ML20031F596
| ML20031F596 | |
| Person / Time | |
|---|---|
| Issue date: | 10/16/1981 |
| From: | Advisory Committee on Reactor Safeguards, NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8110200188 | |
| Download: ML20031F596 (54) | |
Text
_ _ _.
hW"'d REGT ATORY CC}Od~SSION O
O d
O i
f l
Z: =e.V.=2r Of:
JOINT MEETING OF COMMISSIONERS AND 2
..M/s
\\.
ADVISORY COMMITTEM ON REACTOR SAFEGUASD v)
M' (
' [g
'3
- e.
c @/
'~~
g1".4
~
, [h
S D
g
'/),1 l 5...en N
0-I
- A_2
October 16, 1981 p Am.
1 - 53 A_:
Uashington, D.
C.
d T2f'I.
I olgetE-I i
I ' aucansa
.unomos O
F-Q 400 71.:f 4.?. Ave., 5. *4. W a s d.: g = =,
C.
C.
20C24 i
O
=a " #==== m :)
m-*5 8110200188 811016 PDR 10CFR PT9.7 FDR
____.w
1
(])
1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
AND THE 4
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5
6 JOINT MEETING 7
Nuclear Regulatory Commission Room 1046 8
1717 H Streat, N.W.
Washington, D.C.
9 Friday, October 16, 1981 10 The meeting of the Nuclear Regulatory Commission 11 and the Adviscry Committee on Reactor Safeguards was convened, pursuant,to notice, a t 2 05 p.m.
12 COMMISSION MEMBERS PRESENT:
13 NUNZIO PALLADINO, Chairman of the Commission
(}
JOHN AHEARNE, Commissioner ACRS MEMBERS PRESENT4 15 J. C. MARK, Chairaan J. J. RAY 16 D.
OKRENT H.W. LEWIS 17 J.E. EBERSOLE D.
WARD 18 W.
MATHIS H.
ETHERINGTON 19 M.W.
CARBON M.
BENDER 20 D.W.
MOELLER C.P.
SIESS 21 M. PLESCLT W.
KERR 22 P. SHEWMON R. AXTMANN 23 DESIGNATED FEDERAL EMPLOYEE:
()
24 Raymond F. Fraley 25 ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (262) 554-2345
O DISt-Am Q
%is is an u=cfd'. cia.1 =s:sc=1pe of a. =aeH g of da U:1:ad Sta:as Nuclaar Zagulato:r Ca ssics held on. October 16, 1981 is. da Ccamission's. officas a: 1717 E Scraat, N. W., Washing:sn, D. C.
~ha mae:1=g.as open :n puh1' at:andasca and oe'sa=vation.
This. =ansc=1pc has see been raviawed, cc :sc:ad, or edi:ad, a=d 1: =ay c=n=ais i=ac
-sed me.
The =mnscripe is i=:wded solely for gn=ars.L # #cr. a:1ccal.
purposes.
.L2 prsvid.ed by 10 CZ1 9.103, 1: is noe part of -la fc:=al or '"# r. al record of decisi:n of -la ma::ars discussed.
Expressicus of opd d en in -dis =ansc:17e dc =ce sacassarily reflace fi al. data:=1=a:1ces or baliafs.
No plead 1=g or c har paper =ay be. filad. *.ri:h de Cwsics i= a 7 pr:canding as -la
~
resul: af a: addrassed :o any s:2:.a. man or a.r en: c==:21:ad hara1=, excepe as de. C asion =ay au:ho *'.:a.
O~
1 O
O i
v_--y-y-----ev-m---ww e.=,---c-wm1-
2 1
P P O C E_E D INGS
(" }
2 (2:05 p.m.)
3 MR. MARK 4 Gentlemen, the meeting will come to g%)
g 4 order.
Wo have with us Dr. Palladino, chairman of the 5 Commission, and Dr. Ahearne, member of the Commiss'ca.
And 6 I think possibly they have some questions they would like us 7 to comment on and, to some extent, we have some matters we Swould like to ask them to comment on.
9 I have just spoken to Joe as to whether he feels 10 he is in a position to talk about the prospects of the 11 federal budget for the agency, and he said he wishes he 12 were, and if he were he would talk to us, but as it stands 13 he would rather not.
14 Is that it?
15 CHAIRMAN PALLADIN04 That is a reasonable 16 interpretation.
17 HR. SIESS4 He will only talk about happy things.
18 MR. EARKs I think it is talking about things l
19 about which he knows more.
We nave had a couple of 20 questions raised on which ccaments have perhaps been 21 requested and a couple of items on which some of our members l
22 would like to raise questions.
A~d perhaps you have 23 questions you would like us to receive and either comment on
()
24 or at least be aware of.
25 I believe that is where we will have to start.
i ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202' 'J-2345
, - ~ _ _ _ _ - -. _.....
3 t]
1 One of the items on which people here have felt they would 2 like to make some comments has to do with the siting policy, 3 and I believe Dave Moeller will comment on that.
i3e wrote 4 you a long, and probably inscrutable, letter, and hopefully 5 we will explain that.
6 COMMISSIGNE3 AHEARNE:
I thought since Hal came on 7 the committee that nothing inscrutable was allowed to pass 8 f orwa rd.
9 MR. MARKS That was a Saturday and he was not 10 he re.
11 (Laughter.)
12 MR. MOELLER:
Thank you, Mr. Chairman.
13 We did, of coarse, send you a letter on September O
14 16, and I would like to offer a few comments perhaps 15 clarifying scme of the remarks we have made and offering a 16 little bit of background information.
17 The first point we made was with regard to the 18 supplementary information relative to the proposed rule tha t 19 was giving the implication that minimum siting criteria 20 could be established independently of having an overall 21 saf ety gcal and without the benefit of knowing much abcut I
22 the plant that is going to go on tha t site.
23 And we said we did not agree with that approach.
O 24And we re 111 be11 eve the t un1ess rou knew the eete11e of 25 the plant and the overall safety goal you are hoping to O
1 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
4 pJ 1 achieve, you really cannot asness the adequacy of the site.
2 And we find in reading the Sta f f 's ma terial more 3 in detail that indeed they assumed a standard plant was to 4 he located on the site with certain standard engineered 5 safety features.
So in many senses tney are also 6 acknowledging tnat.
7 So we simply are saying this is a fact of life, 8 and perhaps it should be acknowledged.
9 The second item in our letter pertained to 10 groundwater contamination.
And the Staff was proposing that 11 this be covered in the severe-accident rulemaking, that you 12 handle it over there rather tha-handling it wi th re spec t to 13 siting.
If that is done, what we are saying is the two will 14 have to be done in parallel, which perhaps they are, and 15 that we want to be sure that the protection of groundwater 16 does not f all between the cracks, indeed, if it is to be 17 covered in a sever-accident rulemaking, tha t we make sure 18 tha t tha t is the case.
19 The third item we have was that more attention 20 might be given to the protection of what we call " major 21 societal resources" when you are selecting a site.
In other 22 w ords, w hat are the major societal resources that might be 23 present on tha t site s Agricultural land, past.ure land, O
24orchares.
It might be industrial areas.
It might even be a 25 major city somewhere near the site.
O ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
5
()
1 We need to know what they are and what needs to be 2 done to protect them.
And we believe that that should be
{}
L considered in the siting rulemaking.
And we used as an 4 example the.pecial precautions that the Staff had laid down 5 or proposed relative to riverine and esturine sites for the 6 floating nuclear plants.
And indeed, there they said 7 special precautione, mitigative features, would have to be 8 considered or be availaole in case an accident occurred on 9 an FsP located on such a site.
10 The next item, item 4 in our letter, pertained to 11 the f act that in the proposed site rulemaking there is the 12 statement that, "Although the population density around the 13 site is critical in terms of immediate f atalities," they go O
14 beyond that and say, "In terms of the delayed cancers of 15 latent effects the population density is not important or 16 has very little bearing on the situation."
17 Now, until you dig into that, it is very difficult 18 to understand who they are saying.
And the reason they can 19 say this is, as I understand it, in the application of the 20 CRACK Code
+s a given site to calculate latent cancers, they 21 go out for several thousand miles.
Well, if you go out for 22 several thousand miles and you have micro-rem to mil 11cns of 23 people a t these tremendous distances, of course, the
)
24 collective doce, the person-rem from 500 to 1000 miles out 25 there overwhelms the collective dose f rom zero to 50 miles.
