 2345
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.1 nuclear option is being priced out of the marketplace, 2 despite ' the f act that we believe it is one of the least 3 expensive of the options.
This itself is especially 4 critical in times of high in te re st rates.
One of the major 5 problems right now is the financial'one.
6 So changes in regulatory delibera tions do result 7 in additional cost.
Here ve are not talking about whether 8 regulations are suC ficient or adequa te.
It is simply the 9 f act that if they are changed, that they re sult in costs, to and we believe that is intolerable from an operating 11 utility 's poin t of view.
And, of course, in the final end 12 point it is also intolerable from the customer's point of 13 vie w, the user.
14 With regard to sta nda rd s, we see th a t the 15 standards program has two primary benefits:
16 First of all, to provide a control base for the 17 standardiza tion process; and secondly, to set forth criteria 18 f or saf e ty adequacy using the broad technical expertise 19 available in this country.
And by that we also mean, of 20 course, the technical expertise that is available to the 21 Society.
22 Standards can in f act contribute very 23 significantly to a more orderly and more predictable 24 licensing process for new licensees.
We only have to point 25 to the ASME code as an example.
The ve ry f act that tha t ALCERSoN REPCRiiNG COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTCN. O.C. 20024 (202) 554-2345
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1 code is agreed, proven, in use, is an amazing endorsement 2 for the standards program.
And the standards can ensure not
. 3 only, for example, the proper application of safety through 4 any plant, through any new plant so that you kncv it is 5 going to be done, and of course it can result in avoiding of 6 unnecessary imposition of new requirements which are deemed
- 7. unnecessary by the technical expertise.
8 NRC has taken a more active role recently in 9 participating in the ANS standards development, and we. enjoy 10 t ha t, and of course, in endorsing the end product in 11 regula tory guides and similar documents, but in spite of 12 tha t beneficial cooperation in the standards process, there 13 is a continual concern with the endorsement procedure 14 because many times it will include additions or exceptions 15 to the original consensus standard being referenced.
16 This is really contrary to the consensus process 17 and it stifles the benefits of the system, for one thing, 18 and of course it stifles the willingness of the technical 19 individuals to contribute to the process in the first place 20 i f, for example, they think their judgment is going to be 21 superseded.
So we are hopeful methods can be worked out to 22 permit unsupplemented endorsement of future standards which 23 are in f act derived in the consensus process, and we'are 24 asking your help to make this happen.
25 Towards this end we have an agreement between the ALDEASoN REPORTING COMPANY, :NC.
400 VIRGINIA AVE, S.W. WASHINGTON. D.C. 20024 (202) 554 2345
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1 ANS and the NRC staff for detailed cooceration, and that 2 signed a greement is now in its third year, having been 3 recently -expanded in scope.
The document specifies 4 procedures f or setting p rio ritie s, selecting NRC 5 representatives for' standards committees, initiating new 6 projects, and ref e rencing maturo drafts.
7 CHAIRMAN PALLADINO:
Who is tha t agreement between?
8 MR. GRAHAM:
On our side, in the ANS Standards 9 Committee.
10 CHAIRMAN PALLADINO:
Who on the NRC side?
11 MR. GRAHAM:
Can you elaborate the names?
12 MR. RICKARD:
It is the NRC Steering Committee and 13 I am sure your Standards, Pob Minogue on your side.
Jim Millet on the American Nuclea r 15 Society staf f.
He is fr.11 time at EPRI now, working on 16 B &W.
I think many of you would know him or recognire him.
17 MR. GRAHAM:
That activity has been very 18 successf ul in the past two years and we hope it will 19 continue in its larger form.
We request your 20 encouragemen t.
That is really all we are saying.
21 You might be interested in a few numbers that will 22 be helpf ul in your understanding of tho standards effort.
23 It typically requires 175 man-days -- I guess those are 24 person days -- per working group to develop a standard, and 25 70 for a responsible subcommittee and consensus body to ALCER$oN REPCRTING CCMPANY,iNC 40C VIRGINIA ANE.. S.W., WASHINGTON O.C. 20024 (202) 554 2345
16 1 perform the technical review.
I think there is a wide 2 distribution, because the standards I have worked on have 3 taken somewhat longer than that.
4
_This is supplement d by about 15 man-days of ANS 5 staff assistance to provide the standard fo r publica tion.
6 We have five consensus bodies, 24 subcommittees, and 175 7 working groups, with a total of 1320 individual 8 participants.
About 20 standards are published each year; i
9 85 are currently available, of which the NRC has endorsed 21 10 in some form.
11 Just to give you an idea of some of the ones that 12 are coming out very shortly, some of them are to be 13 published this year before December and others very shortly 14 -- I won 't give you the numbers unless you are particularly
.15 interested, but the titles: Operation, Selection and 16 Training; Operational QA for Nuclear Pcwer Plants; 17 Simulators for Nuclear Power Plant Operator Training; 18 Criteria for Accident Monitoring in LWRs; Decay Heat Power 19 in LWPs.
That was published in 19 79, f or e xample, and an 20 earlier standard was endorsed in 10 CF2 50 Appendix K, and 21 we hope the new standard will be ref erenced as well in any 22 revision to Appendix K.
23 Water Storage of Spent Fuel, Dry Storage of Spent 24 Fuel, Light-wa ter Reactor Operator Acrions.
All those are 25 under development or nearing completion.
And then, of ALCERSON REPCRTING CCMPANY, INC, 400 VIRGINIA AVE., S.W WASHINGTCN, O.C. 20024 (202) 554-2345
.O 19 1 concse, since I am mostly engaged in breeder technology, I 2 will add that there are in fact a whola range of breeder 3 standards in preparation.
Particularly some of those deal 4 with the incorporation of standards of design, standards of 5 mitigation of. accidents, standards of safety goals that are 6 required during the design of breeder reactors.
7 CHAIBMAN PALLADINO:
Has there been NRC 8 involvement in those ?
9 MR. GRAHAM:
Yes.
There is NRC involvement in 10 almost all of the Standards Committees.
The only problem is 11 tha t individuals opera te on these committees, they are not 12 representatives of any organization.
13 CHAIRMAN PALLADINO:
I presume that is the way you 14 would like it to be.
15 MR. GRAHAM:
I don't necessarily commit my 16 organization and the NRC rep doesn 't commit the NRC, but we 17 v ould like to feel that a consensus standard is endorsed and 18 endorsed really without exceptien.
All the exceptions are 19 put in during the consensus process.
May I interject here?
21 Joe, one of the problems we occasionally run into 22 with people from your staff being on these committees is 23 tha t frequently they don't get there because they don't have 24 the f und s to get to particular meetings; and I think if you 25 can ha ve, let 's sa y, a more favorable approach, and I knov ALOERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.w, WASHINGTCN. D.C. 20024 (202) 554 2345
20 1 tha t you are all strapped f or f unds, but these are very 2 ~important developments to you, and allowing a little more 3 for those people to get to those committee meetings would be 4 helpf ul and get you direct feedbacA so you get that into the 5 early system.
6 MR. GRAHAM:
That's true.
It's a practical matter 7 but it's a very significant one.
It's more serious from your 9 viewpoint because the industry tends to be there.
10 CHAIRMAN PALLADINO:
That is some thing I will have 11 to look into.
