Text

Summary of 900111-12 357th ACRS Meeting.List of Attendees, Future Agenda,Future Subcommittee Activities,Other Documents Received & Portion of Transcript of 900111 Commission Meeting W/Acrs Encl
	ML20058C608
Person / Time
Issue date:	01/11/1990
From:	; Advisory Committee on Reactor Safeguards
To:	; Advisory Committee on Reactor Safeguards
References
	ACRS-2686, NUDOCS 9011020038
	Download: ML20058C608 (100)
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i TABLE OF CONTENTS MINUTES OF THE 357TH ACRS MEETING JANUARY 11-12, 1990 I.

Chairman's Remarks (Open)...................................

1 II.

NRC Program for Resolution of Interfacing Systems Loss of Coolant Accident (ISLOCA)

(Open)....................

2 III.

Preparation for Meeting with NRC Commissioners (Open).......

5 IV.

Meeting with NRC Commissioners (Open).......................

5 V.

Activities _of the NRC Office for Analysis and Evaluation of Operating Data (AEOD)

(Open)..........-...................

5 VI.

Nuclear Power = Plant Incidents and Events (Open/ Closed)...... 11 VII.

Activities of ACRS Members (Open)...........................

11-VIII. Executive Sessions (Open/ Closed)............................

11 A.

Letter and Memorandum (Open)...........................

11 1.

Resolution of the Interfacina Systems LOCA Issue

-(Letter to-J. Taylor, EDO, dated January 18, 1990).

11 E

2.

Proposed Rule on Emercency PreDaredness Relatina to 10 CPR Part 52. Licensina for Nuclear Power Plants (Memorandum from R.

F.

Fraley for-W. Minners, dated g

January 23, 1990)..................................

11 p

B.

Subcommittee Reports (Open/ Closed)......................

12 1.

Reactor' Safety Research Program (Open).............

12 2.-

ACRS Action on the Recommendations of the Planning and Procedures Subcommittee (open).................

12

[

3.

Appointment of New Members (Closed)................

12 l:

C.

Other Matters / Decisions (Open).........................

16 L

D.

Summary / List of Follow-Up Matters (Open)...............

17 E.

Future Activities (Open)................................

22 1.

Future Agenda......................................

22 2.

Future Subcommittee Activities.....................

22 OFFICIAL USE ONLY Supplement - Section VIII.B.3 - Oeb ' ' Fld 6X[d)I Figure 1

p. 4a Figure 2

p. 4b 9011020038 900111

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11 APPENDICES MINUTES OF THE 357TH ACRS MEETING JANUARY 11-12, 1990 I.

Attendees II.

Future Agenda III.

Future Subcommittee Activities IV.

SUMMARY

OF PLANNING AND PROCEDURES SUBCOMMITTEE MEETING -

JANUARY 10, 1990 DRAFT Summary of Subject Meeting-INTERNAL COMMITTEE USE ONLY

357 ACRS Meeting Minutes IV-2 7

ACTIVITIES OF THE NRC OFFICE FOR ANALYSIS AND EVALUATION OF OPERATIONAL DATA Status Report 7.1 (Handout) FUNCTIONAL DESCRIPTION OF THE OFFICE OF THE ANALYSIS AND EVALUATION OF OPERATIONAL DATA

(

9 OPERATING' NUCLEAR POWER PLANT INCIDENTS AND EVENTS e

Schedule

[

e Status Report Briefing Slides:

e Arkansas One, Unit 2, Potential Interfacing System LOCA Braidwood Unit 1, RCS Leakage Through RHR Suction Relief Valve, December 1, 1989 Dresden 2 and 3, Inoporable HPCI Systems South Texas Unit 2, Failure of Diesel Generator, Nov. 28, 1989 LTR-89-012-000, and Nuclear One SIS Check Valve Malfunction, Due to Missing Internal Parts Resulting in RCS Back Leakage.

Augmented Inspection Team Report, Braidwood Station, Unit 2, December 2-4, 1989.

Augmented Inspection Team Report, Dresden Nuclear Power Station, Unit 2 and 3, November 1-4, 1989 Interim Special Report Regarding a Diesel Generator Valid Failure on November 28, 1989, December 27, 1989.

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i 4

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIS SION

" 6l PERIODIC BRIEFING BY ADVISORY COMMITTEE ON REACTOR SAFEGUARDS LOC $tiODl ROCKVILLE. MARYLAND bdIO JANUARY 11, 1990 l

230&$l 53 PAGES 1

EAL R. GROSS AND C0., INC.

