ML20040E961
| ML20040E961 | |
| Person / Time | |
|---|---|
| Issue date: | 02/03/1982 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1052, NUDOCS 8202080136 | |
| Download: ML20040E961 (40) | |
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ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUBCOMMITTEE ON SAFETY PHILOSOPHY, TECHNOLOGY l
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jointly with SUBCOMMITTEE ON CLASS 9 ACCIDENTS O
m: February 3, 1982 PAGzg: 173 thru 203 g.
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UNITED STATES OF AMERICA 1
2 NUCLEAR REGULATORY COMMISSION 3
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ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
SUBCOMMITTEES ON SAFETY PHILOSOPHY, TECHNOLOGY AND CRITERIA / CLASS 9 ACCIDENTS 5
Nuclear Regulatory Commission 7
1717 H Street, N.W.
Washington, D.C.
8 Wednesday, February 3, 1982 9
The meeting of the ACRS Subcommittees on 10 Safety Philosophy, Technology and Criteria / Class 9 were 11 convened at 1:00 p.m.
12 PRESENT FOR THE ACRSa
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D. OKRENT, Chairman 14 W. KERR, Co-Chairman J. EBERSOLE, Member 15 D.
MOELLER, Member P. SHEWMON, Member 16 C. SIESS, Member D.
WARD, Member 17 DESIGNATED FEDERAL EMPLOYEEa 18 R. SAVIO 19 ALSO PRESENT:
20 R. MATTSON, NRR 21 D. ROSS, RES B.
RERNERO, NMSS 22 J. MEYER M.
SILBEPBERG 23 O
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1 PRESENTATION OF S. HANAUER 2
HR. HANAUER:
My discussion will take less 3 than five minutes.
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4 HR. OKRENT:
These subjects are not 5 unimportant, but go ahead.
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NR. HANAUER:
They are highly important but 7 they are unformed.
I have to give you kind of a 8 bureaucratic answer.
We don't have a safety goal policy 9 approved by the Commission.
We have some drafts.
There 10 has been a lot of technical discussion, a large fraction 11 of which the Commission.has participated in.
We have 12 talked on a number of the considerations today and in 13 other committee meetings.
O 14 Until we get a safety goal or at least a 15 provision or draf t safety goal out of the Commission we 16 have no program for its implementation.
We don't like 17 this very much, but we feel it is only thing to do.
18 What is being censidered is that of course the 19 draf t which you have seen of the proposed safety goal 20 asks the staff to develop during the comment period a 21 plan of how it would implement the safety goal which 22 would have been circulated for comment and we plan to do 23 this.
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24 We will have to have some kind of working 25 group that cuts across the various offices of the NRC O
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and it is proposed to have this steered by a high-level 1
2 management group f or which the first recommendation is 3 to use a group of office directors.
What Mr. Ste11o's
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4 role in this will be we don't yet know.
5 Now one might talk for a ver'y small number of 6 sentences as to the substance of what this action might 7 be.
There are three major spaces in which the safety 8 goal would seem to be applied.
9 The first is in requirements space.
There has 10 been a lot of discussion about getting the requirements 11 of the agency under control, harmonized, consistent with 12 each other and in better balance with the cost / benefit 13 notion of which of these requirements are suitable and O
14 needed.
15 Based on the safety goal, both the numerical 16 guidance and the ALARA, if you like, aspects of it, this 17 should provide a very usef ul guide, first of all, to 18 which requirements should be worked on, and I will come l
l 19 back to that, and more im po rtan tly, having developed 20 this or that proposed requirements, then deciding which 21 ones should be imposed.
My own view is that that will 22 be the most useful application of the safety goal.
23 The second area, and almost equally useful, is
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24 an allocation of resources.
We have, at least on paper, 25 f ar more work than we can do.
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regulatory programs an industry effort which is 1
2 enormously larger than the NRC effort.
The work which 3 we do in reviewing a case if much less than one percent
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4 of the design work that goes into the machine.
The work 5 which we do in other aspects of our regulatory programs 6 is also a very small fraction of the work which goes 7 into the owner's snd designer's efforts.
8 Furthermore, if you look at the list of 9 problems or issues or things for which requirements are 10 needed, things for which development of a resolution of 11 issues is needed, things for which research and i
12 development are needed, things for which guides are 13 needed, things for which work is needed and things for
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14 which multi plant implementation of requirements is 15 needed, you will find this list is almost 16 catastrophically longer than the rate at which we are 17 working on it.
18 Therefore, a very high order of selection is 19 required.
The committee knows this very well.
