ML20055B194
| ML20055B194 | |
| Person / Time | |
|---|---|
| Issue date: | 07/13/1982 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8207200491 | |
| Download: ML20055B194 (80) | |
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PUBLIC MEETING BRIEFING ON SECY-82-275 - Status of tite ATwS Rulemadstg DA=r:
July 13, 1982 PAGzs:
1 - 62 A=:
Washington, D.
C.
1.E.DR%X REPMIN(i E-k l
400 Vi_y d a Ave., S.W. Was 'i p==, D.
C. 20024 d
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- alaphc=a: (202) 554-2245 l
8207200491 820713 PDR 10CFR PT9.7 PDR
W 1
1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY C3MMISSION 3
4 BRIEFING ON SECY-82-275 - Status of the ATWS Rulemaking 5
6 PUBLIC MEETING 7
8 Nuclear Regulatory Commission Room 1130 9
1717 H Street, N.
W.
Washington, D.
C.
10 Tuesday, July 13, 1982 11 l
Ihe Commission set, pursuant to notice, at 12 2.00 p.m.
13 14 BEFORE:
15 NUNZIO PALLADINO, Chairman of the Commission JOHN AHEARNE, Commissioner 16 IHOMAS ROBERTS, Commissioner JAMES ASSELSTINE, Commissioner 17 18 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:
19 W.
DIRCKS
- 3. CHILK 20 M.
MALSCH F.
REMICK 21 R.
BERNER0 W.
OMSTEAD 22 23 AUDIENCE SPEAKERS:
R.
MATTSON 24 W.
MINNERS l
HOUGHTON l
25 ALCERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W. WASHINGTON. D.C. 20024 (202) 554-2345
.r DISCLAIMER This is an ' unofficial transcript of a meeting of the United States Nuclear Regulatory Cc= mission held on Juiv l'3. 1982 in the Commission's offices at 1717 H Street, N. W., Wasnington, D. C.
The meeting was open to public attendance and observation.
This transcript has not been reviewed, corrected, or edited, and it may contain inaccuracies.
The transcript is intended solely for general informational purposes.
As provided'by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed.
Expressions of opinion in Ethis. transcript do not necessarily reflect final determinations or beliefs.
No pleading or other paper may be filed with the Commission in any proceeding as the result af or addressed to any, statement or argument
' contained herein, except as the Commission may autnorize.
e
2 1
EE2GII2I1EE 2
CHAIRMAN PALLADINO:
Good afternoon, ladies 3
and gentlemen.
4 The Commission meets this afternoon to receive 5
a briefing from the staff on the status of rulemaking 6
regarding protection against anticipated transients 7
without scram, commonly referred to as ATWS.
8 ATWS events have long been the subject of an 9
extensive and continuing study by the NBC.
In November, 10 the Commission published for public comment proposed 11 rules for the reduction of risk from anticipated 12 transients without scram events.
13 The rule contains three alternatives for 14 improvements in the design and opera tion of nuclear 15 power ;,lants to reduca the likelihood of failure of the 16 reactor protection system to shut down the reactor 17 following an ticipated transients, and mitigate the 18 consequer.cas of anticipated transients without scram.
19 Extensive comments were received from the public.
The 20 staff is currently in the process of analyzing the 21 public comments.
22 Today, in addition to hearing a report on the 23 status of this rulemaking, I as also hopeful that we can 24 determine the schedule f or issuance of a final rule.
25 Unless my fallow Commissionars have any other ALCERSON REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W.. WASHINGTON. D.C. 20024 (202) 554-2345
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opening comments, I would tura the meeting over to Mr.
2 Dircks.
3 COMMISSIONER AHEARNE:
I guess the only 4
comment I would make is, I think that the proposal we 5
put out actually had two alternatives and referenced a 6
third.
We did not actually put out a third.
7 CHAIRMAN PALLADINO:
I just re-read it and it 8
said four --
9 COMMISSIONER AHEARNE:
That is the staff 10 paper, but the rule had two.
11 CHAIRMAN PALLADINO:
Maybe.
12 COMMISSIONER AHEARNE: 'The staff paper had 13 four.
14 MR. DIRCKS:
I think you are touching on the 15 problem of ATWS, we ace not quite sure.
16 COMMISSIONER AREARNE:
As I mentioned to Bob 17 earlier, I think the problem with ATWS is that the staff 18 repeat time on this is longer than the time constant of 19 our memory.
20 MR. DIRCKS:
It is older than history in the 21 agency.
22 What Bob Bernero is going to do today is carry 23 on in the tradition, and describe to you some approaches 24 to the resolution of the AIWS problem.
Certainly, we 25 don't have any resolution today.
1 ALOEASON REPCATING COMPANY, INC, 400 VIRGINIA AVE.. S.W., WASHINGTCN, D.C. 20024 (202) 554 2345
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1 Bob, why don't you carry on.
2 MR. B ER N ER O :
Well, to start I would like to 3
go through just using the handout rather than the 4
formality of viewgraphs because there are relatively few 5
charts.
Do you each have a copy with you?
6 COMMISSIONER AHEARNE:
Yes.
l 7
MR. BERNERO:
Basically, I think it is usef ul 8
9 In fact, I admit to the flaw that the staff to return tima is longer than the memory span of the 11 Commission.
The Commissioners change and many of you, 12 or some of you aay find this an alien issue, so I have 13 included this slide to redefine the problem, ATWS, 14 anticipated transients without scram, or ATWT, as our 15 British brathren call it, anticipated transients without i
16 trip.
17 Basically, it is a plant condition where some 18 upset condition llis for a shutdown and the shutdown 19 system fails.
It fails to insert the rods, the control 20 rods, and typically, I have listed two examples, it is 21 due to some common cause failure lurking in the design.
22 There was an instance once quite some time ago 23 where a common failure of switch gear caused this.
It i
24 was a certain kind of varnish used and it became thermal 25 plastic from plant heat and caused a similar failure in ALCERSON REPORTING COMPANY,INC.
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all equipment of this type and, therefore, the rods 2
failed to fully insert.
3 We had in experienca in this country with 4
blockage of shared water discharge piping at Brown's 5
Ferry in June of 1980.
6 COMMISSIONER AHEARNE:
Bob, did the first one 7
setually suse the f ailure, or was it f ound bef ore it 8
caused the failure?
9 MR. BERNERO:
As I recall, it was the Kall to reactor in Germany.
It was an incipient f ailure.
11 COMMISSIONER AHEARNE:
Right, surveillance 12 found it.
-13 MR. 'ERNERO:
It was discovered before.
14 COMMISSIONER AHEARNE:
Right.
15 MR, BERNERO:
Similarly, the one, the 16 blockaged of share discharge piping wasn't total.
It 17 was not an ATWS in the full sense of the word that the 18 reactor was at power.
It was not a complete scram, but 19 the reactor had already red ucad the power to something 20 on the order of 30 percent.
Therefore, it was an 21 incomplete shutdown.
It was one side of the reactor 22 sffected because of the way tha the discharga piping was 23 arranged.
24 Ihe charactaristic that I would note about 25 this is, it is not the failure of a low reliability ALOERSON AEPCATING COMP ANY, INC.
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component, a common component, like we frequently speak 2
of reliability of diesel generators, there are two of 3
them to be sure that they start, that you have one 4
available.
5 Here we are talking about a much more reliable 6
system, and failure lurks in this lower probability 7
common cause area, and therein lies one of the 8
fundamental problems with ATWS.
You are not dealing 9
with obvious failure modes.
You are dealing with high 10 reliability systems and, therefore, rare event sort of 11 failures.
12 The characteristic of the failure is 13 significant, and I tried to indicate that next.
The 14 nuclear fission process, at least partially, continues, 15 so the characteristic of this accident is that you have 16 not only decay heat energy to take care of, but you have 17 some more.
18 You have higher than decay heat energy, and in 19 some cases this can be a substantial challenge to 20 containment or the heat removal systeits, and you now 21 have to turn, if the shutdown system doesn't work on 22 repeat demand, to some alternate shutdown system like 23 getting borated water in there, or something of that 24 order.
25 So these are the characteristics of tr.e ATWS ALDERSON REPORTING COMP ANY, INC.
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accident or ATWS threat, that it is typically a common 2
cause failure in i high reliability system, and it has 3
the characteristic of throwing a lot more energy into 4
the acciden t equation than one usually finds.
5 If you look it the next slide, I put the 6
chronology of ATWS because it is a painful trail.
If 7
you go back to the 1960s, questions were raised then.
4 8
In particular, the ACRS called for a study on CMF, 9
common node f ailure of the reactor protective system.
10 iThis started the era where we called on the vendors to 11 come up with analyses.
12 The nuclea r steam supply system v endors, who 13 are the ones who design these shutdown systems, began to 14 furnish analysis reports on this subject in the early 15 1970s.
16 Then, in 1973 a major document was publishedr 17 I generally associated Joseph Hendrie and S teve Hanauer 18 as the authors of this, it was the staff ATWS document 19 WASH-1270.
20 I might add, it also included in its early 21 pages one of the first safety goals that this agency, or 22 its predecessor, ever put out where the concept of 1,000 23 reactors in existence and a society tolerance of about 24 one catastrophy pe r millenium led to ten to the minus 25 six per year is the tolerance for a major catastrophic
(
ALOERSCN REPCATING COMP ANY, lNC, 400 VIRGINIA AVE S.W., WASMNGTON, D.C. 20024 (202) 554 2345
8 1
accident, and then a further factor of ten which could 2
be assigned to any one particular cause.
3 There came about then a safety goal for ATWS 4
of about ten to the minus seven per year.
That comes 5
ri?ht out of that document.
6 As we went along, just a couple of years later 7
W ASH-1400, the reactor safety study, did what purported 8
to be a detached appraisal of the actual risk of 9
accidents and found that ATWS was up there high enough, 10 quite a bit above the staff 's apparent safety goal, to 11 be even a dominant risk contributor in the boiling water 12 reactor.
13 I can return for the moment to that 14 characteristic of the accident, it has associated with 15 it more than the usual supply of energy because it fails 16 to shutdown the fission process and, therefore, when you 17 look at a boiling water reactor, you have got a 18 containment that is lower pressure design, and so forth, 19 and needs dynamic energy removal, therefore, more energy 20 is a greater challenge.
21 The history of the issue went on for a number 22 of years, and the staff position began to be published 23 in a major document that came out in multiple parts, 24 NUR EG-Ou60, parts 1 and 2 came out in 1978, part 3 or 25 volume 3 came out in 1979, and the last part, volume 4,
ALCERSON AEPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W., WASHINGTCN. D.C. 20024 (202) 554 23 5
9 1
which called for a solution came out in 1980.
2 It is two years ago that that document came 3
out and it represented a large amount of work, and was 4
the basis for the staff rule that came forward in the 5
first plaza, and it was highly structured.
I will talk 6
about those rules in a moment -- In fact, let me turn to 7
the next chart, it might be easier.
8 CHAIRMAN PALLADINO:
What is FREI 9
MR. BERNER0s Federal Register Notice.
What I 10 intended th e re was, it took a year for the Federal 11 Register Notice to go out, and tha t is the one you were 12 just discussing when we started.
Some of us referred to 13 that Federal Register Notice as a multiple choice test 14 for the selection of a rule, and I say that having 15 participated in it.
16 The rules that were before us at the time 17 could be characterized in three general groups.
The 18 staff rule, which was a variable, it was redrafted a 19 nu.nber of timas.
20 The staff rule could be described in general 21 tarms is a highly prescriptive rule, which included 22 substantial safety analysis requ? red.
The requirements 23 were set at a certain level of protection for existing 24 plants which an increased level of protection for later 25 pla n ts.
ALDERSON REPOATING COMPANY, INC, 400 VIRGINIA AVE., S.w., w ASHINGTON, O C. 20024 (202) 554-2345
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The utility group or industry position at tha t 2
time, and later culminatino in what we now call the 3
u tili ty grou p proposal, was for a much more simple set 4
of requirements, a reduced set of requirements and far 5
less analysis, turning more to generic analysis as its 6
basis.
7 The third rule, the one in the middle, which 8
we refer to customarily as the Hendrie rule, was put 9
together as a possible compromise solution by, le t's 10 see, then Chairman Hendrie, wherein the idea was to get 11 off the pattern where the staff would sit and analyze 12 the problem and lay out a catalogue of what to do, a 13 "how to fix it" kit for ATWS.
14 The idei was to go into a transition where the 15 initiative for reliability assurance with respect to 16 this threat was clearly in the hands of the plant owner 17 through some demonstrated program of systematic analysis 18 and appraisal of the problem.
19 That is a somewha t id ealistic a pproa ch,
20 certainly compared to current regulatory practice and 21 experience, so there was included in the Hendrie rule an 22 underpinning of immediate, somewhat simplified, fix 23 requirenonts.
24 So all three rules proposed to have certain 25 levels of fixes.
The utility group rule being the ALDERSON REPORTING COMP ANY, iNC, l
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simplest, the staf f rule being the most complex and also 2
including extensive analysis, and the Hendrie rule 3
taking something of a middle ground and setting great 4
store in tais shift of the baton to the owners.
5 OHAIRMAN PALLADINO:
Bob, I missed your 6
characterization of the utility group proposal.
7 MR. BERNERO:
The utility proposal would be 8
f ar fewer requirements, and essentially no plant 9
specific special analysis, far fewer fixes being 10 required.
11 If you turn to the next page, we have made a 12 chart there on the comments received, the 39 comments l
13 received l
14 CHAIRMAN PALLADINO:
May I ask you one other 15 question on the utility group?
16 MR. BERNERO:
Surely.
17 CHAIRMAN PALLADINO:
They apparently have 18 revised this; are you talking about the revised?
1 19 MR. BERNER0s Yes, for simplicity, I am going 20 to talk about the revised one.
21 When you look at the comments, a point I have
[
22 to make at the outset, the utility petition, really, 23 there is one major comment.
The utility group, as a 24 group, submitted i very large set of reports, basically 25 consisting of a wanoric probabilistic risk r.ali is for l
l ALDERSCN REPORTING COMPANY. INC.
400 VIRGiNi A AVE., S.W., W ASHINGTCN. D.C. 20024 (202) 554 2345
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1 each type of plant, and this whole body of historical 2
and techni:a1 argument to say what that petition or 3
proposition says, to support that rule.
We merely 4
counted that submittal as one of the comments.
5 C05MISSIONER AHEARNE:
When you say, for each 6
type of plant, do you mean each vendor?
7 dR. BERNERO:
Each vendor, yes, each nuclear 8
staam supplier, Wastinghouse, GE --
9 COMMISSIONER AHEARNE In a sense there are to four different 11 HR. BERNERO:
So that there are four plant in fact that looks like 12 snalyses, and it is a large 13 one of the volumes there, I think, the grey covered.
It 14 is very large, it is far greater than the usual body of 15 coument received on a rulemaking.
It is major piece of 16 work.
17 Ihere were ten others who wrote separate 18 submittals endorsing that, so we count it as 11.
But as 19 a ma tter of fact, of course, it is a very large group of 20 about two dozen utilities supporting that effort, and 21 saking that submittal.
22 Ine commen t distribution, if you will look at 23 it, included a large submittal for the utility rule, a 24 relatively large ausber for no rule at all, 18, and a 25 body of six which I would characterize as tepid support ALDERSON REPORTING COMPANY. iNC.
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f or the Hend rie rule.
2 COMMISSIONER AHEARNE.
Would Joe also ?
3 (General laughter.)
4 MR. BERNERO:
I don't know if Joe would or 5
not.
6 The difficulty with the Hendrie rule is being 7
able to ask yourself, is it a regulatory solution for 8
1982?
Now, at this time, can we converge on this as a 9
regulatory solution, or is it more a hopeful solution to for two years from now or three years from now.
This is 11 its basic difficulty, the basic question.
12 CHAIRMAN PALLADINO:
One of the things I 13 remember reading, the resea rch to su pport the Hendrie 14 rule would not be available until 1984.
My question is, 15 what is it in the Hendrie rule that needs research?
t 16 MR. BERNERO:
The whole question is, what are 17 the characteristics and what are the regulatory 18 requirements for in adequate reliability assurance 19 program, so that one could turn with regulatory 20 confidence and say to a reactor owner, " Don't show me 21 tha solution to ATWS in terms of boration pumps, or 22 redundan t trip mechanisms.
But, show me your design, 23 surveillante, analysis, and reliability assurance 24 program so that I will go away confident that you are 25 competent to deal with the problem, even though I don't l
l ALOERSON REPORTING COMP ANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON. D.C. 20024 (202) 554 2345
14 1
know how you are dealing with the problem."
2 It is a ma jor cha nge.
It is a 3
non-prescriptive solution.
You are buying the program 4
and not the solution.
5 COMMISSIONER AHEARNE4 You are buying the 6
program with even one step back in that it is not in the 7
details of the program, you are buying the competence of 8
the individual to generate a program.
9 MR. BERNERO:
At this stage, yes.
10 COMMISSIONER AREARNEs Io pick up the 11 Chairman's question, what research supports --
12 MR. BERNERO:
What we are doing is, we have an 13 arrangement with one licensee, and actually they are 14 using the ATWS_ rule as a stalking horse, with no 15 commitment.
16 This is not by any stretch interprated to be s 17 solution to ATWS for that licensee, but tha t licensee --
18 it is TVA -- they are willing to cooperate in the 19 experiment of setting up and running a reliability 20 assurance program for one technical issue, to develop 21 ideas and experience on how does one set up such a 22 program, how does one systematically operates such a 23 program, lad ioes one translate the results of such a 24 program into licensing and regulatory solutions.
25 COMMISSIONER AHEARNE:
When you say, ALDERSON REPORTING CCMPANY, INC, 400 VIRGINIA AVE., S.W. WASHINGTCN. D.C. 20024 (202) 554 2345
15 1
reliability assurance program, Bob, are you saying that 2
since ATWS, as you have described it, was characteristic 3
of a cosmon cause failure of high reliability 4
components, th a t the issue there you would be addressing 5
is how can you guarantee that the high reliability 6
component possesses the high reliability?
7 MR. BERNERO:
In essence, yes.
It is not 8
merely number crunching.
It is not merely trying to 9
prove that a certain component has an asserted level of 10 reliability.
It is looking at the problem, the system 11 that copes with the problem of assuring trip following a 12 transient, and systematically exploring the causes or 13 the possible contributors to failure.'
14 It would be program -- For instance, now in 15 retrospect it is easy for us to say, but it should be a 16 program which would foresee common cause blockage of th e 17 exit water from the scram discharge flow, and say: what 18 are the possible ways that the scran discharge flow can 19 be frustrated?
Does it include gaqqing the volume?
20 Does it include sticking vents, poor drain path, poor 21 plumbing some way or othat?
22 COMMISSIONER AHEARNE:
That sounds more like 23 probability analysis, or systems analysis, I am not sure 24 of the reliability part.
25 MR. BERNERO:
It would be an admixture of what ALDERSON REPORTING COMPANY, INC,
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we usually call probability or reliability analysis, 2
along with the systematic analysis that some of us refer 3
to as the basic design quality assurance, design and 4
operations quality assurance.
Systematic appraisal of 5
failura matas, systamatic appraisal of operating 6
experience in espacially upset conditions.
7 It is more than mere reliability calculations, 8
though.
B2t agais, you see, the difficulty of even 9
defining wha t it is is a signal, I think, that we don't 10 have a clear regulatory solution for 1982.
11 COMMISSIONER AHEARNE:
Are you saying that it 12 would carry with it an implication that having done that 13 type of analysis, that action would be taken independent 14 of any request on our part?
15 5R. BERNERO:
Yes.
The closest analogy I can 16 think of is, when the owner is pouring his concrete, we 17 don't certify the concrete, we certify the program by 18 which he sacs up the concre te pouring, and the 19 acceptanca standards, the criteria, and so forth.
20 COMMISSIONER AHEARNE:
Yes, except tha t that 21 program, as you just mentioned, does have acceptance 22 standards, and there are quality controls in those 23 standards.
So whan ha is pouring it, if he does it 24 correctly, he is running it against a set of standards 25 that tell him that if it doesn't meet these standards, ALDERSON REPCATING COMPANY, iNC.
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he stops pouring and has to redo it.
2
- 18. BERNERO:
It is not clear where the 3
reliability assurance program would leave us.
One is 4
left wi th the implication, at least, that you must have 5
a given level of reliability expressed quantitatively, 6
or a mixture of quantitative and qualitative reliability 7
statement.
6 Again, it is a very difficult thing to say, 9
this is the solution.
Some day maybe it will be, but to today, for 1982, we concluded tha't there is neither the 11 practical regulatory atmosphere for it, nor is there 12 strong support for it in terms of public comments.
13 COMMISSIONER AHEARNE:
Evea if there was an 14 atmosphere in your description, and one could very 15 accurately define that process of doing the analysis, I 16 still think that there would be an essential element 17 missing which is the standard against which one would even if it were the licensee after the 18 measure 19
- ompletion of that analysis, wha t would standard would I
(
20 be used to decide whether or not other action was 1
21 required.
22
- 52. BERNERO:
What are the standards and 23 criteria for a reliability assurance program.
We have 24 only the most tenuous ones now.
25 CHAIRMAN PALLADINO:
Are you speaking still of ALOERSON REPCATING COMP ANY, INC.
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the Hendrie rule?
2
.1 R. BERNERO:
The Hendrie rule, yes.
3 So basically what we are doing now is saying, 4
well, it really looks like we can nitrow our choice from 5
three basic rules to two rules, to what we call the 6
staff rule versus the utility rule.
7 COMMISSIONER AHEARNEa You had mentioned in 8
the paper, and it is again charactarizad on this set of 9
comments, that there were three comments that were 10 difficult to place.
You say, two comments were from 11 utilities which proposed specific fixes other than the 12 published alternatives, which led me to ask, what were 13 these specific fixes that were recommended, that were 14 other than the published alternatives?
15 MR. BERNER04 I don't remember.
Maybe Dave 16 Pyatt, who is here can remember.
Dave is the cognicant 17 engineer for this rulemaking effort.
t j
18
.1R. PYAIT:
I also don't remember the exact i
l 19 fixes, but I know that TVA, for example, had some of 20 each of the alternatives.