COURT REPORTERS AND TRANSCRIRERS 1323 Rhode Island Avenue, Northwest Washington, D.C.

20005 (202) 234-4433 APPENDIX V 357th ACRS Meeting

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DISCL' AIMER This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on m unty 11. 1900, in the Commission's office at one White Flint North, Rockville, Maryland.

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 this transcript do not necessarily reflect final determination or beliefs.

No pleading or other paper may be filed with the Commission in any proceeding as the result of, or addressed to, any statement or argunent contained herein, except as the Commission may authorize.

HEAL R. GROSS Coutt REPORTERS AND TRANSCRISER5 1323 RMo04 ISLAND AVIMUE. H W (202) 234 4 433 W ASHINGToH. 0.C.

20005 (202) 232 6600 l

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION PERIODIC BRIEFING BY ADVISORY COMMITTEE ON REACTOR SAFEGUARDS PUBLIC MEETING Nuclear Regulatory Commission One White Flint North Rockville, Maryland Thursday, January ll, 1990 The Commission met in open session, pursuant to notice, at 2:00 p.m.,

Kenneth M.

Carr, Chairman, presiding.

COMMISSIONERS PRESENT:

l KENNETH M.

CARR, Chairman of the Commission l

THOMAS M.

ROBERTS, Commissioner l

KENNETH C.

ROGERS, Commissioner l

JAMES R.'CURTISS, Commissioner FORREST J.

REMICK, Commissioner

" ~)

.J NEAL R.

GROSS 1323 Rhode Island Avenue, N.W.

Washington, D.C.

20005 (202) 234-4433

J o,

DISCLAIMER This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on nrunrv 11. 1000.

in the commission's office at one White Flint North, Rockville, Maryland.

The meeting was open to public attendance and observation.

This transcript has not been reviewed, corrected or edited, and it may contain inaccuracies.

l 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 this transcript do not necessarily reflect final determination or beliefs.

No pleading or other paper may be filed with I

the Commission in any proceeding as the result of, or addressed to, any statement or argument contained herein, except as the Commission may authorize.

l l-NEAL R. GROSS COURT RfooRTERS AND TRAN5CRitfR$

1323 rho 0E 15 LAND AYtMut. N W.

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STAFF AND PRESENTERS SEATED AT Tile COMMISSION TABLE:

SAMUEL J.

CHILK, Secretary WILLIAM C.

PARLER, General Counsel CARLYLE MICRELSON, Chairman, ACRS CilARLES WYLIE, Vice Chairman, ACRS JAMES CARROLL, ACRS DAVID WARD, ACRS WILLIAM KERR, ACRS CHESTER SIESS, ACRS PAUL SHEWMAN, ACRS HAROLD LEWIS, ACRS IVAN CATTON, ACRS l

.J NEAL R.

GROSS 1323 Rhode Island Avenue, N.W.

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l P-R-0-C-E-E-D-I-N-G-S 2

2:00 p.m.

3 CHAIRMAN CARR:

Good afternoon, ladies and 4

gentlemen.

5 I'd like to welcome the members of the 6

Advisory Committee on Reactor Safeguards and 7

congratulate Mr. Michelson on his new appointment as 8

Chairman of the ACRS and Mr. Wylie as Vice Chairman.

9 The purpose of today's meeting is for the i

10 ACRS to brie f the Commission on four specific matters, 11 their views on how the staff and the ACRS positions 12.

differ on the concept of adequate protection as it 13 relates to the safety goals, the status of activities.

~

14 on containment design criteria, the status of the 15 reevaluation of the ACRS role in the review and 16 evaluation of reactor operating experiences, and 17 highlights from the ACRS meeting with Canada's Atomic 18 Energy Control Board Advisory Committee on Nuclear 19 Safety.

20 Copies of the recent correspondence related 21 to these topics are available at the entrance to the 22 meeting room.

23 I might add that it's interesting to have a 24 former member of the ACRS on the right side of the 25 table here.

I J

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7 1

MR.

SHEWMAN:

It made more room on this 2

side.

3 CHAIRMAN CAHR:

Right.

4 Do any of my fellow Commissioners have any 5

opening comments?

6 If not, Mr. Michelson, you may proceed with 7

your presentation.