The 20 committee is the f ather of the generic issues list and 21 it gets longer rather than shorter.
22 The safety goal and the cost / benefit, 23 risk / benefit approach is in my opinion the logical way
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24 to approach the question of which one of these are we 25 going to expend our resources on or alternatively which O
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1 ones of these must be worked on in order that the 2 regulatory process be adequately safe.
3 These are simply two ends of the same 4 question.
We are already working on this.
I believe 5 the committee has already had from r.y predecessors 6 discussions of the prioritization program that we are 7 actively engaged in on generic issues.
If you haven't, 8 we should discuss this with the right subcommittee.
9 We are in the process in a very crude way of 10 applying a very crude model of cost / benefits to put 11 priorities on the long list of things which we are 12 working on.
This includes the famous list of generic 13 issues, the unresolved safety issues, the TMI Action 14 plan development programs, the ones that aren 't already 15 completed and the things which come from experience.
16 We had an incident at Ginna last week.
Does 17 this mean we should put a lot more effort into steam 18 generator tube ruptures or does it have the safety 19 significance that we thought it had before last Monday 20 and is our program about right?
I think the safety goal 21 will really help us in this.
22 The third area is the one I approach with the 23 m os t trepidation, and that is making decisions on 24 individual cases.
Experience tells me that there is 25 going to be a rash of what I will uncharitably call O
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I half-baked risk analyses which purport to show that 2 this, that or the other requirement is not necessary.
3 Some of them will probably be true.
It will be quite
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4 difficult to find out which are true.
5 It is necessary, in my opinion, to consider 6 safety as a whole and not slice a salami so thin that no 7 slice is important.
8 Yet we have to make regulatory decisions and 9 the idea of safety importance is necessary to making 10 them.
I think we all have today various safety goals 11 which we use in making the decisions that the committee 12 mak es, the staff makes and the industry makes.
To have 13 a numerical safety goal will presumably assist in this O
14 process.
15 We make a very la rge number of such decisions 16 and the guidance that everybody who makes these 17 decisions will get out of a safety goal will presumably 18 be helpful.
19 But in particular we make very difficult and 20 expensive backfitting decisions of at least two kinds, I
i 21 as Helrecently pointed out to me.
22 One is we decide whether to impose new 23 requirements on existing plants and the second one is we
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24 decide in the SEP program and elsewhere whether all new 25 requirements should in fact be backfit onto old plants i
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1 which we discovered don't meet them.
This is the 2 central point of the SEP program on the oldest plants.
3 I don't think we have very well thought
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4 through how to make individual plant decisions and how a 5 safety goal would help us, but my own instincts tell me 6 tha t knowing how the Commission, the technical 7 community, the committee and the Congress maybe actually 8 feels about the level of safety required has got to be 9 in the right direction.
10 Now this is not an action plan.
This is some 11 personal thoughts about what might go into an action 12 plan when we get around to it.
13 Let me ask Mel if he wants to add anything.
O 14 MR. ERNST (Nodding negatively.)
15 MR. HANAUER:
He shakes his head.
16 That ends my presentation, M r. Chairman.
17 MR. KERRs Steve, there is a school of thought 18 that says one can't evaluate a safety goal apart of its 19 method of implementation, that is in a sense the method 20 of implementation is part of the goal, that is the 21 operational part of it.
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22 Could you comment on that.
l 23 MR. HANAUER4 Intellectually it has to be
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24 t ru e.
The easiest way I think about it is I look at 25 Part 100 which has some numerical safety goals in it and
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artai== =ati1 I c a t 11 2 how the emissions are doses are to be calculated and the 3 I am going to compare with those dose guidelines in Part 4 100.
5 I guess that is why we have draft safety goals 6 and the development of an implementation plan to go into 7 the Commission for its consideration before they decide 8 whether to adopt it.
9 MR. EBERSOLEs Steve, may I ask a question.
10 MR. OKRENT:
Go ahead, Mr. Ebersole.
11 MR. EBERSOLE:
This value of a thousand 12 dollars per man-rem, it is suggested for improvements?
13 MR. HANAUER:
Yes, sir.
O 14 MR. EBERSOLE:
Is that to be considered as 15 superimposed on the insurance bought by the utility l
16 against investment losses and operating losses?
17 MR. HANAUER:
No, I don't think it fits that 18 w ay at all.
It is a prescription for doing cost benefit 19 in non-commensuraole units.,It is way to co-measure the 20 units in which our cost / benefit evaluations have to be 21 mad e.