They said, rather than do 21 either the Hendrie or the staff, they had some specific 22 fixes for their plants that they falt could be 23 implemented as an alternative.
24 CHAIRMAN PALLADINO Weren't they worth 25 considering?
The mere fact that we don't seem to ALCERSON REPCRTING COMP ANY, tNC, 400 VIRGINIA AVE S.W.. WASHINGTON. O C. 20024 (202) 554 2345
19 1
remember implies that they must not have been.
2 MR. BERNERO:
Let me interject here.
One of 3
the probless with AIWS all these years is that it is a 4
complex problem, and it is almost like trying to get a 5
consensus on the dinner order in a Chinese restaurant.
6 You go down the menu --
7 COMMISSIONER AHEARNE:
You take one of each.
8 MR. BERNERO:
It is not only that.
If you try 9
to get a consensus on which vegetable dish, and which to pork dish, and which beef, and so on, you can get the 11 first person to give you a very succinct recipee for the 12 menu, and then tha next person says, "I agree with him, 13 but I want to change the vegetable dish from 401 to 14 403," and so on.
That is exactly the character of these 15 changes.
16 COMMISSIONER AHEARNE:
Yes.
17 CHAIRMAN PALLADINO:
Neverthless, I was 18 interested in knowing whether you thought they were 19 constructive.
20 COMMISSIONER AHEARNE:
Wha t led me to ask the 21 question, Bob, you had just said that, theCefore, you 22 could restrictsto two basic versions, and that led me to 23
- onclude that you already had dismissed these other 24 alternatives.
25 MR. BERNERO:
What you have done is force me ALDERSON REPORTING COMP ANY. INC.
400 VIRGINIA AVC. S.W., WASHINGTON. D.C. 20024 (202) 554 2345
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to.a point I was going to m ake a; couple of viewgraphs y-g 2
later, it is this business of th'e Chinese menu.
The
/! y i
U 3' curse of the ATW5 solution,' or the extension of the f
//
p/
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problem, has been just that, getting a consensus on a
.g y.'
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)5 h2 hly intricate formula.
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g j s:
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s i,2here it is a multi-part formdla, cri /.
.' B a
s
,f' 7
L ul ti-pir t solution, and whenever you seem to be a
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i 8
approaching a consensus, s o m e o n e wi.11 s ay, " Gee, that a,
9 sounds crest, except I wou d like to make one more I
j s a To
- chlnge, o'flyo more changes."
It has been a ga r
,/
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11 never-ending process of doing that.
I f
)
12 In fact, a dramatic example is one that we s
/
I (3
juct set a si de',
the Hendrie rule.
The Hendrie rule is, i
pre'scyiti.v,a;.
It< !akes care. of those,really important' 14 I
</.
/
15 fix es in th)e! mind o f t'h e au t, hers.' ~ It then says, on top g
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s t
5, I
a /,.
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16 of that, I,want4tc see thiri',one other thing.
This has 1-
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/.
4 b e e n)4 one of the pri'n,c2 pal r easo ns why the whole affair 3
17 7,,
i,c s 18 goes on and on a'nd on.
9 I f i
19 COMMISSIONER 1HEARNE:
I can well) accept i
20 that.
I uaderstand it'and sympathize, not as much f<
f 21 obviously a s Mr. Pyatt 'can.
But neverthele ss ~if there
- 223 were two alternative suggestions, you can say, "But ther 1
I mak6 any sense," and then I'. suppose there would 23 didn't s
e i
6
~
,24 b e, s:o m e rationale, o r you can say, since your proposal i t 25 here to rrifer to'some peer group and working group to i \\ ))
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t i I ALCERSoN REPCRTiNG COMP ANY, INC, 400 VIRGINIA AVE., S.W. WASHINGTON. O.C. 20024 (202) 534-2345
21 9
g 1
analyze, I guess I don't understand why you are not 2
saying that those sre alternatives.
/
3 MR. BERNERO:
The difficulty you have is that 4
it is not that the utility rule or the staff rule make 5
more sense than some intermediate proposal that TVA 6
hai.
It is just that you are looking at a snapshot of a 7
region on a sliding scale of fix.
You have a spectrum 8
of fixes, and you can't say that fix No. 17 doesn't make 9
sense, but fix No. 18 does, because there tre very 10 nearly the same.
They are not that far removed.
11 The potat wa are trying to reach is, if we are 12 going to reach a consensus, we cannot discuss a 13 semi-infinite distribution of fixes.
We have got to 14 narrow it down.
'J e have to come down to a much more 15 simple set, and make that set classification 16 intelligently.
17 COMMISSIONER AHEARNE:
That is fine, but let 18 se argue that there is a significant difference between, 19 even if it a denumerably infinite set and four.
20 MR. B ER N ER O.
Yes.
21 COMMISSIONER AREARNEs You have said that you 22 have narroded it basically to two, the staff and the 23 utility rules, and there seem to be two additional.
24 That is a whole different issue, but if there is value 25 for public comment going out in the process, I think we ALOERSON REPCATING COMPANY. INC.
400 VIRGINTA AVE S.W. WASHf NGTON, D.C. 20024 (202) 554 2345
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have some obligation, when the comments come back, to 2
say that we will seriously consider them, even if it 3
seans going fros two to four.
4 MR. BERNERO:
May I suggest, when I get to 5
this slide, the one about what the positions are, and I 6
think that will be fairly done, the consideration of 7
those intermediate solutions.
8 There have been many that preceded this and 9
there are many that follow.
Within the staff, we 10 constantly have differences of viewpoint.
11 COMMISSIONER AHEARNE:
Sure.
12 MR. BERNERO:
I just want to make a point with 13 this next slide, :enclusions of the utility group on 14
- ATWS, Not only was that body of submittal, that 15 super-comment on the proposed rulemaking a very large 16 piece of work and ve ry large submittal, but they made 17 some ringing statements with it, namely, that the staff 18 rule and the Hendrie rule failed the cost-benefit test, t
19 and based on their work the conclusion was drawn.
20 COMMISSIONER AHEARNE:
Did you analyze their 21 submittal?
MR. BERNERO:
We are in the process of it, I 22 23 will explain that.
l 24 COMMISSIONER AHEARNE:
So this may be 25 premature, but that sounds very similar to the argument i
l i
l l
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that EPRI came in with when we were going through the 2
final stages.
So I have to ask, is a large part of that 3
based upon a disagreement with staff on the 4
probabilities?
5 MR. BERNERO:
I suspect so.
This is a new 6
piece of work, though, as best we can determine.
We are 7
reviewing it now, and I would suspect in this field that 8
there would be disagreement on the probabilities.
9 COMMISSIONER AHEARNE:
That was part of the 10 issues.
11 MR. BERN ERO:
Remember when LaLouche was up 12 here discussing it.
13 COMMISSIONER AREARNE:
That is what I 14 thought.
15 3R. BERNERO:
I suspect the character of the 16 disagreement is similir, disagreemen t on the probability I
17 calculations.
But this, at least to our knowledge now, 18 is a completely new piece of work, so that we can't say 19 whether it is old stuff revisited, or really new I
20 material.
21 They also went on to say that the utility rule 22 is consistant with current policies, and further made l
23 the comment that the record of the rulemaking and notice 24 of rulenasing for the staff and Hendrie rules are 25 inadequate.
l ALCERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S/W., WASHINGTON. D.C. 20024 (202) 554-2345
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COMMISSIONER AHEARNE:
Could I jump you back 2
to your middle comment.
3 5R. BERNERO:
Yes.
4 COMMISSIONER AHEARNE:
Your slide says not 5
that utility rule is consistent, it says,that only the 6
utility rule is consistent.
7 MR. BERNER0s Yes.
8 COMMISSIONER AHEARNE:
In what way did they
.n onsistent?
~
9 feel that the staff rula was 10 MR. BERNERO:
They seem to be arguing tnat the 11 maount of saterial put out, the basis of analysis, the 12 amount of Federal Register proposal, and so forth, is 13 legally sufficient only to support the conclusion that 14 the utility rule is a0:aptable, and tha t anything more 15 than that would have an insufficient basis in argument.
16 COMMISSIONER AHEARNE:
Two and three are the 17 same?
18 MR. BERNERO:
Very nearly.
We are trying to 19 Characterize their position.
20 We have discussed with ELD this matter.
We 21 have, in the way of a comment here, a major new piece of I merely 22 woCk.
If we ame out, for instance 23 postulate this -- and said, "Bolderdash, this is all old 24 hat, we have heard it before and seen it before, we 25 stick with NUREG-0450, and we hold to a staff rule that ALCERSCN REPORTING COMP ANY, INC.
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25 1
was originally proposed, we might be able to conclude in 2
that inst 13:e that we can go out with a final rule, 3
without renotice."
4 On the other hand, at another extreme, if we 5
said, " Gee Whiz, this is a lot of good work in here, 6
this whole new thing which came out as a comment and not 7
as a part of the rulemaking record, if we put our 8
sassive or our sajor reliance on it and conclude the 9
utility rule," then we would have a serious question 10 about possibly having to renotice because the record is 11 all kind of mixed up then.
12 At least some renotice might be a possibility 13 for us.
This is a very, very mixed up record.
14 COMMISSIONER AHEARNE.
I can understand that.
15 I am still trying to focus on, I am trying to understand 16 what they meant by that the staff rule is not consistent 17 with current NRC poliries.
18
$R. BERNERO:
Bill Omstead of eld just handed 19 se their submittal, where they are saying that the only 20 one of the three that is consistent with the 21 Commission's current policies for new safety 22 requirements, and I at quoting, " Policies tha t encourage 23 the developm en t of a probabilistic safety goal, the use 24 of probabilistic risk analysis and cost-benefit 25 analysis, and an awareness of competing risks."
ALDERSCN AEPoRTING CCMPANY. INC, 400 VIRGINIA AVE., S.W, WASHINGTON. O C. 20024 (202) 554-2345
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COMMISSIONER AHEARNE:
I see.
2 MR. BERNERO:
They go on to say, "The group's 3
rule is consistent with these policies because it uses 4
both probabilistic analysis," etc.
5 Thank you, Bill.
6 They have made this rather strong set of 7
assertions, I thought your attention ought to be called 8
to it.
9 Dur intention is as follows:
First of all, we 10 have work going on right now to prepare a technical 11 analysis report of this massive submittal.
That work is 12 going on, and as I will show on the schedule, it is to 13 be completed by the end of August.
14 Then our intention is to form a task force 15 from staff members, all Renaissance men --
16 COMMIS"IONER AHEARNE.
There are no 17 3enaissance women?
18 MR. BERNERO:
No, we are going to be very 19 sexist on this task force.
20 We will draw these people from NRR, Research, 21 and IE staff here in Washington.
I will say later why I 22 make that distinction.
23 This technical analysis report will be 24 distribated to then, and for information at the same 25 time, we are going to keep the CRGR informed so that ALCERSON AEPORTING COMPANY. NC.
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there is no dead time lag in it, and the ACES 2
subcommittaa that tracks ATWS, I have already talked to 3
the chairman of that subcommittee, so that there is no 4
time lag there, that they are free to hold meetings at 5
the most opportune time.
6 This task force will meet and will have the 7
advice of a task force steering group, and I will show 8
you who the people are in a later slide.
Their basic 9
function is this -- and this is why they were chosen to from the rank of Renaissance men -- they have to narrow 11 this choi:3 intelligantly.
12 They have to consider those two " fall between 13 the cracks" contents, they have to cohsider all the 14 staff's thinking since then.
In fact, they are a great 15 deal of the staff's thinking, these people, when you see 16 their name.
You have heard thaa before and seen them 17 before.
18 Their agenda is basically to simplify the 19 process to three alternatives.
I put down here what I 20 currently think are the approximate alterna tives.
The 21 only one that is not an approximate is the first, th a t l
22 is no action, no rule on ATWS.
23 COMMISSIONER AHEARNE.
That is current 24 practice.
25 MR. BERNERO:
It is current practice, yes.
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(General laughter.)
2 4R. BERNERO:
Basically, then, we would say, 3
ATWS is no more than another severe accident sequence in 4
the panoply of severe accident sequences.
We go in 5
there and consilar it thare.
6 The other I put down as a probable alternative 7
is to adopt the utility position.
It is right now the 8
sost strongly supported and documented of, I will call 9
it, the lesser rules, or less prescriptive, or less to requiring cules.
11 Then go into the staff rule, the Hendrie Rule, 12 the others between the cracks, or whatever, and try to 13 set an alternative.
I suggest one here, alternative 3A 14 in th e ATWS parlance, that would be a representation, a 15 most reasonable representation of a more prescriptive, a 16 more demanding fix.
17 Keep in mind, some of the thinking that is 18 going on in this 2elling of alternatives is influenced 19 by the current Commission considerations of safety 20 goals, for instin e, probability levels.
We have had 21 quite a bit of development of that in recen t months, and 22 it is vary significant to this.
23 The basic strategy is to select three 24 positions, three alternatives.
No more Chinese menus.
25 You either take the enickan, the steak, or the lamb ALDERSON REPCATING CCMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345
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chops.
Those three alternatives would be offered 2
(General laughter.)
3 1R. BERNER0s This staff group would choose a 4
consensus position.
If you note who the people are, 5
that is an important staff consensus.
It is consciously 6
choosing people who are the isplementers, the people who 7
would make implementation of this a reality.
8 CHAIRMAN PALLADINO:
Do you mean achieving 9
consensus on the three options?
10 MR. BERNERO:
No, on the selection.
The task 11 force has the burden of deciding what are the three 12 options really before us, and then deciding which one is 13 tha propet staff consensus position. -
14 COMMISSIONER AHEARNE:
How do you see them 15 using PRA in reaching this position?
16 ER. BERNERO:
Wisely.
17 (General laughter.)
18 ER. BERMERO:
PHA is a fundamental element of 19 ATWS analysis and has been ever since the beginning.
I 20 see these people as being either themselves very i
21 knowledgeable in the field or supported by staff.
Many 22 of these people have professional staff.
23 COMMISSIONER AHEARNE:
Let me ask the question 24 somewhat differently, then.
25 Do you see them, either themselves, or with ALCERSON AEPCRTING COMPANY. INC.
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the staff or contractors, Aving any additional 2
probabilistic analysis or rather taking what has already 3
been done?
4 MR. BERNERO:
This time, I see no work de 5
novo, no new probabilistic analysis, but we are using 6
expert probabilistic analysis review of this work, and 7
comparing it to NUREG-0460 Volume 4,
which is the other 8
document of large significance.
9 The whole purpose, then, is a staff consensus 10 position is formed and it is presented to the CHGR, 11 which is part of our procedure now.
They have been kept 12 informed with the background literature to expedite 13 solution or consideration of it.
14 Ihen upon clearance through CRGR, the solution 15 would be offered to the Commission for adoption.
As I 16 said before, whether it be a final rule, or another 17 proposed rule, it remains for legal advice to tell us of 18 tha t.
19 COMMISSIONER AHEARNE:
You have just dismissed 20 the first op tion ?
21 3R. BERNERO:
No, I didn't intend to.
If that 22 were the solution, I think we would be compelled to come 23 to the Cos21ssion and say that that is the solution.
24 COMMISSIONER AHEARNE:
In which case, I think, 25 there would be a withdrawal from this.
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MR. BERNERO:
Yes.
2 COMMISSIONER ROBERTS:
Does the ACES get 3
involved at this point?
4 ER. BERNERO:
The ACRS is not directly under 5
sur control, but on rulemaking we ha ve a memorandum of 6
understanding.
I have already spoken to the Chairman, 7
Bill Kerr, of the ATWS Subcommittee, and we will defer 8
to their desires for when, where and how they wish to 9
discuss the analyses, the solutions, the proposed, 10 alternativas, so that they are in a position to give 11 timely advice.
12 We have not heard back from them.
They know 13 of this general schedule, and it seems a reasonable 14 approach to them, at least informallly.
So I would 15 expect that in parallel with the CRGR review, you would 16 see the ACRS review.
17 COMMISSIONER AHEARNE:
How do you see the 18 safety goal fitting into this?
I am looking at your 19 proposed schedule.
In what way would you envision this 20 task force using what version of the safety goal?
The task force won't have a 22 formal version.
They will be interpreting, and I think 23 the whole affair must be translated to you with an 24 interpretation of why this level of core melt 25 probability or core damage probability is considered ALCERSCN REPCATING COMP ANY, INC.
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1 tolerable, or is :ensidered intolerable.
The basis will 2
have to be clear, and the staff will be reading the tea 3
leaves on what you are going to adopt or endorse as an 4
implementation plan.
5 You are right at the end here.
You are, as 6
people say, at the short hairs.
You are talking here 7
about probabilities that are in the realm of ten to the 8
minus five per year, or ten to the minus six per year.
9 It is a very real question.
Are you going to pursue 10 individual accident sequences, or overall probability 11 ALARA or how ALARA down to these levels.
It is a very 12 delicate call.
13 A tolerant safety goal, a su b stan tially 14 tolerant safety = cal, tolerant on core melt probability 15 especially, might drive you toward no rule on ATWS or a 16 very simple rule on ATWS.
A less tolerant goal could 17 easily get you toward a more demanding, more like a 18 staff rule.
19 CHAIRMAN PALLADINO:
What would be a simple 20 ATWS rule?
21 3R. BERNERO:
A simple ATWS rule would be, on 22 boiling water reactors, recirculation pump trip, and 23 maybe not much else.
The scram discharge volume, some 24 basic things like that.
25 Ihen the more prescriptive, the more demanding ALCERSoN REPCRTING COMP ANY. iNC, 400 VIRGINIA AVE., S.W., WASHINGTON. D C. 20024 (202) 554-2345
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fixes, would get you up into additional shutdown system 2
switch gear, getting you up into relief valve over 3
pressura protection, a variety of things.
4 So given that this would follow it, we would 5
have the tachnical analysis report of the record before 6
us on or about September 1,
distributed to the task 7
force work group and to the CRGR and the ACRS for 8
information, whila tha task force is working.
9 In the month of September, the task force, and to ultimately the task force steering group, would meet in 11 cloister, with vodka and donuts to facilitate decision, 12 and reach this consensus.
13 CHAIRMAN PALLADINO:
This is the consensus on 14 which of these three options.
15 3R. BERNERO:
Yes, the selection of options 16 and the selection of the justifiable or desired option.
17 CHAIRMAN PALLADINO:
Can they do this in 20 18 days?
19 3R. BERNERO:
In some of our discussions, I 20 have asked myself over and over again, what are you 21 going to do in the next 30 days beyond that, if you 22 don't do it.
23 It is toca of getting the righ t people, with 24 dedicated attention, for a modest amount of time, and 25 saying, converge and make a decision, force a decision.
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Ihis whole procedure is intended to do that.
2 COMMISSIONER ROBERTS:
Can you briefly explain 3
the relationship between the task force and the task 4
force steering?
5 MR. BERNER0s It is a difference in the amount 6
of work, and also, if you will'look carefully, you can 7
see a first level management and second level management 8
relationship between many of the people.
9 The task force is selected from five people, 10 all of whom are very knowledgeable about the subject and 11 have long regulatory experience in a variety of ways, 12 either in PRA or in the actual.
Warren Minners and 13 Thadani are notorious for ATWS.
14 (General laughter.)
15 COMMISSIONER ROBERT 5:
Do they agree with that 16 characterization?
17 MR. MINNERS:
I paid my debt to society.
18 (General laughter.)
19 MR. BERNERO:
The steering rommittee includes 20 Roger Mattson and Steve Hanauer.
I am there because the 21 rulemaking responsibility is in my group.
My Branch 22 Chief for Reactor Risk Analysis, Gary Burdick, is up 23 there in the task force.
24 Then we brought in two people, two division 25 directors f rom the regions, Tim Martin from Begion I and ALDERSON REPORTING COMPANY. INC.
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John Olshinski from Region II, both of them are quite 2
knowledgeable.
The amount of time the steering group 3
spends is less, the effort and time, and th e resources t
4 for,the people in the field, for Rot 7r, and Steve 5
Hanauer, and so forth, is more rational.
6
'J e also hava questions about whi:h hat to l
7 wear.
For instance, Ed Jordan in IEE, who might very 8
well be involved, and myself are both members of the 9
CRGR.
So in this case, he sits as CRGR and I sit in 10 this task f orce steering group, and my alternate on the 11 CR3R, Denny Ross, would act as the CRGR member for 12 that.
13 CHAIRMAN PALLADINO:
It sounds like 14 interlocking directorates.
15 MR. BERNER0s It.is.
It is the ultimate 16 conflict of interests.
But basically, this is the 17 approach.
18 Dur feeling is that the only practical 19 solution, if thera be one at all, is to force a solution l
20 with sufficient homework done and sufficient time, not a 1
21 whole lot of time, and what amounts to a demands select 22 aither no action, todast action, or strong action, and 23 don't go around the table modifying and modifying and 24 modifying like we have done for years.
25 CHAIRMAN PALLADINO:
Must they reach a l
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consensus on the things they are not going to modify?
2 MR. BERNERO:
They have to reach a consensus 3
on the statement of th e rule, what are the requirements 4
of the rule.
5 CHAIRMAN PALLADINO:
They do that also within 6
the 21 days?
7 MR. BERNERO:
Yes, in the month of September.
8 It is going to involva at least two to three weeks of 9
work for the task force, and a good solid week of work 10 for the steering.
11 COMMISSIONER AREARNE:
You have got a 12 com mitm ent for those people to put in all that time?
13 MR. BERNERO:
Yas.
14 It is basically not something that has 15 suffered for lack of attention, you know.
ATWS has had 16 inordinate resources poured into it, and years'and years 17 of staff affort, contractor effort, industry effort.
18 3R. DIRCKS:
I think that it has created 19 another one of these clouds of ancartainty that hangs 20 over the whole process that one way or the other we have 21 got to get rid of, either vote it up or down, get it 22 enacted or not enacted.
We just can't have this 23 uncertainty hanging over everybody in the agency.
24 CHAIRMAN PALLADINO:
I agree with that, and I 25 agree that getting together for a concerted effort is a ALCERSON REPORTING COMP ANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON. O C. 20024 (202) 554 2345
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good idas.