8 MR. MICHELSON:

Thank you, Mr. ChLirman.

As 9

you pointed out, we have four princiral areas for 10 discussion this aftarnoon.

With your permission, I'd 11 like to put them in a

slightly d '. f f e r e n t

order, 12..

starting out with our containment performance criteria 13 first.

14 In each case, we have a lead presenter who 15 will make a short presentation and then we'll follow 16 it with questions and answers.

So, in the case of 17 containment performance criteria, David Ward is the 18 lead presenter.

19 MR.

WARD:

Several months

ago, with the 1

20 Commission's

urging, and in fact the Commission's l

l 21 direction, the ACRS undertook a program that will l

22 attempt to develop new containment design criteria.

l 23

Now, we intend that these would be applicable for l

24 future designs.

By that I mean for plants that are 25 not yet designed.

So, we don't see these as

(

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necessarily applicable to the so-called evolutionery 2

set of designs, by which I m e a r, the ABWR, the SP/90 3

and the CE 80+.

We do see them as being applicable to 4

what have been called the passive designs, the smaller 5

plants which have not yet been designed in detail, and 6

to

others, possibly even including LMR and HTGR 7

plants, although much of the focus of our effort is 8

directed toward LWRu to the extent that any new 9

containment criteria are general enough they could be 10 applicable to any type of reactor plant.

1 l

t 11 CHAIRMAN CARR:

How would they affect the l

12 EPRI design requirements for the so-called passive or 13 the -- beyond the evolution?

~

14 MR.

WARD:

Well, they could affect those I

15 definitely.

I'm not sure what those will be, but we 16

would, in

fact, hope to influence those by our 17 program.

we've talked about 18 The reason for this 19 this before, so I'll just summarize it very briefly--

20 is that present LWR containments are specifically 21 designed for a design basis accident which is, in 22 fact, the LOCA accident.

This is reilly as a sort of 23 a stand-in.

They're a surrogate for core damage 24 accidents for which containments are really intended.

j 25 We think that enough is now known about

.1 NEAL R.

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severe accidents, through experience, but especially 2 l, through research of the last ten years or so, that 3

there's a

new containment design criteria more 4

explicitly addressing severe accident phenomena and 5

the so-called s'evere accident issues can be developed.

6 So, we've

taken, first, an information 7

gathering step.

We've gathered information and I'll 8

have to say opinion from a number of experts.

In 9

fact, at four subcommittea meetings over the past few 10 months, we've heard from 25 invited experts.

These 11 individuals represented a number of institutions and 12 types of institutions, vendors, architect engineers, 13 major national labs, your staff at the NRC, consulting

'~

14 firms, utilities and EPRI.

We got quite a range of 15 opinions.

16 l'm not going to go into that in a technical 17

way, but they range from what I

might call the 18 suggestion that we should stand pat, that the existing 19 design criteria are good enough and we should continue 20 with

those, and they range to suggesting that 21 containment design really should consist of a shel1, a 22 means to cool a molten core, and some sort of a 23 filtered vent system for venting any excess pressure i

24 that's created by any means in an accident so that the 25 shell remains intact.

l r-)

... J l

NEAL R.

GROSS 1323 Rhode Island Avenue, N.W.

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4 7

l there's a

lot of 1

Well, this is

- ~

2 information.

I guess I can say there's considerable 3

enthusiasm from the presenters and from others we've 4

talked to about what we're attempting here.

But some 5

doubts have been expressed about whether we're going 6

to be able to come up with anything that's useful in 7

the near-term.

We still think we can.

We're now in 8

the process of digesting what we've heard and what 9

we've gathered from other sources.

We've been hearing 10 research iesults and analyses over the past several 11 years.

12 Our subcommittee is going to consider a set 13 of proposals at our next meeting, which is on February 14

28th, and following that we believe we can develop 15 some information that we could put in the sort of 16 paper that the Commission was requesting.

I'm hopeful 17 that.we can get that out in the spring.

18 COMMISSIONER REMICK:

A set of proposals?

19 MR. WARD:

From the ACRS.

20 COMMISSIONER REMICK:

You 'said the 21 subcommittee is going to consider a set of proposals.

22 MR. WARD:

Yes.

23 COMMISSIONER REMICK:

Oh, I see.

24 MR. WARD:

Okay.

The subcommittee is going 25 to start considering some proposals at the end of r-l 6

med NEAL R.