12 MR. GRAHAM:
The ANS, of course, in the Standards 13 activity can provide a very useful leadership role because i
14 they have access to the technical judgments in a large 15 number of areas through the divisions of the ANS.
So we can 16 operate in a leadership role.
We can set up a stra tegy to 17 provide a caref ul mix of people in the Standards Committees, 10 a careful mix of the projects to provide a foundation for 1
19 th e technical requirements of the standards.
20 The third topic I wanted to mention briefly was 21 PRA.
I guess you know it is a further illustratica of the 22 role the ANS can play in establishing technical criteria f o r 23 the regulatory process.
We have the current project to 24 develop a procedures guide on probabilistic risk 25 assessment.
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.r-1 21 1
Another one.is the ANS responsible for the 2 administration of the projects, but we are deeply involved 3 in three key areas.
We have representatives on the 4 technical steering committee, including one of the two 5 co-chairmen, and we are sponsoring a conference in April of 6 1982 which is essentially a wide peer review of PRA 7 procedures guide, and tha t will be a culmination of the 8 effort.
9 And finally, the effective project director is one to of the ANS representatives, Jim Millet, whom you just heard 11 mentioned.
The project is obviously not a Standards effort, 12 but it is being conducted in a way to gain vide industry 13 acceptance, and I think that he important, and we hope the 14 guide will be endorsed by the NRC as representative of the 15 industry 's --by that word I mean including NEC, -- the 16 industry's best tec'hnical judgment on how to approach PRA 17 for nuclear power plants.
18 COMMISSIONER AHEARNE:
I have hopes that that 19 a pp roach -- it 's no t j ust the ANS that is involved.
The 20 IEEE is involved.
21 MR. GRAHAM:
Tha t is true.
We are only acting 22 here as a project administrator.
23 COMMISSIONER AHEARNE:
I hope that is going to be 24 successf ul because it is an attempt on our part to try to 25 involve two major professional societies to develop ALDERSON REPoATING COMPANY,INC.
400 VIRGINIA AVE S.W WASHINGTCN. D.C. 20024 (202) 554 234S c-_
22 1 techniques that we would hopefully be able to use f or all of 2 our people.
So in a way it is a pilot program.
If it works 3 here, then I would expect there would be other areas we 4 could do something similar.
5 ER. GRAHAM:
I think in each of the three areas I 6 have mentioned, NRC has shown a positive approach, and we 7 would like to congra tulate you on that.
All we are saying 8 is on standardization perhaps a more positive approach would 9 help.
10 CHAIRMAN PALLADINO:
Could I ask you a question?
11 Maybe it is difficult but impossible to answer, but do you 12 find the NRC's exceptions surprises, or do you think a
- 13. number of them arise out of close diff erences of opinion
\\_
14 tha t exist right within the consensus group ?
15 MR. GRAHAM:
One of the difficulties in the iG standards sometimes is that there is a feeling that maybe 17 there is a close difference, where in any other consensus 18 body it is not a significant difference, but the NRC 19 representative might say, okay, we will let this go but my 20 opinion would be reflected in the endorsement to the 21 standard.
22 We have had that difficulty, for example, in what 23 u se d to be called MCN-214, General Design Criteria for the 24 Breeder Peactor Plant.
There was a consensus s ta nda rd 25 arrived at, and this was rewritten, for example, for the ALOERSoN REPCRTING COMPANY,INC.
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1 Clinch River Plant as another set of general design criteria 2-which reflected the standard almost entirely, with the 3 exception of one or two points.
4 MR. EUNTZING:
The Commission, of course, must 5 always maintain its independence to establish whatever 8 regulations and standards it thinks are appropriate, and the 7 industry effort is certainly a valuable input because it is 8 practical and real and technically sound.
Rut finally, it 9 is your judgment.
10 Now, the surprises arise, however, when the NRC 11 does not participate in the early formulation.
When they 12 come in at the very end, the group suddenly finds that the 13 NRC approach is dif ferent, or if they have not participated 14 a t all and then it comes to the Commission, suddenly there 15 is a viewpoint being represented that maybe not had been 16 considered before.
17 So I think the point Octave was making has been 18 well tak en.
Early p a r ticipa tio n, even though it costs some 19 money to do that in travel, by knowledgeable staff people in 20 the standards developing programs helps avoid sur; rises at 21 the end of the process.
22 CHAIRMAN PALLADINO:
Okay.
23 MR. GRAHAM:
Thank you very much.
24 CHAIRMAN PALLADIN04 Did you have more?
25 MR. GRAHAM:
No, I finished.
l l
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2 t4 3
1 MR. RICKARD Manning was going to make a few 2 remarks here on management in the regulatory process.
3 MR. MUNTZING I'm Manning Muntzing, Vice 4 President of the American Nuclear Society.
I just would 5 like to say first that we're delighted to have this 6 opportunity to meet with the Commissioners and some of the 7 key staff that are here.
8 I might just say that it's sort of a pleasure to 9 be back sitting around this table.
In fact, it's very 10 f a milia r.
It used to be in another room down the hall.
We 11 did n ' t have as many microphones on it.
I think we had two 12 in the center.
But it's still the same table.
In fact, 13 some things change but the table seems to go on forever.
'(
14 COEMISSIONER SRADFORD:
Are your initials on 15 there?
16 MB. MUNTZING:
I think they're here somewhere, Mr.
17 Commissioner.
18 (Laughter.)
19 I would like to make a few general observations 20 and then turn to some specifics.
In the first place, we 21 would hope to ccavey to the Commission the idea that the 22 American Nuclear Society is a keen watchdog of safety.
You 23 are no t alone in this endea vor.
We have 13,000 peopie who 24 represent the technical nuclear community in this country as 25 well as throughout the world.
And we are concerned with ALOERSON REPCATING COMPANY,INC.
400 VIRGINIA AVE., S.W. WASHNGTCN. O.C. 20024 CO2) 554-2345 l
1
c-c 25 1 technical, scientific problems and their solution.
2 So you may from day to day think you're sitting
- 3 h ere and the only watchdogs of safety in the country or even 4 the world.
But we want you to know that we are out there as 5 a watchdcg as well, concerned about the issues that you are G concerned about from a technical point of view.
7 COMNISSIONER AHEARNE:
I don't think we have ever 8 thought we were the only watchdogs of safety.
9 MR. MUNTZING:
I'm delighted to hear that, Mr.
10 Commissioner.
Sometimes those of us on the outside are not 11 quite so sure about that, so we take your comment with a 12 great deal of reassurance.
13 (laughter.)
14 I want to talk a bit about management.
I have 15 been on the inside of that here in prior years and I would 16 like to share with you some views that may be constructive.
17 But overall, I think that the point that we would primarily 18 van t to emphasize is this:
19 We perceive that all too often the Commission, 20 instead of approaching the problems from the scientific, i
l 21 technical poin t of view, tends to add a strong political 22 note to it.
i 23 Now, we understand that that is of course 24 necessary.
But I think what we would sa y, and being 25 technically oriented, is that we would hope that the ALCERSON AEPoRTING CCMP ANY. INC, 400 VI3GINIA AVE., S.W., W ASHINGTON. O.C. 20024 (202) 554 2345
76 i
1 Commission wo uld direct its staf f tha t it should approach 2 the problems from the highest degree of technical and 3 scientific ratienale and ability, and leave to the 4 Commission whatever political judgments that need to be made 5 with regard to that.