But I would nope that judgment would be used 2
that if you are getting somewhere, and you need another 3
few days, that you would use them.
Certainly.
But it is too much 5
of a temptation to take one more month and one more 6
alternative.
We want to avoid that at all costs if we 7
can.
8 Basically, that is the strategy.
I threatened 9
that I was going to have a final ATWS rule buried in 10 here, and I wish I did.
11 CHAIRMAN PALLADINO:
Is that the paper to the 12 Commission?
When you say "Present paper to the 13 Commission," this the action document-?
14 MR. BERNE30:
Yes, it would be the action 15 document.
That could be one of three thinos.
It could 16 be a final rule f or adoption and promulgation.
It could 17 be a proposed rule because of the legal record 18 questions.
Or it could be a withdrawal or closure of 19 the rulemaking action depending on what the staff 20 position is.
21 CHAIRMAN PAL 1ADINO:
Bob, one problem I have, 22 I read these various proposals.
I read one, and I think l
23 I understand it.
I read another and I say, "3ee, that
[
l 24 sounds a lot like the other one."
25 Could you highlight the major fea tures of the I
i l
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staff and the utility rule, or maybe highlight the 2
differences as you understand them at the present time.
3 There are a number of places where they seem similar.
4 MR. BERNERO:
Let me try to do it in general 5
terms, I am not rasily prepared to go into the 6
particulars.
I would welcome support from Roger 7
Mattson.
8 CHAIRMAN PALLADINO:
I in expecting that the 9
staff has a better talking knowledge than I do.
10 MR. BERNERO:
Or than I do.
11 CHAIRMAN PALLADINO:
I was thinking of your 12 talking knowladge, but not in such specific detail.
13 MR. MATTSON:
There is one f airly easy way to 14 characterize the alternatives that are in front of you.
15 I will leave out the "do no thing," except to say that 16 our estimate, fairly solid over the last four or five 17 years, is that the probability of the big ATWS is on the 18 order of two times ten to the minus four per year of 19 reactor operation.
20 CHAIRMAN PALLADINO:
Does th a t take into 21 account Navy experience?
That was one of the things 22 that 23 MR. MATISON:
It is not inconsistent with the i
24 Navy experience.
25 CHAIRMAN PALLADINO:
I don 't know what that ALCERSON REPORTING COMPANY. INC.
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means, but does that mean you took it into account?
2 MR. MATTSON:
Yes, sir.
3 THAIRMAN PALLADINO:
That was one of. the 4
points that the utility group made.
5 MR. MATTSON:
Yes, that is a point of some 6
long standing difference among us.
We probably should 7
discuss that in private.
8 THAIRMAN PALLADINO:
Okay.
At least 9
e ve ry thing that is in there, you took into account.
10 MR. MATTSON:
Yas.
11 The proposal by the utility is essentially a 12 prevention only proposal, no mitigation of ATWS.
The 13 staff's proposal, alternative 3A, came out of 14 NUREG-0460, Volume 3, it is some prevention plus some 15 mitigation of ATWS.
16 the philosophy being that yo u can ' t ever prove 17 that you have done enough to prevent it.
To meet the 18 safety goal, because of common mode failures and the 19 inability to f orecast them, th er ef o r e, you put in a 20 little mitigation to make up the difference.
21 CHAIRMAN PALLADINO:
What sort of mitigation?
l 22 MR. MATTSON:
In the case of the boiler, the 23 improved raliability of the standby liquid control 24 system, and the ability to inject boron reliably.
25 CHAIRMAN PALLADINO:
Don't they both have ALCERSCN AEPoATING CCMPANY, INC.
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40 1
1 injection of boron?
2 MR. MATISON:
The utility alternative has the 3
standby liquid control system, it is unable to cope with 4
an ATWS event, It hasn't sufficient --
5 CHAIRMAN PALLADINO:
Adequately, is that what 6
you are saying?
7 MR. MATTSON:
With minor ATWS events, it could 8
cope with them.
It coulan ' t cope with what we believe 9
is the two times ten to the minus fourth event.
to CHAIRMAN PALLADINO:
It doesn't do it fast 11 enough, is that what you are saying?
12 MR. MATTSON:
Not enough delivery fast enough, 13 that is right.
14 Alternative 4A, which is the staff rule in the 15 proposal for rulemaking, is prevention plus mitigation, 16 that is, let me call it, goldplated mitigation, a highly 17 reliable system.
I think it is fair to say that since 18 you published a draft safety goal, alternative 4A is, in 19 the staff's view, if I can sense it, overkill.
It is 20 too much.
Alternative 3A is closer to your safetr 21 goal.
22 CHAIRMAN PALLADINO:
Is the chief difference 9W 23 between 3A and the utility 4this standby liquid control 24 system, making it larger?
25
- 13. MATISONs Yes, that is the chief ALCERSON REPORTING COMPANY. INC.
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41 1
difference.
2 CHAIRMAN PALLADINO:
What about snalyses, is 3
there major difference there?
4 3R. MArriiLN:
Yes.
The utilities would do it 5
without plant by plant or design type by design type 6
analysis to prove conformance.
7 One of the difficulties with 3A was that it 8
was developed on the basis of some analysis and some 9
projection as to what we thought some of these changes 10 would do.
The projection in the case of the boiling 11 water reactors was fairly oven out by a generic 12 analysis -- Warren, correct me -- in 1979 or 1980, but 13 there remains to be some analysis.
14 I think that is part of the task in front of 15 the people who will be looking at these things over the 16 next couple of nonths.
There is not a lot of difference 17 between 2A and 3A except for changing the standby liquid 18 ontrol system reliability in the case of the boiler, 19 and all of these analyses.30 if we eliminate the 20 analyses, we might close the dif f erence between us and 21 the industry.
22 COMMISSIONER AREARNE:
Roger, is there any 23 difference between them in the way they treat either 24 dif f erently PWRs, or amongst PWRs, different vendors of 25 PWRs?
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MR. MATISON:
Warren reminds me that I have 2
not placed enough emphasis on the PWR problem here, so 3
let me talk about that for a sinute.
4 Th e Westinghouse plan ts by and large do not 5
have an ATWS problem.
The relief capacity of the 6
Westinghouse design always has been higher.
The 7
reliability of the design of the auxiliary feedwater 8
system and the scram reliability is judged to be higher 9
for the Westinghouse design.
10 There are some Westinghouse plants where that 11 is not.true, because they are sensitive to 12 architect-engineer parts of the plant.
For example, 13 Surry was a Westinghouse plant that was used in 14 WASH-1400, and the reason it turned out good, because it 15 had the good ATWS design.
There are other Westinghouse 16 designs that we know are not that good.
17 B&W and C-E lack pressure relief capability to 18 neet the 4A prescription, but if you understand the 19 difference between 3A and 4A is the amount of l
20 titigation, then you also understani that the amount of l
21 mitigation is measured in terms of the probability of 22 exceeding the mitigation ca pability.
23 So if you lower the probability that you are 24 going to live with, that is you want to cope with 90 25 percent of ATWS as opposed to 99 percent of ATWS, then l
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what you are doing is giving the existing relief 2
capability the possibility of keeping up with certain 3
AIWS events.
4 So it is really a risk control solution f or 5
tha PWRs.
You decide what risk level you want, and we 6
can tell you whether you choose alternative 2, or 7
11ternativa 3, or alternative 4 That is wnether you 8
chose the utility proposal, the staff proposal 3A, or 9
the proposed rule, alternative 4.
So the key to the to safety goal is a very important question.
11 COMMISSIONER AHEARNE:
To still focus on the 12 question I have asked, though, are you saying that 13 depending on where you place that choice, on one side of 14 the line, you would place requiresents on ill PWRs, and 15 as you move the line, you begin to drop requirements on 16 some vendors and keep them on others?
17 MR. MATTSON:
Yes.
18 CHAIRMAN PALLADINO:
Roger, looking at the 19 utility group report, they come and describe the staff 20 rule, snd they list seven design f eatures f or BWRs.
21 Among the first five, the fifth one is an effective SLC 22 system.
23 They go on and say, "The utility rule agrees 24 in principal with items one through five.
The principal 25 differences are that item four and five of the staff ALCERSON REPOAT:NG COMP ANY, INC.
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rule must be autosatically initiated, and the staff 2
anticipates th a t f urther analysis, which the staff rule 3
also requires, would require a large rapacity standby 4
liquid control system."
I guess they are saying the 5
same th i ng.
6 MR. MATTSON:
There are two differences of 7
some long standing between us on the standby liquid 8
control system.
9 CHAIRHAN PALLADINO:
Sorry, Roger.
10 MR. MATISON:
One difference on the standby 11 liquid control system is whether it is 86 gallons a 12 sinute or
'4 3 gallons a minute.
I don't remember whether 13 their revised proposal was to change the plumbing and 14 pat it up to 86 GPM, I get tell from what was read.
15 MR. MINNERS:
I don't remember.
16 MR. MATTSON:
New plan ts, it would be 96, and 17 old plants, 43.
18 MR. MINNERS:
Yes.
19 MR. MATTSON:
The difference on automatic 20 versus manaal is another area where it may be possible 21 to draw the staff and the industry closer together.
22 We said in the NURE~-0460 documents that we 23 needed an automatic standby liquid control system.
The 24 reason was that you required this delivery of 86 GPM in 25 two minutes to rope with the so-called design basis ALCERSON REPCRTING COMPANY. iNC, 400 VIRGINIA AVE, S.W.. WASHINGTON, D C. 20024 (202) 554 2345
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ATWS.
2 Two minutes is pretty fast to rely on an 3
operatot to take that action, especially because if it 4
is an inadvertent operation of the boron system, he has 5
a big clean-up job and people are no t going to be very 6
happy with it.
Re has to make a tough choice in two 7
minutes.
8 A possible alternative has been talked about, 9
and that is to put a system on the standby liquid 10 control system much like the automatic depressurization 11 system, which is a sort of clock.
The clock starts 12 running, and if the operator doesn't intervene to stop 13 the clock in a two minute period, it is going to go 14 off.
15 It is like the ADS system, if you don't 16 intervene to stop the automatic depressurization system 17 in a boiler, it is going to go off automatically, but it 18 gives you a warning that it is about to go off 19 automatically.
If for some reason you know that it is 20 not supposed to, you can stop it from blowing down and l
21 messing up containment.
22 It may be possible that there is some l
$ct, 23 com promise between us on that p.
24 CHAIRMAN PALLADINO:
Even on the capacity, 25 they don't disagree with ha ving an effective SLC system, ALDERSON REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
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- I J
1 but they refer to the fact that the staff is going to 2
require an analysis which they believe will rpquire a 1
3 larger capacity.
D 4
I am not sure that you are not toge'ther gree.%
5 there.
I _- :::: that if the analysis showed A la'rger 6
capacity, the utility group couldn't be agaigst it, 7
could they?
8 MR. MATISON:
I am not sure.
t 9
What we have required for analysis is for the[
(
10 boilers to tell us, with engineering a n a ly sis',jthat what 11 they propose will work.
We think it will, and they N
I 12 think it will, but the analyses have not been done,to 13 prove it.
Somehow the analysis has to be done.
Ifiit 14 can be done generically, we would like that better than/
15 anything we can think of.
16 CHAIRMAN PALLADINO:
What I am getting at, I 17 didn't think you sete far apart.
18 COMMISSIONER AHEARNE:
Unless either the staff 19 or the industry has changed s'abstantially, they are 20 going to be far apart on their* assessment of thei 21 probability --
22 CHAIRMAN PALLADINO:
Yes.
23 MR. MATISON:
I don't think that is the 24 debilitating feature of reaching an ATWS solution today, 25 no, sir.
\\
l ALOERSON REPO7 JING COMP ANY, !NC, 400 VIRGiNI A AVE., S.W, WASHINGTCN, D.C. 20024 (202) 554'-23 4 f
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COMMISSIONER AHEARNE:
Roger, the only 2
difficulty is you and up bain; is far apart is the two 3
groups were a year ago.
You have got to reach 4
fundamentally different conclusions on the 5
cost-benefi.t.
1 6
MR. MATISON:
I am convinced that they will 7
lose on that scota -,
8 (General laughter.)
9 MR. MATISON:
-- in front of any reasonably 10 informed body.
11 We took that issue to the ACBS for over two 12 years, and we /
ed of it.
13 COMMISSIONER AHEARNE:
Roger, I agree with i
14 you.
i '
MR. M A TTSO NI, They;are wrong on that issue.
11 5 16 (General laughtar.)
/
17 COMMISSIONER AMEARNE:
Unless they have new 18 information, I agree with you.
19 The point was, as long as one says, we are 20 going to have a cost-benefit =riterion, which the i
21 Commission has said, and if you disagree very strongly, 22 two orders of magnitude on the probability, then you 23 'atve got to come out differently.
24 CHAIRMAN PALLADINO:
I was talking 25 specifically about the capacity of the standby liquid
\\
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1-
' control system.
It would seem that if the analysis i
2 shows that you nead a bigger rapacity, both of you would 3
agree that you need a bigger capacity.
4 00MMISSIONER AHEA RNE But the analysis may
- }
5 ' have fundamentally in there, when you get to what you 6
need, a kay.
/
7 CHAIRMAN PALLADIN0s I am not following you.
r f
8 1 CONNISSIONER AHEARNEs 9ha t I mz saying is 9'.tha t y'our nged can be colored by how probable do you s
t,
' 10 feel ~some of the avants'are.
if, 11 i
CH AIR M AN PALLADINO:
I didn't get that.
.d 00MdISSIONER'AHEARNEs I didn't read this 13 document.
CHAIRMAN PALLADINO:
To determine what is 14 e
15 needed, you have to have further analysis, and I was 16 thinking pure'y technical.
l 17 1R.,MATISON:
If you decide you want to fix 18 it, then you do the analysis that you referred to.
If i
1 19 it says that you have to have 86 GPM, you have to have 20 86 GPM in order to fix it.
21 I thin't John's point is, deciding whether to 22 fix it is s function of dollars and probabilities, and i
23 if you sre two orders of magnitude apart on the 24 probability, one of you eithat has to win or you have to 25 draw the two examples together.
x i
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CHAIRMAN PALLADINO:
Perhaps I read this too 2
literally.
3 Ihey all agree that we need an effective SLC 4
system.
Maybe it is the word " effective" that is 5
o pe ra tive, but I took that as meaning that it will work 6
the way it is supposed to when called for, and there is 7
uncertainty as to whether the capacity has to be bigger 8
or smaller.
That sounded like you ought to get together 9
on that one.
10 5aybe I an sisreading it.
It did not sound as 11 big a difference as otherwise indicated.
12 MR. MATTSON.
Except that it is the 13 probability of the bigger event that is at issue.
14 COMMISSIONER AHEARNE:
I gather you are having 15 sosebody go through it.
16
!R. MATTSON:
Yes, we will have that at least 17 clarified, if not rasolved.
18 CHAIRMAN PALLADINO:
They indicate two other 19 things here that the utility group doesn't agree with:
20 independent and diverse actuation circuitry for ATWS 21 mitigating systems, and automatic containment isolation 22 after fuel failure caused by an ATWS.
I can ask 23 questions more about the second one than the first one, 24 mainly because I don 't understand the first one.
25 Don't vs have adequate means for isola ting ALOERSON REPORTING COMPANY. INC.
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containment without adding special isolation 2
requirements because of ATWS?
3
- 13. MINNERS:
Warren Minners of EST.
4 It is always the question of adequate.
I 5
think what the staff is sayin7 is in ATWS you get 6
different signals than you do for a LOCA, and the 7
roatainments ira 7anarally designed to isolate for 8
LOCA.
9 So I think the question was to have some 10 radiation detection equipment that would isolate the 11 containment, s direct radia tion signal, rather than just 12 the LOCA system signal, which may not be present in an 13 ATHS event.
14 CHAIRMAN PALLADIN04 There are radiation 15 signals within the primary system, within the reactor 16 vessel?
17 1R. MINN dS:
Yes, it is mainly to close the 18 main steaaline isolation valve, as I remember.
I am l
19 reaching back in ny memory now, and I am not too sure l
l 20 anymore.
21 CHAIRMAN PALLADINO:
I see that works for the 22 staff, too.
23 (Genersi laughter.)
24 CHAIRMAN PALLADINO:
But if it is a radiation You tra not measuring 25 monitor, I am not sure what ALCERSON REPORTING COMP ANY INC.
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fission products in the water, or anything like that, 2
are you?
3 I am not sure what you are measuring, because 4
it says, "after fuel failure," and it seems to me, if 5
you go as far as fuel failure, you ought to have had 6
some other things isolate the containment.
7 MR. MINNEBSs That may not necessarily be 8
true.
It is what standard you want to use.
We were 9
ronsidering that Pa rt 100 was the requirement that would 10 have to be met, and there were some analyses that showed 11 that you might not meet Part 100 unless you had a 12 diverse means of isolating the containment.
13 HR. MATISON:
Just to make the point, and he 14 has made that point, this is why the safety goal 15 question is a good question.
If you choose through this 16 rulemaking to make ATWS a design basis accident, then 17 Part 100 is an interesting question.
Must we meet Part 18 100 for a design basis accident, I think the lawyers 19 will tell us, yes, we must.
Then you have to worry 20 about the dose calculation for Part 100.
21 On the other hand, if you choose to come to 22 ATWS and the systems to control it v ia probabilistic 23 risk assessment and the safety goal, then you calculate 24 the consequences in concert with the system design, and 25 you compare it to the safety goal and the dollar value ALCERSoN REPORTING COMPANY,INC.
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of the msn-ren, and you make i decision of how much to 2
fix.
4
( + U,g g,
3 There is a downside to proceedingA'* hat sounds 4
like a happy solution, that askes it easier to meld all S
these things together.
The downside is,
+h tis 6
sensitive to plant unique analysis, and tha t is the very 7
thing that the utilities are trying to avoid in their 8
comments -- don't do more analysis.
You are going to 9
have choices like this to make.
to CHAIRMAN PALLADINO:
There is another thing 11 that bothers me.
We have said several things about the 12 safety goals, and one of the thin;s I remember reading 13 and saying was:
We are not going to use the safety goal 14 as another layer of regulation, at least not for the 15 time being.
We are going to use safety goals to assess 16 our requirements.
We are going to go through our normal 17 regulation.
Yet, everything I hear, including this one, 18 puts it in as another requirement, possibly.
19 COMMISSIONER AHEARNE:
I don't think they are 20 saying, putting it in as a requirement.
They are more l
21 saying that depending on where you come out, it could 22 significantly affect where they come out in this rule.
23 MR. BERNERO:
The safety goal and the 24 character of its definitions of acceptable safety is a 25 very significant factor in choosing the appropria te ALOERSON REPORTING COMP ANY, INC, 400 VIRGINIA AVE S.W.. WASHINGTON, D.C. 20024 (202) 554-2345
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regulatory requirements for AIWS.
It is 1 very 2
significant contributor because we already have a long 3
history, note than ten years, of dealing with this 4
problem in probabilistic risk analysis phase, and the 5
safety goal illuminates.
6 We are hsve been talking for yests at what 7
level do I want to fix it; how far down in probability, 8
or how fst down in risk do Iwsnt to push this accident 9
sequence of concern.
We might translate regulatory 10 requirements into have a standby liquid con trol system 11 of 80 gallons a minute, or something like that l
12 CHAIRMAN PALLADIN04 That I can understand.
13 MB. BERNERO:
But at its root, that regulatory 14 requirement would have, at least implicitly, a basis in 15 probabilistic risk analysis, and the safety goal speaks 16 directly to th a t.
The safety goal, even what you have 17 on the street now has already very strong influence on 18 this whole consideration.
19 CHAIRMAN PALLADINO4 If you are using it as a 20 tool to decide which way to go.
21 MR. BEFNERO:
The regulatory requirements, 22 yes.
23 HR. MATTSON:
Let me see if I can take th a t a 24 step further.
25 CHAIRMAN PALLADINO:
I misunderstood that to l
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1 mean that it war going to be a plant by plant type of 2
assessment.
%tW 3
MR. MATTSON:
More important than Yi you are 4
doing plant unique analysis, is some feedback from your 5
gentlemen on now you want the safety goal used.
Let me 6
try to give you some numbers.
7 The Hendrie solution in WASH-1270 was a ten to 8
the minus seventh goal for ATWS, do not exceed a 9
probability of an ATWS at any reactor greater than 10 to 10 the minus seventh per year.
NUREG-3453 said, estimating 11 that ATWS is one of ten dominant contributors, and given 12 you don't want to exceed ten to the minus fifth per 13 reactor year, make ATWS ten to the minus sixth.
Your 14 safety goal says, don't exceed ten to the minus fourth 15 per year.
16 When we start to home in on this, the choice 17 between the utility rule and 3 A, that is between 18 prevention only and prevention plus mitigation, is in 19 the balance depending on how you use the safety goal, or 20 how you vaat us to use the safety goal.
21 ER. BERNERO:
Think of that with the 22 implementation plan.
23 CHAIRMAN PALLADINO:
I have been trying to 24 meet the burden.
25 COMMISSIONER AHEARNE:
Since we have been i
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wandering through probabilities of occurrence, I am 2
still trying to get a good understanding of this 3
dorument you sent out, I would like to understand --
4 CHAIRMAN PALLADINO:
Which document is that?
5 COMMISSIONER AHEARNE:
This is Pre crsors to 6
Potential Severe Core Damage Accidents.
7 What are the implications for ATWS probability 8
from this document?
9 MR. BERNERO:
Excuse me, is there a protocol 10 question addressing this?
11 As far as ATWS is concerned, I would have --
12 By the way, I have one of the principal authors, Joe 13 Min ne ric k, and Bill Cottrell from Oakridge National 14 Laboratory here, and we have been discussing this 15 document.
They are here to brief NRR on that document 16 tomorrow.
17 We have been discussing it, and I don't recall 18 anything on AIWS ger se.
Let me ask.
19 CO MMISSIO N ER AHEARNE:
I could not find it.
20 MR. BERNER0s The only one I know of was 21 Brown's Ferry in June 1980, which is half-year outside 22 of this one.
23 MR. MINNERS4 The precursor sequences have a 24 failure to spring probability in them, and they adopt 25 the W ASH-1' 00.