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1 F'ebruary and then we'll bring those through the full J

2 committee process 3

COMMISSIONER REMICK:

Okay.

and evaluate them.

4 MR. WARD:

S I don't know if any other nenbers, Carl, 6

would like to say anything on this.

Doctor Siess has 7

been very active in this.

8 CHAIRMAN CARR:

And that paper is the one we 9

asked you to give us on the scope and the schedule 10 and --

11 MR. WARD:

Yes, that's it.

I was afraid you 12 were going to say the date when we asked us to give it 13 and I was a little embarrassed.

~

14 CHAIRMAN CARR:

You said spring.

15 MR. WARD:

Yes.

16 CHAIRMAN CARR:

We asked for it sometime a 17 little earlier than that, I think.

18 MR. WARD:

Yes.

19 CHAIRMAN CARR:

But I'm hopeful we can get 20 it in in time so that it leads the work that EPRI is 21 trying to do before we -- because we've now held up 22 all the designers to wait for the EPRI document in the 1 come the controlling factor, 23 situation.

So, you'v.

24 perhaps, if you don't watch out.

25 COMMISSIONER REMICK:

Was there any l

.. _i NEAL R.

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consistent thread of suggestions of the people that 2

you had in, any couple topics that seemed the majority 3

of the people emphasized?

4 MR. WARD:

Yes, I'm a little hard put right 5

now to summarize it in that way for you.

6 COMMISSIONER REMICK:

Okay.

7 MR. WARD:

I wish I could, but I just can't.

8 COMMISSIONER REMICK:

Yes.

9 COMMISSIONER ROGERS:

Will you be able to 10 address this question of defense in depth insofar as 11 it relates to the HTGR and LMR reactors?

12 MR. WARD:

We're certainly going to grapple 13 with that.

In fact, in these 25 invited experts, we j

~ ~~

14 heard from LMR people and high temperature gas reactor 15 people.

So, we have their views and we are going to 16 try to -- we're certainly going to consider them.

17 MR. SHEWMAN:

And some of these consider the 18 passive safety or most of them were --

19 MR. WARD:

Right.

20 CHAIRMAN CARR:

Any other questions on that 21 subject?

Okay.

Let's proceed.

22 MR.

MICHELSON:

The next agenda item that 23 we'd like to discuss is the ACRS views on the NRC 24 safety goal policy and its relationship to the onset 25 of adequate protection.

Again, David Ward is lead on i

j NEAL R.

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this.

2 MR. WARD:

Well, over the past couple years 3

we've furnished a good bit of advice to you, perhaps 4

more than you wanted to hear, on how the safety goal 5

policy might be

used, how the policy might be several letters.

6 implemented.

That's what we've 7

We mentioned in one of them sort of on the oblique 8

because it had come up -- the staff had initiated we made some comments on how the safety goal 9

this 10 might relate to the concept of adequate protection.

11 The Commission couldn't figure out exactly what we 12 meant by this and, in fact, you concluded that what we 13 said seemed to be at odds with what the staff saw as 14 the relationship between the safety goal and the 15 concept of adequate protection.

16 So, we got together with the staff and we've 17 had a number of interactions.

The staff has attempted 18 to boil that all down in a SECY paper, which I believe l

19 has just been issued. SECY-89-375, and they do, in 20 fact, I think, give a good summary of what we meant.

21 It seems not. really to differ from the staff's 22 position on the use of the term " adequate protection."

23 In 89-375, in the summary, they quote from 24 the November 20th, 1989 letter of the ACRS where we 25 said, "We do not attempt to equate the safety goals to i

a.

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adequate protection in the sense in which the courts

- ~

2 have recently considered it."

The staff goes nn to 3

say, "On this key point therefore, the ACRS and the 4

staff positions do not differ."

I agree with that.

I 5

think we do not.

6 Just by way of explaining -- well, I hope it 7

will explain what we did mean.

I'd like to quote a 8

couple short paragraphs from our February 16th, 1980 9

letter and the staff also quotes these in this SECY 10 paper.

11 This is from our letter now.

"The term 12

' adequate protection' has importance in legal areas of 13 safety regulation.

Although it is needed and used 14 with apparent precision in legal instruments, its 1

15 technical definition is not precise.

In general, it 16 is accepted as equivalent to the term 'with no undue 17 risk to public health and safety,' often used in other 18 contexts.