ALDER 5oN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
6 1
Now, if you look zero to 50 miles, the population 2 density has a clear effect on the number of latent cancers, 3 because the number of people getting such-a nd-such a dose O
4 within that 50 miles depends upon the density.
5 So we think that that needs to be cla rified and 6 clearly the rules should state what it means.
Simply,to say 7 that population density has very little impact on delayed 8 cancers without an understanding of how that conclusion was 9 reached could be misleading.
10 MR. OKRENT:
May I offer one more comment in that 11 area ?
I have been wondering whether there are assumptions 12 in the CRACK Code that telate to just how interdiction would 13 be done, how long something would be interdicted, how 14 cleanup would be done that were good f or the purposes of 15 W ASH-1400, because we are coing to have to do something that 16 needs to be thought out as to how real they arc. given 17 various kinds of situations and various kinds of surrounding i
18 regions.
How important is it to get back into the city or 19 to use this particular region of grounds and so forth.
That 20 might in fact not make all sites look quite the same in this 21 regard.
22 I myself am not prejudging that the Staff's 23 conclusion is wrong.
At least, I have not myself seen a Q
24 detailed enough look to know that you can say all sites are 25 the same from the point of view of delayed effects.
O ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON. D.C. 20024 (202) 554-2345
, -.. _.. _. _. ~, _ - - -,. _, _, _ - _ - -.,,. - ~ -. - -. -
..., ~.. -.. - - - - _. - - -. -
7
(])
1 MR. MARK 4 Is this not also true, Dave, with 2 respect to the FNP7 It is certainly true that there are a 3 f ew items that are the major threats for an FNP, but if one 4 vished to look at them, they are all at some order of 5 magnitude lower than the corresponding threats from a site 6 in Kansas or Massachusetts even, and tha t that cught to be 7 kept in perspective, too.
8 It is true that the worst effects are whatever 9 they are, but it is also to be remembered that the FNP has 10 an advantage f rom the point of view of surrounding 11 population that is not apparent in the site in the northeast 12 U,s.
13 MR. MOELLER:
I think that is very true, 14 particularly f rom the standpoint of immedia te f atalities.
15 It would have the benefit of the three-mile dista'nce.
16 MR. MARKS Per gross man-rem.
17 MR. BOELLER Yes, per gross man-rem it would have 18 a benefit.
Our item 5 in the letter addressed the fact that 19 the Staf f proposed five alternative approaches for 20 specifying demographic criteria.
We were glad to see them 21 off ering these alternatives.
22 Our comments there were as follows:
23 First, they seem to be specifying average
'( )
24 densities and not the limits on densities in a particular 25 segment er sector leading out from the plant.
We think that
]
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345 i
8 1 if they do not limit the densities in given sectors, this
{}
2 would permit large cities, relatively large cities, to be 3 close to a plant.
So we think that needs to be considered.
(1s) 4 CHAIRMAN PALLADINO:
I think they have taken that S under advisement, and I think they are now thinking of 6 getting some s0ctor --
7 MR. E0ELLER:
Limits.
8 CHAIRMAN PALLADINO:
-- limits.
9 MR. MOELLER:
Very good.
10 The next item is if the rule permits the use of 11 sites with relatively large population densities -- which 12 some of the information they were proposing seems to be 13 going that way then you do lose the incentives for
()
14 choosing the best site.
And we would like to see that, and 15 I am sure you, too, would like to see that incentive 16 maintained.
17 Then they also looked at meteorology.
And you may 18 know tha t they concluded, at least at one point, that the 19 meteorology of a site had very little impact on making one i
I 20 site better than another.
We asked is this simply an 21 artif act due to the approach they used.
That is, they only 221ooked at existing sites to evaluate the impact of 23 meteorology, and if you only look at existing sites which
(])
24 are supposedly better than the bad sites, then maybe this 25 would prove to be true.
t O
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
o
()
1 Frank Gifford, who is a consultant, of course, to 2 the committee now, concurred with us in this particular 3 comment and said pertsps that needed more evaluation.
4 Another item was this proposed density limit for, 5 I believe, the northeastern United States of 750 people per 6 square mile.
Our question was is that the smallest density 7 limit that reasonably could be applied?
8 The way they reached this number, at least as we 9 understand it, was to i
.t '.y certain population density 10 limits to given regions of the U.S.
Then they said if we 11 applied this as our limit, how much of the land would remain 12 u sa ble a s sites.
And maybe a density limit of such-and-such 13 would rule out 30 percent of the land, another density O
14 limit, a lower number would rule out 50 percent of the land, 15 or something like this.
16 Well, we believe that needs further examination, 17 because I know in listening to them and hearing that a 18 certain limit migh t rule out 10 or 20 percent of the land, 19 that did not, to me, seem to be too bad to lose 10 or 20 20 percent.
I do not know when you reach a point where you are 21 1n trouble by ruling out what percent of the land.
Put we 22 thought it needed more attention.
We also, as I say, 23 believe tha t they need to look at that a little more.
()
24 Our sixth point dealt with the use of past 25 disasters in terms of selecting a safety goal or in terms of ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
10 1
()
determining what risk the public is willing to accept.
2 I believe Dr. Okrent was the one who pointed out 3 that nuclear accidents, of course, carry psychological 4 impacts 'nd you cannot weigh them on a one-to-one basis in 5 compa ring them to other types of disasters.
6 For example, it was pointed out to me that the 7 earthquake in China killed half a million people.
That does 8 not mean that we are willing to accept or that China is 9 wi211no to accept a nuclear accident that kills half a 10 million people.
So you cannot directly compare nuclear and 11 nonnuclear risks.
And if you are comparing them on 12 one-to-one basis, you ought to put in and clearly specify 13 the qualifications that will accompany such an approach.
14 We also found that they used a number of source 15 terms in their evaluations.
They used a range of accidents 16 and then they combined these accidents ranging from very 17 severe to not so severe.
And they looked at the probability 18 of occurrence of each of these accidents, and then they 19 combined -- they used a composite accident for their 20 calculations of the la tent cancers, immediate fatalities and 21 then to ultimately come up with an acceptable population 22 density.
23 We think that this needs justification.
It needs
()
24 to be explained.
And we also think that they should clearly 25 point out that when they are doing t,h i s, th ey are assuming ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 23 5
11
()
1 some type of a plant, because they come up with an accident 2 and with a probability.
/'N 3
And therefore once again siting and the plant are V
4 not independent.
They are proving it to us through the very 5 process they are using to make their calculations.
So we 6 a re sim ply calling for clearer explanations of how they are 7 going about each of their assessments.
8 Lastly, we looked at the evacuation model that 9 they blended into the CRACK Code in order to calculate their 10 laten t effects and so forth.
We were not convinced they 11 were using the best models, 12 We also did not see them looking at sheltering and 13 other types of protective actions.
We believe -- and this 14 is what Dr. Okrent was implying to -- you need to look at a 15 whole sequence of protective actions implemented at va rious 16 times af ter the accident occurs so that you get a clear 17 indication of the key parameters that are affecting the 18 detriment that results.
19 Lastly, on the comparison of nonnuclear and 20 nuclear risks and nonnuclear and nuclear accidents, we think 21 t ha t they should spell out the fact that we have pretty good 22 data on nonnuclear accidents.
We can tell you about 23 automobile accidents or aircraf t crashes and so forth.
We
()
24 cannot tell you about nuclear accidents, and the statistics 25 there are poor -- happily so.
And that should be clearly O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
12 1 specified.
{]Fy 2
I think that, in summary, represents some of the 3 background to our comments.
If you have any questions, I or 4 other members of the committee will be pleased to try to 5 answer them.
6 MR. MARK:
I would like to add that reliance on or 7 attaching quantitative meaning to the CBACK Code is a 8 mistake.
This is an attempt to calculate something.
It 9 correlates some possible behavior, obstruction of the 10 atmosphere and some assumed effect.
11 And that effect -- which you I am sure know a 12 great deal better than I is one which there are attempts to 13 move on through the Biological Effects of Ionizing Radiation 14 Committee of the National Academy -- is in fact not known.
15 The levels that are very frequently --
16 MR. MOELLER:
That relates back to this thing of 17 calculating latent cancers out to several thousand miles.
18 In the BEIR-III report, for example, they made the statement 19 t h a t, "We are unable to observe any health effects from 20 total doses to a population of one rem."