4 ALCERSON REPORTING CCMPANY, INC,
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MR. BERNERO:
Yes.
But as far as a precursor 2
of ATWS, va don 't have th a t until 1980.
3 CHAIRMAN PALLADINO:
Jim.
4 COMMISSIONER ASSELSTINE.
I have one 5
question.
6 Bob, when you described very briefly the 7
roaparison of the three alternative rules, you describe 8
the utility group's proposal as a reduced set of 9
requirements, and essentially no plant specific 10 analysis, and you described the NRC staff proposed rule 11 as a highly prescriptive rule, that included 12 requirements for detail and intensive plant specific 13 analysis on the prevention side only, and then later you 14 got to the question of prevention versus mitigation.
15 On the prevention side only, you say the 16 utility proposal is prevention only, without 17 mitigation.
The staff's proposed rule is a combination 18 of prevention and mitigation.
19 Could you characterize the degree of 20 prevention in the staff rule as opposed to the utility 21 proposal, that is, does the util'ty proposal propose to 22 compensate for not providing mitigation measure by 23 providing a much higher degree of prevention protection 24 tha n the staf f proposal, or is it the other way around?
25 MR. BERNER0sM1 ;o my perception, I don't know.
ALCERSON REPORTING COMPANY, INC, 400 VIRGINI A AVE., S.W., WASHING ~CN. O C. 20024 (202) 554-2345
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Roger, or Warren, do you.know of any ?
2
- 13. MINMERS:
I have not read the utility 3
proposal in detail, maybe Don Newton is here --
I 4
believe they are roughly the same in the prevention 5
area.
Roughly the same, not exactly, but roughly the 6
same.
7 MR. H3U5HTON:
Don had to leave.
I am Tom 8
Houghton with AMC, and we did a lot of this work for the 9
utility proposal.
10 We do have mitiga tion in our proposal in terms o f,dejautomation of the auxiliary feedvater system and the 11 12 turbine trip for PWRs.
We consider the manual 13 initiation f or the boron system as mitigation in the 14 boiler.
15 In addition, there is some very extensive work 16 that has gone on in operator procedures by the BWR 17 owners' group to consider this manual initiation, and l
18 that specifically includes the ATWS situation.
Ano the r 19 part of the staff is working on that area.
20 COMMISSIONER ASSELSTINE:
The other question I 21 had.. Bob, both you and Roger mentioned that one of the l
22 strongest concerns from the utilities in their comments f
23 is the requirement for detailed plant specific l
(
24 evaluations.
l 25 I think when you were talking abouC l
ALDERSON REPCRTING COMPANY. INC.
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formulating some variation, perhaps, of the staff and 2
the Hendrie rule, you mentioned the possibility of 3
looking again at the need for the detailed plant 4
specific evaluations.
5 Is one possibility, including perhaps a more 6
conservative set of prescriptive requirements as an 7
alternative to some or a large portion of the plant 8
specific evaluations that might have been contemplated 9
in some of the alternatives in the staff rule?
10 MR. BERNERO:
In theory, you could bound the 11 plant specific variation by including something of a 12 limiting fix.
C e r t ain1.y, the staff would like to see 13 relief on that ground, too.
14 There is a lot of industry resource, a lot of 15 staff reso2rces that would be tied up by plant specific 16 analysis, snd it might be that the judicious choice of 17 the solution, of the fix, would obviate the need.
18 COMMISSIO N EF: ASSElSTINE:
But is it possible 19 avan to have an alternative f o r mula tion; that is, you l
20 need a fairly significant or conservative set of 21 prascriptive requirements or, in the alternative, if you f
l 22 don't like that, you come in with a plant specific 23 avsluation to damonstrate that some lower level 24 COMMISSIONER AHEARNE:
To some extent, that is 25 11 Ways avsilabla.
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MR. MATISON:
We tried tha t once upon a time, 2
and that lad us to alternative 4A.
3 COMMISSIONER ASSELSIINE:
Yes.
4 MR. MATISON:
If we g e t rid of plant unique 5
analysis, I think it will not be in lieu of hardware.
6 It will be finding some clever ways to use generic 7
ana*jcts and stuff that has already been done to arrive 8
at a t chnical basis for saying that, if you fix it, 9
either 2A or 3A, then the level of protection isp c ' *. be 10 able to state what it is sufficient to satisfy you, if 11 you want to choosa 2A or 3A.
12 COMMISSIONER ASSElSTINE:
So it is essentially 13 not a trade off between the hardware hnd analysis.
14 COMMISSIONER AHEARNE:
You have to realize, 15 Jim, that iollars of hardware you are talking about in 16 some of these options are in the 55 to 53 million a 17 plant.
18 COMMISSIONER ASSELSTINE:
Very significant.
19 MR. MATTSON:
Between 3 and 4 that might be 20 the case.
21 COMMISSIONER AHEARNE:
Right.
22 MR. MATISON:
Not between 2 and 3.
23 COMMISSIONER AHEARNE:
No, it is when you get 24 into 4.
25 MR. MATISON:
Yes.
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COMMISSIONER AHEARNE:
As you say, that was 2
the previous attempt at it, and you got into u you were 3
up to thosa kinds of dollars.
4 CO MMISSIO N ER ASSELSTINE:
That is all I have.
5 CHAIRMAN PALLADINO One other question.
I 6
noticed in the utility plan, they have requirements 7
about specific operating procedures and operator 8
training, and yet that did not come up in the 9
discussion.
Is that a significant issue, Roger?
10 MR. MATTSON:
We have already done that, Mr.
11 Chairman.
We require as a matter of licensing today, 12 and hava a backfit requirement that they have ATWS 13 mitigating procedures which, in essence, say do the best 14 you can with what you have got.
If the rules come along 15 and change what you have got to deal with the ATWS event
{
l 16 17 CHAIRMAN PALLADINO:
Is that the case here 18 also?
19 MR. MATTSON:
Pardon me?
20 CHAIRMAN PALLADINO:
They are not saying any 21 acre than that, are they?
No. E d:At k b u e so.
22 MR. MATTSON:d I think what the gentleman just 23 said, and what that says, is that they are doing a good 24 job of those procedures, and if we would accept the 25 manual standby liquid control system, they are convinced ALCERSON REPCRTING COMPANY. INC.
400 VIRGiNI A AVE., S.W4 WASHINGTCN. D.C. 20024 (202) 554-2345
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that through trainin7 and procedure, that is good 2
enough.
3 CHAIRMAN PALLADINO:
Any other questions.
4 COMMISSIONER AHEARNE:
I would just like to 5
sake a comment.
6 I will be very interested in seeing this 7
process.
I will only comment that I will be leaving in 8
about a year, so I would like to take you up on your 9
proposal that I will have a chance to vote on the final 10 rule.
11 MR. BERNERO:
If this process doesn't work, so 12 4111 I.
13 (General laughter.)
14 COMMISSIONER ASSELSTINE:
I see you have a lot t
15 of support.
l l
l 16 MR. BERNERO:
Yes, I won this case in a raffle 17 while I was out of town.
l 18 (General laughter.)
19 CHAIRMAN PALLADINO:
I was introduced to ATWS 20 in the mid-60s, and I don't have much more time left.
I 21 would like to see it done in John Ahearne's time, too.
22
'....:. ' more?
J 23 (No response.)
24 CHAIRMAN PALLADINO:
Thank you very much, that Velf v s sj{illu m t a s tiv e.
25 1
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The meeting is adjourned.
2
( '4 h e r e u p o n, at 3.20 p.m.,
the Cc= mission 3
sdjourned.)
4 5
6 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ALOERSON REPCRT;NG COMP ANY, ;NC, 400 VIRGINIA AVE.. S.W., WASHINGTCN. O C. 20024 (202) 554 2345
m NUNAR REGULATORY COMMISSICN This is te certify that the attached proceedings before the o
COMMISSION MEETING in the matter ef:
PUBLIC MEETING - BRIEFING ON STATUS OF THE ATWS RULEMAKING Date of Freceeding:
July 13, 1982 Dceke Nu=ber:
Place of Proceed.ing:
Washington, D.
C.
were held as herei.1 appears, acd that this is the criginal transcrip:
therecf fer the fila of the Cc==issice Patricia A. Minson Official Reper.:er (Typed) h W
i Official Reporter (Signature)
/
4
BRIEFING ALTERNATIVES REGARDING ATWS RULEMAKING JULY 13, 1982 ROBERT M. BERNER0 0FFICE OF NUCLEAR REGULATORY RESEARCH
AES.
o ANTICIPATED TRANSIENTS WITHOUT SCRAM o
PLANT UPSET TRIGGERS SHUTDOWN o
SHUTDOWN SYSTEM FAILS TO INSERT RODS COMMON FAILURE OF SWITCHGEAR BLOCKAGE OF SHARED DISCHARGE PIPING o
NUCLEAR FISSION PROCESS CONTINUES MORE THAN DECAY HEAT ENERGY l
RELIANCE ON SECONDARY SHUTDOWN MECHANISMS l
CHRONOLOGY OF ATWS ATWS RAISED AS ISSUE; 1960's ACRS RECUESTED STUDY ON CMF 0F RPS FIRST NSSS VENDOR REPORTS 1970 - 1971 AEC STAFF ISSUED WASH-1270 1973 WASH-1400 EVALUATED ATWS 1975 RISK TO PLANT REVISED NSSS VENDOR REPORTS 1976 NUREG-0460, VOL 1 & 2 1978 NUREG-0460, VOL 3; RECUESTED 1979 EARLY VERIFICAT10N REPORTS FROM NSSS VENDORS NUREG-0460, VOL 4; REGUIRED 1980 IMPLEMENTATION JF ALTERNATIVE 4A FRN ON STAFF, HENDRIE AND UTILITY 1981 ALTERNATIVE RULES
I LOTARISDN_DE_ALTERNALIVERULES i
SIAEE lEllDRIE UI.lLilY_GROLE l
ANALYSES NET ACCEPTABLE PER-INCORPORAlE A ELIA-NONE PROPOSED.
IIASED EQUIRED FORMANCL CRITERIA ON BILITY PROGRAM.
ON A PRA PERFORED.
ATWS ACCIDENT.
DIVERSE MOST LIELY REQUIRED; MOST LIELY EQUIED, AFFECTS MOST PLANTS.
SCRAM SYSTEM FOR PLANTS AFTER 1969.
0 tiler SCRAM DISCllARGE SCRAM DISCilARGE SCRAM DIScilARGE EOUIREENTS VOLUE FIX FOR BWR'S VOLUE FIX FOR BWR'S VOLUE FIX FOR BWR'S AUT0 START MITIGATING Auf0 START MITIGATING AUT0 START MITIGATING FEATURES FEATURES FEATURES
?
ATWS RULE
SUMMARY
OF COMMENTS RECEIVED (39 TOTAL)
UTILITY PHlHD.tl HENDRIE RULE STAFF RULE NO RULE OTHER 11 6
1 18 3
i i
UTILITY HENDRIE STAFF NO RULE OTHER TOTAL UTILITIES:
10 5
14 2
31 PRIVATE CITIZENS:
1 1
2 REACTOR MANUFACTURERS:
3 3
ARCHITECT ENGINEERS:
1 1
2 ATOMIC INDUSTRIAL FORUM-1 1
CONCLUSIONS OF UTILITY GROUP ON ATWS 5
THE STAFF AtlD HENDRIE RULES FAIL THE COST-BENECIT TEST ONLY THE UTILITY RULE IS CONSISTENT WITH CURRENT NRC POLICIES THE RECORD AND NOTICE FOR THE STAFF AND HENDRIE RULES ARE. INADEQUATE i
STEPS TO PREPARE FINAL RULE o
PREPARE TECHNICAL AflALYSIS REPORT OF UTILITY GROUP STUDY ON ATWS o
FORM A STAFF TASK FORCE CONSISTING OF REPRESENTATIVES FROM NRR, RES AND IE f
o DISTRIBUTE TECHNICAL ANALYSIS REPORT TO TASK FORCE, AND FOR INFORMATION TO CRGR AND ACRS SUBCOMMITTEE o
TASK FORCE MEETS AND REACHES A CONSENSUS CHOICE FROM THREE ALTERNATIVES:
A.
NO RULE ON ATWS.
PUT INTO SEVERE ACCIDENT CONSIDERATION B.
ADOPT UTILITY PETITION.
THIS IS VERY CLOSE TO " ALTERNATIVE" 2A 0F NUREG-0460 (EXCEPT FOR WESTINGHOUSE PLANTS)
C.
CONSOLIDATE STAFF RULE AND HENDRIE RULE INTO A RECUIREMENT SIMILAR TO " ALTERNATIVE" 3A 0F NUREG-0460.
DELETE RELIABILITY ASSURANCE PROGRAM FOR NOW AND ELIMINATE EVALUATION MODELS o
PRESENT CONSENSUS POSITION TO CRGR o
PAPER TO COMMISSION
_______ _ -- _ ___-__ -____ -_-_ A
PROPOSED SCHEDULE o
PREPARE TECHNICAL ANALYSIS REPORT 9/1/82 AND DISTRIBUTE TO TASK FORCE, CRGR AND ACRS SUBCOMMITTEE o
TASK FORCE MEETS AND REACHES A 9/21/S2 CONSENSUS o
START REVIEW BY CRGR 10/15/82 o
REVIEW COMPLETE BY CRGR 11/15/82 o
PRESENT PAPER TO COMMISSION 12/1/82 6
w
1 O
TASK FORCE i
R. BAER (IE)
G. BURDICK (RES) i C. GRAVES (NRR)
W. MINNERS (NRR)
A. THADANI (NRR)
TASK FORCE STEERING R. BERNER0 (RES)
S. HANAUER (NRR)
T. MARTIN (R I)
R. MATTSON (NRR)
J. OLSHINSKI (R II)
J. SNIEZEK (IE) r c.,,...
F x
p* *%
y'
/q l
June 28, 1982 g
/
SECY-82-275 RULEMAKING ISSUE I nformation)
For:
The Commiss oners From:
Executive Director for Operations
Subject:
STATUS OF THE ATWS RULEMAKING
Purpose:
To inform the Commission on the public coments received on three alternative proposed ATWS rules and the current status of the rulemaking effort.
Category:
This is an information paper covering a major policy matter. Resource estimates, Category 1, preliminary.
Discussion:
Three alternative proposed rules were published for coment on November 24, 1981. One of these alternatives was developed by the NRC staff; the second alternative was a proposal by former NRC Chairman Joseph M..Hendrie; and the third alternative was originated by a Utility Group on ATWS (which represents 22 utilities). ' The Utility Group-proposed rule had previously been published on November 4, 1980. The due date for public comments was April 23, 1982.
Thirty-nine public comments were received and a tabulation of the organizations providing comments and their oreferences are given below:
Utility Hendrie Staff No Rule Rule Rule Rule Other Utilities
- 10 5
14 2
Private citizens 1
1 Reactor manu-facturers 3
Architect
-engineers 1
1 Atomic Industrial Forum 1
- Nine of these utilities were members of the Utility Group, but submitted individual comments.
Contact:
David W. Pyatt, RES 443-5960
The Commissioners Discussion:
Most of the utility comments preferred no rule on ATUS.
(continued)
However, many chose either the Utility Rule or the Hendrie Rule as the more favorable of the alternatives presented (including some within the Utility Group).
The No Rule category includes thou who felt that the risks from ATWS are already sufficiently low plus those who recommended combining the ATWS rulemaking with other Commission activities such as the Severe Accident Program or the development of a Safety Goal.
Three comments were difficult to place in either category.
Two comments were from utilities which proposed specific fixes other than the published alternatives, and one was from a private citizen.
The comments provided by the Utility Group on ATWS consisted of a three-volume technical report which includes a review and evaluation of past NRC and industry studies, a generic but substantial probabilistic risk assessment of the issue for each NSSS vendor, and a value-impact of all three proposed rules.
Their conclusions are:
~
1.
The Staff and Hendrie Rules fa'11 the cost-benefit test.
2.
Only the Utility Rule is consistent with current NRC policies.
3.
The record and notice for the Staff and Hendrie Rules are inadequate.
In order to resolve the ATWS rule issue, it will be neces-l sary for the NRC staff to evaluate the Utility Group report.
l This is currently being done (RES) with support by a technical assistance contract.
Although the proposed Hendrie Rule is intuitively appealing, it must be recognized that there is no detailed study available today to support it.
The Divi-sion of Risk Analysis (RES) has recently initiated a research program, which will eventually provide answers to many ques-tions about the Hendrie Rule.
However, the first results of this program will not be available until early 1984.
This may effectively preclude the Hendrie alternative from serious t
consideration.
A report will be prepared which contains a critique of the Utility Group study and other public comments.
This report will be circulated immediately to a Staff Task Force of RES, i
l
s 4
'/he Comissioners
-3,'
+
t NRR and IE personnel and for information to the CRGR and the ACRS.
The Task Force will meet and reach a consensus on the following alternatives:
\\,
1.'
No ATWS ruleLor include ATWS under the Severe Accident Program.
i 2.
' Adopt the proposed or a modified version of the Utility Group rule.
3.
Adopt the Staff rule or a modification of it.
4.
Adopt those portions of the Hendrie rule for which we have a technical basis.
8, The following schedule is proposed:
Provide input to Task Force, 9/1/82 CRGR and ACRS Task Force reaches a consensus.
9/21/82 of alternatives ReviedcompletebyCRGR 11/15/82 Present paper to Commission 12/1/82 William. Dircks Executive Director for Operations
Enclosure:
1.
Federal Register Notices on ATWS Rules i
DISTRIBUTION:
Commissioners OGC OPE OIA l
ACRS Secretariat l
l sTsn Proposed Rules
- " = ' " + ' "
h Vol 48. No. 20$
L Tuesday. Novecher *L 1961
[
g.
Ths of ma FECERAt. REGISTER action has been determined to be "not
- 23.1982. will be considered if practical t _,
contaes nouces to to cuche of me maior.
to do so, but only those comments preocsed issuance of ndes ard The Regulatory Fleubility Act(Pub.L received on or before this data can be I'
regutauons. The purpose of mese notces96-334) Is not applicable to this action; assured of consideration.
f, [p*Np,E*Ym.'"rufe theref re.a Regulatory Floibility ADORESsES: Comments should be r,
Analysts will not be prepared.
submitted in writing to the Secretary of b.
mawg ;nor to me adeptica of t!w final This proposed action is intended to the Commission. U.S. Nuclear r
eliminate an unnecessary bulletin.
Regulatory Commission. Washington.
F ',
thereby saving the Covernment the cost D.C. 20555. Attention-Docketing and
~
DEPARTMENT OF AGRICULTURE of periodic revisions.
Smice Branch. All cemments received This program is listed. J:e Catalog
.n and aII referenced and other NRC
[ ural Electrification Administration of FederalDomestic Assistance as documenis refevant to the ATWS issue j
10.850-Rural Electrifica Qcn Ioans and
.7 CFR Part 1701 Loan Cuarantets.10.851-Rural Mll WHdle fu pubhinspectkn in the Commission's Public Document K.
Prop: sed Rescission of REA Bulietin Rural b Bh
- Roorn at n17 H Street NW..
6 0
to, Washingtors. D.C. Copies ofreferenced 81-7:381-11 Ac Nev: Rural E!ectrification -
A written submissions made NRCreports may be purchased from the p
8
- "I nand Administratio'n, USDA.
pursuant to this action willbe made AcT :N: Proposed rule.
available for publicinspection dunng,
regularbusiness hours at the above Regulatory Commission. Washington.
i' suMuany:The Rural Electnfication address.
055m.
~
Administration (REA? proposes to
- ** "* " *" *" C"# CU b
Dated: November 1s.Iset.
cmrnd Appendix A-REA Bul!etins to David W. Pyatt. Office of Nuclear Harold V. Huntee.
- provida for the rescfasion of REA Regulatory Research. U.S. Nuclear Bulletin 81-7:381-11. ** Changes or Ad**8" ^
Regulatory Commission. Washington.
L.
Corrections in Une Constraction."
frn o. ewnc m n me =s D.C. 20553. (301} M3-3960.
which has become obsolete. The sea cocc suo. s.=
p primary purpose of REA Bulletin 81-regarding protection against anticipated i
I s on etion ange 0 e"
Ic NUCLEAR REGUt.ATORY transients without scram (ATWS)
REA Form 216 was rescinded in an COMMISSION events has long baen a subject of effort to eliminate unnecessary REA extensive and continuing study by the 10 CFR Part 50 NRC staff.The sigmHcacce of ATWS for 6
forms. REA Bu!!etin 81-7:381-11 ts reactor safety is that some NsWS considsred to be unnecessary.
Standards for the Reduction of Risk.
events could result in salting of the cc.TE: Public comments must be received From Anticipated Transients Without reactor fuel and the re! ease of a large i
by REA no later than January 25,1982.
Scram (ATWS) Events for L!ght. Water
- amount of radioactive fission products.
J ratss: Submit written comments to Cooled Nuciear Power Plants The pnncipal benchmaric for deciding ths Director. Engineering Standards ACfNcr. Nuclear Regufatory whether and to'what extent nuclear
}
Division. Ru'ai E!ectnfication Commission.
power plants should be modified i
Administration. Room 12 0. South Propcsed ruIe.
because of ATWS-related safety Action:
Building. U.S. Department of concerns is set forth in subsec*lon Agriculture. Washington. D.C. 20250.
suMMAar.The Commission is 1811(3) of the Atomic Energy Act.That FOQ FuTTHER INFORMATION CONTACT:
considering three alternatives for section grants !o the Commission the P
.\\fr. Edwin N. Limberger. telephone ( 02) amending its regulations to require authority to "presenbe such regulations 47-7040. A Draft impact Analysis has improvements in the design and or orders as it may deem necessary bien prepared and is available from the operation of!!ght. water coo!ed nuclear
- in order to protect health and to L
Dirzctor. Engineenng Standards power plants to reduce the likelihood of minimize danger to life or property."
Division. at the above address.
failure of the reactor protection system Throughout the history of regulating SuMEMENTAnY INFORMAT1oN: pursuant to shut down the reactor (sciarn) nuclear reactors, the dual Concept of
[
to the Rural Electnfication Act, as following anticipated transients and to preventing accidents and miti;2 ting amended (7 U.S.C. 301'et seq.). REA mitigate the consequences of anticipated their consequences should they occur.