Another

term,

'in full compliance with 19 regulations,' is used as a surrogate on occasion for 20 either of these.

21 "We believe that the safety goal should play 22 an important but indirect role in defining adequate 23 protection.

Ideally, compliance with the Commission's 24 regulations is a

suitable surrogate for defining 25 adequate protection of the public.

However, we la NEAL R.

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believe that the adequacy of the regulation should be 2

judged from the viewpoint of whether nuclear power 3

plants as a class licensed under these regulations 4

meet the safety goals."

5 So, we were not really attempting to provide 6

a lawyerly definition of adequate protection.

Our 7

understanding is that the term is used in regulations 8

only in the backfit rule.

That's 50.109.

We believe 9

a backfit rule of some sort is important and we also, 10 as we've stated in our letters on the safety goal, we 11 believe that all, the entire body of regulation should 12 be in conformance with the safety goal policy, not 13 vice versa.

In other words, we don't see that the 14 safety goal policy should be developed to be in 15 conformance with, for example, the backfit rule.

It, 16 in fact, should be the other way around.

17 Now, whether the backfit rule presently is 18 in conformance with the safety goal policy, we don't 19 have an opinion at the present time and I'm not sure 20 we're interested in trying to establish one.

But we 21

believe, and we've suggested in a

couple of our 22

letters, that there should be a program within the 23 staff to systematically review the entire. body of 24 regulations, which would include then the backfit 25

rule, to determine how the body of regulations is i

e.

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I serving the purposes of the safety goal policy.

in fact, Doctor Lewis had 2

Well, I think 3

some additional views on that.

I don't know if you'd 4

like to mention that. Hal.

5 DOCTOR LEWIS:

Why don't you just go on.

6 MH. WARD' Well, that's really all I had to 7

say at this point.

8 DOCTOR LEWIS:

Okay.

Well, no, I really there are 9

have nothing to add.

People sometimes 10 really three things at issue which people do sometimes 11 mix up.

One is the body of regulations.

The other is 12 the safety goal and the third, which is probably the 13 most important, is how safe the plants really are out

~

14 there.

We've concentrated and this letter 15 concentrates on relating the body of regulations to 16 the safety goals.

I guess I've independently written 17 you a letter which says you ought to also try to 18 relate the safety goals to the actual safety of the 19 plants and that somebody ought to do that one day.

- 20 But that's the only additional thing I would add.

I 21 still believe that, but that's my personal view.

22 CHAIRMAN CARR:

Yes, sir, Counselor?

23 MR. PARLER:

Mr. Chairman, would I be out of 24 order if I would ask permission to make a brief 25 comment?

I s

NEAL R.

GROSS 1323 Rhode Island Avenue, N.W.

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l immmmmmmmmmmmimmin-n mm umi-

a 14 1

1 CHAIRMAN CARR:

Go right ahead, as long as 2

the reporter knows who you are.

3 MR.

PARLER:

I'm

Parler, William,in t he 4

illegal office.

5 This February the 16th, '89 ACRS letter and 6

the November the 20th letter do include the paragraphs 7

that were read about the term " adequate protection."

8 T'- s t paragraph puzzled me for quite a long period of 9

time.

It suggests that there is an area, perhaps a 10 considerable

area, in which the term

" adequate 11 protection" is only meaningful in the legal arena.

I 12 always thought that the term in the Atomic Energy Act 13 was the fundamental basis for the actions that this

~ ~ ~

14 Commission took.

15 But, in any event, the important distinction 16 that I - want to make is this.

The term " adequate 17 protection" does have certain specific legal 18 consequences.

For one thing, unless you make the 19 finding, as I've already said, of adequate protection, 20 you can't license a nuclear power plant.

If you do 21 license one and you can no longer make the finding of 22 sdequate protection, you've got to take or you 23 should take enforcement action'.

24-Under the backfit rule, if you have to take 25 e particular action in order to achieve the level of i

t J

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adequate protection, you don't worry about the backfit 2

rule.

Costs are not n consideration.

3 So, those are the legalisms.

But the 4

underpinning for the determination of whether or not 5

there is an adequate protection finding that can be 6

made, that does not have a legal input.

That's from 7

the technical staff.

That's what the Agency is all 8

about, as I

understand it, and I

wish that that 9

distinction had been made in this paragraph.

10 Thank you.

11 CHAIRMAN CARR:

Thank you.