The costs are in terms of money, which is the 22 public's money and occupational exposures and maybe 23 increased risks coming from side effects of the things O
24 ve think are impro,ements.
The benefits are e,erted 25 man-rem in the public.
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1 So if I leave out some important things it is 2 the public's money and the public's man-rem.
In order 3
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to compare then one has to have an equivalence and that 4 is the dictated equivalence.
I don't think it has to do 5 with insurance.
6 MR. OKRENTs Suppose the Commission decided 7 that they wanted to at least see what kind of 8 implementation plan the staff or NRR had in mind before 9 they even published it for comment and said, you know, 10 this is February 3 and we would like to see it on March 11 3.
Would you say it is impossible?
12 MR. HANAUERa No, sir, they would get a 13 one-month ef fort.
O 14 HR. OKRENT4 This sort of suggests that the 15 staff has been doing nothing along these lines when you 16 say a one-month effort, in other words, up to now, 17 except for the five minutes Steve Hanauer thought while 18 he was talking.
19 (laughter.)
20 HR. HANAUER:
Well, a great deal of thinking 21 has in f act been done by a small number of people with 22 some distinguished exceptions.
These people are not 23 generally the managers of the agency who have, I have to
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24 s ay, thought very little about the subject.
25 I have a bunch of thoughts on it, you have a O
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1 bunch of thoughts on it, Mel has a bunch of thoughts on 2 it and a few other people one can name have really 3 thought very hard about this question.
But a number of
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4 the people who really have to figure out whether this is 5 the right kind of implementation scheme for the agency 6 they have manage have not spent much time on *:.
7 HR. OKRENT:
Are you willing, either of you, 8 to go beyond what you have already said, recognizing it 9 is preliminary and so forth, just to what in fact you 10 would recommend to NRR management, for example, whether j
11 they wanted a one-month or a two-month statement, 12 whatever it is?
13 ER. HANAUER:
Does the committee really want O
14 to hear Frank Rowsome's, Mel Ernst's and Steve Hanauer's 15 personal thoughts are on the subject?
16 MR. OKRENT:
Well, I am interested in knowing 17 what you think is practical and what you think might be 18 impractical for one reason or lead to all kinds of 19 difficulties even if it is not quite impractical if you 20 could provide us with those ideas.
I don't know how the 21 other members feel.
22 MR. KERR:
Why don't you get the other 23 presentations and give Steve a chance to think about it O
22 a 31t.
25 HR. OKRENT:
Dr. Hoeller.
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1 MR. NATT3ON On the implementation I had some 2 questions if I could just throw them out to show you 3 what troubled me say in reading the prosposal.
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4 One is they proposed the thousand dollars per 5 person rem.
My question was will there be cases in 6 which this thousand dollar per person rem limit will be 7 controlling?
You know, in terms of routine releases it 8 was seldom that the thousand dollars ever was 9 controlling.
In other words, if you met the basic 10 requirements for clean-up systems you never had to do 11 any more under the thousand dollar per person rem rule.
12 But here I don't have the faintest idea whether that 13 rule will be controlling or in which cases it might be O
14 controlling.
Then you are talking implementation.
They 15 say that we will prorate or do'the calculations on the 16 basis of the remaining years of life for the plant or 17 the remaining years that it is intended to operate.
18 Well, how will we determine how many years a 19 plant has yet to operate?
I don't know.
20 Another thing in the report it says that we 21 a re only looking at safety goals for the power plant 22 itself.
Later we may look at safety goals for the other 23 components of the fuel cycle.
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24 Well, do you mean therefore without any 25 question that the power plant itself represents the O
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1 greatest hazard of all of the components in the fuel 2 cycle?
I assume that is true.
3 MR. OKRENT:
The last question would be one
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4 for Mr. Remick when he comes.
That is not quite an 5 implementation question.
We will get a chance to see 6 him tomorrow.
7 MR. MOELLERa I gather these safety goals are 8 for a single reactor and a single power plant.
9 MR. OKRENTa Sometimes for a site and 10 sometimes for a reactor.
11 MR. MOELLER:
Well, I guess I missed that if 12 it is sometimes for a site.
13 Another implementation question.
We are going O
14 to make the goal or have the goal be no more than 15 one/ tenth of one percent of the natural or the total 16 cancer in the popula tion?
17 MR. OKRENT:
You are getting into some details 18 today and I don 't know which of the staff considers to 19 be subject to a 20 MR. MOELLER:
--- a closed meeting.
21 MR. OKRENT:
Yes.