I proposts to amend Appendix A-REA transients without scram (ATWS1 1.e defense in depth. has been used to y
Bulletins to provide for the rescisaion of events. This will reduce the overalf risk achieve this o(ective. Thus. conservative i
REA Bulfetin 81-7:381-11. " Changes or of nuclear power plant operation. The design. construction. testing.
T Corrections in Line Construction Since consequences of this regulation will be maintenance and operation of plants are nn significant effect on the economy will to require efectric utilities to install required so that accidents will not
- tA.
occur, since no significant increase in esttain equipment in nuclear power happen (i.e have a low probab.lity of cost for consumers subscribers.
plants and. possibly, to implement a occurrenceJ. Then to provide defense in L
industnes or Covernment will result.
reliabt!!ty assurance program.
depth, the capability to mitigate their
[-
and since no sigmficant impact on oATES: Comment period expires April consequences is required for accidents economic enditions will be caused. t! tis 23.1982. Comments received after Apn!
t!!at are postulated to cccur esen though I
- ..tr
.7
- i Fcdcral Rg;ister / Vol..in. No. 20tl / Tuen!.iy, Nmember 21. rat / P oposed Rules
~
57322 the design is required to include submitted to the Commission for neither of these alternative proposed measures to prevent them, consideration in.m early version in rules will. if promulgated. have a ATWS acc dents are a cause for SECY 80-409. September 4. I!mo, and in signi!! cant economic impact on a concern because a mismatch can final form in SECY 80-409C. November substantial number of small entities. ne develop between the power generated in 7.1980. The second NRC. proposed rule alternative proposed rules affect only the reactor and the power dissipated in is a recent proposal by former NRC the licensing and operation of nuclear controlled ways if the scram system Chairman Joseph M. !!cndrie.' Dr.
power plants.The companies that own fails to shut down the reactor following Hendrie's aim in starting afresh was to these plants do not fall within the scope a fault in the normal heat dissipation try an approach that would make of the definition of"small entities" set functions (transient events).The power licensees look carefully at their plants forth in the Regulatory Flexibility Act or mismatch can threaten the integrity of for ATWS.related vulnerabilities and the Small Business Size Standards set the barriers that confine the fission then fix these vulnerable areas.
out in regulations issued by the Small products. A core meltdown accident. In employing systems analysis or-Business Administration at 13 CML Part some cases accompanied by a failure of reliability techniques.
21.Since these companies are dominant containment and a very large release of De Commission believes that the in their service areas. this proposed rule radioactivity, is a possible outcome of likelihood of severe consequences does not fall within the purview of the some ABVS accident sequences.nua, arising fmm an ATWS event during the
- Act, s
the consequences of some postulated two to four year period required,to First NRC. Proposed Rule (the Staff ATWS accidents are unacceptable.
Implement a rule is acceptably small.
Rule) nere have been roughly one his judgment is based on (a) the thousand reactor years of experience favorable experience with the operatin8 The review and evaluation by the accumulated in foreign and domestic reactors. (b) the limited number of NRC staff of the information that has commerciallight. water. cooled reactors operating nuclear power reactors. (c) the been developsd over the past ten years on ATWS events and of the mannerin without an ATWS accident.This inherent capability of some of the experience suggests that the frequency operating PWRs to partially or fully which they should be considered in the of ATWS a cidents is less than or of the mitigate the consequences of ATWs design and safety. evaluation of nuclear order of once in a thousand reactor events. (d) the partial capability of the power plants is contained in the report years.There have been several recirculation pump trip feature to
" Anticipated Transients Without Scram precursor events, i.e, faults detected mitigate ATWS events that has been for I.lght Water Reactors
- NUREC-r that could have given rise to ADVS implemented on allBWRs of high power 0460. Volumes 1 through 4.There are events.nis suggests that the frequency level, and (e) the interim steps taken to two primary factors in the staf!'s of ATWS accidents though less than' develop procedures and train operators evaluation.ne first is the degree of assurance that ATWS events can be once in a thousand reactor years. may to further reduce the risk from some not be very much less. Such frequencies ATWS events. On the basis of these prevented which depends on the are too high for accidents of the severity considerations, the Commission believes reliability of current reactor protection described above.Thus the NRC has that there is reasonable assurance of systems.The second is the capability of
-- a determined that reductions must be safety for continued operation until existing reactor designs to mitigate the i
made in the frequency severity, or both implementation of a rule is complete.
consequences of ATWS events.
the frequency and severity of ATWS ne implementation schedule contained he reliability of cur ent reactor accidunts.
In this rule balances the need for careful proMon systems has been edmated.
1 no Nuclear Regulatory Commission analysis and plant modifications with b ed per 8 pe to has under consideration three proposed the desire to cany out the objectives of an b t r s,
- ver, alterna e rules, each ten ed to the rule as soon as possible.
the vety high level of reliability required accidents.T vo of these originated-Paperwork Reduction Act is difBcult to demonstrate with confidence because it depends on I
within the NRC, and are described A request for clearance of any accurately deternuning the rate of below. De third is set out in a petition application and reporting requirements common cause tailures. Common cause for rulemaking filed by twenty utilities of the alternative finally selected will be failures involve failures of multiple
(" Electric Utilities Petition." PRM 50-29.
submitted to the Office of Management components resulting from a single 45 FR n080. November 4.1980 and the and Budget under the Paperwork cause or event. Reactor protection supplement to the petition published on Reduction Act(Pub.I.96-311). At the systems are carefully reviewed to February 3,1981. 48 FR 10501).He time. the SF-43 " Request for Clearance." Identify and eliminate all but the most i
utilities
- petition will not be reproduced Supporting Statement. and related unlikely common catise failures.
here: however, the current period for the documentation submitted to OMB will However, one connon cause failure in utility petition is hereby reopened to run be available for mspection and copying the reactor trip portion of the protection concurrently with that of the two NRC for a fee in the NRC Public Document system of a commercial nuclear power m.j proposed rules for the purpose of Room at 1717 H Street NW.
reactor has occurred during comparing and contrasting the utility-Washington. D.C.
approximately 1000 reactor-years of petition with the two proposed rules Regulatory Flexibility Certification operating experience.ne failure was I
published herein.Both of the NRC-In accordance with the Regulatory detected during normal surveillance and proposed rules mandate improvements Flexibility Act of 1980. 5 U.S.C. 605(b),
corrected before any event requiring a
~ '
in ATWS prevention and mitigation.
ney differ in scope. approach, and the Commission hereby certifies that reactor scram occurred.There has also been one partial failure to scram in a The first NRC-proposed rule is known
'see the memorandum of ch.wm.a loseph M.
commercial power reactor. Which criteria.
Hendne to Comnussioners Cainsky. Dmdford..ad occurred at low power and resulted in
'l as the staff rule and is a direct
{
outgro,wth of NUREC-mGo. " Anticipated $'Q,Q%djj"'y"S(j,g*,
no core damage or radiation release.
Common cause failures have also o
Transients Without Scram for Light comm,,,ian s Public oocumens Roosi. snr H occurred in other systems in nuclear l
Water Reactors." Volumes 1-1. It was street.v.v. w.shwron, o.c.
D p.
F;d ral Reafster / Vcl. 46. N2. 2:8 / Tursday. Novzmbir 24, 1981 / Propos:d Ru!zs 57523 power plants and other potentfal alightly revised form in Volume 4. The Alternative : for the ten older plants
=
common cause failures in reactor intent of the proposed rule is to adopt a that began operation before late 1969.
protection systems have been identifed. combination of the attematives Because of their unique characteristics.
Bec use of the low rate of occurrence of recommended in Volume 4 (except for the stafIbelieved that more extensive e
c*mmon cause failures. operating one change for reactors designed by modiacations would not be appropriate
~
exp rience is not, and cannot be.
Westinghouse and licensed to operate for these plants. The proposed rule does a
sufficient to conclusively determine on a before 1984).The proposed rule wo 41 not explicitly address these plants statistical basis whether reactor implement the requirements in a (except in the implementation schedule).
protect!on systems are reliable enough different manner from that described in but the intent is to consider any to make the probability of unacceptable Volume 4 of NUREG-mco.The form of exemptions from the acceptsace criteria,
consequences from ATWS events the requirements in the proposed rule is of the proposed rule for these older a
acceptably small.no prediction of also different from that recommended in plants based on analyses by the common cause failures is as much art as NUREG-Ma0in that the proposed rule licensees and evaluations similar to I
it is science. System reliability analyses specifies acceptance criteria for ATWS those conducted under the a
that attempt to predict the nature and mitigating systems while the required Commission's systematic evaluation r
frequ:ncy of common cause failures mittgating systems are specified in progrars (SECY-77-561 October 1977) In stdhr from problems of completeness Volume 4.
context with the overall safety of these l
and accuracy, particularly when the Altemative lis to make no facilities.
desired failure rate'is extremely small modifications at all. As discussed, the Alternative 3. as modified!n the While quantitative estimates of NRC has concluded that the reliability proposed rule, would increase the protection system reliability provide of current reactor protection systems is reliability of the reactor trip portion of k.
important Information, the conclusion as insufficient with respect to ATWS and the reactor protection system for some to thudequacy of protection system that the probability of ATWS events is plants and provide for the mitigation of rellibility must be based on engineering suHiciently great to warrant most ATWS e' vents. The re!! ability of
(
Judgmint.The NRC has concluded that improvements. Therefore, this the protection system would be thneliability of current reactor alternative is not represented in the increased in the same manner as in f~'-
protection systems has not been proposed rule.
Alternative 1 However, this increased dembnstrated to be adequate and most Alternative 2. as modified in the reliability of the reactor protection N
lik ly is not adequate.
proposed rule, would incraase the system would not be required in plants i-n2 probability of severe reliabi!Ity of the reactor trip portion of that have a greater capability to mitigate p
cons 2quences resulting from ATWS reactor protection systems and improve ATWS events.The mitigation of most p
events is also affected by the capability the capability of existing systems to ATWS events in pWRs was expected to cf nuclear power plants to mitigate mitigate some ATWS events. Reliability be accomplished as in Altemative 2.
ATWS events. This capability varies of the reactor trip systems would be except that means would be required to s
dIpinding on the design of the reactor increased by the addition of isolate the containment early in an L.
systrm and the status of systems and supplementary protection systems that ATWS event upon detection of radiation r
ths values of system process variables would be independent and diverse from released from failed fuel. The mitigation at thi time the event occurs. The the reactor trip portion of the current capability of BWRs was expected to be L-capIbility of a plant to mitigate ATWS reactor protection systems. Diversity increased by providing automatic cysnts can be assessed by analy' sis, would be achieved by the use of initiation of the Standby Liquid Control L
Howsver, uncertainties in the design ccmponents from different System and increase its flow capacity.
chnracteristfes of the reactor, the manufecturers, by the use of Considering the state of design and y-probability of failure of the mitigating components having different principles construction, and a balancing of public 5
syst:ms and the probability that the of operation or power sources, and by safety benefits against economic cost H
vtluis of system process variables will the use of components in different the Commission proposes in this first be different from those assumed in the operating modes (normally energized vs.
rule that plants receiving an operating analysis all combine to produce normally deenergized). This alternative license before 1984 should be required to k
unc1rtainty in the results.Therefore, the would not provide increased reliability implement Alternative 3 as modified in difficulty of demonstrating a capability of the reactivity control portion of the the proposed rule.
ta edequately mitigate ATWS events is protection system. Le., the control rods Alternative 4. as modified in the
~
similar to the difficulty of demonstrating and control rod drives. However. Inthe proposed rule, would increase the th:t AnvS events can be prevented.
case of reactors designed by General reliability of the reactor trip portion of Based on analyses performed to date.
Electric it was proposed to increase ths the reactor protection system of all h:w:v:r. it is clear that. In most cases, reliability of a portion of the control rod plants and provide for the mitigation of 7
presint reactor designs have inadequate drive system. i.e., the control rod drive almost all ATWS events.The reliability i
capibility to mitigate the consequences scram dischars;e volume. The capability of the protection systems would be 6
cf mtny postulated ATWS events to mitigate ATWS events would be increased in the same manner as in i
should they occur.
Improved by providing actuation
' Alternative 2. The mitigation of virtually Having concluded that improvements circuitry that is separate from the all ATWS events was expected to be are n:eded to reduce the probability of reactor protection system for some substantf ally increased 77 additional severe consequences from ATWS existing systems such as primary system pressure relief capaciq w. the reactor
~
ev:nts, the staff developed four relief valves, turbine trip. and auxiliary coolant system.The mitigation alternatives, three of which would feedwater in pWRs and the recirculation capability of BWRs was expected to be
{
reduca this probability by increasing pump trip in BWRs. This alternative is increased by the addition of high 4
incr: mints and would require increasing very similar to the proposed rule offered capacity neutron poison miection nci ie safe cmounts of modifications. The by the utility group.
gyste alternatives were first described,m The staff propmc Voluma 3 of NUREG-04G0 and again in NUREG-0460 to implement only Commission propows in this fitst tu!e w
r i
f_ _..--
~
fideral !!cgieter / Vol. M. No. rS / Tuesd.iy. No em!mr 3. !M1 / IMesed Rules
= __
575M whe e :he level of safety is aircady high.
that these extensive design changes criteria for acceptable evaluation the Advisory Commit:ee on Reactor i
could only be practicai!y incorporated in models. Since the parameters in the Safeguards (ACRS) recommended plants not near completion and not to be evaluation model are uncertain to some omitting the requirement for degree and some may vary over the i
licensed before 1984.
lifetime of the plant, the level of safety is improvements in the protection system ne proposed requirements in Volume determined to a large extent by the reliability.Rus. the proposed rule i1 a
4 of NUREC-m60 were in the form of allows the protection system
{
specific design changes.The proposed degree of conservatism in the improvements to be omitted if more rule also specifies the design changes parameters used in the evaluation conservative values of the parameters, models, which effect the conservatism such as moderator temperature required to improve the reliability of the of the calculated consequences of coefficient are used in the evaluation protection system and the response for postulated ATWS events.The proposed models and the capability to comply containment isolation. but the changes rule specilles that realistic values of with the acceptance criteria is in mitigation capability are required parameters may be used when the value demonstrated. In plants licensed after through the specification of acceptance Is known with reasonable accuracy, but January 1.1984 or later the time criteria critena for evaluation models.
that parameters with large uncertainties available to design and install the and mitigating system design criteria.
must be conservatively treated.no modifications to the protection system is ne spec 2fication of cntena requires intent is to obtain realistic analyses of sufficient to ensure that the design licensees and applicants to demonstrate the course of ATWS events, yet predict process would not be compromised and that the designs of their plants are in the consequences conservatively. In improvements in the protection systems compliance and thus provides more order to ensure that the consequences of of allof these plants is required by the assurance that the safety objective is most ATWS events willbe within the being attained.nis form also allows the acceptance criteria. the proposed rule proposed rule.
Ooe plant modification that would be-designer more flexibility in design and a specifies that the value used for required by the proposed rule is already greater potential for minimizing costs, parameters that vary over the lifetime of beingimplemented on boiling water Although the ultimate safety objective the plant (the most significant of these la is to limit the release of radioactivity to the moderator temperature coefficient) reactors. In an order dated February 22.
the environment the acceptance criteria must be a value that is not exceeded 1980. licensees of BWR plants were in the proposed rule are directed toward over most or virtually all of the plant directed not to operate after December ensunns the integrity of the reactor lifetime. In the case of the moderator 31.1980 without a recirculation pump coolant system and the reactor core temperature coefficient, the value used trip installed. I.icensees have also been following ATWS events.'112e staff In the evaluatfon model that was less directed (IE Bu!!etin No. 80-17 dated July 3.1980, and NUREC-0737 recognizes that failure to satisfy these negative than the value expected to be
." Clarification of ThfI Action &n acceptance criteria does not necessarily experienced during 90 or 99 percent of.
Requirements") to ensure that operating result in severe radiological the design lifetime of the plant would procedures and operator training consequences and has considered the ensure that the consequences of most or address the actions to be taken in the additional safety margin in developing virtually all ATWS events would not plants as now designed if an ATWS did the proposed rule. In formulating the violate the acceptance criteria.
occur.These requirements are prudent proposed rule, the Commission has Although improvements in the measures that will reduce the risks from considered the need to compare for each plant the offsite doses that might result capability to mitigate ATWS events ABVS events during the interim period from ABVS events with10 CFR Part 100 provide a significant increase in the before the plant modifications guidelines Based on conservative level of safety, there is some uncertainty determined by the Commission to be j
generic calculations performed by the associated with this conc 2asion.This necessary can be Installed.
staff. there is reasonable assurance that uncertainty derives from the uncertainty In particular cases, additional calculated offsite doses from ABVS will in the reliability of mitigating systems requirements or earlier implementation.
be within the Part 100 dose guidelines if and in the evaluation models used to may be appropriate. For example, the acceptance criteria of the proposed define them.Because of this uncertainty candidates would be those existing rule are met. Accordingly, the the staff believes that improvements in nuclear power plants that a o Commissio !.as decided that applicanta reactor protection system reliability.
considered to be at high risk sites owing -
and licensees will not be required to should also be required.These to a combination of population density..
calculate the potential oiIsite modifications to present reactor meteorological conditions and other.
radiological doses resulting from an protection systems, as with any factors.
ATWS event under i 100.11.lf only modifications to a nuclear plant, have The proposed rule would provide for these guidelines for calculated offsite the potential forintroducing.
implementation of the requirements in doses were specified. the flexibility for unrecogmzed failure modes that could stages in order to gain the greatest the designer would be increased. but the result in a decrease in the level of increase in safetyin the shortest time attainment of the safety objective would safety. A carefulafesign process in and at the least cost.The modifications be more difficult to demonstrate.If conjunction with the quality assurance, to improve the reliability of the systems designs were speciSed.the
. venfication, and test programs is flexibility of the designer would be necessary to ensure that this will not protection system and the mitigatirut reduced. and the demonstration that the occur. However, the implementation of system actuation circuitry would be these improvements in reliability in required within two years of the safety objective had been attaineC
'some plants is to be accomplished accomplish this, descriptions of the effective date of the rule. In order to would be generic rather than for -
within two years. and such a short modifications are to be submitted for specified plants. Prior attempts at such a " design and installation schedule might review by the NRC within one year of generic demonstration have been -
compromise the design program. In the effective date of the rule.
unsuccessful, as discussed above.
The level of safety, that is, whether plants such as those designed by Pursuant to the Atomic Energy Act of Westinghouse, which have a enpnbility 4
most or virtually all ABVS events can to mitigate nearly all ATWS es ents and 1954, as amended, the Energy be mitigated,is specified through the
~
_ 3 n
D t
Fcd:ral Regist:r / Vol. 4tl. N2. 228 / Tuesday. N:v mb:r 24. 1981 / ProposId Rul:s 57323 F
Reorganization Act of 1974. as amended, the RCS pressure boundry does not models must represent the effect of the rnd section 351 of title 5 of the United exceed that permitted by the " Level C failures in mitigating systems that are a i
St:t2s Code. notice is hereby given that Service Lirrut" as defined in Article NB-direct consequence of the ADVS event t
adoption of thu following amendments 3000 of Section III of the ASME Boiler being modeled. For facilities issued to 10 CFR Part 50 is contemplated.
and Pressure Vessel Code and the operating licenses on or after January 1.
8 calculated deformation of RCS 1964, and not standardized to a facility L
PART 50-00MESTIC t.! CENSING OF components is !!mited so that the at the same site that was issued an PRODUCTION AND UTIUZATION operability of components necessary to operating license before January 1.1984.
FACILITIES safely bring the reactor to and maintain evaluation models must also represent
[
i L The cuthority citation for 10 CFR it at a cold shutdown condition is not the effect of the likely random single p
'1 Part 50 r: ads as follows:
Impaired, or (B) the integnty or' fadures of active components in operability of RCS components must be mitigating systems.
p Authority: Secs. taa.104, tat,182. tas. as demonstrated based ou conservative (ii)De value of parameters that vary Stat,936,937, 948. 953. 954. se amended (42 assessments of tests conducted to over the lifetime of the facility or USC 2122. 2134. 2:m. 2 :32. 2233): secs. 202.
- en, as Stit.1244.1246 (42 USC 5e42 ss4e).
determine the integrity or operability of represent the characteristics of unliss (therwise noted. Section 1*a also components under the conditions mitigating systems that are permitted by issued under sec.122. sa Stat. 9:9. 42 USC accompanying postulated ABVS events procedure to be inoperable for any f.
2:52). Sections 50.a0-50 at also issued under and based on the likely condition of the period during operation must be t
Sec.184. 60 Stat. 954. as amended. Secs.
components over their design life.
Selected so that values that would result I~
$hk S
,,Yofsc, (ii) fue/ integrity. The calculate,d in violation of the acceptance criteria demage to the reactor core as a would not be expected to occur during 2:3. 68 Stat. 95s. as amended: (42 UAC consequence of postulated ATWS (A) hiost of the design lifetime of 2:n). I 50.54(1) issued under sec. tett, as Set.9c (42 UAC 2:m(ill, and 1I sofo.
events. Including oscillations of power facilities issued operating IIcenses so.n and I sof a issued under sec. teto, es and flow, must be limited to ensure that before January 1.1984 or of facilities L
Stat. 950, as amended: (42 UAC 2:02(o)) and the core geometry is not distorted to an standardized to a facility at the same the Laws referred to in Appendices.
extent that would impair core cooling or site that was issued an operating license
- 2. A new I 50.80 is added to read as safe shutdown.
before January 1.1984.
('
(iii) Radioactivity release.He (B) Almost all of the design lifetime of follows:
calculated release of radioactivity from fa u issued opaW Uunsa on u l 50.60 Acceptance criteria for protection the fuel rods to the reactor coolant anu Januan 1.1W. except fastiu
,-against anticipated transient without scram system during postulated ATWS events standardized to a facility at the same g
events for Sght-water <ooled nuclear must not exceed one percent of the site that was issued an operating license pawn plants.
radioactivity within the fuel rods of a before Januaq 1.12.