And they also said 21 they are unable to estimate or they have never observed any l
22111 effects from dose rates of 100 millirem a year.
23 Now, that being true, that might be used as a
()
24 cutoff point for the distance to which you do your l
25 calculation.
O 1
l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
13
(])
1 MR. MARK In the same area of discourse there is 2 the thing frequently said, " Gene tic ef f ects must be very 3
{)
frightenino.
And indeed, they a re very f rightening from the 4 point of just using the word.
But there is absolutely no 5 experimental evidence cf genetic effects on humans which has 6 yet been observed anywhere."
7 MR. SHEWMON:
At that level, do you mean?
8 MR. MARKS At any level.
We have had people die 9 from radiation.
We have not had any examples, have we, of 10 genetic ef fects?
Not in Japan, anyway.
11 MR. MOELLER:
Our basic data are the Japanese 12 data.
And of the 100,000 or more people who were studied, 13 wha t, for 35 years, and all of their offspring, they bnve O
14 y et to date observe a single excess genetic defect as a 15 result of the radiation exposure these people received.
16 MR. MARK:
It is worth mentioning or keeping in 17 mind tha t this is said over and over again, and the evidence 18 f or it is distinctly hypothetical.
We know there must be 19 one, but we are not quite sure where it applies.
20 CHAIRMAN PALLADINO:
Dade, I thank you very much 21 for your comments on the siting criteria.
22 Let me say, since I did not make any opening 23 remarks, I am very pleased to be with you once again.
It
()
24 hardly seems possible two months have ela psed since I is 25 down here last.
But I can assure you they have been a O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554-2345
14
(]
1 well-filled two months, at least from my standpoint, and I 2 know from yours, too.
3 I very much appreciate your comments on the citing 4 criteria.
Some of them dovetail opinions which I had when I 5 c, -
down here.
I have asked EDO and the Staff to determine 6 whether or not tthere are compelling reasons fcr having an 7 early si tin g rule issued at this time.
And that response I 8 expect to come in the form of a recommendation to the 9 Commission.
10 I have spoken on a couple of occasions about my 11 own f eeling that before we issue a siting rule, unless there 12 is a compelling reason to do it now, we ought to try to 13 complete our safety goal study, which I am hopef ul still can 14 be done before the end of the year.
But I do not want to 15 promise that.
16 Then I would hope to see some further 17 clarification of the source term and see these matters used 18 then for the siting rule.
19 I also have an innate feeling ths t if we try to 20 decouple the siting rule from the engineered safeguar.ds, we 21 may discourage innovation.
And I do not think we are far 22 enough along that we ought to bring that about.
23 Your letter pointed out a number of items that I
()
24 had not considered, and I appreciate the insight that this 25 memo adds on those particular points.
And I am sure that O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
15
()
1 the Staf f will be taking cognirance of it.
2 I was interested whether or not you had some more 3 specific thoughts on the possible consideration of major 4 societal resources or how they might be approached.
If you 5 have, it might be very helpful to broaden our thinking on 6 that point.
7 MR. MOELLER:
I believe we could perhaps provide 8 you something later on that.
9 If Dr. Okrent has any remarks, we could call on to him now, because he has been the major thrust behind our 11 thinking on this particular subject.
12 HR. OKRENT:
Later would be better than now, so 13 f ar as i av concerned.
O 14 MR. MARK If that is what we can be useful about 15 on this point, you did inquire if we had any formulated 16 opinions on this marvelous new question of pressure vessel 17 thermal shock.
And I think that is one thing you would like 18 to have us say what we can about.
And I suppose Paul 19 Shevmon should start that.
20 ER. SHEWMONs It seems to me there are at least 21 two questions with regard to short-term.
I guess the 22 f eeling is it is a serious problem but not a crisis.
So 23 with regard to the rate at which things are happening now
()
24 with Staff and the vendors, the feeling is the vessels are 25 young enough and the conservatisms, though not quantified as O
ALDERSoN REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
16
{}
1well as they will be one year from now, are such that we 2 feel that the rate a t which things are going or the way 3 things are going is appropriately conservative or is an 4 appropriate procedure.
5 MR. MOELLER:
We are having difficulty hearing.
6 MR. SHEWMONs Okay.
Thank you.
7 So we would not recommend a short-term action 8 different from what is now coing on.
9 With regard to the intermediate term, we have set 10 u p a subcommittee which will follow the work of the vendors 11 a t the Staff and raise other questions the ACRS subcommittee 12 is formed to do.
13 I think the main aims will be examining the ways 14 in which transients can be reduced.
And this I think the 15 Staff is working on, and I am sure the vendors are.
16 A different concern has to do with 17 overpreesurization.
There has been a sense tha t is the 18 novel aspect of this, the idea that we could indeed mess 19 around f or a quarter-hour, a half-hour or longer, and let 20 the thing cool down, and then overpressurize it.
21 And the degree to which you can rely on an 22 operator understanding the sitt ation af ter a quarter of an 23 hour2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> and taking the right actian to avoid pressurization or
()
24 repressurization or tha t you ;an build into a system ways to 25 exclude this with a high degree of certainty, I think, is O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
17
()
1 one of the things we will look hard at.
2 Finally, we would like to look closely a t the 3 conservatisr.s that are in here.
These calcuations are 4 always done in bounding efforts, and the heat transfer is 5 certainly one of there on which there are honest differences 6 of opinion.
And the vessel toughness on the outside as 7 opposed to the inside is another.
8 But we will have a group of consultants, and we 9 will look hard at these.
I think that is a fair summary to 10 start with, at least, of what we have done.
11 ER. MARK:
Mike, would you like to add to that?
12 MR. BENDER:
Not very much, except to emphasize 13 the problem may be different for different reactor systems.
O 14 It is not necessarily so that every BWR has the same 15 problem.
And obviously, the site because of the history of 16 the vessel itself will have some variation to it.
If there 17 is a problem, it is likely to be only with the fuel vessel 18 a s the S ta f f report has noted.
19 I suspect the distance is quite short for the 20 short term.
There are a few vessels said to have high 21 copper content.
Some have high copper content but not much 22 radiation exposure or comparatively not much.
23 I think if we were going to put some emphasis on
()
24 urgency and recognizing that the analysis of the problem may 25 tak e a while, I would be putting my emphasis on being sure O
ALDERSON REPORTING COMPANY,INC, 400 VlftGINIA AVE, S.W., WA39:NGTON, C: O. 20024 (202) 554 2345
18
()
1 that the operational arrangements for the few critical 2 vessels are really paid closer attention to than the bulk of 3 the vessels that are of concern.
{)
4 We could, in the short term, make sure that the 5 training for those particular vessels that are concerned is 6 brought up to snuff and we are not relying on just a 7 generalized kind of understanding, but all the operators 8 know something.
It would probably be a kind of precaution 9 the regulatory staff could do without much burden.
10 I agree with Dr. Shewmon -- and I have said this 11 before -- there are a lot of consultants' estimates in this 12 business, and it takes a while to understand them.
in 13 setting up the subcommittee we have drawn upon a few O
14 consulta nts, some of whom are sitting over there.
Dr. Kautz 15 and Dr. Zudans are here.
And we plan to ha ve Dr. Irwin and 16 some others as well as some of the regulatory staff, 17 regulato ry staff's research people being involved in this.
18 We would like to make sure the channels are kept 19 o pe n.
It is a problem to get information if we always have l
20 to go through the regulatory staff before we can directly l
l 21 make contact between our consultants and those doing 22 research.
Obviously, we are not going to report anything l
23 through formal channels without the regulatory staff knowing
()
24 wha t we are doing.
As a matter of fact, we hope to have 25 subcommittee meetings at which they will be present, so we l
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 e--**#r r
y--- + -
w-w-,. - y,,,,g,.
y.
_ ~,,
19
()
1 can have an exchange of views.
2 I think those are my only comments.
(]}
3 MR. MARKS Are there other comments members of the 4 committee would like to have made available here?
5 I think the general tenor of this is what the 6 Staff is doing gives us the feeling of being at least 7 reasonable.
Whether fully adequate is slightly a different 8 matter.
They are doing wha t they can, and there is no need 9 to declare an emergency this month.
10 CHAIRMAN PALLADINO:
There are a couple of 11 questions I might raise.