6 COMMISSIONER BRADFORD:
Could you give me an 7 example of the Commission's political approach ?
8 MR. MUNTZING:
Yes.
Let me sort of tell you what, 9 we have in mind.
We see, for instance, from the research 10 programs which are done in the labora tories and under 11 contract to you, and we see from the operating experience 12 certain bits of information which we have not seen before.
13 For instance, when the ECCS criteria was 14 established some years ago when I was at the Commission, 15 there were some things we didn 't know and because of tha t we 16 instituted various conservatisms, various compensations for 17 what ' ve did not know.
18 Since then a lot of research programs have been 19 operated, Oak Ridge and at Idahc, and we certainly know a 20 great deal more about it today than we did at that time.
21 Unf ortunately, while the technical and scientific community
- 22 would ad vise you with regard to this, the conservatisms th a t 23 hav e been institu ted remain.
24 And in fact that is what tends to happen.
Once a 25 decision or requirement is instituted, it is never removed.
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27 l
1 Why is that?
Well, that, Mr. Commissioner, is a political 2 decision that once a requiremen t is placed it remains.
And 3 the answer of tentimes is:
Well, we know a little bit more 4 and maybe we have a -little bit bigger margins of saf e ty th a n 5 ve used to have; isn't that good?
-6 I suggest to you that's a political decision and 7 not a scientific-technical decision.
If you look at these 8 things in a technical, scientific way, you will find there 9 are occasions when requirements should be increased and 10 occasions when they should be decreased.
I don't think you 11 have decreased them recently.
12 In fact, I believe one of the problems with this 13 Commission is, in re ac tion
.o Three Mile Island, which had 14 to occur, is the f act that you have done what a great many 15 commissions do in this town:
You make one mistake with 16 another, or you overreact to compensate for something that 17 has occurred.
And I think there has been a certain degree 18 of overreaction.
I suggest it's more political than 19 technical.
20 COMMISSIONER AHEARNE:
Manning, I gather as ; art 21 o f that, as I recall, earlier you suggested it would really 22 be more appropriate to allow the staff to make technical 23 judgments and leave the political judgment to the 24 Commission.
I think that was part of your earlier 25 sta temen t.
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'N 1
I gather, th e re f o re, that you conclude that 2 currently we are either requiring, asking, or allowing the 3 staf f to make political judgments.
Which of those?
4 MR. MUNTZING:
Yes, I am suggesting that it has 5 probably only been in recent times, and certainly not in the 6 early da ys of the Commission, where the Commission maybe 7 could speak wit!' one voice to the staff, and I think we all 8 know that problem.
9 We have the reorganization plan of last year.
In 10 f ac t, when I walked in the room earlier I think ycu were 11 talking about some of its implementa tions.
But there has 12 been a period of time in which the staf? had five voices 13 speaking to it.
I headed the staff here at the Commission I
14 for three and a half years and I don't think the staff can 15 sta nd that.
16 And I think this staf f at this Commission has been l
17 extremely responsive when it knew what people wanted tc have 18 f rom it.
What I think and what I would advise and what we 19 believe is sound is for the Commission as one voice to speak 20 t o the staff.
And what we would sa y you should say to them 21 is:
You bring us the straightforward technical, scientific 22 evaluation and analysis, and we don't want any overlay of 23 political judgments, whether it's that that nicht color your 24 thinking on this.
Just give it to us straight.
25 COMMISSIONER AHEARNE:
I gather by the way you say ALOERSoN REPCRTING CCMPANY,INC.
400 VIRGINIA AVE S.W., WASHINGTON, C.C. 20024 (202) 554-2345
29 1 that, is that currently you believe, A, we have not asked 2 the staf f to give it to us straight, and B, the staff is not 3 giving it to us straight.
Is that correct?
4 MR. MUNTZING:
I would say that the N2C's 5 activities during at least its first five years of operation 6 -- and it takes a while to change th a t around -- has been 7 that the staff hardly knows what you want done.
8 COMMISSIONER AHEARNE:
Then you are not saying we 9.have told them not to give it to us straight.
You 're sa ying 10 they don 't know what we're asking.
11
'MR. MUNTZING:
I think some Commissioners have 12 asked for it one way and some another.
And I think the 13 opportunities are present with a full Commission, five
(
14 members at this time -- only since August, actually; for 13 15 months there were only four here.
16 COMMISSIONER AHEARNE:
I know it well.
17 MR. MUNTZING :
But there 's a full complement ard I 18 think the opportunity unner the Reorganization Act. it i.e 19 possible now for the Commission to speak with one voice to 20 the staf f and give them the directions and the leadership --
21 and the leadership -- that you would like to have them 22 pursue.
And I don't think this has been possible before.
23 COMMISSIONER AHEARNE:
'J ell, I probably agree with 24 a lot of your comments.
I just would have to take exception 25 to the point that as f ar as I know we have never asked the ALCERSON REPORTING COMPANY, INC.
400 VIAGINIA AVE., S.W., WASHINGTON. O.C. 20024 (202) 554 2345 l
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30 1 staff to give it to us anything other than straight.
- Now, 2 it may well be that the staff has at times, under various 3 pressures, bent one way or another.
But I know whenever 4 they come up here we have always tried to get from them, is 5 that your best technical judgmert.
6 I've had similar conversations that you just went 7 through with them, saying political issues -- if there are 8 political decisions to be nade, they are surnosed to be made 9 on this side of the table, not on that side.
10 MR. MUNTEING:
Yes, we 're in agreement.
I think 11 ve ought to be careful about using the word " straight."
12 What we want to emphasize is that the judgments from the 13 staff as they come to you should be technical and f
i 14 scien tific.
15 COMMISSIONER AHEARNE:
Yes.
16 CHAIRMAN PALLADINO:
Even that is not always 17 clear, because sometimes just the way the question is 18 phrased, the wa y we ask the staff may influence the kind of 19 technical an
. _ that we get.
So sometimes the question has 20 political overtones right in its formulation.
21 MR. MUNIZING:
I would certainly concur with 22 tha t.
23 CHAIRMAN PALLADINO:
And then tha t gives the 24 appearance that the staff is meddling with the political 25 part of the issue.
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31 1
MR. MUNTZING:
But as a technical society, in 2 looking at the process, we are sensitive to this issue, 3 maybe more so than others that you may hear from.
And what 4 we would simply do is encourage the Commission -- and it may 5 already be clear, but if it's not, vs would says Say again 6 to the staf f, please bring to us the best technical, 7 scientific judgments, and leave to you, the political 8 appointees, the political decisions that must be made with 9 regard to that data.
to COMMISSIONER BRADFORD:
I think my two fellow 11 Commissioners have been remarkably gentle in the face of a 12 very provocative set of comments from you. I must say for a 13 lawyer you have drawn some rather extraordinary conclusions
(
14 on the basis, as near as I can tell, of no ovidence at all.
15 I'd like to h ea r a specific rule, a specific decision of the 16 Commission that you think has been made on a political 17 basis.
18 MR. MUNTZING:
'4 ell,'I gave you one example, 19 Commissioner Bradford.