22 MR. MOELLER4 They are going to compare it to 23 the cancer incidence in the population or compare it to (O/
24 the acute death rate within the population.
Now whose 25 numbers are they going to use?
Are there official
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1 numbers, and presumably there are.
2 MR. OKRENT That would be something for 3 Mr. Remick.
Those wouldn't fall within the area of
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4 implementation.
5 MR. M0ELLERs Oh, I thought it might because 6 in order to implement it I have to know those numbers.
7 NR. OKRENTa Perhaps.
8 MR. MOELLER:
Then the whole schedule for 9 implementation, I mean maybe when you meant 10 implemen ta tion you could mean several things when you 11 use the word " implementation."
One would be what is the 12 schedule for implementing the safety goal policy once it 13 is established.
The other thing will be wher. do you O
14 take action in a given circumstance.
You know, in your 15 report you had the hazards states and Steve has done th e 16 same thing and it is pretty clear, but there is none of 17 tha t here.
So I don 't know when you implement or when 18 you take action is what I am really saying.
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19 MR. OKRENT4 First of all, criteria is not a 20 part of our current discussion.
21 MR. MOELLER Okay.
Then by implementation 22 you mean when do you implement and how do yOu implement l
23 the policy.
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24 MR. OKRENT4 Yes.
25 MR. BENDER:
Just to add one point to Dave 's O
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1 questions.
It looks to me like you need to have some 2 exemplary computations to see how to apply this thing.
3
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MR. MOELLER:
Yes.
4 MR. BENDER:
I had trouble with that but I 5 don't envy the guy that has to do them.
6 (Laughter.)
7 MR. MOELLER:
I wanted to see an example.
8 Like with Appendix I we were given examples of the 9 calculations.
Maybe it is too early, but we don't have 10 any here and yet we are steamrolling along as if we have 11 done those calculations and we know this can be 12 implemented or that it will work.
I don 't know.
13 MR. EBERSOLE:
Let me ask another question.
I 14 am bugged by this lonesome requirement for considering 15 the cost / benefit improvements be based on simply 16 man-rem.
If you look at the THI-2 case the man-rem was 17 vitually nothing.
I think the industry would be rather l
18 willing now to put such thingc as level gauges on, but I 19 am not sure about that, or put whatever it takes to 20 avoid a TMI-2 accident again and that the staff should 21 consider the aspect of the challenge and not the final 22 event.
23 MR. OKRENT:
I would say this is a topic that
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24 we should raise with Mr. Remick.
It is in fact a l
l 25 question that should be posed to him.
1 O i
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1 Well, let's see, I have heard a suggestion I 2 think from Mr. Kerr that we hear f rom Mr. Rowsome and 3
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then come back and ask any of three or all of the three, 4 Hanauer, Ernst and Rowsome, if they would tell us what 5 they think should be done as they see it from the point 6 of implementation or what is practical or impractical 7 and so forth.
8 It is not quite clear to me how RES is going 9 to talk about a research program to support 10 implementation if MRR doesn 't know what implementation 11 means.
So I will assume NRR really knows what 12 implementation means but they haven't told management.
13' (Laughter.)
O 14 PRESENTATION OF F. ROWSOME/RES 15 MR. ROUSOME You will find my presentation l
16 frustrating, too, in that is more bureaucratise than the 17 substance on these issues.
18 As you know, DBA has had projects underway for 19 a couple of years to develop a technical foundation f or 20 safety goals and these are being reoriented in light of 21 the " proximity of a goal.
What I as prepared to talk to 22 you today about is that reorientation.
23 We have a project at Pacific Northwest
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24 Laboratories which a substantial subcontract to Battelle 25 Columbus entitled " Improved Methods For Incorporating O
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Risk In Decision Haking."
It is now being divided into 1
2 three principal tasks with a lot of subtasks on each one 3 of them.
4 One of the pricipal tasks is to analyze the 5 Commission pronouncement, if and when it comes, both 6 technically and from a problems in implementation point 7 of view, 8
The first task with a delivery date in late 9 spring or early summer, May or thereabouts, is an effort 10 to do a techincal analysis of the quantitative terms in 11 the safety goal along the lines of what was in the 12 appendix to NUREG 0739, that is a sensitivity analysis 13 on the parsmeters and what are the implications of being
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14 at threshold looked at from as many points of view as we 15 can think of to look at them.
l 16 The subsequent task is to look at options for 17 implementation or interpretation where there are degrees 18 of freedom in interpreting them, and there are many, 19 what are the implications of the choices there and 20 provide some feedback to the staff and to OPE on the 21 implications of the several options for interpretation, 22 and then to develop a paper describing options for 23 implementation principally in the standards development
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24 arena but touching also on casework and on the research 25 priority.