One, the last point that Mike 12 raised.
Are you having difficulty getting theinformation 13 tha t you feel would be beneficial to. you 4.n civing advice to b'
14 the Commission?
15 MR. BENDER:
I will not say " difficulty," Joe.
I 16 think that is wrong.
You want to be sure that protocol is 17 not violated.
Whenever a contractor is doing work for a 18 contracting officer, he is always concerned about whether 19 the contracting of ficer wants him to give information.
We 20 would like to be sure those barriers are eliminated so the 21 flow of information in terms of technology is easy.
22 CHAIEMAN PALLADINO:
There are times when I could 23 see the protocol, as you described it, being necessary.
But 24 I would hope it does not become prohibitive to the extent 25 tha t it interferes with your givin? this good advice.
And O
ALCERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. I'V24 (202) 554-2345
20 O
' merde rou =1ont we n t to neve nr-rre1er te1x to et 1eest =r 2 executive assistant to see what the problems are and what 3 might be done.
4 MR. BENDER:
We will certainly make a point of 5 doing that.
I guess Ray is here somewhere.
6 CHAIRMAN PALLADINO:
You mentioned the problem was 7 serious and not a crisis.
And while I understand the words, 8 I was wondering if you could give a little better definition 9 of what you mean and maybe to set forth what I was looking 10 for is how much time do you think we have before we should 11 be considering actions on the plants most in jeopardy of 12 f acing this problem?
13 MR. SHEWMON:
Let me not answer that question in a 0
14 dif ferent way.
15
( Lau gh t e r. )
16 There is a memo here that I circulated, and it 17 starts off with saying, "A proh' bition against cold 18 pressurization of the reactor pressure vessel has been part 19 of the technical specifications of every PWR licensed in the 20 U. S.
Thus, the recent discovery that one can conceive of 21 coolant and pressuriza tion transients which may rupture the 22 RPV are a restatement of a known fact."
23 The reason I do not think you can answer that is 24 if you run through a transient which is the same as going to 25 full pressure when the reactor vessel is cooled on the 3J ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
-.,. - - _. -, - - _ _ _, _ - _ ~, _ _ _ - ~ _.
21
()
1 inside -- that is, if you get to an extreme enough transient 2 -- you can crack a lot of different vessels.
3
(])
So any discussion of this has to start coming back 4 to, okay, so the operator will not do anything for 15 1
5 minutes, can we rely on him to cool things for half an hour 6 and then repressurize it or that the reactor control system 7 vill not go awry or do something like tha t?
And tha t gets 8 to be an unanswerable question.
9 I cannot quantify things, but the feeling of the 10 people I ha';e talked to is there is enough conservatisms 11 there so that we feel genuinely optimistic, or generally 12 optimistic, to keep on going.
And the reason I cannot give 13 you and I do not think anyone else can give you an answer on 14 how long is there is this hazy reason of how extreme a 15 transient do you want to assume?
16 Of the transients we have had so far then, there 17 certainly is a matter of years and it is not clear, even 18 when we say "vears" there, that the calculations still are 19 not very conservative and tha t they would be in error, that 20 the crack would not come yet then.
21 CHAIRMAN PALLADINO:
The reason I press this, I 22 know the dif ficulty of trying to make any estimate, but 23 there are various pressures that come on the Commission to
)
24 do things when people, including members of Congress, feel 25 there is a very specific probles.
So any advice that can be ALDERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
22
()
1 given, saying we have a certain degree of confidence tha t we 2 a re right, even on the oldest plants, for a period of time 3 would be helpf ul, because that coupled also with wanting to 4 make sure that we are taking the actions we should be taking 5 to try to better define the problem or cope with it or 6 resolve it, let us see what courses of actions we have.
7 MR. MARKS I think we are probably not at all in 8 the position of being able to discuss the last question, 9 resolving.
10 CHAIRMAN PAllADINO Try to know what " resolution" 11 really means.
12 HR. MARKS So I think we are in the position of 13 saying something to the effect -- and I vill ask Carl if he O
14 himself could say this -- if we have transients of the sort 15 we have had, then we should not expect serious trouble.
16 MR. SHEWMON:
That is true.
17 MR. MARKS Anywhere for some time.
If we can 18 avoid those transients, we can do things, or at least the 19 Staff can do things, which will reduce the likelihood of 20 those occurring again.
21 MR. BENDER:
I do not think I would want to go 22 quite that far.
The two or three vessels -- I think it is 23 probably about that number -- that have a combination of
()
24 high copper and their level of effluents, unless you have 25 looked a t he system arrangement enough -- and we have not A
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WA IHINGTON, D.C. 20024 (202) 554-2345
23
()
1 -- I do not think we are able to say for certain that they 2 cannot be in trouble.
3 I think my intuition says they are not in
{}
4 trouble.
And while I would not say it is a crisis, I would 5 say it is sufficiently urgent to make it worthwhile to look 6 at those particular systems enough to make sure you 7 understand them.
That could be urgent and not a crisis.
8 And it would not hurt anything to do it.
9 MR. HARK:
However, would you agree, Mike, that if to operational procedures can be put in place c-and I am not 11 sure we know exactly how that can be done -- to avoid the i
12 worst transients or transients worse than we have seen, then 13 there is nothing about this situa tior, which one would expect O
14 to lead to any big problem within the next modest number of 15 years?
16 HR. BENDER:
I think given tha t the procedures are l
17 in order, there is no problem at all.
18 COMMISSIONER AHEARNE May I ask a question?
19 ER. MARK:
(Nods affirmatively.)
20 COMMISSIONER AHEARNE:
Mike, you say for these few 21 vessels, we have to look at them more in detail.
From what l
22 you know of what the Staff is doing in looking at specific l
l 23 plants, is that the approach that you believe they ought to
(
24 be taking?
Are there other things they are not doing you 1
25 believe they should be doing?
O ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON. 0,C. 20024 (202) 554 2345
24
()
1 MR. BENDER:
I think they are doing all of it in 2 some form.
If I were going to judge it at all, I would say 3 tha t there is not enough integration of that kind of
('}
4 investigation.
Heat transfer analysis is being done in one 5 places the vessel evaluation is being done somewhere 6 itself.
The Staff itself is negoti,ating with the users and 7 owners of the vessels to see what those transients are.
8 And that is a pretty diffuse kind of arrangement.
4 9 And it might be valuable to be able to couple that a little 10 higher by assioning some one or twc individuals who can 11 concentrate on it until you are sure you have all the pieces 12 in place.
13 CHAIRMAN PALLADINO:
I think another problem that O
14 arises in looking at the various scenarios that might bring 15 about pressurized thermal shock, there are pieces of 16 analysis being taken that were made for one plant and then 17 another piece made f or another plant, another piece made for 18 another plant, and implied in those are a number of 19 assumptions that vary from plant to plant.
And then they 20 are applied to another plant where the assumptions are not 21 even -- are nowhere valid.
22 MR. BENDER:
I think you are stating the problem 23 exactly ri g h t.
(
24 CHAIRMAN PALLADINO:
So I agree with you we need i
25 some integration on that point.
i ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345 t_
25 m
1 But getting back toiDr. Ahearne's question, do you 2 f eel tha t the committee has looked at what we are doing
(])
3 closely enough so th a t you feel reasonably confident ve are 4 doing the right thing?
Or maybe to put it the other way, I 5 would be very happy if you would take the time to look at 6 what we are doing closely enouch so that the committee can 7 develop some comment.
8 MR. BENDER:
Just to paraphrase what Paul Shewton 9 said, we have organized the subcommittee because we think it 10 will take some time to do it.
I would guess that to get an 11 answer that would be usable will take on the order of a 12 year, at least six months, but just because it takes that 13 long to get people to do things and have some discussions.
O 14 My impression of the Staff's effort is that they 15 have a reasonably good understanding of the problem,.but 16 they do not yet have a complete plan -- and I do not think 17 they profess to have a complete plan -- f or resolving this.
18 I think they have just begun to organize their ef fort.
I 19 think we do not see differently from them that organization 201s needed.
21 MR. SHEWMON:
Let me bring one other point in.
22 A nd that is, to take a variant of what you just said as an 23 exa mple, the systems that have had to meet the
(
24 most-dif ficult-to-predict transients --
25 MR. KERRs Dr. Shewmon, I know what you are saying OV ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
26
(])
1 is important.