20 COMMISSIONER RRADFORD:
Do you want to try again?
21 I didn't hear it.
A specific rule, a specific decision, a 22 specific point.
23 MR. MUNTZING:
Yes.
The example I gave before was 24 the ECCS criteria which I think that --
25 COMMISSIONER BRADFORD:
This commission.
4 ALCERSoN RE?CRTING COMPANY, INC.
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c-N 32 which demonstrates that in 1
MR. MUNTZING:
Yes.
2 f act there seems to be a political j udcaent that once a 3 regulation is in place that it is not relaxed, even though 4 better data and better information would tend to show that a 5 change would be appropriate.
6 COMMISSIONER BRADFORD:
When did this Commission 7 decide not to relax the ECCS criteria based on political 8 considerations?
9 MR. MUNTZING:
I think the Commission can at any 10 time, if it finds that new inf orma tion is a vailable to it, 11 can take action.
I would hope that it would.
12 COMMISSIONER AHEARNE:
Now, come on, Manninc.
You 13 made some charges about the political actions on behalf of i.
14 the Commission, and Peter has asked a perfectly reasonable 15 question:
Give an example, a concrete example.
16 MR. MUNTZING:
Cf where the political judgments 17 have been imposed?
18 COMM ISSIO N ER AHEARNE:
Yes.
19 MR. %UNTZING:
I would say tha t the recent 20 emergency planning rule is an example.
I don't believe it 21 is really based on sound technical scientific judgments.
I 22 think it was a political decision.
23 COMMISSIONER BRADFORD:
I Know you thiNk it was.
24 In f act, you said you think many of our decisions are 25 political.
But I don't think it was, and to convince me to ALCERSON REPORTING COMPANY,INC.
470 VIRGINIA AVE., S.W WASHINGTCN, O C. 20024 (202) 554-2345
33 1 the contrary you'd have to be able to point to something 2 o ther than your opinion about it.
And you, I take it, 3 follow Commission meetings.
You have paralegal people-4 here.
You review all the documents.
5 Aside from the fact the Congress did pass a law g
6 requiring upgrading of emergency planning standards, where s
7 in that process is there a reflection of political 8 considerations?
9 MR. HUNT 1ING:
Well, I think, Mr. Commissioner, 10 you and I would just have to. disagree on this point.
Ycu 11 have stated your opinion and I've stated mine.
But I think, 12 f or example, the process of the deadline for certain warning 13 systems is really not very well-founded.
And you know, if
(
14 you had looked at the technical realities of it,.it would 15 have been seen not to have been an appropriate decision.
16 A nd I believe it was a da te probably picked just as a l
17 political decision.
l l
18 And let us say here, you know, that's your job.
I 19 wouldn 't sort of be concerned that this has to occur'from
~
20 time to time.
It will, and that's what Commissioners do.
21 The y a re selected to make these judgments and to arbitrate 22 dif ferent points of view, and that's what has to happen.
22 COMMISSIONER AHEARNE.
I was with you a lot of the
~
g 24 way, 3anning, but on that particular deadline I have to
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25 comment.
We asked the staff, can this be met.
We net wi h J
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3u 1 people from various states, from utilities, asking them, can s
2 this be met, is this a reasonable deadline.
In fact, we 3 slipped.
We put the dondline further out becausa we were 4 told tha t 's. unreasonable, the! original deadline.
We put it 5out and we were told, it looks ticht but we think we can 6 make it.
.'.nd the staff,' assured us, yes, that can be made.
7 It turned out that was wrong, and as you know we e just recently -cone-through the process to put it out.
G s But I would really dif fer ylth you on that one.
We did try 10 to make an: estimate of 'what was a reasonable deadline to 11 choose.
12 MR. MUNTZING:
I'm glad to hear that expressed.
13 C.V.2 cf l the thingc that we feel is extremely important with 14 regard to the; nuclear option is the credibility of this i
15 Coalission.
Ani if-in fact the credibility in the public's
~
16 mind is cot high, th'ere is a great deal of problem.
17 And for instance, we recently have seen done by I
18 the. National Sciencq Founda tion " Attitudes of the U.S.
~ 19 P ur lic Towa rd Egie nc e and Technology."
And they have asked 20 q uestions in the,p uclea n field, and unfortunttely the 5
w.
'w 21 f ederal regula tory agency they didn't name the NRC, but W
22 in the nuclear field -- is very low in the credibility g
23 standard tha t..we a re e valua ting.
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2 you 're technically and scir'stifically sound and ma' ting s
3 correct decisions.
When you say that certain alarms have to 4 be in -by certain dates for safety reasons and the date comes 5 and gces and people' aren't ready and you take another period 6 of time, the public is not impressed.
Therefore, we think 7 that a strong reliance on technicil and scientific judgments i
8 is key to a better public impression of the work that you
~
9 do.
+
10 Well, I have some other things, but I'm sure I'm 11 out of time.
12 COMMISSIONER BRADFORD.
Let me make one further 13 comment on the business of politicizing the safety 14 decisions, with just one further point on that business of 15 politicizing safety decisions.
I don't want to be 16 unrealistic about the process, but let me suggest that to 17 the extent there is a process of politicization there is a t 18 least as mcch responsibility, in fact more so, on the 19 indiastry side of the table than on any other single point.
20 I'm not talking now about the ANS.
I realize tha t 21 ' t is not politically oriented.
But I must say, if I had to 22 p u t my finger on a possible source of political influence in 23 Commission decisionmaking that dominates more than others, N lt would lie in the amount of pressure that at least in the 25 last year has been generated by industry groups through i
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36 1 specifically the House Appropriations Gommittee with regard 2 to the licensing process.
3 If there is a single heavy source of political 4 pressure in terms of agency decisions on every:hing from 5 resource allocation to scheduling to outcomes, it ccmes in 6 large part from sources generated within the nuclear 7 ' industry.
8 COMMISSIONER AHEARNE:
I would have to take 9 excep tion.
I would have to say that at least in the three 10 yea rs the pressures have been f rom both sides, and they go 11 in cycles.
And during part of the time the pressures are 12 just as intense --
13 COMMISSIONER BRADFORD:
They do come from a number
~
14 of diff erent directions, at least in the la st year.
m 15 COMMISSIONER AHEARNE:
But if I go back over all 16 the years, it can vary.
And I wouldn't pick out a single 17 Committee, because at some other times other Committees have 18 pushed just as hard in a different direction.
19 MR. RICKARD:
Well, I can assure you that they're 20 no t going to come from the American Nuclear Society.
I do.
21 n o t want to cut that off if there is more discussion.
22 MR. MUNTZING:
I have a lot more things to say.
23 I '.s just varming up.
24 (Laugnter.)
25 MR. RICKARD:
I would like to move on to Angie.
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CHAIF. MAN PALLADI:!Cs If I may make a comment, I 2 think that the Coamission is sensitive to f aults t!.at it 3 has, but in order to correct them we do need some 4 specificity to the observations that are being made, and I 5 think it would be helpful if we could get some examples.
6 Now, as I was listeni.sg to the discussion, you 7 brought up emergency planning and the question wcs raised:
8 Well, where did the political part come into it?
I almost 9 said:
Well, where could you avoid it?