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1 A second principal family of tasks in this 2 research project is to develop a handbook of value 3 impact analysis.
The princial or immediate, I should 4
the immediate objective is to provide the staff
- say, 5 with guidelines on how to deal with the Stello 8 committee, on what would be an appropriate value impact, 7 cost / benefit, risk / relevance measure for use in i
8 defending regulatory initiatives, but subsidiary 9 objectives involve a cost / benefit determination bid to ticket rule-makings and for prioritizing research or 11 action on newly discovered safety issues and things of 12 tha t kind.
13 The Value Impact Handbook will include at the O
14 outset what is in effect a decision tree that provides 15 the reader with a tool for classifying the kind of 16 problem he has and saying if you have got a problem of 17 this type the scope and level of approach for value 18 impact analysis appropriate to it and the tools 19 available to you can be found on page thus and such.
So 20 it is a kind of program learning chart to find your way 21 to the right methods.
22 The appendices that actually give examples and i
23 provide instruction will grow with time.
Clearly we
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24 can ' t tell a contractor to go off and do all things for 25 all men right away.
It takes a while for that to ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
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1 happen.
2 So that what we expect to do is publish a 3 partial draft that can be used, at least trial used, 4 starting sometime next fall that will have many branches 5 of this decision tree up front not yet filled in, an 6 incomplete set of appendices but a rough cut on some of 7 the ones that most commonly crop up before the CRGR and 8 then over the next year or two they will fill in more 9 and more and more of the appendices and provide to mid -course corrections and revisions to the material in 11 the front on the basis of their experience with it and 12 the evolution of the safety goal usage and wh a t-no t.
13 A third task and a smaller task is to go af ter O
14 a example and a first cut at research prioritization in 15 the specific contert of LHFBR research.
16 We are providing the contractor with a 17 decision matrix, a decision flow chart which is intended 18 to allow him to start with a PRA or the user, the user 19 of this decision technique to start with a PRA, a rough 20 PRA of a conceptual design and from that identif y where 21 the unpleas'a'nt surprises might be lurking and under what 22 rocks might a risk much higher than the safety goal h3 23 lurking and identify first what you can deal with in the
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24 regulatory arena immediately.
You can figure out a way 25 of draf ting a standard to deal with that to limit the O
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1 risk there.
2 If it takes more than that, if you need more 3 research to identify how to write the regulation, you 4 develop a little decision tree about whether it is 5 appropriate to have the licensee do the research and NRC 6 merely audit it or to decide what level of overview, of 7 oversight over research done by others, done by the 8 applicant is necessary, and to sort of a small hard 9 kernel of research that the agency needs to do to make 10 decisions that will assure that the stones under which 11 high-risk items might be lurking have been dealt with in 12 the regulatory arena to see if we can make a discipline 13 out of that approach to research prioritization.
14 That is the objective of the last one.
15 The Statement of Work is just now being 16 w ritten.
The program has been ongoing before but with a 17 rather different direction and this is a major l
18 redirection of the first project.
19 We have a second research project at Oak Ridge 20 entitle " Evaluations of Acceptable Levels of Risk."
21 Virtually all of it is subcontracted to a number if 22 policy theorists, Paul Slovic, Baruch Fishoff, Sarah 23 Lichtenstein and Ralph Keeney, who are writing an array
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24 of papers on a variety of social and political and 25 institutional issues surrounding safety goals and which l
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- mechani m for technica1 i ta=ce 2 advice and input to OPE and to Research.
3 MR. WARD:
Frank, what are you going to get 4 out of this?
I mean, what is the relationship between 5 the output from that effort and the thousand do11ars per 6 man-ren?
7 MR. HOWSOME The six papers we are getting 8 out of it are very c1ose to publication and they in a 9 sense are a partial disconnect with the Commission 10 movement because they more properly belong to the input 11 when you are thinking about how to start your safety 12 goal and when you have one in f ront of you, although 13 they may retain some relevance when the pub 11e comment O
14 and evaluation and feedback on the safety goals takes 15 place.
If the Commission wants to entertain the idea of 16 revising them substantive 1y this material may be of 17 usef ul input.
18 In addition, the technical assistance 19 mechanism, which is the primary active one after these 20 papers are completed, and, as I say, most of them are in 21 dra f t already, will be the principal mechanism.
We will 22 have these noted authorities on the institutional and 23 socio-political dimensions of the problem on tap for 24 advice and guidance on implementation and the like.