2 MR. SHEWMON I ha ve got it on.
I could stick it 3 in my mouth if that would help.
4 MR. KERRa You might try swallowing it.
5 CHAIRMAN PALLADINOs I see nothing has changed.
6 (Laughter.)
~
7 At least insofar as the comradery on the 8 committee.
9 MR. SHEWMON:
Let me try to get organized again.
10 The kinds of transients which have been most 11 dif ficult to predict and, in a sense, the scariest, have 12 been those in which the control system has gotten befuddled 13 or it and the operator together got befuddled, and the O
14 system went through long transients that were difficult to 15 follow or even know what was going on.
16 On the other hand, the vessels which have the 171argest degree of embrittlement come with those plants that 18 have a steam generator, you know, the CE and Westinghouse, 19 not a once-through steam generator.
And these things have a 20 lot more steam wa ter to boil of f in the steam generator.
21 The transients are generally slower, and they do not seem to 22 be near as prone to that sort of situation.
23 So I think that we have a coincidence of the
()
24 things which cause concern is nice; I mean this one is bad 25 in that regard, and other kinds of plants are bad in the ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
27
()
1 oth, s,
but you do not have the combination of the worst of 2 both worlds in any class of plant.
3 CHAIRMAN PALLADINO:
I wonder if I might ask 4 another question.
5 NR. MARK This is a question you raised, and we 6 vant to be as helpf ul as we can.
7 CHAIRMAN PALLADINO:
A mention was made of one 8 suggestion that we should undertake, and th a t is the 9 training of the operators for the plants that have a problem 10 most pressing, to make sure tha t they are adequa tely trained 11 to cope with transients that might lead to pressurized 12 thermal shock.
13 Are there any othe.r things that come to mind that 14 might be useful in our deliberations?
15 HR. BENDER:
I am not sure.
I do not think we are 16 absolutely certain everything is known about the fluence 17 that should be known.
And so you could try to refine the 18 computations for '. hose specific vessels that are most 19 vulnerable.
20 I think the same point could be made about the 21 chemistry for the most volume in each vessel.
I think the 22 materials history of those vessels is probably well known, 23 but I am not certain it is known.
And the little bit of
()
24 dialogue I have had with various people suggests it needs 25 more definition than we presently have.
ALDERNN REPORTING COMPANY,INC, 400 VIRGW:A AVE., S.W., WA% NGToN. D.C. 20024 (202) 554 2345
28 O
so 1 e=14 ter to set ta t xiae
- 1aror==t1 a 2 together and try to get something Cotumented that says here 3 is what we know about these vessels that are really 4 critical, rather than to just have something that says these 5 are the tem pera tures that a re reported.
6 I would try to get something that backs up those 7 temperatures better than we presently have.
With that, I 8 think you could know better than I could tell you how 9 sig..ificant the problem really is for the older vessels.
10 MR. MARK It occurs to me, sir, that with respect 11 to these things which are thought to be the ones that are 12 most subject to concern, we should not simultaneously ask 13 that we train the operators and that we do not rely on any n
v 14 oDera tor action.
15 CHAIRMAN PALLADINO:
Let me make sure I did not 16 get conf used on the double nega tives.
17 (Laughter.)
18 I think it is because un til we know more about 19 what we want to know, we want to be sure we can get operator i
20 action if we need it, that we are saying le t us try to make 21 the best of it.
22 MR. SHEWMON:
One of the statements that I heard i
23 in the Staf f presentation was they were not sure in the long lO 24 run they could rely on operator action and they would like l
25 to get out some other way.
And I guess our feeling is I l
i ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W, WASHINGTON, D.C. 20024 (202) 554 2345
29 O
' taiax th t et er the de=1= ror aet ne 1a -
2 CHAIRMAN PALLADINO:
It would be nice if we did 3 not need operator action but 4
MR. MARK:
In that case, we would not need 5 operators and we could forget all of this malarkey about 6 training.
7 CHAIRMAN PALLADIN0s That is what I was getting 8 at.
I was saying it would be nice if we did not need 9 operator action, but when the operator can contribute U.
10 control in this situation, I think we should take advantage 11 of it.
12 MR. MARK:
I think we should not merely take 13 advantage of it; I think we should even be willing to rely O
14 upon it.
~
15 MR. BENDER:
I agree with that for a few vessels 16 in a few plants where we can concentrate on the training.
17 It is not like having to deal with a few hundred of them l
18 where the uncertainty evolves from the f act that there are 19 so many combinations of circumstances.
20 CHAIRMAN PALLADINO:
When I fly, I take comfort at i
21 the fact that there is a pilot up front that can take i
22 evasive action.
23 (Laughter.)
24 Well, I do not know if I have much more to ask 25 except to indicate that I share your concern.
As a matter l
ALDERSON REPORTING COMPANY,INC, 400 VIRGINlA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
30
({}
1of fact, I. view this as a very serious probl"3 we need to 2 come to grips with.
And the remarks I get indicate we have 3a time f rame that should be long enough for us to study the 4 situation.
5 But I will be looking with great interest, as I 6 know all of the other Commissioners will be, to the results 7 of your subcommittee 's deliberations.
And any advice that 8 you have for us, please do not hesitate to send us as soon 9 as you are confident that it represents your best thinking.
I 10 HR. OKRENT:
I would like to support what Mr.
11 Bender urged; namely, that for a few or several, as the case l
12 m a y be, vessels that are the most likely to be troublesome 13 as one understands the situation now, one needs to put a lot 14 of resources into the matter, certainly those he mentioned 15 and also the identification of transients that, if they 16 occurred, would be troublesome.
17 We do not want to have to learn about the bad 18 transient because it occurs.
19 MR. MARK:
I do not know that those cessels are 20 the eigh t which happen to be called to public attention, 21 though.
22 CHAIRMAN PALLADINO:
Representative.
23 MR. MARKS I thought they were somewhat confused
()
24 b y saying we will take two of each vendor.
25 CHAIRMAN PALLADINO:
I would rather check before I O
AtDERSON REPORTING COMPANY,INC, 400 Vl3GINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
31 1 comment.
2 MR. MARKS It may be some are more subject to 3 transients and have more attention, some of them are more 4' irradiated and have more copper and need more attention.
5But I believe tha t the selection of the eight was a little 6 bit watered down by saying they must have two BCWs, two CEs, 7 two Westinghouses, and two GEs.
8 COMMISSIONER AHEARNE:
No GEs.
9 MR. PLESSET:
No GEs.
10 MR. MARKS Anyway, they were a 11ttle bit confused 11 by that parameter, whe rear I think the selections of the 12 ones which most need the kind of attention that Mike was 13 talking about may not be just that same list.
14 ER. BENDER:
That is almost certain to be the 15 case, and it is a question of which are most vu3nerab1e to 16 certain transients as we11 as those which are most 17 vulnerable because they have the highest fluence level.
It 18 is not one as opposed to the other.
I think we just have to 1
19 take a look and see.
20 CHAIRMAN PALLADINO:
But in connection with what 21 D av e was saying, it is my understanding that some of th e 22 studies made to date are disclosing there are other 23 scenarios that 1ead to incidents of pressurized thermal O
24 shock end 1eed to verhavs worse situations thea the Rencht 25 Seco situation.
ALDERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
- - - - -.. - _ -. _. =
32 1
ER. OKRENT:
I would assume when you look you 2 could find them.
3 MR. BENDER:
I do not know that we have seen s
4 anything like that.
I think people can postulate other 5 things.
And Dave is right that there is no excuse for not 6 doing a good job of postulating.
But I would still say that 7 Rancho Seco is as severe as anything I have been able to 8 learn about.
9 MR. MARK:
I balieve that is what we have on this 10 here.
I guess you will be awa re, from what has been said, 11 that the committee really regards it as a problem which 12 needs any attention one can give it.
13 There are a couple of ether items which may not 14 take terribly long.
15 Mike, would you be willing to say a word about 16 this question as to whether the enunciation of things in the 17 form of regulations is the best way to handle technical 18 issues ?
19 MR. BENDER:
This is a favorite topic of mine.
I 20 do not know that I represent the entire committee's 21 position, but at least I am sure I have some allies.
22 We had a discussion last month with the regulator; 23 staff and the director -- or the counsel to the staff, I O
24 guess -- concerning just how nuch detail belongs in 25 regulations.