(:) Definitions. (1)" Anticipated pressurized water reactor or ten percent (3Wgoung Systen: Meda. ATWS Tr:nsisnt Without Scrum" (ATWS) of the radioactivity within the fuelrods mitigating systems must be independent, m:ans en anticf pated operational of a boi!!ng water reactor, separate and diverse from the reactor occurrnce as defined in Appendix A of (Ivj Cantainment. The calculated protection system. ATWS mitigating i
this pirt followed by the failure of the containment pressure temperature, and reactor protection system specified in humidity resulting from postulated systems must be designed. qualified.
monitored and periodically tested to f
Crnzr:1 Design Criterion 20 of Appendix ATWS events must not exceed the ensure continuing functional capability 3
A of this part.
design values of the containment under the conditions accompanymg (2) "ATWS evaluation model" means structure and components or the t
ths calculational framework for contained mitigating systems, equipment postulated ATWS events. including i
natural phenomena such as r
evclutting the behavior of the nuclear and components. For boiling water earthquakes, storms, tornadoes, powIr plant during a postulated ATWS reactor pressure suppression hurricanes, and floods expected to occur L
evInt containments the relief or safety valve during the design life of the plant.
(3) "ATWS mitigating systems" means discharge !!ne flow rates and ATWS mitigating systems must be thosa systems including associated suppression pool water temperatures automadcally initiating when the L
controls. instruments, power supplies must be limited so that steam quenching conditions monitored reach cnd othsr systems assumed to function instability will not result in destructive predetermined levels and continue to when svaluating the behavior of the vibrations.
nuc!zar power plant following an ATWS (v) Long. term shutdown and cooling.
perform their function without operator action unless it can be demonstrated s
evint.
The reactor design must permit the -
(b)(1) Acce;:'tonce Criteria. Each light-reactor to be safety brought to and that an operator would have adequate I
information and would reasonably be watre-cooled nuclear power plant must maintained at a cold shutdown be designed constructed. and operated condition following potuived ATWS expected within the time available to so that the consequences of postulated events without inserta.." Aantrol rods.
take the proper corrective action.
anticipated transient without scram (2) Evoluotion Model Criteria. (i)
(4) Evo/uotion mode /s. Each applicant I
(ATWS) events calculated in ATWS evaluation models must, with or licensee shall submit evaluation accordance with an ATWS evaluation reasonable accuracy or acknowledged models as defined in paragraph (b)(2) of mod:1 approved pursuant to paragraph conservatism. represent the actual this section together with the I.
(b)(4) of this section conform to the characteristics of the facility modeled description and results of the analyses f
following criteria:
and each significant physical and test necessary to verify the validity o
(!) Primary system pressure. The phenomenon that would occur in the of the assumptions made in preparing I
calculatzd reactor coolant system (RCS) reactor and related systems during the such evaluation models to the Nuclear g
l pressure and temperature resulting from course of the modeled event. Evaluation Reguistory Commission for approval by l
postulated ATWS events must be (mthin six months of the effer.tive date 3
of the rule) or prior to issuance of an a
timited so that either (A) the calculated is,. 5 so.ss. tor.pprov.t or iht. tacorporatton maximum primary stress anywhere in tiy referm operating license, whichever is la ter.
s h
h i
g 5 TG S br.:1 i'.c;;ister / Ve!.
G. h :20 / rum!.iy. Lvc "Imr :1.16,1 / Pnmmed Rules (5) Plans heesmplicace. Each (iii) nose modifications necmary to reliability deficiences in those functions
. pplicant or IIcensee shall submit a reduce the common mode failure and systems that prevent or mitigate descnption of all measures to be taken potential of the control rod scram ABVS accidents. To cover the to ensure compilance with the critena discharse volume in plants designed by possibility that the reliability assurance set forth in paragraph (b)(1). (b)(2) and the Ceneral Electric Company including programs might fail to correct an (b)(3) of this section together with such diverse scram discharge volume level obscure reliability defect. some proposed changes in technical sensing devices: and additional requirements for ADVS specifications and license amendments (iv) nose modifications necessary to. mitigation would be selectively as may be necessary to ensure provide a supplementary reactor trip mandated.nese improvements in compliance with these enteria to the system that is diverse from the reactor ADVS tolerance of reactor plants have Nuclear Regulatory Commission as tnp portion of the current reactor been chosen to afford an opportunity to q
follows:
protection system.
learn from experience without incurring (i) For all light water. cooled nuclear
(:) Lemption. Pressurized light-a substantiallikelihood of an power plants for which operating water-cooled nuclear power p ants unacceptable radiological release.
licenses have been issued on or before issued operating licenses before January The NRC is exploring the possibility August 22.1969. no later than (eighteen 1.1034 or standardized to a facility at that the regulation of reactor safety may months after the effective date of the the same site that was issued an evolve toward regulating the process by rule),
operating license before January 1,1984 which licensees ensure public heath and (ii) For all light. water. cooled nuclear need not comply with the requirements safety and away from licensing the n
power plants for which operating of para' graph (c)(1)(iv) if the facility details of plant design and operation.
I licenses have been issued after A gust conforms to the requirements of Programs like the reliability assurance 22.1969. no later than (one year after the paragruph (b) of this section except that program in this proposed rule offer effective date of the rule) or prior to the fraction of the design lifetime used promise of growing into a formal issuance of an operating license.
to determine the value of parameters auditable way the NRC can determine I
i whichever is later.
must be greater than that specified in that IIcensees are doing a satisfactory (6) Implementation. Each applicant or paragraph (b)( )(i) of this section.
job of ensuring public health and safety.
l I
licensee shallimplement those measures (3) Submittal. A description of the A number of diverse regulatory necessary to ensure compliance with the measures together with such proposed initiatives are supportive of this tread.
enteria set forth in paragraph (b)(1) of changes in technical specifications or Among them are the requirements on
'i this section on the fo!!owing schedule:
license amendments as may be.
licensee' staffing and organization. the i
(i) For all light. water nuclear reactor necessary to ensure compliance with the proposal that licensees employ power plants for which operating criteria set forth in paragraph (c)(1) of probabilistic risk assessment methods licenses have been issued on or before this section must be submitted to the as design and operations management August 22.1969. by dates agreed upon Nuclear Regulatory Commission no later-tools. and the pilot studies of with the NRC.ncse dates must be than (nine months after the effective independent design reviews.'
submitted for approval not later than date of the rule) or prior to issuance of The necessity for and content of the i
(three years after the effective date of an operating license. whichever is later.
proposed rule is based on (1) operating (4) Imple nentation.Those measures experience to date with power reactor the rule).
required under paragraphs (c)(1) of this scram systems. (2) system reliability a
(ii) For aillight water. cooled nuclear reactor pogver plants for which section must be completed:
analysis. (3) the qualitative findings of operating hcenses have been or may be (i) For all light. water cooled nuclent reactor risk assessment, and (4) ABVS - -
Issued after August 22.1969. but before reactor power plants for which accident analysis.
(three years after effective date of the operating licenses have been or may be e
as nr dial rule), all modifications shall be issued after August 22.1969 but before g
completed prior to startup followm, g the (two years after effective date of the -
reactor.lt occurred at Browns t'arry Unit first refueling that begins (three years rule). all modifications shall be 3 n June 28.1m A!&wgh ee after effective date of the rule).
completed prior to startup following the padicular scram syste,m failure mode (iii) For alllight.wster-cooled nuclear first refueling that begins (two years Gat caused 6e went ts very unMy to reactor power plants isc<nsed on or after after effective date of the rule).
cause a sevue radiological release (three years after effective date of the (ii) For all light-water cooled nut! car accident. the event and the reviews rule), all modifications shall be reactor power plants !! censed on or after resulting from it revealed a numbcr of completed prior to issuance of an (two years after effective date of the reliability deficiencies in the BWR operating license.
rule), all modifications shall be scram systems. Dese are now being Actuotioniin addition to those completed prior to ismuance of an rectfied by the mdustry subject to the (c) Additiono/ requirements-(1) operating license.
rMew and approval of the NRC staff.
requirements set forth in paragraph (b)
(d) Dose calculations. Applicants or One objecuve of the proposed reliability of this section.cach light water. cooled lica nsces are not required to calculate assurance program is to iristRutionahze nuclear power plant except as provided the potential of!' site radia:ogical doses within the licensed industry the in paragraph (c)( ) of this section. must resulting from an anticipated transient be provided with:
w4hout scram event under i 100.11 of thorough evaluation and implementation
'j (i) Actuation circuitry for ABVS this chapter.
'sn. for cumpw. xac Acuan rian occweed miti; sting systems that is independent Sec nd NRC. Proposed Rulo (the As A Rnali of the nt!-: Acten rian* Nt:Un-and diverse from the reactor protection Ifendria Rule) 06ea
- Policy on Proceeding wi h Pendina system:
Canstruction Permit,and Manufactunna thanse (ii) Prompt automatic containm'ent The essence of the second NRC.
Appi canca sECwas.:co. and tJse or isolation initiated by a significant source proposed rule isihat power reactor trikpenden Design neue..tIDRshe the
"" tory Procns? SEChat-in Copin ut thne of radiation in the containment resulting licensees would be required to from failure of the fuel rods following implement a reliability assurance
[n,To'n" N c' N 7n$ $ 7 N postulated ABVS events:.
program to seek out and rectify
.N w. wa e ros.o c s
- v. 9 '
\\
~
i Federal Regist2r / Vel. 46. No. 2:s / Tursday. Novem6er 24.19a1/ Proposed Ruhs 57527
[
cf the lessens of experience with compromise the avalfability of one of studies lika those now being made In I
functions important to ATWS the systems required to initigate an respense to the Browns Ferry incident.
r i prevention or mitigatio:r.
ATWS event.or both.
These can be counted on to make a Rrliab tity daficiencies in safety
. Thus a third objective of the recurrence of that failure mode much p
systems differ substantially in the kind reliability assurance program is to less likely la the future.
- 1 p
and frequency ofosportunities to detect search out and evaluate the poten'tfal Calculations of the expected L.
and repair them. Some faults are seff-common cause failures that might consequences of very severe reactor cnnruncing ar.d thus elicit prompf
' contribute to failure in two or more accidents have been made in the i
repair. Others show up in each systems whose reliability is important to Reactor Sofety Stucfy (WASII-1400J '
suryciDance test. Some faults may not ATWS accident sequences. This search and other studies. The results indicate be r:vealed by routine surveillance should embrace noronly auxi!!ary that the accidents that could t:sts. For instance. the reIIability defect systems but also human factors via test.
reansticaHy be expected to result in l
resp nsible for the partial scram failure maintenance, and operations: technical lethal radiation doses outside the plant L
ct Browns Ferry could not have been specifications dealing with equipment site are those denoted as release i
detected in routine surveittance tests of availability: and environmental category 1. 2 or 3 accidents in the th2 scram system.
conditions in the plant.
notatioit of WASH-1400. These are also System reflability cafcu ations by the A fourth objective of the reliability the accidents that are expected to cause Electric Power Research Insdtute and. assurance program is to search out and substantial offsite property damage.
[
cth:rs have shown that component evaluate the susceptibility of the Studies of ATWS accidents in f;ilures of reactor scram systems that redundant divisions of each safety pressurized water reactors (PWRsl
[
cre d:tected and corrected in each system important to ATWS prevention suggest that only a small percentage of r
surnillance test are very unlikely to or mitigation to common cause failure.
reactor scrams are IImiting transients.
c:use AnvS events. Other system Concern with common cause failure That is, only a small fraction of the flihJe modes can'only be detected in modes of the scram system has been opportunities for ATWS accidents occur I
soma but not alt surveillance tests. Still central to the history of the ATWS under circumstances that most severely L
cth:rs show up only in some or a!!
controversy.
challenge the ATWS tolerance of the~
f.
genuine demands upon the system.
A common cause failure of an plant. In addition, the qualitative Soma reliability defects cannot be electrical nature has already occurred ht findings of PWR risk assessment studies d:tected even in genuine system a reactor scram system in a commercial suggest that even the most IImiting
^ d:mands unless triggered by other nuclear power plant (Kahl reactor) that classes of ATWS accidents in PWRs are
~
fritures. Examples of the latter category could have resulted in its failure to unlikely to produce a release category 1.
are the hydraulic design deficiencies in operate on demand.That failure was 2 or 3 radiological outcome.
tha BWR scram discharge systent detected during normal surveillance and In boit!ng water reactors (BWRs] a revsated by the incident at Browns rectified. A similar common cause substantial fraction of scrams take place Fstry. Such blind spots in the experience fadure was detected and corrected be under circumstances that can lead to a bass for safety systems cat :onceal the startup testing of the Monticello Ilmiting transient. BWRs are least serisus flaws in reliability.Thus a reactor. Estimates of the upperIhnits of forgiving of those ATWs events in second objective of the rel! ability the frequency of ABVS events for the which the reactor is isolated. Even if tssurance program is to conduct a commercial power reactor Industry are reactor isolation does not cause the thorough analysis of the startup test of the order of 10-8per reactor year.The transient in the first place. the effects of program, the surveillance test program.
NRC staff has concluded that operatin2 a failure to scram are likely to trigger tnd the record of system functional experience is not suf!!ctent to determine. reactor isolatfort. Furthermore. BWR risk ~
experience to identify and-where conclusively on a statistical basis assessment studies suggest that ATWS fusible-close loopholes through which whether reactor scram systems are accidents may give rise to release dtsign deficiencies. construction teilable enough to make the probability category 1.2 or 3 (as descnbed in d:ficizncies. vulnerability to test or of unacceptable consequences from WASH-14001 outcomes.
L mamtenance error. or component ATWS events sufficiently small.
These arguments suggest that PWRs failures might escape detection and thus The improvements==tmg fro =
Inay already achieve the minimum correction for considerah!e periods of the proposed reflability assurance ATWS tolerance necessary to time.
program will make ATWS accidents Tess supplement the rel! ability assurance Stud!cs,mtiated in response to the likely and the systems that mitigste a
program. whereas improvements should Browns Ferry partial scram failure AnVS events more re!!able.
be mandated for BWRs to strengthen mdicated that two auxillary systems,
Nevertheless, it is necessarf to ensure their provisio ts for ATWS mitigation.
l thtt s:rve the scram sytem as well as that mitigating systems wdi render the However, a more careful analysis of J
othzr systems. could have caused partial outcome of most AT'..S events ATWS tolerance is required in the t
or ccmplete scram failures.This acceptable. The principle of uitfense.m discovery is suggestive of a classof depth calls for reactor plan,ts to be proposed rule to provide the basis for
)
and form of actions to be taken by
]'
common cause failures that might designed and operated m such a way
- h.censees.
s comp omise the safety of a reactor.
that a rare ATWS accident can be Fai.ures in auxiliary systems might tolerated.
In PWRs. the IImiting transient with L
caus2 the initiating transient as wc!! as The requirements for ATWS tolerance respect to ATWS is a complete den ide the reliability of the scrum in light. water cooled commercial power interruption m the delivery of feedwater 2, stem. or they might contnbute to the reactors are intended to afford art to the steam generators at full power.
Shoufd the scram fail to shut the reactor scrum fai!ure and also could opportunity to learn from experience without placing the public health and f
- "Ud' ' " '" d'* '" u aThe ana.ry syrems ora.ae uvh. ven safety in leUEardy. Thst first occurrcnce from the Dhisiotr of Techmeal Informattom anl' g
system semag the scram discharge volumes. amt the compressed air system somny the air. ops.rmed of an ADVS precursor due to any oocuma cormut. uA.wc!=r stenut.aory scr2m v.shes.
particular failure mode will result in commm.on. was. :
mn. o c. m t
i L
/j.
37523 I;;iral Re;;ister / \\*11. 46. No. ::ti / Tuenlay. Non mber 24. 1931 / P c;'osed Rc!cs down. the continued power ;;cr.cration gross above-ground failure of pres ureinject:on system and (5) the and the declining heat removal. as the containment.This is not among the more integnty of reactor coolant pressure secondary coolant bods away, causes a probable outcomes of even the most boundary valves through which a LOCA surge in pressure of the reactor coolant.
severe and damaging pressure would bypass containment and could The severity of this pressure excursion excursions associated with ABVS in not be isolated.
is a sensitive function of the moderator PWRs.
In some PWRs. the very rapid temperature coefficient, the capacity of Analysis of ADVS transients by the autostart of the auxiliary feedwater the relisivalves attached to the reactor NRC staff and the reactor suppliers system following a feedwater transient coolant system. and the speed with suggest that Westinghouse reactors.
can overcool the reacter if the scram is which the auxiliary feedwater system have sufficient relief capacity so that successful. In such plants, the rapid start g
starts.The pressure surge will subside pressure excursions expected oflimiting logic may be interlocked to take place as the power decreases due to the ADVS transients will not be damaging.
only if the scram fails. However, such increasing moderator temperature.
provided that the auxdiary feedwater interlocks must not degrade the Subsequent reactor coolant system starts promptly. Combustion reliability of the auxiliary feedwater replenishment and reactivity controlis Engineering and Babcock and Wilcox system for the more frequent loss-of-provided by the high pressure injection reactors may be subject to severe feedwater transients in which the scram (IIPI) system, which pumps cooling pressure excursions even with prompt is successful and in which a delayed water containing a reactivity poison into start of the auxiliary feedwater system.
autosurt of auxdiary feedwateris the reactor coolant system.
should the ADVS accident take place appropriate.ne identification of the ne most severe test of the ATWS when the moderator temperature required instrumentation and the tolerance of a PWR lies in its survival of coefficient is unfavorable.The NRC staff training of operators may be made a the pressure excursion and in the has argued in NUREG-0400 that these part of the reliability usurance-suar N start of the auxiliary plants should Ir.atall additional relief program. and the verification that the feedwater and high pressure injection capacity to improve their ADVS instruments and the critical pressure systems.ne possible outcomes of the tolerance. ne industry has argued that boundary valves on the reactor coolant pressure excursion are (1) the reactor such modifications are very expensive, system have the required tolerance for coolant system and interfacing ~
will produce substantial occupational the limiting pressure excursions would exposures to radiation to those b'e part of the ABVS tolerance equipment are undamaged. (2) the reactor coolant system remains intact installing them, and are unnecessary requirements.
but instruments on the pressure because the plants already have The moderator temperature boundary fail or the valves for the HPI sufficient tolerance of the pressure coefUcient, which strongly influences '
system are damaged. [3] the reactor-excursion, according to their analyses in the severity of the reactor coolant coolant system is ruptured producing a proretary reports.
pressure excursion for limiting ADVS loss-of-coolant accident (LOCA) to The NhC. In reassessing its position, transients,is at its least favorable value containment. (4) steam generator tubes has concluded that the minimum ABVS during the early months of operation rupture causing a primary.to-secondary tolerance necessary to complement the with the first fue!!oad.The early months LOCA or a LOCA to other interfacing
' reliability assurance program does not of plant operation are also characterized systems. or (5) combinations of (2). (3) or dictate adt5tional pressure relief by a higher-than-average frequency of (41. ne first outcome is clearly capacity in CE and B&W plants in light transients and safsty system failures as preferred. ne second outcome makes it of the several mitigating factors noted the plant is shaken down and the plant clear that care must be taken to ensure above. However, there are a number of - personnel gain experience with the that the operators have sufficient other safety.related Incentives to alter equipment.nerefore.much of the risk information about the status of the the provisions for reactor coolant associated with ADVS accidents is reactor to manage the recovery. Should pressure reduction or relief In PWRs.
expected to be concentrated in the first '
the HP1 pressure boundary valves all These include deliberate months of plant operation. One seize in the closed alignment, the core depressurization to enable low. pressure mitigating facter is the less-than-will melt.His is one of several paths safety injection in small LOCAs and equilibrium Inventory of Ession products from ABVS to a contained core melt feedwater transients with scram, to accumulated in the fuel at this time.
accident. A LOCA to containment is avoid the melt-through of reactor vessels Nevertheless. FWR reactor licensees likely to be mitigated by the Emergency while at elevated pressure, and to would be required to propose and Core Cooling System (ECCS) even.
enable the ECCS accumulators to implement particularly stringent limiting though the initial pressure conditions extend the point of no return for the conditions of operation in the technical are outside the design envelope for restoration of AC power in station specifications to constrain operation ECCS analysis.Thus no core melt is blackout accidents.Re NRC expects to when combinations of the unavailability expected (although a contained core take up the case for and against altered of mitigating or preventive equipment.
melt is a remote possibility), and a core pressure relief provisions for PWR the prevailing moderator temperature melt with missile damage to reactor coolant systems in the coefficient, and the power level containment is a still more remote forthcoming rulemakings on severe encroach upon the toleranca of the plant possibility. Steam generator tube rupture accidents.
for the pressure excursions to be can provide a leakage path to the ne required ADVS tolerance of expected ofIlmiting AnvS transients.
outside atmosphere that bypasses PWRs rests: (1) upon the prompt start of In large. modern boiling water containment. However. ECCS is likely to the auxiliary feedwater system. (2) the reactors a transient with failure to be successful so the core would not availability of instruments necessary for scram from full power is very likely to melt. All but one steam generator can the operators to diagnose the ABVS cause. or may follow, the isolation of the very probably be isolated, thus accident sequence and successfully reactor, notably a trip.of the main steam terminating a minor release.
maneuver the plant to minimize the isolation valves. If the reactor coolant g
ne severe release category L 2. or 3 release of radiation. (3) the training of recirculation pumps continue to run, the events 4 cur only for a core melt and a operators. (4) the availability of the high power level w111 remain high and a 4
t 4
1
{
Fed 2ril Reyist:r / Vcl. 46. No. T'S / Tuisday. Noveinb r M.1981 / Propos:d Rules 57529 I
sevxra pressure excursion wil! take Reactor Core isolation Coding system AnvS events. mus threatening plac2. Even if the reactor coolant system (RCIC) shon!d be expected to autostart. successful mitigation. In some seqzence surviv;s the pressure sun;e. the very,
and run, delivering coolant to the variants, operators might be tempted tat y
high st2am ifow wi!! rapidIy heat the reactor."111e flow rate Je!ivered by the depressurire the reactor to enable !aw
.L suppression pool and pressurize the RCC is lower than that of the HPCI. if pressure reactor coolant injection but,in containment. !n addition. the high.
the RCC is the sole operative means of so doing. disable turbine-driven coc! ant p
pressure coolant infection (HPC) may replenishing reactorcoolant. the injection systems or otherwise not suf! Ice to cool the core: overheating adequacy of core cooling, rather thart compromise possible avenues of and care damage may foITow. Ultimately. the heat deposited in the suppression successful ATWS mitigation.The
[
E th2 containment is expected to rupture poof. Is likely to be the factor limiting reliability assurance program must du2 ts cverpressure while the core the time allowed to shut down the
' entail a thorough investigation of such sustiins damage. Continued care reactor withcut unacceptable ATWS accident sequences, of the -
coolant replenishment is questionable consequences.The RCIC can instrument indications available. and of after containmentrupture. Alarge successfully cool the reactor once it is the possible range of operator actions, r:diofogical release is a plausible shut down, and it can slow the bodoff of Operator training should familiarize outcome. A necessary mitigsting feature reactor coolant in the reactor.
operators with the optium strategies and F
s is thus a prompt automatic trip of the The NRC has concluded that the alert them to serious errors that could p
recirculation pumps to avoid the.
liquid reactivity poison injection syste:s occur in dealing with ATWS accidents.
pressure excursion and diminish the in large, modern BWRs must have a BWR reactor operators may be powir and the consequent steam flow to start time and poison infection rate such subjet.t to a strong disincentive tcr I
~
the suppression pool Cven a trip of the that either of two redundant trairts of
- actuate the Standby Liquid Contro!
recirculation pumps, the reactoa power high pressure reactor coo! ant (SLC) system because of the cestIy will st*bilize at roughly 30** power until replenishment systems. either of which nature of spurious SLC actuations. They th2 reictor coolant boils down and may be expected to be available under may also be inc!Inetf to override an stam bubbles (void formation} in the ATWS conditions.can successfully autostart of the SLC if they doubt that cars throttie the chain reaction.
mitigate ATWS transients.The two an ATWS Indication is genuine or the i
Thire:fter. a static or oscillatory trains may be the HPCl and RCC.
failure of the scram system is equilibrium wd! be maintained in which The criteria of successful mitigation irreparable. The NRC recognizeas the tha reictor sustains the average power are:(1)The containment temperature ligitimacy of the concern with the cost of F
nicessary to boil off however, much and pressure must remain within the spurious SLCactuation
-reictor coolant is delivered, up to about design envelope. (2} the core must retain To deal with these conIIIcting 303 power. Analysis shows that HPCI or coolable geometry,and (3) neither concerns, the NRC proposes to require main feedwater can adequately cool the prompt fatalities nor serious offsite the automatic start of the SLC system core to avoid extensive core damage, property damage are predicted by under c:rcumstances diagnosed to be Howsver, the power delivered to the analyses whose conservatism is ATWS sequences. Licensees are free to suppression pool will be greater than the compatibfe with that employed in employ reilability engineering methods pool cooling system can dissipate.