25 MR. BENDER 4 I want to take note of that O
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1 phrase that Frank used.
It is really worth preserving, 2 partial disconnect.
I wish I had thought of that and I
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3 vant to remember to use it in the future.
I think that 4 is a key answer to your question.
5 MR. ROWSOME There is a third research 6 project through Oak Ridge National Laboratory to Band 7 Corporation and principally Ken Solomon.
We are now in 8 the process of trying to figure out how to redirect this 3 effort and haven't gone very far.
10 The skills available there are operations 11 research and decision theory and socio-political 12 dimensions.
Rand is not close to the technical issues 13 in reactor safety or the regulatory issues that we deal O
14 with.
It is not immediately obvious how we are going to 15 structure this project.
16 Let me say, incidentally, tha t these projects 17 vere being managed by Bill Vassily before he lef t and 18 that since his departure we have given project 19 management for these project jointly to Pat Rathbun and 20 to P. K. Niyogi, Pat Rathbun, in part because she is 21 good at this sort of thing and in part in the hopes of 22 some coordination over the dinner table.
23 That brings in another dimension to this,
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24 though, that she has been captured half time by NRR to 25 work on the fire drill having to do with emotional O
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1 stress at TMI and she is managing the research to deal 2 with that issue for NRR.
(])
3 It is altogether possible that we will 4 conclude tha t the best way of using this contract 5 mechanism ts to put it to work on that and the f ree up 6 the resources to launch another initiative on the risk 7 criteria utilization.
8 There are a number of other projects in DRA 9 tha t have a peripheral bearing on it.
One of the ones to tha t comes closest to direct relevance is the siting 11 research project at Sandia intended principally to 12 support the siting rule, but it has generated CRACK runs 13 for 92 sites I believe in the country for each of five O
14 hypothetical source terms of release categories, 15 severity of accidents bins, that allows us to relate 16 frequency of occurrence in an identified release 17 catetory with what the off-site consequences are, a t 18 least to the extent to which you are prepared to believe 19 the CRACK code.
I 20 One of the tasks we will without question task 21 them with doing is when we get an unambiguous 1
22 definition, one or more unambiguous definitions, of how 23 to translate the thresholds in the Commission's safety 24 goals into consequence measures, CRACK code results.
25 We will back out of these runs what the
(:)
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1 constraints are on the frequency of occurrence of each 2 of these release catetory bins at each of the sites.
3 MR. KERRs One might characterize these then
{)
4 as solutions waiting for a problem.
5 (Laughter.)
6 MR. ROWSOME In this context, yes.
7 You are familiar with the other ones, IREP, 8 RSSHAP and so forth.
So I won't spend this late hour 9 talking about the others.
10 MR. OKRENT:
Why don't I see whether we have 11 any volunteers to give us some more insight into 12 implementation.
13 3R. ERNST There were a couple of questions O
14 raised I guess which I am not sure it is an insight 15 towards implementation but - one was the thousand dollars 16 a man-rem and whether or not that would be an operative 17 num ber.
18 I can recall a couple of months ago I guess i
19 doing a back-of-the-envelope calculation which might 20 indicate for a moderately high population density site 21 taking typical PRA results.
You might have some' thing on 22 the order of maybe as much as $10 million per plant i
23 lif etime to spend.
I don't wa n t to get too many numbers
()
24 floating around, but you are perhaps in the millions of 25 dollars range, within that kind of a number, so it could
)
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1 be an opportune number.
2 HR. HANAUERs I guess I would like to say i
3 something.
4 (Mr. Hanauer goes to the blackboard at this 5 point and draws a diagram as he is talking.)
6 If this is a risk scale then the population of 7 plants is scattered in a way, and the abscissa doesn't 8 mean anything except it separates plants, is scattered 9 in a way in which we are only just beginning to 10 understand from our slowing growing multiplicity of 11 evaluations.
12 If the numerical guidance of the safety goal 13 is here then these three plants, and I am not saying O
14 anything about error bands at the moment, I know that 15 the discussion has to have that but I don't know yet how 16 to do it, but these three plants ought to be improved 17 and brought somehow within the safety goal.
18 However, this plant righ t here, which is well 19 below the numerical guidance, may in f act have been 20 susceptible to improvements which return more than a 21 thousand dollars per man-rem and perhaps should have 22 come money spent on it in improving its safety.
23 So that, to the extent that I understand the
()
24 proposed safety goal, it is not only the plants which 25 stand up above the numbers which are susceptible of O
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1 application of the safety goal but also the ones which 2 are down in the population of plants which nominally 3 satisfy it.