We are beginning to see more and more mU ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
33
(])
1 rulemaking kinds of things which draw a great deal of 2 technological substance into some kind of a documentary form 3 that can be looked at by the reriew boards.
It can also be 4 challenged by intervenors.
And if it is in a regulation, it 5 probably should be challenged if appropriate.
6 But I think just a history of doing things in a 7 complicated technology like this tells you that it will be 8 almost impossible to write words that are sufficiently clear 9 to make them really usable in some kind of a legal framework 10 of the sort that is used for hearings.
So the concern that 11 I have developed has to do with how f ar to go.
12 And this last discussion we had had to do with the 13 qualification of saf ety-related equipment.
I think we all O
14 agree that we have to qualify the equipment, but I have my 15 doubts about whether the document that is being prepared l
16 will be very helpf ul in making certain that the 17 qualifications are properly developed.
18 It is only an illustra tion.
But it is a current 19 one.
I would prefer to discourage doing too much of that 20 sort of thing.
There are lots of other ways.
The 21 regulato ry guides are not bad.
Even though we gripe about 22 them sometimes, they are a better mechanism f or laying 23 things out.
()
24 And as I understand it, there is an attempt to go 25 more for rulemaking and away from regulatory guides.
And l
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WAShlNGTON. D.C. 20024 (202) 554-2345
34
(])
that is a more inflexible kind of situation, and I would 1
2 want to discourage the Commission from doing too much of 3 tha t sort of thing.
4 I think that is about all I can say.
5 CHAIRMAN PALLADINO:
How widely is your view -
6 shared among the other committee members?
7 MR. BENDER:
I do not want to speak for other 8 committee members.
9 MR. SIESS:
If we are talking about getting 10 proscrip tive requirements into the re g ula tion s, I share 11 that.
I would rather see regulations and performance 12 criteria keep the proscriptive stuff in a reg guide or a 13 review plan where it is more easily changed as a result of O
14 changing technical perceptions.
15 I think Appendix R is an example, where the
,16 technical position was incorporated into the rules.
There 17 are very proscriptive requirements on fire protection.
We 18 objected to it at the time, and I think it is a example.
19 CHAIRMAN PALLADINO:
It is what?
20 MR. SIESS:
A good example.
I am not sure where
(
21 Appendix K falls in this.
I do not know whether appendices 22 are central pacts of the rules.
But certainly that is 23 proscrip tive, and changing it is quite difficult.
Maybe it
(
(j 24 should not be changed, but that is beside the point.
25 MR. MARK:
We surely have examples in the seismic l
l l
A.I)ERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
~...
35
(}
1 business of stuff which was put on " stone tablets" which 2 ought to have been rethought several times over.
And if it 3 gets into a form where it cannot easily be modified and 4 reinterpreted, it is in the wrong place.
5 CHAIRMAN PALLADINO Well, just as your committee 6 may have differing views on this, you will find that there 7 a re diff erent views among the Commissioners and even among 8 staf f people.
If you reach any consensus on this, your 9 advice might be quite helpful.
10 As a matter of fact, I am hoping that we can have 11 a f uture meeting where we can have more of the Commissioners 12 present.
And I think tha t when we schedule our next 13 meeting, I would like to make sure that we schedule it 14 insof ar as possible to get a better presentation.
15 But some of these thoughts, even though they do 16 not come out of a consensus memo or letter, they might be 17 worth talking about with the other Commissioners present.
18 I share a number of your views, and I think we 19 were successful in a couple of recent actions in getting 20 some of the specificity out of the rules and putting it in 21 other forms.
22 MR. MARK Is another example the ANS 1941 curve 23 -- or '51 ANS decay heat curve plus 20 percent, which has
()
24 been known f or at least two decades not to relate to any 25 physical f act.
And there it is in rules.
O ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
36 1
(}
MR. SHEWMON:
One vehicle for this, if the 2 Commission members at that time would be willing to comment, 3 would be the reaction to the survey that I guess the senior 4 staff did in some utilities and got back a f air variety of 5 things, some of which might well have been predictable, but 6 many of which are somewhat consistent with what Mike is 7 bringing out.
8 CHAIRMAN PALLADINO:
Are you talking about the 9 Orders and Bulletins?
10 ER. SHEWMONa (Nods af firmatively.)
11 MR. MARKS We wanted to raise that question.
12 MR. BENDERS If I could just add a postscript, we 13 do not know how much trouble will be created.
We have a lot n'
x-14 of the specificity in the reg guides now.
And the thing I 15 am concerned about is once it gets into a rule, the 16 opportunity to negotiate for a specific circumstance is 17 almost ruled out.
It takes so long to get an exception, it 18 takes so much discussion with lawyers before you can even 19 enter into the regulatory hearing, that the cumbersomoness 20 of negotiating gets in the way.
21 For example, the reg guide spectrum on 22 earthquakes, I think Carson cited, is a very good one.
Ws 23 have got it there.
We know it is a fairly arbitrary
(])
24 bounding of things.
And it is used as a point of 25 ref erence.
But if it became la w and we had to use it to the 7.)
ALDERSON REPORTING COMPANY,INC, 400 MAGINIA AVE., S.W., WASHINGTON, D.C. 20024 (207) 554-2345
37 O
1 exclusion of all other bases, I am sure we would get into a 2 lot of trouble.
Sometimes it does not even address the 3 right problem.
4 CHAIRMAN PALLADINO:
I appreciate your comments on 5 this.
And as I say, if you have any consensus that you 6 would like to transmit to the Commission, it might be quite 7 useful.
8 MR. MARK Let us go on then.
9 Bill, would you say a word on the compaction of 10 bulletins, orders, and requests?
11 MR. KERRs My comment has to do with execution.
12 We recognize concerns have arisen and are addressed by the 13 Staff in terms of bulletins, orders, rules, and regulations, O
14 a nd tha t the intent is thereby to make reactors safer.
But 15 in order for this to occur, they have to be carried out in 16 some f ashion.
17 It is a continuing concern, I think, on the part 18 of many of us that the groups that propound these do it 19 without total awareness of the fact tha t th ese are being 20 laid on to a very large population of other bulletins, 21 rules, and orders.
They are being scheduled and followed 22 without any overall coordination which attempts to determine 23 priority in the situation in which resources are finite and D) 24 in which, theref ore, the Licensee ma y be forced into doing
(
25 not a very good job on some things which should receive more
- O l
l l
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
u i
1 38
()
1 resources and attention.
2 It is not clear to us that any such scheduling or J coordina ting activity exists within the Commission.
It may, 4 but in a number of cases when we have tried to find sources, 5 I have been unable to.
It also is not altogether clear tha t 6 there is some group, body, or mechanism which, even after a 7 rule has been considered to be quite important by a 8 division, group, or whatever, looks at this and says is this 9 really worth the effort in the present context, will it take 10 the resources and time that sight better be spent on 11 something else?
12 It is a tough call to make, but in a situation in 13 which the number of activities to be carried out are large O'
14 and the resources and time are finite, it seems to me that 15 question ought to be raised.
16 The scheduling especially seems to us in some 17 cases to be arbitrary.
And by " arbitrary," I do not 18 necessarily mean bad.
It just seems in some cases to have 19 no relationship to what is being asked.
It takes time to 20 make studies, to order things, to get them installed, to get 21 them tested and in to operation.
22 And we repeatedly see schedules that simply do not 23 looh realistic on that basis.
A rather bizzare example, to
()
24 m e, is one recent situation in which --
25 MR. SHEWMON:
Do you want to try another mike?
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2245
39 1 That one has gone dead.
2 (Laughter.)
3 MR. KERR4
-- in which we had suggestion on the 4 part of the Staff that a device, a system be procured and 5 installed before it had been approved by th e S ta f f a nd 6 before there had been any significant testing of the device 7 or system.
8 Recognizing this was considered to be a panacea or 9 at least a partial cure for an important problem, 10 nevertheless, I have reservations about installing and 11 beginning to use something that does not have Staff approval 12 and does not have any significant testing.
13 I do think that example is unusual, but it is 14 illustra tive of the concerns we have.
I do not think this 15 is a ne w conce rn.
And I doubt if it is news to you that we 16 have it.
But it is important enough that we want to 17 emphasize it.
18 CHAIRMAN PALLADINO:
Your comments on this point 19 are rather timely.