WASH-1400.s to minimize the hkettnood of spurious ThIrefore. containment overpressure Concern has been expressed that the actuations under non.ATWS futura remains a distinct possibility RC:C. though capable of meeting these circumstances provided these provisions unless the reactor is shut down, either success criteria, does not prevent the do not compromise the reliability of the l
by control rod insertion or by Ifquid automaticdepressurization of the essentfal SLC safety function in genuine J
reactivity poison infection. Well before reactor coolant system. Operator action ATWS sequences.
tha containment is significantly is necessary in less than ten minuted to In light of the analysis and operator pressurized. the suppression pool will override the automatic depressurization training associated with the reliability approach saturation, and the steam or to throttle low pressure ECCS should assurance program. It is not deemed 6
condinsation will become unstable.
the depressurization occur.The NRC necessary to preclude provisions for Chugging steam condensation may staff does not wish to force an alteration manually overriding the autostart of the l'
threaten containment intergrity or of the logic goveming the automatic SLC. As part of the reliability assurance prsssure suppression and thus shorten depresurization system (ADS) which program, a thcrough analysis is to be i
tha time available to shut down the might comprotnise the reliability of the made of the c:rcumstances in which an retctor without unacceptable ADS in non.ATWS events. Options to operator might be tempted to override a r
I consequences. In !!miting trunsients, the resolve these competing concems will genuinely needed SLC actuation.
~
a failura of the main feedwater system be evaluated by the NRC staff during Consideratir i should be given to may ba the initiator of or companion of the comment period. We are interested improved iztrumentation if the correct r
tha initiating event. The !!PCI is a in receiving comments on the potential dia;nosis Jf such sequences is
?
smgle. train system.The fault orhuman effects of the three proposed rules on ambiguot s. Operators must be trained i
error that precipitates the initia!
this subsystem (high-pressure makeup) to give first pnarity to safety rather than tr:nsient might also disable the HPCL In of the BWR desi;n.
to the availability of the plant for power cddition, system reliability analyses Several factors complicate the generation.The anticipation that h2ve indicated that HPCI may fail or be analysis of the ATWS. tolerance of BWR repea:ed manual scrams or quick fixes a
unavailable in as many as frorn l'E to plants.The delivery of main feedwater, in the control cabinets may succeed in 103 of the cases in which a demand is which may be available in some ATWS insert.ng the control rods would be an mads of the system.This may be accident sequences. may dilute liquid unacceptable justification far overriding i
insufficient reliability for the mitigation Poison and increase the power levelin SLC actuation.
of a potentially serious accident having In conjunction with this form of the
[
a frequency of occurrence that might be j"j l $ g ! $ ["j' 7 rufe. the NRC does not deem it y
necessary that the SLC meet the single-as high as once in a thousand reactor ommm cannos. tr i nocter anuiatory years. A second diverse system the commmon. w+ncun. O c. :um.
failure cnterion as weil as the indicate.!
g i
t l
37330 Fi.deral Re;;istir / Vol. 46. No. ::G / Tec.!..y. November M. Inst / Pmm ed Rules f_
s l
success enteria. In the very unlikely
!!censee and to reliute the NRC staff of (a)Initio/tcliobility assuronce event of an ABVS event and a failure of much of the detailed 7nvolvement in procrom. The initial reliability automatic and manual starts of the SLC experience review and the selection of assurance pro;; ram must include an analysis and classification of the system. a fallback strategy is available procedural or hardware backfits in the principal determinants of the through manual rod insertion and context of ADVS risks. For this reason.
radiological severity of each class of intervention in the reactor protection the proposed rule emphasizes criteria ADVS accident sequences in terms of system control cabinets. Nevertheless, for the sound implementation of the the initial plant conditions, the type of the SLC must not depend upon a single reliability assurance program and limits initiating transient, the failure mode of division of an auxiliary system the the staff review to these criteria.
the reactor protection system. and the failure of which would also compromise together with the conventional review state of operability orinoperability of the reliability of the scram system or of and approval of the license amendments other active hystems affecting the the recirculation pump trip or precipitate associated with changes in design or outcome.This analysis must be the initiating transient.
operation.
BWRs must also operate under Pursuant to the Atomic Energy Act of employed in each of the following elements of the reliability assurance specified Limiting Conditions of 1954. as amended, the Energy
[
Operation that constrain power Reorgani:stion Act of 1974, as amended. program:
l (1) Training oflicensed reactor generation under circumstances in -
and sectfon 553 of title 5 of the United operators in the diagnosis and prognosis which equipment unavailability States Code, notice is hereby given that of the several ABVS accident compromises the reliability of systems adoption of the following amendments sequences. Operators must be trained to important to ABVS prevention or to 10 CFR Part 50 is contemplated.
make productive use of their time during mitigation.
The older lower. power-level reactors PART 50--00MESTIC UCENSING OF ADVS accidents to effect mitigation.
may differ sigmficantly in the levels of PRODUCTION AND UTILIZATION Consideration must be given to ABVS-tolerance provided. These plants FACILITIES improving instrumentation, displays, d
to ize '
Q].'E{" Y p]d would be required to submit anafyses of au ority tat a for 10 CFR d6 VS toferance for review by the a sfbs a in e ths Authority: Sees. ta3.104.1st. ta2. is3. se De dual approach of ATWS Stat. 938. 937.94a 953.954. as amended (42 rsdiologicaI severi'y of the outcome.
l tolerance and the reliability assurance UAC n33. :134. =ol. =32. =331: secs. :02.
(2) An analysis of hypothetical errors program provides defense in depth. Each :os as Stat.1:44.1:ts (42 USC. 5842, Sa4el.
in or erroneous departures from proper allows the other to be implemented unless othese noted. Section 5038 also test and maintenance procedures for without highly conservative margins.
Issued under sec.1=. 6a Stat. 939. 42 USC The margin provided by ABVS-2152. Sections 40.ao-50.81 also tsaued under systems whose reliability i~ important to tolerance allows realistic cost-benefit sec.184. sa Stat. 954 as amended: (42 USC ABYS prevention or mitigation.
considerations to govern the selection 2:341. Secs. 50.too-50.10: issued under sec.
Consideration must be given to and schedule ofimplementation for tae, as Stat. 955 i42 USC =381. For improved designs, test equipment, fixes suggested by the reliability.
purposes of sec.=3 sa Stat.95a. as precedures, and personnel training to amended;(4:USC =73). I 50.54(i) issued minimize the likelihood that the assurance program.
The very costly accident at Three Mile under sec.1611. 6a Stat. 949: (42 USC.
reliability of these systems will be
=ottill and 1150. o-5011 and I sofa issued compromised by errors in test and Island has demonstrated that the under sec. teto, as Stat.950 as amended;(42 protection of a licensee's investment in USC = otto)) and the I.aws referred to in ~
maintenance.
(3) An analysis of the blindspots in a reactor plant provides a powerful Appendices.
the experience base with systems economic incentive to search out and correct reliability defect,s in the
- 2. A new I 50.60 is added to read as important to ATWS prevention or functions that protect a reactor core follows:
mitigation through which reliability considerations, together with a realistic I 50.60 Starnfards for trie reduction of risk defects might escape detection for from damage.These economic from Antic! pated Transients Without Scram considerable periods of time.
evaluation of offsite risks affecting (ATWS) events for Ught-water-cooled Hypothetical reliabi!Ity deilciencies must be classified by (i) kind (design public health and safety, are sufficient. nuci'8' Po**r P ants-deficiency, construction deficiency, l
to determine the scope and schedule of Each light water-cooled commercial vulnerability to test or maintenance the more expensive or intrusive -
power reactor licensee shall establish error, active or passive failure). (ii) alterations in plant operation or design and maintain a reliability assurance affected components or subsystems. (iii) emerging from the reliability assurance program for functions associated with severity of the reliability of deficiency, The reliability assurance program is the prevention and mitigation of and (iv) the frequency and kind of program.
Anticipated Transients Without Scram not to be ? paper study to demonstrate. (ATWS) employiryg etate-of-the-art opportunity to detect the deficiency. A to the NRC staff that the plant is already methods and procedures to identify.
test program covering startup or one-safe enough.The role of probabilistic vulnerabilities to failure. Each licensee time-only tests, tests associated with evaluations is secondary to the is responsible for the implementation of' perfodic plant overhauls, and inservice surveillance tests must be dev, eloped qualitative search for and evaluation of cost-effective improvements to reduce and implemented so that the mean time specific types of reliability defects.The
- ATWS risk. Defense in depth must be to detect the deficiencies Is reduced to reliability assurance prograrr. is not maintained by operating commercial the extent reasonably achievable.
intended primarily to assist NRC staff review. Rather. it is to be integrated into - power reactors only in modes that (4) An analysis of the susceptibility of afford an opportumty to learn frcm the conduct of plant management, experience with ATWS events without ~
the plant to common cause failures of personnel training. and the conduct of severe radioactivity releases Specific two kinds: those in which a sin;Ie root operations. It is intended to strengthen acceptance criteria are delineated cause degrades the reliability of the responsibility for safe design and redundant divisions of a safety system
~
operation of the plant resting with the below.
~l
Fed:ral Re;;ister / Vol. 48. Nc. 2 ts / Tu:sday. Novemb:r 24."1981 / Propostd Ruhs 57531 important to ABVS prevention or (2) Pressuri:ed water reactor licensees and approval. Holders of operating mitigation, and those in which a single receising an operatinglicense after licenses, app!! cants for operating root cause desrades the reliability of Aupst 22.1909. shalb licenses, and those expecting to file an two or more s) stems whose concurrent (il Provide for the prompt, automatic app!! cation for an operating license fdlure contnbutes to a severe ABVS start of the auxiliary feedwater system within one year of (the effective date of accident sequence. The kinds of root under circumstances indicative of a the rulel shall file the reliability causes to be considered are those listed transient entailing loss of main assurance program plan at a time to be in paragraph (a)(3)(i) of this section.
feedwater and a failure to scram.
agreed upon by the NRC staff.The time Consideration must be given to (ii) Ensure that the instruments afforded for plan development will be
' improved design or operation to reduce necessary for the diagnosis of and not less than one year (from the vulnerability to common cause failures.
recovery from ADVS accident effective date of the rule 1.Those holders
, (b) Continuing reliability assumnc, sequences will not be disabled by the of construction permits who file an pmymm. Each commercial power effects of such accidents, and application for an operating license on (iii) Ensure that those reactor coolant or after (one year from the effective date reactor!!censee shallmaintain a * --
system pressure boundary valves of the rulej shall file the reliability contincing reliability assurance program for functions important to ATWS through which high-pressure miection the re et r a functional assurance program plan at the time of preve tio and mitigation that includes
}n re Bcm gpIMom plus 1IConfi8 # tion control for desi "s, those valves whose integrity is essential must identify (i) the ways the reliability to the av assurance program will be integrated 8
procedures,"and techmcal specificationsuncontam.oidance of unisolatable-ed loss of coolant accidents into the engineering and operations to assure consistency with the initial reliability assurance analyses.
retain their integrity throughout limiting - management of the plant. (ii) the ABVS transients.
reporting and approval requirements (2) Procedures for updating affected (3) Commerciallight-water-cooled internal to the hcensee s orgamzation.
portions of the initial reliability assurance analysts for, and prior to, power reactor licensees not covered in (iii) the plans for information evaluation departures from the controlled design, para raphs (c)(1) or (c)(2) of this section and exchange among licensees as part shall submit an analysis of the ADVS of the experience feedback function. (iv) procedures. or technical specifications.
tolerance of their plants.
the criteria for reporting to the NRC. (v)'
Applications for license amendments to (4) Each commercial power reactor the criteria for the adoption and e
s tl lude a pjg,me {cha IIcensee shall prepare submit for review scheduling of alterations to plant design I
g the and approval, and implement Ilmiting or operation emerging from the change en the reliability of systons Conditions of Operation that proscribe reliability assurance program, and (vi) peration in, and mandate expeditious the date at which the initial reliability (3
. p n nce ee back aIstem to retreat from. operation under conditions assurance studies can be completed. A review operational and test data on that compromise the ABVS tolerance of brief~ summary of findings and plans for relevant systems in the licensed plarit the plant. Limiting Conditions of the resolution of reliability deficiencies and the relevant experience at plants
. Operation'should also mmimm must be filed with the NRC upon hning a similar system design. Each operation under conditions in which the completion of the initial reliability cperational occurrence must be ADVS tolerance of the plant would be assurance studies. Subsequent reviewed for clues to oversight or errors severely tested by a limiting AnVS discoveries of re!! ability defic.encies in in the reliabil:ty assurance analyses, event. Consideration of the prevailing the plant must be reported in accord The trutfal reliabihty assurance analyses plant parameters as well as equipment with prevailing practices for reporting and cost. benefit analyses based thereon operability is appropriate in the Limitin8 licensee events. The rell' bility a
, i-cre to be updated when the experience Conditions of Operation-assurance program will be subject to feedback system reveals oversights or (5) For the purposes of this pargraph, audit by the NRC. It is not expected that limitations m these audies.
the ABVS tolerance of a plant is the NRC will engage in routine review (cl Design andoperotion forAnFS inadequate if any of the more limitin8 and approval of the program unless a l
tolerunce. (1) Boiling water reactor transients. followed by a total faih.re of pattern suggestive of noncomplir. ace is licensees receiving an operating hcense the scram system, result in any one of b'"
"d.
after August 22.1969, shalh the following:
(2) Appl.icants for or holders of l
(i) Provide equipment to trip (i) Containment pressure or operating licenses abj,ect to paragraph automatically the reactor coolant temperature above the design values.
(cM1) or (cM2) of this secuan shall file recirculation pumps under conditions (ii) Loss of coolable geomet in the with the NRC plans for the indicative of an ADVS event.
core, or
'l (ii) Provide equipment to (iii) Releases of radioactive material
- implementation of the requirements of automatically deliver liquid reactivity that may realistically cause any offsite paragraph (c) of this section (within one poison so that either of two independent prompt fatalities or serious offsite year of the effective date of the rulej or l
retctor coolant replenishment system '
property damage.
upon license application. whichever is g
trains expected to be available during (6) Applicants orlicensees are not later.The fullimplementation of the ABVS events can successfully bring the required to calculate the potential offsite requirements of paragraphs (c)(1) (c)( ).
l resctor to stable hot shutdown.' Die radiological doses resulting from an and (c)(4) of this section must be poison injection system must not depend ABVS event under 1100.11 of this completed:
(i) For all light-water cooled nuclear
{
for its function on a single division of an chapter.
auxiliary system whose failure could (d) Schedule ofimplementation and reactor power plants fer which I
precipitate the transient, degrade the reporting requirements. (1) plans for the operating licenses have been or may be t
reliability.of the scram system. or defeat impicmentation of the reliabdity issued after August 22. IM9 but before the recirculation pump trip. and assurance program called for in (three years after effective date of the (iii) Provide a reliable scram discharge paragraphs (a) and (b) of this section rule), all modifications shall be volume system.
must be filed mth the NRC for resiew completed prior to startup following the l
Fa!eral Re. ster / 'M M No. 22G / T - % ';
<r 2t 1931 / F # u E M 57532 first refueling that bui.s (three years existing financial e.teri. wuchi be quotations, and (31 su iment imer n
after effective date of the rule).
relaxed to more c!asely rewmble disclosures.The National Association of lii) For al! light. water cooled nuclear requirements established by maior Securities Dealers Automated Quotation reactor power plants licensed on or after exchanges.
Systern ("NASDAQ"). now in operation i
oats: Comments should be received by for tert years. hr.s great!y improved the (three years after effective date of the 1
efficiency of the OTC market and has rule). all modifications shs!I be January 29.1982.
addressed the first two concerns of the completed prior to issuance of an -
AooRess: Comments, which should refer operating license.
to Docket No.R-0372. may be mailed to Board, ne SEC. over the past few (3) Holders of operating licenses the Secretary. Board of Governors of the years, has improved ar.d strengthened Federal Reserve System.:Oth Street and its disclosure rules, so that financial subject to paragraph (c)(3) of this section shall file with the NRC plans for Constitution Avenue.N.W, Washington. information on fc ~.gn as well as the accomplishment of the ATWS D.C. 20551. or delivered to Room B-:::3 domesticissues is available to the tolerance assessment caIIed for in between 8:45 a.m. and 5:15 p.m.
public in a comprehensive and timely paragraph (c) of this section (within one Comments received may be inspected at fashion. In addition, the National year of the effective date of the rule].
Room B-1122 between 8:45 a.m. and 5:15 Association of Securities Dealers Such licensees shall file the results of p.in except as provided in 1:St.6(a) of
("NASD") requires that its domestic and these studies, together with proposed the Board's Rules Regarding Availability foreign issuers file financial data with it changes. { any, m design, procedures.
ofInformation [12 CFR St.6(a)).
as a prerequisite for trading on and techmcal specifications to assure FOR FURTHER INFORMATION CONTACT:
NASDAQ.
Robert S. Plotkin. Assistant Director.
None of the approximately one-ntat on s'r e the hallfiled Laura Homer. Securities Credit Officer.
hundred eighty (180) foreign stocks I
with the NRC for review and approval or Jamie Lenoci. Financial Analyst..
currently in the NASDAQ system can be
[within three years of the effective date Division of Banking Supervision and placed on the OTC Ust, as they do not of thW Regulation (202-452-2781).
meet the existing criterion, which Dated at Washington. D.C. this 19th day of SUPPt.EstENTARY INFOREATIOPC in July requires all OTC Ust candidates to be hmber.1m 1969 the Board adopted criteria for
" organized under the laws of the United Including stocks on the OTC Ust. In States or a State " A growing number of For the Lclear Regulatory Commrssm.n.
S**"*3 I Chn*
discussions leading to the selection of requests have bern received from both Secretary of the Carmission such criteria, the BoardIndicated investor groups and the general public to tru o wwu u-s ms==e generally that (a) stocks to be included include foreign OTC stocks on the Oit s'wo cooe t"*-*w on the Ust should have =arket ust. When the Board first adopted its characteristics similar to exchange-criteria for inclusion en the Ust, there listed securities. (b) manipulation by was insufficient financial d!sclosure for
~
FEDERAL RESERVE SYSTG issuers to be included or excluded from foreign issues.This problem has now the OTC Ust should be made as difficult been remedied. Furthermore. foreign 12 CFR Pa-ts 207,220, and 221 as possible, and (c) fluctuations m the issues can and do list on national
[ Docket No. R-03721 number of stocks on the Ust should be exchanges and are therefore minimized..
automatically eligible for margin credih.
proposal To Revise Criteria for Initial The changes now proposed in the In this connection, the Board also -
I and Continued inclusion on the Ust of OTC Ust criteria are the result of a proposes to allow American Depositorv y.1 OTC Margin Stocks review of the OTC margin stock listing Receipts ("ADRs") to be eligible for
~
~
AGENCT. Board of Covernors of the and continued listing requirements in inclusion on the OTC Ust. ADRs 'are light of recent developments m the receipts issued against securities of Federal Reserve System.
securities markets in general, the OTC foreign issuers deposited in an 1
ACTiote Proposed amendments.