12 COMMISSIONER REMICK:

Dave, I

know the 13 Comniittee in the past wanted to be sure that the-14 Commission understood that this area of adequate 15 protection was not the only area where perhaps the 16 Committee and the staff differed.

I assume that that 17 is still the Committee's position, that there are I

18 other areas that we differed on the implementation.

l 19 Is that still the Committee's 20 MR. WARD:

Yes, that's correct.

There were, 21 I

think, four other points where our February

'89 22 letter still had some differences with the draft of l

23 the staff paper which was to provide for the final 24 process, I guess, of implementation of a safety goal.

25 We, in fact, thought some of these other areas were l-I 1

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more significant than concerns about the 2

definition of the term " adequate protection."

3 CHAIRMAN CARR:

Dc you have problems with 4

the SECY-89-375 paper?

5 MR. WARD:

No.

6 CHAIRMAN CARR:

Okay.

Is it fair to say 7

that if this is adequate protection and you're down 8

here and you've got to shut down or get fixed to get 9

above that, somewhere between here and the safety goal 10 a backfit analysis is required if you're going to make 11 a change to a plant.

Is that the way you tre trying 12 to tell me?

13 MR. WARD:

Not me.

~

14 CHAIRMAN CARR:

That's the way I understand 15 it.

Maybe it's too simple a picture.

16 DOCTOR LEWIS:

I have a problem with that.

17 DOCTOR SIESS:

I don't know, but I think one 18 of your problems is whether adequate protection is 19 here or here or here.

I think we don't have a 20 definition of adequate protection other than the 21 circular definition Mr. Parler just gave us.

22 CHAIRMAN CARR-It'a up here.

23 DODTOR SIESS:

Yes.

I mean if we let the 24 plant operate, then by definiticn it provides adequate 25 protection.

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CHAIRMAN CARR:

That's right.

If it didn't, 2

we'd shut it down.

3 DOCTOR SIESS:

I agree with you about being 4

above and below, but there's a long argument about --

5 CHAIR $AN CARR:

Well, but the plant's 6

operating, so it's above the adequate protection line 7

per se.

8 DOCTOR SIESS:

Yes.

9 CHAIRMAN CARR:

Or on it or whatever.

Now, 10 if we're about to make it do something, we're 11 admitting we're trying to make it do something to keep 12 it above that line and we do the backfit analysis if 13 it's an already operating plant.

Now, somewhere up

~

14 here safety goals exist that we're going to decide the 15 whole body of operating reactors will someday--

16 that's why we want to look at our regulations, not at 17 the plant, but at the regulations.

Is that the way we 18 see it?

19 DOCTOR LEWIS:

Yes, that's right.

And, in 20 fact, the only place I had a problem with what you 21 said was that you were talking about a plant when.you 22 said adequate protection and safety goal and you've 23 just 24 CHAIRMAN CARR:

Well, the safety goal is 25 certain not -- I mean down here we shouldn't the F

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safety goal, while it applies, it shouldn't sffect 2

anybody who's already at the adequate protectior.

3 level.

4 DOCTOR LEWIS:

Well, no.

The adequate 5

protection, as Mr. Parler said, is really in the eye 6

of the beholder.

He didn't say it that way, but I 7

think that's the way I interpret it.

I could think it 8

l conceivable, and I may well be wrong on the legal 9

point, conceivable for the Commission, although it 10 would be a dumb thing to do, to set a safety goal --

11 l

CHAIRMAN CARR:

We do some dumb things, yes, 12 DOCTOR LEWIS:

Well, you know, we've all 13 done dumb things.

Here we are.

But I could imagine a

"~

14 situation in which the Commission decided that the 15 safety goal numbers in the light of experience and so 16 forth are too low and set a new adequate' protection 17 level.

You have trouble justifying that, but' adequate 18 protection is a regulatory issue and the safety goals, I

19 as you've said and we've recommended many times 20 think the letter we're reading was signed by a

21 gentleman named Remick -- have said that the safety 22 goals are to be used to judge the adequacy of the 23

CHAIRMAN CARR:

But the safety goals, if you 24 used them that way, would require you to change the 25 regulations.

e-

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DOCTOR LEWIS:

Yes, that's right.

~

2 CHAIRMAN CARR:

And then the regulations 3

would require you to change adequate protection.