Secause emergency 10 planning involves people, it involves the government groups 11 at a variety of levels, we car.no t escape the political
~
12 aspects of a number of these problems.
13 If you get back to whether sirens are better than 14 tone radios or something else, that's a technical decision.
15 And I wasn t in on all of the early work, but I gather that 16 the staff recommendations on those things were made with 17 good, honest technical input.
Ani again, technical matters 18 involve a great deal of judgment.
They are not always 1
19 defined by a particula r n'imber.
20 I'm not trying to defend what we do, but I am 21 encouraging you to see if you have input that would be 22 'h elpf ul to us, give us soro specificity in the examples and 23 m a yb e it would be useft1 to us.
24 3R. EUNTZING:
We would welcome that.
We don't 25 h av e 24.c time tcday, but we would welcome that.
And I think r
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^
38 1 the point we simply want to emphasize is, we expect that 2 this Commission cust reach a political decision between 3 competing interests or points of view, but it should be you should have first and foremost 4 first and foremost 5 before you the best technical advice and counsel you can 6 receive.
7 CHAIRMAN PALLADINO:
In order to do it, though, if 8 you could point out where on particular examples we fell 9 short, it ma y help us identify wha t we need to do.
10 MR. MUNTZING:
Very well, we will take that on and 11 provide you with any further thoughts we ha ve.
1 CHAIRMAN PALLADINO:
Okay.
Thank you.
13 MR. RICKARD:
Angie?
14 MR. GIAMBUSSO:
I'm Angie Giambusso.
I'm on the 15 Executive Committee of the Board of rirectors of the ANS.
I 16 also ha've, I was going to say, fond memories of this table 17 --
18 COMMISSIONER AHEARNE:
Just restrict it to 19 memorie s.
20 MR. GIAMSUSSO:
I think it's in my blood.
I've 21 shed a little bit of a y blood here.
22 I would like to talk for a couple of minutes on 23 the impact of the President's Nuclear Oversight Ccmmittee.
24 'd e h a ve been reviewing the reports of the Oversight 25 Committee and asking ourselves, how can the American Nuclear ALCERSON REPCATING COMP ANY. INC, 400 VIRGINIA AVE S.W. WASHINGTON. 0.0. 20024 (202) 554 2345
39
-9 1' Society help in terms of solving some of the problems and 2 mee ting some of the points that have been raised by the 3 Committee.
I would like to try to just answer that in a 4 rather summary form.
5 I think first, in general what my friends have 6 said here in the past already has covered some of this.
In 7 general, we have already mentioned the role that the Society 8 has in a rather general way.
Our objective is to expand our 9 efforts to serve as a credible source of technical data and 10 technical-inf ormation related to science and engineering for 11 the pcblic at large, for the technical community, and for 12 governmental, f ede ral, state, local activities.
13 We are conducting these technical topical 14 conferences and national conferences where we deal with the 15 major technical issues, to obtain exchange of data and 16 analysis again on a local and international basis, as we 17 mentioned.
It helps in a rather general way to improve the 18 technical status, the technical proficiency of the community 19 as a whole.
We provide input and work on the manpower 20 pro blem, and how can we cet more people into the nuclea r P
21 field and help train them.
22 N o,w, there are also some specific itens that I 23 just want to tick off rather quickly.
John Graham mentione.d 24 developing the nuclear technicTl standards, most of which 25 relate in one way or another to the nuclear safety t
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'1 objectives.
The standards are more and more needed, and we 2 think we have been helping specifically, as John mentioned, 3 and we hope to continue to do so.
4 A specific standard that has been earmarked and 5 identified by the Oversight Committee was that related to
?
6 the balance-of-plant personnel, and we would hope that we 7 'could continue and try to develop more meaningful 8 standards.
The Committee took the ANS and the ANSI group a 9 little bit to task on what we did on K, but on some 10 standards they.were too general and not enough to be 11 specific guidance either to the utilities or the regulatory 12 g ro u p.
So that's one specific thing that we certainly would 13 m ov e on.
14 As was mentioned, we are working with IEEE on 15 behalf of the NBC for the probabilistic risk assessment.
We 16 think we could do more, that we could assist the N3C in 17 organizing and conducting the seminars and workshops for the 18 review of major technical problems, get the thing on the 19 table and let it all hang out in terms of all the technical 20 vie ws.
21 As the Chairman has said, we are not dealing on a 22 technical issue where we come up with a finite answer and we 23 have a number, whether it 's righ t or wrong.
There is a lot 24 of technical judgment and the people who are going to make i,
25 the.decisiens of all these technical judgments, and tha t has ALDERSCN RE?oRTING COMPANY. INC.
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41 1 not always been the case in the past for one reason or 2 ano ther.
3 The methodologies, how do you calculate certain 4 things?
We go back and see the different views that have 5 occurred over the years on how you calculate stresses.
More 6 needs to be done on that and we think we could help in that 7 a rea.
8 Public information and orienting and educa ting tLa 9 public is another rather major element that all of us have 10 responsibility for.
We can do it individually, that ic each 11 organiza tion can do their own tning, or we can in some areas 12 combine our resources and try to help.
13 Here is one that we are fully in concern with the 14 N RC.
We believe we could help conduct public-criented 15 mee tings th rough our ANS local chapters to explain and 16 discuss nuclear technology, related safety issues, and so 17 o n.
I know the NBC staff has been doing some of this, more 18 I guess with the press, but plans to do more in terms of the 19 public.
20 And finally, in general we believe ve can 21 contribute substantively by providing technical assessments 22 o f selected subjects that are involvec in the proposed NRC 23 regulations, some of them the NEC rules.
And we will work 24 o n a selective basis and give you the benefit of cur 25 collective technical input for these areas.
That's not too ALOERSON REPCRTING COMPANY, INC, 400 VIRGiNI A AVE, S.W WASHINGTON. 3.C. 20024 (202) 554 2345
42 r -
1 provocative, but 2
COMMISSIONER AHEARNE:
Does the ANS provide formal 3 comments on rules?
I'm trying to think back and I don't 4 recall that 5
MR. RICKARD:
We are only engaged 1 r. one at the 6 present time, and tha t 's in coanection with the vaste 7 competence hearing.
8 COMMISSIONER AHEARNE:
Yes, I've seen that one.
l 9 So that you don't have a standerd policy to try to either 10 not comment or comment?
11 MR. RICKARD:
No, there 's no t such a policy.
12 COMMISSIONER AHEARNE:
Do you have a formal 13 mechanism by which it goes to a particular committee and i
14 that committee decides whether or not to comment?
l 15
-MR.
RICKARD:
We have a Public Policy Committee 16 within the ANS and tha t Public Policy Committee processes 17 all of our public policy statements, and they in turn are" 18 agreed to or are finally approved by the Board.
But in the 19 case of the rulemaking, it was from a special ccomittee tha t i
20 was arranged, but our comments were processed through a 21 subcommitee of the Board.
It was the Executive Committee of t
22 the Board.
l
,23 COMMISSIONER AHEARNE:
I was trying to take up 24 something Angie said and think about when we normally go out 25 and ask for comment on a rule, does the ANS make it a -- d o ALCERSCN REPCRTING CCMP ANY,:NC, 400 VIRGINIA A%E, S.W.. WASHINGTCN O C. 20024 (202) 554 2345
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43 y
1 you just have a normal process by which you take that 2 request for.-comment and'a judgment is reached on whether or 3 not comments should be made?