. Market in particular, and staff Amencan depository. and are exempt suuuAnr.The Board proposes to amend experience with administering the..
from registration under Section 12 of the the requirements set forth in Regulations requirements. It is believed that revistng 34 Act.There are approximately sixty C.T and U for mclusion and continued the criteria is especially appropriate at (60) ADRs currentlyin NASDAQ.The
-. inclusion on the Ust of OTC Margin -
this time because of a recent decision to Board would allow ADRs to be Stocks ("OTC Ust"). Brokers and-revise the U:t three times a year considered forinclusion on the OTC dealers may not extend credit on stocks commencing in 1982 rather than twice a Ust, provided the foreign securities H
which are traded over-the. counter year as is the current practice.This has against which the ADRs are issued a're unless such stocks appear on the OTC been a frequent recommendation of the registered pursuant to Section 12 of the List. Loans by banks and other tenders see.arities industry. The following is a 34 Act, which imposes certain reporting that are used to purchase stocks that discussion of the specific proposals to requirements upon the foreign issuer.
.1 appear on the OTC Ust are subject to amend OTC Ust criteria.
This approach is consistent with the A. Deleting Requirement That Issuer be policy currently employed by stock It propo ed m ndm nts w uld Organized Under the Laws of the United exchanges with respect to exchange listings ' and with the Securities and
~
modify three areas in the existing rules States or a State
~
anje C for initial and continued OTC Ust
~
ss s
eligibility.First they would permit As early as 1964,when the SEC first t
equity securities of foreign issuers and recommended a broadening of the Amencan Depository Receipts ( ADRs") Federal Reserve a margin authority to designated,as n. ati.onal market system 4
ser,n to be considered for OTC List inclusion..
encompass over.the-counter stocks, the Second, the proposals would replace Board indicated that secunties, to be g,,g,r s,,,,,n,,,i,,,,ii,,,a,'4
, u esch.n e mit tisi Aons unir it m.
certain criteria which must currently be eligible for credit at a broker should met in the alternative and replace them meet the prerequisites of(1) market
- mtm. resisted under seenos t2.
s with mandatory requirements. Finally.
depth.(:) a reliable s3 stem uf stc Refense No. 34-tsist.
j
' f a
g 3080 Federri Register / Vol. 45. No. 215 / Tuesday. Novemb:r 4.1980 / Proposed Rules I
=
serum from not less than 18 animaIs All persons who desire to submit
- urbine tnp and auxi!Iary feedwater e
shall be pooled for the toxin. antitoxin wntten comments concerning the independent of the reactor protection systen' r
titration. In the retest. the pooled serum petition for rulemaking should send their The petitioner states that %ese r
from vaccinated guinta pigs is diluted comments to the Secretary of the proposed modifications am c
1:25. If the retest titer is less than :.5 Commission. U.S. Nuclear Regulatory straightforward and well understood by A.U. per m!. the serial is unsatisfactory.
Commission. Washington. D.C. :0535.
the industry and the NRC Staff. Thus. ~
All wntten submissions made.
Attentiom Docketing and Service they will not require great expenditures t
pursuant to this notice will be made Branch-of resources for technical analysis and available for public inspection at the FOR FURTHER INFORMaT!oM CONTACTt J.
they can be adopted in short order by a tddress listed in this document during M. Felton Director. Division of Rules notice.and-comment rulemaking.
regular hours of business (8 a.m. to 4:30 and Records. Office of Administration.
Because a substantial portion of the p.m., Monday to Friday, except -.
Washington, D.C. 20555. Telephone: 301-modifications if they will resolve the U.S. Nuclear Regulatory Commission.
Industry is already willing to make these holidays) in a manner convenient to the public business (7 CFR 12.7(b)).
492-72n.
anVS issue for existing plants, there is Done at Washington, D.C., this 30th day of StlPPLEMENTARY INFORMAT1oN:
' unlikely to be much regulatory efIort October 1980.
Pc Jtioner sectric Utilities (a group of required to imposed them.Most J. K. Atwell.
companies which have over sixty important of all, the proposed.
-l Acting Deputy Adounistator. Veterinary nuclear power reactors currently in modifications clearly decrease the risk
~'
Sernces.
." operation, under construction, or of ATWS without simultaneously grao ma.an en.4 n.wea.s t '
planned) requests that the Commission increasing other. competing risks."
saAsse cone ace.se-a initiate rulemaking on the Anticipated De petitioner states that, in regard to Transient Without Scram (ATWS) issue the development of a regulatory program through one of two approaches outlined to resolve the ATWS issue for new plants.%e [Eectric] Utilities do got
~
la the petition.
NUCt. EAR REGULATORY COMMISSION Petitioner first requests that the believe that an.ATWS rule for new
, \\
Comml==fon use a notice-and-comment plants should be developed until the to CcR Part 50
'rulemaking proceeding based on the results of the degraded core rulemsking
- ' 7 IDocaat No.Pau-50-2sl publication of a proposed rule which the are known. Because the same Iss,ues and
- .?
petitioner sets out in a proposed new facts are crucial to each. ATWS ts -
~:i Eectric Utstles; Fmng of Petition for 150.47 to 10 CER Part 50. Petitioner's simply a subpart of the degraded core Rufemaldng proposed new I 50.u' reads as follows:
matter. *
- N Accordingly, there seems
- ~
'* b* ** **""d * **" '*' ***k5"5 150.47 Standardsfor Reduction of ABVS s lutions for new plants in Acancn Nuc! ear Regulat try g,gg.iticipotM &nsiente
} ~. _
WikutScum (ATWS]
f,
'8
Comnu== ion.
Each boi!!ns or g-M !ight-water Petitioner also states that %e second E~
AcTroec Publication of petition for mc! ear power reactar for which a -
prerequisite for an ATWS~ rule for new
( J' ' '-
rulemaking from electric utilities.
construction permit application was med as plantais the definition. either by policy SUMa4ARY:The Nuclear Regulatory d enffstive date of the rule shaII. as statement or rulemaking, of a safety goal pnn pangra i'
, Commnsion is publishing for public.
for nuclear power plant regulation * *. *.
, cg c, g rf m An a
ABVS involves the reduction of risks comment a petition for rulem=Irmg filed -Tramients Without Scum (ATWS).h ML.
befcre the f%==halon on September 16.
mhhfications requued bt eis nie must be - that are already =m=II. Since it is s
[.
1980, by sectric Utilities. His petition.
' completed as expeditioowy as is feasible.
Impossible to reduce risks to zero, the
., wl+h a=s been assigned Docket No.
taking into account the time needed foe philosphical question always remain =
PRM-60-d. requests that the design M.,c w: and approval, equipment - 'how safe is safe enought Although. of Commission address the issue of avacability and the regional d-ad foe necessity, the lack of a safety goal has Anticipated Transients Without Scradt power.
-not precluded rulemaking in the past, it
- a. For boding water necton ---ahwi would be unwise to ignore safety goal
- (ADVS). ATWS has been designated an.
de
.. guidance that should soon h
- available. -
- Can h
, Unresolved Safety Issue by the J-
=-
,,, o p g
Commiasion. An Anticipated Transie,ntJ reempt of a signalIndicative of an ATW5
.Recent recognition that such guidance is y.
r-
, Without Scram occurs at a nuclear evenc(zl an ihml. redundant and -
essential suggests that it will be -
i power plant if an abnormal operating diverse electrical means to initiate a reactoe - available in time to guide a new-plant f
condition (" anticipated transient") that scram upon receipt of a stenalindicative of ATWS rule."
an ATWS event and (3) a scram discharge petitioner further states that "A third should cause the plant's reactor t
volume system destgned and Installed such capacty to receive and final prerequisite for a new-plant I_.
' ' protection system to initiate a rapid
- iII ha suffici MVS) rule is further d on -
shutdown (" scram") of the reactor fails c
- b. For preneurized water necton probabilistic ' analysis. He extent to
, =,
to function DATE Comment period expims ~ ~
minufactured by Combustion Engineering.
. which safety analyses should resy on
. _ January 5.1981. 2 ~ '".
- ' -',
- Inc. and the Babcock & WHcox Company, this technique, and the methodology to
]..
ADonassat A copy of the petition for '
provide (t) an alternata means to shut down be used when it is applied, must be more 7
.. rulemaking is available for public-redundant to the electricalportion of the.
clearly defined. * *
- Efforts to these the nector that is diverse from and E.
inspection in the Commission's Public.
ends are already planned. * * *"
Document room.1717 H Street. N.W.,.
reactor protection system up to but not Finailly. In regard to its recommended
{',
, Washington. D.C. A copy of the petition. -
- P","*1**g ABVS rulemaking approach noted g
may be obtained by writing to the Independent of the reactor pmtection system.
above, petitioner states that %e.
,Dmsson of Rules and Records. Office of c.For pressurized water reactors
[ Electric] Utilities recognize that, after Admir:f stration. U.S. Nuclear Regulatory manufactured by the Westinghouse cecme the degraded core, safety goal and Commission. Washington D.C. 20555.
corporation. provide automatic initiation of probabilistic analysis efforts have been
- f
~
., [.
jh a
s s S-Federal Register / Vcl. 45 No. nS / Tuddly. N:.vember 4' 1980 / Prop'ied Rules 7308[
o completed. the Commission may see a For the Nacieer Requietory rh..ron. '
environmentalreview, permits and need to augment the ATWS rufe sammelt. ChiDr.
proposed for aristing plants. * *
- We. Secremryofthe Coe==-
compffanca and related contractors and...
~
interagency support) associated with enforcing Section 28.related '
do not belive that this will prove to be yao surren.4 m :w the case.Butif the Commission lacks saAssia cone no our confidence, it may prefer to adopt.
requirements..._
oArza: r'amments should be submitted the Utilities
- proposed rule as an
" Interim
- measure. to be finahzed in the OFFICE OF THE FEDERALINSPECTCR_. by December 4.1980.
3 Aconass: Comments should be in wake of these efforts, quite possibly at ' FOR THE ALASKA NAT11RAI. GAS, J writing and sent to Mr.Ned H-ngerer,
~ d the same time that ATWS requiements TRANSPORTATION SYSTEM j_. Office of the FecieralInspector Room
,1 are set for new olants.-
e-
- - m -WJ.,. Y 2413. Post Office Buirding.1200 -
.i De' petitioner reqIres'ts'that if the
"" y art, N.,.
.* p/.. & Pennsylvania Avenue. N.W.
. j, f c'~==i=Wiour decides not to proceed with - Reimbursement of Cosh ' '. 2 the rulernahng approach outlined Post ruverMan issponnaATiose COsrTACT.*
above, an ATWS rulemaking proceeding AcaNCv: Office of the Federalfaspector Mr. Ned Hengerer. General Counsei.'
~
with formal evidentiary hearings be for the Alaska NaturalCaa conducted using certain adjudicatory
. Transportation, System.
. : ;Offica of the FederalTnspector..
., (ANGTS). Room 2413. Postoffice procedures the petitfoner feels are N ACTioac Notice ofproposed rula==Idna ', Building.1200 Pennsylvania Avenue,,
reqmred.Da ptitioner's ----
"=I
.., N.W Washington. D.C. 20044. (202) 275-
. adindfemtory ;-_ _ - are as follows.-
suasasany:These proposed'rures -
- c. c. - 1144.
L A hearing board to be appointed, - which the OfHee of the FederalInshte sedards and MMy. * ~ mmM Mh *~
'T-~
from the ASI.B and ASIAB panels.
.. -Inspector (OFI) will recover certain'
.- I. Background composed of technically qualified
.' experts who can bring a fresh approach, cnets from the sponsorma companies for.
. b issue ofreimbursement.was the Alaska Natural Gas Transportationi - raised by the ANGTS sponsors in.** - '
to the evidence.
- .. System (ANG'IS).The sponsoring 2.AI! relevant documents available to companies of ANGTS are obligated to-~ '. context of the FederalInspecto 1979 confirmation hearmgs. Since 4
.E
- the NRC Staff. including internaf reimburse tBe United States for costs the OFI has been' studying the mstter.
mentoranda and working pepers to be ' incurred by certain Federal agencies Because of apparent disagreement placed in a technical data bank and relative to rights-of.way across Eederal. between the sponsors and the made available in one or more public '
lands.
Department of the Interior (the Federal document rooms.
While reimbursement. In some form or agency primarilyinvoIved in
- 3. A' statement ofissues to be other. Is mandatory, the mechamsm for reimbursement), the OFIfound it l.
prepared by the hearing board after its adminntration is more flaxible.
.~
advisable-after consultation with the statements of contentions are filed by -
Section 9 of the Alaska Natural Gaa sponsor's and appropriate govern =ent -
t-t parties and one or more prehearing Transportation Act(ANGTA) requires.
officials-to establish a project.apacific conferences are held.
and Sectica 28(1) of the MineralI. easing policy on reimbursement. This po!Le,
- 4. Written statements of pocition to be Act (hG.A) allows, the OFI to employ a, only gdverns operations of the OFI.
filed by all parties.
reimbursement mechanism different Recently, however, in a case dealing i
- 5. Written cross-statements to be filed. from that of the Department of the with Trans Alaska p!peline System, the i
Interior (DOI). Accordingly, the OFI will Court of(%ms ruled that Section 28 (1) by any paity who wishes to respond to cther parties.
seek appropriated funds for all tctivities reimbursement could only be-in its budget, to be followed by the implemented pursuant to authorizing
- e. A public hearing to be held, with all ANGTS sponsors making the necessary regulations, as required by the -
parties having an opportunity to present reimbursement directly to the U.S.
Independent Offices Appropriations -
sworn witne'sses and documentary Treasury on a quarterly, after-the-fact Act. Alyeska Pipeline Service CompanyF evidence in support of their statements basis.
.. v. US No. 384-78 (CT. C1. June 18.
and cross. statements.
The OFI will not seek reimbursement 1980), s!!p op. at 8-12. While the status
- 7. Questioning of witnesses to be for any ofits permit-coordination, of this decision is still uncertain, the OFI
' - conducted by the hearing board, with activities related to the Department of now, out of an abundance of action, the parties allowed to submit suggested the Interior (DOI] processing right-of.
establishes these proposedTegulations.
questions for the board to ask: cross.
way and permit applications for use of In this manner our cost reimbursement b'
exammation to be conducted by the
. Federal ! ands. Nevertheless. a portfon of program could not subsequently be p.rties if they specify the issues on tha OFI's enforcement activities will be invalidated. were the Alyeska decision whicn they wish to cross-examine and reimbursable. Reimbursement is first to become final and binding.
.atisfy the board that cross-examinatfort limited to OFI enforcement actions II. Discussior is needed to explore these issues related fo ANCIS construction pnmarily adequately.
on Federallands. Reimbursement is A* App!Icability of Reimbursement to
- a. A proposed rule to be recommended furtherIlmited to the OFI enforcing ANGTS by the hearing board to the Commission.. Federal agencies specific authority ANCTS as a natural gas pipeline along with a supporting discussion that under Section 28 of the MIA.There will project. is obligated to reimburse the Explains the evidentiary basis for the be no reimbursement for enforcing the U.S. for certain costs. incurred by I
rufe' authonty of Federal agencies not related Federal agencies, relative to rights-of-
- 9. Oral argument by the parties before to the Grant right.cf.way and related way across Federal lands. Specifically.
tha Commission.
permits. Reimbursement applies to the Section 28(1) of the Mineral I. easing Act costs associated with OFI field (MLA), pub. L 93.153. 30 U.S.C.185.
l t
Dated at Washuuton. DC this ath day of personnel and appropriate headquarters requires oil and gas pipeline applicants Getober 1980.
support (engineering review.
to reimburse the U.S. for (1)
'L I
~
4 A.
Ikr
~
Federn! Regi;ter / Vol. 46. Nr. 22 / Tresday. February 3.1981 / ProposId Ruls 10501 COMMISSION
'. sumuAan These proposed m!es and by SBA to be socially a'nd economically NUC1. EAR RECULATORY ~
r regulations set forth standards and disadvantaged under the section 8(a) procedures for challenges by third '
, Program..
parties and government prime (c) An interested party challenging a contractors to certification of elig:bility small business' eligibility to participate
[ Docket No. PRI4-50-al by interested companies pursuant to in the 8(bl subcontracting program, on i
was:nese rufes am hereby published. the grounds that the business is n Eectric Utilities; Supplement to Petition for Rulemaking In p.oposed form.The public is welcome economically disadvancaged AosNcy: Nuclear Regulatory to comment upon them by April S.1981.
Individual (s), wiH provide the SBA an.
. Aconssa r%-m.ata should be district omca having furisdiction over
- .~""d-r Acnoec Notice of receipt of supplement submitted in dupha'= to the Associate the geographical ares where the to petition for rulemakins PRM-50-29.'
Administrator for Minority SmaH chaHenged business has its principal
,suessaany:ne Nuclear Regufatory-Business and Capital Ownershi.
place ofbusiness, with specific and P
l Commiss:on has received a suppfer2ent. Development.Sman Business
- relevant information to supportits Admini=tration.1441!. Street.N.%
allegations. The eligibility determination t
e Tor em a edby Room 317. Washington. D.C 20418.
win be based primanly ott facts and.
f pon Punman WFOnAsADOes cQMTACT." '
allegations supplied by the parties to the IIntesoTved Safety Issue. Anticipated-
. Berkaley Boyd. Of! Ice of Minority Small Transient Without Scram (ATWST.The Business andCapitalOwnership SBA.If.deemad necessary or appropriate.SBA may utilize other supplement. which is dated fanuary Sm Development;1441 f_ Street.N.W.
. Information ihits files and may make ~
1981. contains a' proposed appendix to Washington, D.C 20418. Phoned 2A inquiries includIngrequests to the-
,10 CFR Part 50 which the petitioner asks the Commission to considerin parties or other persons for additional 653-65 a suppt.sanorrany utronasADOsc Pursuant specificinformation.The burden cf connection with its petition.PRM-50-22.
which was published in the Federal to section 5(b)(6) af the Sman hamss estabitshing its social and econnrnk Register for comment on November 4 ' - Act.15 II.S.C 634(b)(6), the disadvantaged status by submitting full '
% AdminIntrator for SBAis authorzzed to informade m SBA shan beope 1980(45 FR 73080).He petmoner's
""h" such rufes andregulations as he concern whose disadvantaged status is proposed appendix addresses the issue orchteria for Evaluation of Scram deems necessary to carry out the under consideration.
Discharge Volume Systems for Boiling authority vested in him pursuant to the g
g Small Business Act. Accordingly, the received all of the. formation it Water Reactors.
m following amendments to Part 124 of 13
. Anonessam Copies of the supplement CFR are hereby published in proposed mquires,it' win make a recommendation i
to the SBA regional omce within 7 and the petition for rulemdin's PRM-
- form, working days. %e regional offica will L
50-29. are available for pubHc inspection Public comments upon these In the (Smmission's Public Document then review the district office
- i Room.1717 H Street NW., Washington.
pmposals will be accepted and evaluated, and certain SBA ules and mcommen on wi war.-eo,sys D.C. A copy ofboth documents may be -
obtained by writing to the Division of regulations win be amended thereafter of receipt and render a written decision.
Rules and Secords. OfHca of in order to carry out the provisions of An interested party adverse!y affected Administration. U.S. Nuclear Regulhtory the SmallBusiness Act to which they by the regional office decision may relate.
appeal to the SBA Central Office 8(a) l Commission. Washington. D.C. ;D555.
Eligibility Committee within 10 daya of l
S.
pon runTHEn INFOne4ADON CONTACE Dated: (anuary a, tset.
receipt of the decision. If the decision is
[. M. Felton, Director. Division of Rules A. Vamou weaver, appealed. the regional office wt!! then and Records. Office of Administration.
Adamistroton forward the entire file to the 8(a)
U.S. Nuclear Regulatory Commission.
- It is proposed to add new } 124.4-1 to EIIgibility Committee in the SBA Ccatral r
Washington. D.C. 20555. Telephone:301-read as set forth below:
Office.The Committee will make a
- II*
I 124.4-t section s(a) engibmty recommendation to the Associate Dated at Washington, D.C. this :Sth day of challenges.
Administrator for Minority Small g
lanuary 19a1.
(a) Generat, Thes9 regulations apply Business and Capital Ownership For the Nuc!ent Regulatory Commission.
in the case of a challenge concernin5 the Develo'pment (AA/MSB& COD). The
'g 8**"'I I 02a-eligibility of a smar.' usiness to
_,AA/MSB& COD will then render a final Secretary o/the Commission.
participate in SBNs subcontracting decision on the eligibility of the p h ne ra,4 :.:-a. us =t program on the basis of its eligibility as challenged business for participation in i
r t
on m scaos m us
, a socially and economically the section 8(d) Subcontracting P cgram.
disadvantaged owned firm.
Onca this final determination has been (b) For purposes of qualifying as a made there will be no right of appeal SMAl.1.BU3INESS ADMINISTRATION socially and economically
-within the SBA organizational structure.
disadvantaged business owner (s) under (e) Whenever a protest challenges the the subcontracting program. SBA will size status of an alleged small business, 13 CFR Part 124 presume members of the foUcwing b
}
Chattenges to Certification of E!!gibility groups are socially and economically g "hl e the ze procedures set g
3g by Interested Companies Pursuant to disadvantaged. The groups are Black a
- ""-"*""S*"
Section 8(d) of the Small Business Act Americans: Hispanic Americans: Native
?
ses coca mw Americans: Asian Pacific Americans:
i acENcy:Small Dusiness Administration.
4CT1oN: Proposed 'ules.
other ;roups identified by SDA. arid any g.
individual (s) who has been determmed r
h
,e-
- m 3 m m mm u u nwnnetm vmm wenMGHWWMf6%MVNWfM'(HQ
- c 12/81
-g 9
4 TRANSMITTAL TO:
cument Control Desk, 016 Phillips
- b p
9 ADVANCED COPY TO:
O 'The Public Document P,oom p
g DATE:
9 lY2el cc': OPS File N
w From: SECY OPS Branch C&R (Natali.e-)
g Attached -are,: copies of a Commission meeting transcript /s/ and related meeting document /5/.
They are being forwarded for entry on the Daily Accession M
List and placement in the Public Document Room.
No P
other distribution is requested or required.
Existing DOS identification numbers are listed on the individual documents wherever known.
b e
Meeting
Title:
b e Eq m MCA/-8dcQI S A g A P/rt03 M v
ju Ooen if MEETING DATE:
9 I
N Closed DCS COPIES:
I' Copies (1 of each Checked)
ITEM DESCPIPTION:
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