As a ma tter of f act, it is one of the i
l i
20 items I have been concerned about af ter coming to the l
21 Commission.
l 22 This morning I approved a press release that I
23 addresses this point.
The press release reflects action by l
,lO 24the commission.h1ch hos been underway for at least seven or 25 eight weeks.
The aim is to allow the agency to focus its O
ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
40 O
'prioritie end those or the auc1eer 1adu ter oa reauire eate 2 that have the greatest safety significance.
3 And we are establishing the Generic Requirements 4 Reveiv Committee that has the responsibility to review and 5 recommend to the EDO approval or disapproval of requirements 6 to be imposed by the NRC Staff on one or more classes of 7 reactors.
8 The committee will be chaired by a new deputy 9 executivs director for regional operations and generic 10 requirements.
Victor Ste11c, currently director of NRC's 11 Office of Inspection and Enforcement, will fill this new 12 pos t.
His former deputy, Richard DeYoung, will become 13 director of the Office of Inspection and Enforcement.
O 14 The Generic Requirements Review Committee will 15 determine whether or not the requirements will contribute 16 eff ectively to helping safety and whether or not it will 17 place unnecessary burdens on Licensees or agency resources.
I 18 By having the committee submit the recommendations 19 directly to the EDO for approval, we hope to get a single 20 agencywide point of control.
21 Now, in addition, we feel that we have not perhaps 22 taken as much advantage of our regional offices to interact 23 with the Licensees, and so we are upgrading those regions O
24end heving them report direct 1y to the tDO with edditione1 25 responsibilities that are outlined in the press release.
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON, D.C. 20024 (202) 554 2345
14 1 1 And I can leave yoh a copy.
2 I hope this will help address some of the 3 questions that you raise.
4 MR. KERR Joe, I think that is the fastest 5 response the ACRS has ever received.
6 (Laughter.)
7 MR. SIESS:
Joe, what role will the value impact 8 statements play?
9 CHAIRMAN PALLADINO:
What is that?
I am sorry?
10 MR. SIESS:
What role will the value impact 11 statements pla; in that?
12 CHAIRMAlf PALLALIN04 Very much.
There is more to 13 the press release.
O 14 MR. SIESS4 Okay.
I just want to say that they 15 are effective as of doing something like this.
There is 16 only a f ew things wrong with it.
One is they are absolutely 17 worthless, nine out of ten of them.
And second, there has 18 been no indication that anybody looked at them on any 19 reasonably high level to compare values and impacts of one 20 action versus another.
l 21 CHAIRMAN PALLADIN04 Well, I honestly do not 22 believe. we have given enough real attention to value impact 23 statements.
I appreciate that trying to make th ose O
24 assessments is fraught with many pitfa11s ene shortcomings.
25 Yet I think we can do much better than we have been doing.
O ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W WASHINGTON. D.C. 20024 (202) 554-2345
_. _. ~
42 Q
1 And we do have some tools available which, if we have enough 2 data, can be put to use.
3 MR. KERRs It seems to me it would be worth 4 considering the possibility of having a different group 5 prepare the impact sta temen t and the group proposing 6 whatever action is being proposed.
7 CHAIRMAh PALLADINO:
The various actions would 8 still be proposed by the various offices.
And in my 9 thinking, in my planning paper I identify two categories:
~
10 those which the issuing office feels are so important to 11 saf ety that they ought to be implemented immediately or 12 there is some legal requirement; and there are those that 13 would have to be processed by this committee in a matter of O
14 two working days or they go to EDO for direct action.
That 15 I would anticipate to be a very small number of actions.
16 The others would be proposed by the issuing office.
And 17 this committee then would f unction to review them, ask for 18 enough information on the value impact statement so that a 19 reasonable assessment can be made.
20 Now, it has been pointed out this will cause a l
l 21 problem, and that is a part of the desired effect, I think.
22 (Laughter.)
l 23 MR. SIESS:
Who will be on this committee?
O 24 canta*>" >>ttiorno-we neve aot 14eatiriea e11 or 25 the people.
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
43
()
1 MR. SIESS:
Will they be ex-officio?
2 CHAIRMAN PALLADINO:
We have not identified the 3 offices from which they are going to come.
Tha t will be our J
4 next step.
5 MR. SIESS:
It will be more or less ex-officio 6 representatives?
7 CHAIRMAN PALLADINO:
Oh, yes.
The people who are 8 selected I hope will f ollow what we try to do at the 9 university, have them leave their departmental hats at the 10 door and act in concert in the best interest of the 11 Commission and the industry they are trying to serve.
12 MR. MARKa What a f antastic idea.
13 MR. SIESS:
And said with a straight face, too.
O 14
( Laughter. )
15 CHAIRMAN PALLADINO:
I have seen it work once in a 16 while.
17 MR. SIESS:
That is the difference between"a dean 18 and a department head.
19 CHAIRdAN PALLADINO:
I missed that.
20 MR. SIESS (Indicating.)
21 CHAIRMAN PALLADINO:
All right.
22 MR. MARK:
We have two small things that we would 23 like to mention.
One, Ha1.
()
2^
MR. LEWIS:
first I want to associate myself with 25 a lot of the things that have been said about the OV ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
44 1 specificity and proliferation of regulations.
That is just 2 one sentence.
As an example, and on this one there is 3 certainly not a committee consensus, and in fact I knou of 4 only one member on my side that I am sure of, and that is 5 me.
But there might be others.
6 MR. HARK:
There are two.
7 MR. LEWISs We are beginning to pile up support.
8 It is the question of inerting, containment interting.
The 9 concern is at two levels.
One is the level of inerting, per 10 se, as the hydrogen mitigation or combustible mitigation 11 procedure, and the question of whether sufficient attention 12 has been given to the downside risk of inerting and whether 13 suf ficient a ttention has been given to alternate means of 14 h yd rogen con trol.
15 Our understanding from this morning from NRR is 16 tha t although the proposed rule will specif y inerting, it 17 will now have at 1 east an allowance and may suggest an 18 alternate means of hydrogen control.
I was pleased to hear 19 tha t, because it was originally far too specific.
20 But at another level of discussion, the whole 21 question of the importance of hydrogen mitigation is a 22 f airly good examp1e of whether or not the Commission is 23 going to take probabilistic risa assessment seriously, O
24because wherees views differ en the sub3ect, et111 thi s 25 committee and other exalted committees have recommended to i
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
45 1 the Commission that it make more use of PRA in deciding
(}
2 which rules to promulgate and which regulatory actions to 3 take.
4 This seems to be a case in which a very limited 5 PRA was done on the subject and in which the recommendation 6 from the probabilistic analysis staf f was that inerting 7 probably would not cut its own weight.
And this is very 8 limited consideration of the downside risks, only a 9 consideration of the upside risks.
10 We heard from the NRR that this was in the end 11 discounted in formulating the rule because a number of the 12 people in NRR really do not believe in PRA or do not take it 13 seriously or do not believe the results or do not believe it 14 was done well or one or another reason.
15 But at that level, leaving aside the specifics of 16 inerting, it is a case in which one can ask whether a proper 17 assessment of the impact of a rule on safety and of those 18 things which will be lost which are both economic and 19 saf ety-related, whether a proper balance has been struck in 20 f ormulating the rule.
21 And I have some concern that it has not been.
And i
22 in f act, I know some others do, too.
23 HR. OKRENT:
If I can offer a point of view
()
24 perpendicular to that rather than opposite 25 (Laughter.)
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
46
()
-- I would say the PRA we were giva' was 1
2 inadequate for making e decision based upon the PRA.
So I 3 am in fact a big supporter of trying to use PRA to help in 4 decisionmaking, and i think it sould be done more.
And as 5 you know, I recommended it be done in connection with the 6 vessel question.
And I think it would be useful, it could 7 he useful, for hydrogen, although I am not urging that 8 something be delayed in that regard.
9 But if you are going to do PRA, I think you should 10 do it well and you should do it systematically, you should 11 use it to learn what you know and what you do not know, and 12 you should use it to learn how important are the 13 uncertainties.
In sor.e cases they are unimportant, and in O
14 some cases they dominate in principle, so when you are done, 15 you have the picture laid out.
16 And in fact, the very act of doing it tells you in 17 f act how important things are and so forth.
That is not 18 what we have in the PR A we got.
So I would say it does not 19 provide me with the basis for judging.
It indicates a way 20 to go on the question of inerting.