4 5
8 7
8 9
10
-11 12 13
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14 15 16 17 18 19 20 21 22 23
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MR RICKARD:
No, we would not always comment.
It 2 may be discretionary within the division.
For exaLple, 3 -there is a Fuel Cycle Division.
Members of the Fuel Cycle or the 4 Division may feel that it's important to comme.
5 Power Division.
Or it can happen the other way also, 6 tho ugh.
It can be members of the Board or members of the 7 Executive Committee that feel that we have a.worthwhila 8 comment to make and initia te, going in the other direction.
9 CHAIRMAN PALLADINO:
To get there from the 10 standards group, in other words if we're putting out any 11 standards, does the ANS comment on those, especially if you 12 think we 're going off --
Frequently, but not consistently.
14 Is that a f air sta tement?
It usually will come up from one 15 o f the division executive committee sembers, and there is an 16 ef f ort made to coordinate it with the other divisions that 17 are involved.
If it is a Power Division thing, it may 18 involve the Reactor Operation Division and the Nuclear 19 Saf ety Division.
The individual who puts together the 20 position paper and coordinates with the executive committee 21 will make sure he coordinates it with the other involved 22 divisions.
23 But there is not a formalized mechanism.
Usually 24 it has to be by one of the key members of the division.
25 MR. LAWROSKY:
May I make a comment, because I ALDERSON REPrRTING CCMPANY,INC, 400 VIRGINIA AVE., S.W., W ASHINGTCN. C.C. 20024 (202) 554 2245
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1 have more experience in this than any of th ese here.
Nobody 2 speaks for the ANS except through the Board of Directors.
3 The official position of the ANS is through the Board of 4 Directors.
Any comments can originate any place within the 5 Society or-even outside the Society and be fed into it.
6 We have, at least in the past and in the 7 foreseeable future, have limited our comments strictly on a 8 technical ~ basis.
We have avoided quite studiously any other 9 aspects as f ar as any ru makings or any other comments to 10 government agencies, such as the NRC or other ;eople.
So 11 that's the process that we go through in order to make 12 comments from the American Nuclear Society.
We do not 13 restrict our members to make comments as individuals.
14 That 's their preroga tive.
15 COMMISSIONER AHEARNE:
Was there ever a discussion 16 tha t led to the conclusion that you would try to comment on
.17 each technical rule, or it sounds --
18 MR. LAWROSKY:
It's on a case-by-case basis.
We 19 have not made a gene'ral statement th a t we would get involved 20 in every one, because the resources are such and the 21 dispersion of our membership makes that almost impossible.
22 MR. RICKARD:
We have to be rather selective on 23 this thing.
24 MR. LAWROSKI:
It's not only selective, it's a 25 very serious one that we've looked at each time, where it ALCERSoN REFoRTING CCMPANY. INC.
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a6 1 has a much larger impact, where we ' f eel tha t it's very 2 important to get the best technical information.
3 COMMISSIONER AHEAFNEt It sounds like some 4 individual member, either low or high, sees that this is an 5 issue that is sufficiently important that the ANS ought to, 6 and then tries to generate the support.
7-MR. LAWROSKYs Yes.
The first step is to ask for an 9 extension of the time, normally, so we can do something.
10 And then we get the appropriate people to coordinate it.
11 12 13 14
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COMMISSICi4ER BRADFORD:
If you were going to take 2 up a new topic, why don't you do that?
I have a couple of 3 questions on earlier presentations.
4 MR. RICKARD:
I was going to ask Octave to present 5 some comments.on the manpower situation.
Mr. Chairman, Commissioner Ahearne 7 and Comnissioner Bradford, my name is Octave DuTemple.
I am 8 the executive director of the American Nuclear Society and, 9 I might add, the only officer of the Society that is paid.
10 The others all donate their time, and I work for them, 11 including one year the Chairman was my boss.
12 I am here today to discuss a matter with you that 13 I f eel is E'ot at all controversial to any of us but is a i
14 common problem we are f acing in terms of manpower and 15 perhaps to put in one or two pieces of data that are not 16 generally available or recognized.
And the seriousness of 17 i t we can measure in some form in the marke tplace -- I say 18 we, the American Nuclear Society '-- through its advertising 19 in Nuclear News.
20 As you know, frequently the amount of advertising 21 for positions available is quite a gcod index of th 2 22 demand.
.Let me give you some specific numbers.
23 In 1978 ve saw 124 pages of advertising in' Nuclear 24 News tha t were directed specifically to the membership and 25 said that these posiitions are available.
In 1978, 124.
In ALDERSoN AEPoRTING COMPANY,INC, 400 VIRGINIA AVE., S.W. WASHINGTCN, O.C. 20024 (202) 554-2345
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48 lt 1 1981, based-on ten months actual and two months projected, c
2 we will have something on the order of 460 pages 3 specifically addressed to the membership.
These are the 4 positions a vailable.
Now, tha t is very close to about a 400 5 percent increase in roughly tnree years.
6 Now, we look at the number of students in our 7 student branches.
We have 52 student branches in the United 8 States and four overseas outside the United States.
In 1978 9 we had 1950 students.
In 1981 we have 1603.
Now, how does 10 tha t 1603 compare, say, to the number of degrees that are 11 granted at the bachelor level in all phases of nuclear 12 science and engineering?
In 1980, for instance, there were 13 2100 degrees at the undergradua te level in what we consider 14 nuclear science, nuclear engineering.
So if you go to the 15 engineering side, we would have almost 90-95 percent.
And 16 of the total, we have something on the order of 75-Sn 17 percent of the students are members of the ANS.
18 The Society, incidentally, subsidizes these 19 students rather heavily in terms of going to meetings and in 20 terms of lower-price publications.
So that we do a great 21 deal in tha t a rea.
22 Now, in 1980 there were in the nuclear engineering 23 field at the bachelor -level 529 degrees issued.
At the 24 master's level there were 360.
At the Ph.D. level there 25 were 104.
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~
1 Now, there is another interesting factor you 2 should know.
At the Ph.D. level, of this 104, something 3 like about 60 of then were granted to individuals who were 4 not citizens of the United States.
I think you are familiar 5 with-that.
But in this area we see an overwhelming 6 preponderance.
In other words, assuming we say that some of 7 them will stay, we tend to say about hal of them are slated 8 to go outside the United Sta tes.
That is not all bad, but 9 that is not cetting us Ph.D.s here.
10 Now, the universities, of course, are also in a 11 bind, in two ways.
One is that the students seem not to be 12 going into nuclear engineering, per se, although engineering 13 enrollment is up in many areas, at least the last couple of 14 yearc.
15 But in addition to that, the marketplace is j
16 drawing the professors away from the universities.
You are 17 a wa re, I know, of the funding problems we have had in the 18 universities throughout this country in the last three or 19 four years, and so the young professors that are needed to 20 train these are being hired away.
21 Now, there is also lack of operating personnel.
22 And this is even more serious.
But I am going to defer here 23 for _ a few minutes to Eon Stinson, beca use he has got more 24 specific experience in this ares.