4 MR. WARD:
The argument there is that the 5 ratepayers are the beneficiaries and you just help them 6 to understand that?
7 NR. HANAUER:
That is the argument behind this 8 kind of a safety goal, sure, behind this part of the 9 saf ety goal.
The thousand dollarsd per man-rem spends 10 their money to improve their safety using this threshold 11 which implies what they ought to be doing today to 12 improve their safety goal.
13 MR. KERR:
By the way, is this going to be O
14 ind exed to the cost of living or to inflation?
15 MR. HANAUER:
It is not provided.
A thousand 16 dollars per man-rem was very controversial in Appendix I 17 time but what with inflation I don 't hear near as much 18 noise about it these days.
19 MR. KERBS We are downgrading human lives.
20 HR. HANAUER:
In a variety of ways.
21 (Laughter.)
22 HR. HANAUER:
Some recent experience I have 23 had with some cost benefit estimates tells me that there
()
24 ought to be a threshold, that to spend $1,000 dollars on 25 plant "X" in order to achieve the abatement of one
()
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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' oetson-ces is n
dese or tais ococe.s secouse it 2 probably costs a million dollars in hidden costs to do 3 it.
So the model is too unsophisticated.
4 I don't know what we are going to do about it 5
6 7
8 9
10 11 12 13 O
14 a
15 16 l
17 f
18 19 20 21 22 23 O
u 25 0.
ALDERSON REPORTING COMPANY,INC, 400 VIRGINEA AVE., S.W., WASHINGTON, D.C. 20024 (202) 354-2346
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1 but clearly an implementation has to be considered.
2 MR. OKRENT:
Mr. Bender.
3 HR. BENDER:
In connection with the ALARA
(}
4 principal, whatever it is, there is always this question 5 of how f ar out do you go when you are considering the 6 improvement.
A very small dose spread over enough 7 people can become a lot of man-rem.
I think that has 8 been pointed out before and it is not something that is 9 unique to my thinking.
10 How is that going to get into this thing?
11 Flying to Canada it imposes the same kind of risk and I 12 wouldn ' t want to impose a thousand dollars of penalty on 13 the airlines to protect people going to Canada or O
14 something like that.
15 MR. HANAUER:
Well, I don't understand the 16 last point.
The draft which you goes out to 50 miles.
17 If you believe the linear theory, then.a very small dose 18 to a whole lot of people is a very real human effect.
19 If you don't believe the theory then you ought to impose 20 some kind of a individual dose threshold and not abate 21 person rems which involve very small doses multiplied by 22 very large numbers of people.
23 MR. BENDER:
Well, I don't know that I believe
()
24 or disbelieve the theory because the theory doesn't 25 apply in many cases.
O ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202).554-2345
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1 MR. EBERSOLE:
It seems to me it is not as 2 simply as that because what we are using to calculate 3
{}
these person-ress, as my esteemed colleague refers to 4 it, is a computer model.
We don't have any evidence 5 that there is an increase in exposure at 50 miles.
6 MR. HANAUER:
That is correct.
That is one of 7 the approximations in the implementation.
8 MR. MOELLER:
The fact that the staff has cut 9 it off at 50 miles I think shows good judgment.
10 MR. KERR They would even better judgment if 11 they would cut it off at five.
12 MR. MOELLER:
Well, they have cut it off at 10 13 miles for one and 50 for the other.
They have to do O
14 something that will be acceptable.
It is like the 15 thousand dollars, it seems to have become acccptable.
16 MR. BENDER:
Well it was a lot more rational i
17 when it was applied to Appendix I because there you did 18 have a known risk that you could see.
Here you only get 19 the exposure if a certain set of circumstances goes with l
l 20 i t.
21 MR. HANAUER:
It is an expected value.
So in i
22 order to apply this in any quantitative way we have to 23 believe the probabilities and the consequences.
We all
)
24 know what the dif ficulties and error bands are on them.
25 HR. BENDER:
Could I ask a practical but CE).
ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE, S.W WASHINGTON, D.C. 20024 (232).554 2345
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1 perhaps legal question about the concept.
Being a 2 non-lawyer I don 't have any problem talking about one.
3
()
I think my inclination would be to say if I didn't like 4 the concept that I would like to challenge the validity 5 of the cost / benefit business in the courts.
6 Is there a legal opinion on whether this kind 7 of thing ought to have a cost benefit analysis 8 associated with it?
9 NR. HANAUER:
There have been discussions with 10 the lawyers but we are not privy to them.