In other words, I think 21 tha t is a subject, an important subject.
And if you are 22 going to get into hydrogen control, you can look in more 23 than one direction.
You can ask, for example, is the
()
24 current method of hydrogen control conducive ;o other events 25 going beyond the degraded core and a variety of other O
ALDERSON REPORTING COMPANY,iNC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
47 1 things.
(}
2 It is a complex question, and if you are going to 3 look at it, you have to look at it in a thorough way and not CJ 4 as a piece of the picture.
5 MR. KERRs I would say that was about 30 degrees, 6not 90 degrees.
7 MR. 1EWIS4 Can I respond to that?
I think the 8 disease of wanting to do something perfectly before you pay
/
9 any attnetion to it is a very bad disease.
And whereas the 10 defects in the PRA ve were presented are known to me and the 11 people who did it, it is not automatic that when something 12 is not done perfectly that the answer is precisely wrong.
13 It seems to me it should be taken seriously for 14 what it was worth, no more than it was worth, but not simply 15 discounted because there is a visceral dislike for PRA on 16 the part of some people.
17 MR. MARK:
I think there were two things in your 13 point, one of which Dave clearly addressed and which clearly 19 needs to be kept in mind.
The other was the rather specific 20 inj unction you must inert rather than you must achieve a 21 meaas of hydrogen control.
And that is a kind of separate 22 issue.
23 Now, there is one last point, if you will still
()
24 allow us a f ew moments, sir.
The committee has spent a 25 considerable amount of time.
I will ask Dr. Siess to ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
48
(])
1 comment on this, on trying to take a look at the research 2 program, the research budget.
And it has done it in two 3 separate packages, once for Congress, as required by them at 4 a date which is rather early in the calendar year, and we 5 have done it a couple of times for the Commission separately 6 about six months later, which is early in their preparation 7 of material for OMB but, as far as I can tell, not early 8 enough.
9 And I think n question some of us have is whether 10 one such report might not serve all the purpose that this 11 effort manages to serve anyway.
12 Chuck, do you want to clarify tha t?
13 MR. SIESS:
I am not sure I can clarif y it, but 14 the report to Congress started out being quite long and 15 detailed.
After a couple of years, the Congress said, "We 16 really want something on the budget as well as a review of 17 the p rog ra m.
Talk about dollars," which we do.
The 18 Commission said, " Gee, that's nice advice you are giving to l
19 the Congress.
How about giving it to us in July when we are l
20 working on the budget?"
21 So we agreed and got them a report, which was l
22 almost as long as the one to Congress.
They said, " Gee, we 23 only expected a three-page letter."
()
24 And then there is the third thing, that Carson did 25 not mention, and that is the long-range research plan we O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
_ ~
49 Q
1 reviewed last year.
It is proposed those come out once a 2 yea r.
The procedures the Commission set up said we were 3 supposed to review that.
4 Now, we are doing two things:
We are reviewing 5 the research program, and we are doing that with the Staff 6 in a 1ot of detail and meeting with individual groups, a 7 research group subcommittee meetings.
Then we have meetings 8 here.
We bring Bob Minogue and those people in.
And we are 9 spending a lot of time on this, and they are spending a lot 10 of time on two or three reports a year.
We are getting a 111ot of input from the Staff.
They are 11stening and doing a 12 lot of things we have asked, although it takes the.1 a lot 13 longer than we think it ought to.
14 At the same time, we are taking the benefit of all 15 of this and putting it into writing, into a report or, 16 rather, two reports.
And we think we could do just about as 17 vell by putting it in one report and continuing our review 18 and continuing our interaction with the Staff and continue 19 the report to Congress, which they have asked for, and make 20 that the big one.
21 Now, that report comes out in February, which is 22 just about the time the Staff is working out its long-range 23 plan and starting its next budget cycle.
So it is very O
24 usefu1 as advice to them, e1though it is ta1xing ebout e 25 dif feren t b udget.
But the advice is in there, comes July O
ALDERSON REDORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
- -. ~~
50 1 and the Commission has got to do something on the research 2 budget.
3 If you ask us, we will comment.
But we would O
i 4
j prefer to have more specific questions and just comment on 5 the dollars of the budget and the reasons with maybe a two-6 or three-page letter rather than a nicely printed-up o
l 7 report.
8 9
10 11 12 13 14 l
15 t
16 17 l
18 l
19 20 l
21 22 23 0
24 25 O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 554 2345 L
51
()
1 What to do about the long-range research plan, we 2 haven 't agreed.
We didn't think too much of it as a 3 long-range research plan.
And unless it turns out to be 4 some other kind of document than the one we saw, I think 5 that there is a fair amount of feeling on the Committee that 6 it's not worth our time to review it, because it's not 7 covering anything we haven't already talked about.
8 It is just too much, too long, too detailed, and 9 the long-range aspect gets all mixed up in the projections.
"0We feel that the long-range planning is necessary next 11 January when they start working on the budget, January of 12 '82.
They are working on the ' 84 '85 budget, which is at 13 least two years or three years ahead.
So there is always a 14 long-range aspect. '
15 But we have mixed feelings on the long-range 16 plan.
We think they need something, but we sure didn't get 17 much out of reviewing it that we didn't accomplish by going 18 through the other reviews we m3de.
19 CHAIRMAN PALLADIN04 It would seem we ought to try 20 to consolida te, and maybe Ray Fraley could talk with my 21 executive assistant to see whether there are any problems in i
22 consolidating this report.
But I will say this:
I read all 23 of your letters on the research aspects of our activity.
I
()
24 f ound them very useful.
I 25 I think your comments on the long-range plan will
()
l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 2M24 (202) 554 2345
52
(])
1 lead to a better plan.
But I view your looking at the 2 research program rather significantly, because it represents 3 almost half of our total NRC budget and it ought to relate 4 to the activities people think we are going to need and not 5 have things going on that may have second order benefits.
6 HR. SIESS:
There's no suggestion we diminish our 7 review of the program, simply that we cut back on the number 8 of reports, which take a lot of time.
The way this 9 Committee works, it takes a lot of time to come out with a 10 report.
11 CHAIRMAN PALLADINO:
I agree, we should try to 12 consolidate if we can.
13 MR. SIESS:
I drafted a letter to the Commission,
/"~
kNl 14 to the Chairman, outlining this proposal, if the Committee 15 gets a chance to look at it.
16 MB. KERR:
And we spend a lot of NRC staff time as 17 vell.
18 MR. HAPK:
We have really beaten those poor people 19 very hard to get then down to our Subcommittee meetings, 20 saying the same thing sometimes over and over and over 21 again, and making them guess to things they didn ' t know,
22 because we said we would like to have the answer to this or i
23 t h a t.
And they have been very Telpful.
They generally try
()
24 to meet our requests.
25 But we are not sure that the number of separate l
ALDERSON REPORTING COMPANY,INC, 1
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
~.
53 Q
reporting events makes across the board sense.
We did talk 1
2 very slightly about this point with Bob Minogue this 3 morning, and while he may have had separate thoughts on the 4 matter, at the time he said he thought the thing he supposed 5 ve should do if we were trying to condense our reports would 6 be to put what we could into the report to Congress and 7 possibly let that be the report.
8 MR. SIESS:
He liked the timing on that.
9 CHAIRMAN PALLADINOs What's that?
10 MR. SIESS:
The timing on it was fine for him.
11 CHAIRMAN PALLADINO:
As I said, let me exaine the 12 pros an'd cons.
I certainly agree we ought to try to 13 consolidate on the reporting you have to do.
14 MR. MARKa That was all we wanted to mention 15 here.
Thank you very much, sir.
It was very good of you.
16 We will reconvene here in ten minutes.
17 (Whereupon, the joint meeting was adjourned.)
18 19 20 21 22 23 24 25 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON D.C. 20024 (202) $54 2345
NUCIAR FIGULATORY CO.*Cd.ISSICN This is to certify that the attached preceedings before the in the ::1atter cf:
Joint Meaeting - ACRS/C012iISSIONERS
- Date of Preceeding:
October 16, 1981 Dceket Number:
Place of ?: cceeding:
Mashington, D. C.
sere held as herein appears, and that this is the criginal transc:-ipt therecf for the file of the Cecsission.,
Sharon Filicour Official Reporte.- (Typed)
M&;b*,'
bCC/#l Official Repceter (Signature) l l
l l
t O
I i
.