25 Ron, would you make a few comments, please?
i ALDERSoN REPORTING COMPANY,;NC, 400 VIRGINIA AVE., S.W, WASHINGTON. O.C. 20024 (202) 554 2345
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1 NE. STINSON.
I am sure you are aware recently of 2 the hearing on Louisiana Fower and Light that they did not 3 have adequate staffing and manpower.
We feel this is just 4 the tip of the iceberg, based on what we see around the 5 industry.
Some of the problems are coming about as perhaps 6 sorge of the new utilities in the nuclear business should 7 have done - a better job in planning, the technician-level 8 p eo ple, the reactor and senior reactor operators, and some 9 of that type thing.
10 But beyond that, some of the requirements that 11 have come out since THI and some that are still in draf t 12 form are requiring such a high level of training that the 13 men are going f rom four to five shifts so that they have 14 adequate time to meet the training requirements.
So it l
15 increases the staffing requirements for the utilities, and 16 then you begin to look at how long it takes to qualify an 17 operator, even one tha t already exists, it has become a l
l 18 monumental problem for the industry, and it is one there are 19 no easy answers for.
Another factor that is facing all 21 o f us an d, I think, also the Commission is th a t, for 22 instance, in the August 31, 1081, U.S.
News E World Reports, 23 in these little printed statements they give in certain 24 areas, they call attention to the fact that the recent 25 survey by the Engineering Manpower Commission says that the ALOERSON REPCRTING COMP ANY,6NC.
400 VIRGINIA ANE., S.W., WASHINGTCN, O C. 20C24 (202) $54-2345
51 1 highest pay for all engineers is basically nuclear 2 engineering, with a median salary of $38,0000.
It turns out 3 that I have looked at the original data, and we are not the 4 highest or the second-highest paid.
The highest are 5 petroleum engineers.
6 But you and your contractors and all the rest of 7 us are f aced with a shortage of personnel, and it is one 8 that does not look like we see any solution without putting 9 considerable ef fort in on all our parts.
10 Now, you need people not at the junior level 11 coming out of school.
We have to be feeding people into 12 this industry, and we have got to get the engineers in 13 there.
14 Now, what are some of the ways we can do it?
15 Well, we can use some of the traditional ways, and I will 16 give you some suggestions which are not new.
But as far as 17 I k no w, at the present time you are not supporting any kind 18 of a scholarship program or a fellowship program in these 19 are as.
20 COMMISSIONER AHEARNE.
True.
But one thing that I would call to 22 your attention is there was considtrr.ble discussion in the 23 executive committee of the ANS yesterday on this problem.
24 Dick Lah ey -- of RPI, is it not -- who is a member of the 25 executive committee, was discussing this at some length and l
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52 1 was proposing the crea tion of an industry-university f und to 2 help these departments.
3 Now, what I would call to your attention is that I 4 am sure ve will do something on this, and I would urge the 5 Commission to try to make your proper and reasonable 6 contribution to try to help the industry to solve this.
7 COMMISSIONER AHEARNE:
By " contribution," did you 8 me~an financial?
9 MR. CU TEMPLE:
Yes, I mean financial.
10 (Laughter.)
11 COMMISSIONER AHEARNE:
I think the gentleman you 12 must speak to resides in some white building out furth,er.
And I am sure we will talk to 14 him.
15 CHAIRMAN PALLADINO:
In view of the severe 16 shortages that the industry has, I am not impressed with the 17 efforts made by the industry to encourage people to go into 18 'the nuclear engineering field.
As a matter of fact, it is 19 quite depressing, even to the extent of advertising properly 20 for, let us say, o p e ra' to rs.
21 I do not want to go into specifics, but there hava 22 been programs that would give a pretty gcod background -- I 23 was almost going to say " perfect" background -- but s pretty
, 24 good background for operating-type people.
And the 25 enrollments are falling down, and it took a great deal of te ALOERSON FEPORTING COMPANY. INC.
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h) 53 1 effort to get enough attention to that problem to get 2 industry just to put appropriate ads in the area.
3 I do not think the industry has taken any specialt 4 steps to put out scholarships or fellowships to help the 5 universi ties.
Nor do I think that they have identified to 6 the people in their own area that there are promising 7 opportunities for individuals in this field.
8 So I think while we are primarily a regulatory 9 body and we recognize that there are shortages of personnel 10 and probably should recognize the influence of that shortage 11 on the orders we put out, nevertheless I think the industry 12 itself must help in the fellowship area.
I think that is true.
One of the 14 things, though, that has really taken all the slack out of 15 it is the post-TMI situation.
I think there needs to be a 16 serious look as to is it the proper utiliza tion f or the 17 overall nuclea r safety for some of the things ocing on m
18 tod ay.
Joe, I certainly do not have to 20 tell you these problems, as dean of engineering and 21 nuclear.
You and I have been in these problems for years.
22 But I think, for instance, in helping, if you can handle or 23 place some or give preferential treatment to the 24 universities to get BCD work so that you can keep these 25 you nger prof essors e= ployed twelve months out of the year i
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e Su 1 rather than nine or ten, that gives them enough to perhaps 2 keep them in there, because if they get paid on a ten-month 3 basis and two months for nothing, the salaries being offered 4 just pull them out.
5 Now, I think the other area I would suggest is 6 tha t we hold student conferences.
And the Department of 7 Energy has given us some support in tha t area.
The industry 8 has given us some support.
A student conference costs us 9 something on the order of about 525-30,000.
We usually get 10 some DOE support for about a third of that, and industry 11 gives us the rest.
12 You are very familiar with that, and you have run 13 some of those at F?nn State.
I think if you can see your 14 vay to support one or two of those that again brings the 15 students into a dif f erent atmosphere.
16 These are regional conferences, and we are not 17 asking you to do it by yourself.
We are say ng, as an 18 employer.
And we get the other employers to work with us to 19 d o this.
20 I think I would just stop right there.
Are there 21 any questions?
22 CHAIP. MAN PALLADING:
I am sure there are a lot of 23 questions and comments.
We also have another Commission 24 mee ting due to start right now.
25 But, Peter, I know you had a couple of questions.
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COMMISSICNER BRADFORD:
Cne of them goes all the 2 vay back to the beginning, and I just held it.
I am not 3sure I remember it very clearly.
Eut you began by extolling 4 the need for a safety goal to improve, and I think you used 5 the phrase like " rationality in the licensing process."
6 And my concern with it is I do no t think you 7 really m eant licensing process.
I gather from what you said 8 af terwards that you meant regulatory process.
I wanted to 9 be sure that I was clear on that, because by and large I 10 think the saf ety goal and the licensing procese are probably 11 not likely to come into mesh with each other for at least 12 some time.
That may be about the last 13 MR. STINSON:
I understand.
I guess I did not say 14 w ha t I meant.
15 COMMISSIGNER BR ADFORD:
Mr. Graham, you talked 16 several times about barriers to standardization and wishing 17 tha t the NRC vere more enthusiastic.
Wnat sorts of NRC 18 actions have impeded standardization?
19 M2. GRAHAM:
I am not in the ligh t-water reactor 20 ind ustry, so I have not been involved in the standardization 21 process, per se.
But simply, the treatment of each -- let 22 me back up one stsge.