Ask Mr.
11 Remick tomorrow.
12 MR. MOELLER Just one other thought on the 13 thousand dolla rs.
I could join either side, you know, O
14 to argue it should be higher or to argue that it should 15 be lower relative to the Appendix I number.
But I guess 16 if you used your Alpha, which they reject, you would 17 have a higher number, meaning you should be willing to 18 spend more because it involves large numbers and so 19 forth in an acute event.
20 HR. OKRENT:
I think tomorrow when we talk 21 with Mr. Remick we should really look in detail at just 22 wha t is involved.
There is a package here of a certain 23 distance and a certain number.
It may or may not
()
24 represent the societal costs.
You have to think about 25 that, but there is, as I sa y, a package and you can't
~
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W, WASHINGTON, D.C. 20024 (202) 554-2345
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take part of the package and have what the author was I
2 trying to present.
3 3R. GRIESMETERa There is also a problem in
)
4 interpreting that package.
In fact, much of the reason 5 why it is not out now is because of disagreements among 6 the Commissioners on how you should interpret the 7 stuff.
I won't say any more because it is privileged, 8 but that is the reason why it is not out right now.
9 MR. OKRENT:
I gather the staff doesn 't want 10 to offer more on implementation.
11 (No response.)
12 MR. OKRENTa This in effect means what I will 13 be telling the c mmittee tomorrow is that the staff as 14 of how has nothing specific to tell us concerning how 15 they will respond to the Commission request for an 16 approach to implementation.
17 MR. HANAUERa Tha t is right.
18 MR. OKRENT:
That is what I should say.
19 MR. HANAUER:
Right.
20 MR. ROWSOME4 One further addition you may 21 wan t to think about is that we will argue internally 22 tha t the IREP stype PR A 's are not measures of compliance 23 and ought not to be used that way and the kinds of PRA's (f
24 tha t we see likely within the state of the art do not 25 look to us to be reliable measures of how a n individual
()
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
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/~T 1 plant stands up against this issue.
U 2
MR. OKRENT:
That will be the position of the 3 Office of Research?
4 MR. ROWSOME:
That will be the PRA position.
5 MR. OKRENT:
I can understand tha t position.
6 (laughter.)
7 MR. OKRENT:
Well, I am going to propose to 8 the subcommittee that with regard to the discussion on 9 saf ety goals we ask that there be the presentation and 10 discussion with the representatives of OPE insof ar as 11 the formal part and that there be no formal 12 presentations from NRR or the Office of Research, but 13 that there will be something on the agenda that shows v
14 discussion with representatives of OPE, NRR and Research 15 and let the committee delve however it will on what is 16 of interest.
17 Does that sound agreeable?
18 (Committee members nodding in agreement.)
19 MR. OKRENT:
I just wanted to let the 20 representatives here know what we were proposing for the 21 f ull committee meeting.
22 We are not all that late now since we have 23 picked up time in the last item.
()
24 Do the members here want to discuss this at 25 all or are you pretty weary?
)
^
4 ALDERSoN REPORTING COMPANY,INC, 400 VIRGINtA AVE., S.W, WASHINGTON, D.C. 20024 (202) 554-2345
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1 MR. KERRs I would propose to continue this Q
2 interesting discussion over dinner.
3 HR. OKRENT:
Hearing no objections, I will 4 adjourn this subcommittee meeting.
5 (Whereupon, at 6: 45 p.m.,
the subcommittee 8 adj ourned. )
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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'O la the 22C04P cf - ACRS/ Subcommittees on Safety, Philosophy, Technology and Criteria and Class 9 Accidents l
U4U4 cf Freceeting: February 3.
1982 Deckat llunher:
F12Ce of PrCCeedi3g:
Washington, D. C.
ars held as hereis appears, acc thab. this is the cet;ical. :: anse:-1;;
therecf fcr che file of the C =:::1ssicc.
Mary C. Simons eO Cff*.=ial Reger:4r (!7:ec) f Offici31 Espcriar (Sifnaccre)
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NUCLEAR REGULATORY COMMISSION This is to certify that the attached proceedings before the e
in the satter of: ACRS/ Subcommittees en Safety, Philosophy, Technology and Criteria and Class 9 Accidents Date of Proceeding: Februarv 3, 1982 Docket llu::1ber:
Place of Proceeding:
Washington, D. C.
were held as herein appears, and that this is the criginal transcript thereof for the file of the Commission.,
Patricia A. Minson Official Reporter (Typed) e Q W L.' -
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