23 I think, first of all, the standardization process 24 in the paperwork is an important function.
If you remember, 25 there was a stage where, oh, several years ago ve had l%
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1 standard SARs produced, where one or two of them was, I 2 believe, an A/E-produced standard SAR for the A/E part of 3 it, balance of power.
This is an enormously simplifying 4 activity on the part of an applicant, but that activity did 5not get anywhere.
And in fact, that was sort of dropped.
6 MR. GIAMBUSSO:
I might add also, not just the 7 total plant but sections of certain systems were put in as 8 topical reports, and unfortunately the Staff could not get 9 around to reviewing them.
So it is a matter of 10 reinstituting the system again.
11 But once they were reviewed and they were 12 standardized, perhaps a lot different organizations might 13 have different systems, but at least they were reviewed and 14 the Staff passed judgment on them within the particular 15 boundary that was established for that system and it became 16 the standard system that they would plug in a few other 17 designs.
18 dB. GRAHAM:
Then the'procest,- for example, of 19 regulatory review becones a process of deciding whether tha t 20 particular standard design has been implemented correctly.
21 COMMISSIONER BRADFORD:
And where is that broken 22 down ?
23 MR. GRAHAM:
'4here is it broken down?
24 COMMISSIONER BRADFORD:
It sounded as thcugh what 25 you were describing is a perfectly good idea, but I gathered ALDERSCN REPCRTING COMPANY, INC.
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-1 f rom what you said in some way the NRC had not responded.
2 MR. GRAHAM:
That is right.
Almost immediately 3, af ter that, the NRC review stopped, in the sense that each 4 application was considered a new application and replicate 5 systems were not given credit for prior review.
And so 6 replicate systems were not used, essentially.
Now, I believe the SSUPPS plants are standard 7
8 plants.
9 CHAIRMAN PALLADINO:
It is very difficult to 10 necessarily approve a system by itself, because as TMI has 11 shown more vividly than anything else, there is an 12 interaction among. systems that I think a standardized 13 d esig n, a complete one, is something that cuold be quite 14 vell handled.
One of the problems has been the 15 balance-of-plant portion of tha t design.
16 MR. GRAHAM:
There are lots of things you can 17 standardize in the plant design.
18 CHAIRMAN PALLADING:
Oh, yes.
19 MR. GRAHAMa Paperwork is one of them, for 20 example.
21 CHAIRMAN PALLADINC:
Do you have more?
22 COMMISSICNER AHEARNE:
No.
I just regre' we do 5
23 not have more time.
Certainly, Manning could get more 24 pro vocative.
25 (Laughter.)
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CHAIRMAN PA1 LADING:
You have encouraged me to 2 make a comment.
I was-going to refrain from doing it.
I 3 think there is sometimes an oversimplified review of what it
~
4 takes to design a plant or even to analyze it, and that
- 5. there is not necessarily a technical viewpoint.
And let me 6 tell a story, and this is a true story.
7 I had a student who had gotten a B.S.
in 8 electrical engineering.
He came from a master's in 9 nuclear.
When he got his M.S.,
he came in to tell ne he was to going back to electrical engineering.
I said, " Fine, if 11 that is what you like."
He said, "Oh, I an goir.g back 12 because in electrical engineeriny you do not need the 13 judgment that you do in nuclear engineering."
i 14 I said, "Well, I don't mind your going back to 15 electrical enginee ring, but not for that purpose."
So I 16 engaged him in a discussion of what limits the power that 17 one gets out of an electric generator.
And after some 18 discuss on we got to the question of materials.
And then i 19 asked what influenced materials, and he said " Temperature."
20 I s aid, " Good.
And what influences tempera tura?"
He said, 21 "Well, the amount of power you are going to ge t out. "
I 22 said, "Is that all?"
I said, "How about cooling?"
23 "Oh, yes, yes, cooling would be important."
I 24 said, "W ell, n ow, if both are important, now we have to 25 address what is the best way to cool it, and we have to talk i
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59 1 about what medium we are coing to use for cooling, what 2 pressure we are geing to operate 1t at, whether it is going
~
3 to be one pass or two pass, and how much of the output are 4 we willinq to put to pumping that fluid."
5 And I said, "Oh, by the way, is the power 6 generator uniformly along the axis of the genera tor?"
He 7 says, "Oh, no, no, they are end effects."
8 We went through this, and he sa id, "You know, you 9 make the design of electric generators sound as complicated l
10 a s a nuclea r reactor. "
I said, " And don' t' you ever forget l
11 it.
What's more, nuclear ractors con't rotate."
12 (Laughter.)
13 CHAIRMAN PALLADINO:
Now, the point is tha t 14 sometimes ve f ail to realize th a t there is a trade-off of a 15 lot of parameters when we come to design something.
And it 16 is the same when we analyze it.
You can talk about whether 17 this pump is going to run or that pump is going to run, what 18 powcr it is going to take, what it has with regard to the 19 uncertainty on flow.
And all these things pla y an impo rtan t 20 part in reaching what we call a technical decision.
And 21 sometimes the interplay or the decision is misconstrued to 22 be conservatism.
But there is a difference between 23 conserve.tism introduced by a sa f ety f actor and conserva tism 24 t ha t you have to almost take into account in the balance of 25 oncertainties.
ALCERSCN REPORTING CCMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTCN. D.C. 20024 (202) 554 2345
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I only introduce that because I was concerned that 2 sometimes we do take an oversimplified view of a very i
3 com plica ted ta sk.
And that has to be reflected in what we 4 call the technical decision.
And sometimes it looks, in 5 part, like a political decision or overconservative 6 decision.
I would like to make one last 8 point.
We use standard design criteria both for 9 balance-of-plant equipment, motor control systems, 10 electrical switchgearm, whatever it is.
11 Over the years, if you get into any single 12 utility, a young engineer is given the standard to revamp 13 every year or so.
These books get thicker and thicker i
14 because he f eels morally obligated not to take anything out 15 b ut to keep adding to it.
And this is exactly the process 16 we see going on on a far greater order of magnitude and 17 complexity and wha t it is doing to the manpower and design 18 and operability and maintainability.
19 Every now and then you need to go back and strip 20 i t, bring some comaonsense back to these.
21 CHAIRMAN PALLADINO I very much appreciate your 22 coming and talking to us.
I found it a very fruitful 23 exchange.
I think we can benefit f r o e. more input of'this 24 nature.
And we certainly will try to take advantage of both 25 your offer of help and the comments that you have made to us ALCERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. O C. 20024 (202) 554-2345
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1 today.
Thank you very much.
2 (Whereupon, at 4: 40 p.m.,
the Commission 3 adjourned. )
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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ALDERSON REPC AT:NG CCMPANY, INC, 400 VIRGINIA AVE., S.W, WASHINGTCN. O C. 200 4 (202) 554 2345
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,g NUCLEAR REGULATORY COMMISSION Tais is to certify that the attached ;roceedings before the
,h COttriISS70ti MEETIN';
~^
1:I the :: tatter of:.
Briefing by American Nuclear Scciety on Current Activities m
Date of Proceedi.qg:
September 24, 1981 Docket !! umber :
Flace of Proceeding:
Washington, D. C.
were held as herein appears, and that this is the original transcript thereof for the file of the Coc:::rission.,
Ann Riley Official Reporter (Typed)
("
_ b $11,)
Official Reporter (Signature) rn y