4 DOCTOR LEWIS:

Well, you actually you 5

could presumably change the level of safety of the 6

plants without changing the regulations by exhorting 7

people to do better.

8 CRAIRMAN CARR:

Well, that's INPO's job.

9 MR. WARD:

Yes.

10 CRAIRMAN CARR:

Okay.

11 COMMISSIONER CURTISS:

I do have one 12 question, following up on that point, because I'm not 13 sure I still grasp the position that the ACRS is 14 taking.

If I

understand what you're saying, the 15 safety goal ought to be the vehicle that's used to 16 judge the adequacy of the regulations.

17 MR. WARD:

Correct.

18 COMMISSIONER CURTISS:

And if it is true, 19 and let's just stipulate for the moment that the 20 regulations as a body reflect what is necessary to 21 achieve adequate protection, why is it that you are 22 not therefore saying that the safety goal ought to be 23 used to judge what is, in

essence, adequate 24 protection?

25 MR.

WARD:

You know, I think we're coming I

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perilously close to saying that.

I mean in plain 2

English terms, to me, that's what it means.

But I 3

think there is a special meaning, legal meaning of the 4

term " adequate protection," and I'm not sure we can 5

really fit it on this scale, as Chairman Carr is 6

at tempting t o.

That's a problem.

7 COMMISSIONED CURTISS:

It is, as the General 8

Counsel points

out, a

legal term or has legal 9

consequences, but it's a technical judgment.

I guess 10 I'm wondering why you're shying away from the 11 conclusion that the safety goal ought to be used to 12 judge adequate protection, whether it's because of 13 some consequence that flows from that or some anxiety

~

14 about the legal implications of making that 15 connection.

But everything you said leads to that 16 conclusion in my mind.

17 MR. WARD:

Well, I think the term " adequate 18 protection," if the body of regulations is providing 19 assurance that the public is being adequately 20 protected against risks from the operation of the 21 population of plants, but we're reluctant to attempt 22 to use the safety goal to define the term " adequate P3 protection" for en individual plant.

24 CHAIRMAN CARR:

Well, isn't it fair to say 25 that the safety goal is not based on a

strong mJ m

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l technical basis?

' ~

2 MR. SHEWMAN:

It is fair.

May I comment?

3 CHAIRMAN CARR:

And therefore you can't use 4

it to define adequate protection, in my opinion.

5 COMMISSIONER CURTISS:

I do think that's a 6

policy question and maybe the distinction between --

7 MR.

KERR:

All of our discussion here has 8

seemed to implicitly assume that the safety goals 9

represent a higher level of protection than adequate 10 protection.

I don't think we know that.

In fact, I 11 would say there is some esidence to suggest that 12 existing reactors may be better than the safety goal 13 and this is part of our difficulty.

We do not hnve a 14 good quantitative estimate of what the current body of 15 reactu is producing in terms of risk.

16 CHAIRMAN CARR:

Yes.

I read.you all's 17 statement as saying you'd really like to modify the 18 safety goal a

little bit in your hierarchical 19 structure to give it a little more of a foundation.

20 MR.

KERR:

I'm saying that defining the 21 safety goal can be done, it seems to me, without 22 worrying about where reactors are.

This is a policy 23 decision that says, "In o'u r wisdom an a Commission, 24 this is what we think one should try to achieve."

One 25 needs to be reasonably realistic.

There's no point in I

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setting something that's obviously impossible to 2

achieve.

3 But we have not, I think, as yet, connected 4

the decision that was made and I personally think that 5

the safety goal policy statement is reasonable.

We 6

have not yet connected that in a quantitative way, and 7

it's not going to be ecay to do, with where the 8

current body of reactors in this country is.

9 COMMISSIONER ROGERS:

That has to come out 10 of some kind of a study, some kind of a comparative 11 study.

Le' me ask if this concept that I'll just 12 sketch to you seems to fit what you're saying.

13 Safety goals are arbitrary, really.

They're

'~~

14 based on a policy decision as to what we're all l

L 15 comfortable with, what we think the public would be 16 comfortable with, what we think those that put us in l

17 place would be comfortable with looking after their 18 safety.

So, they are arbitrary, but they can be 19 defined fairly precisely because we have free choice 20 to do that.

Once the safety goals have been 21 established as a policy matter, then in principle--

22 we haven't done it yet, but in principle, one could 23 test to see whether on the average, the regulations 24 that we have in place have created a

system of 25 reactors which meets the safety goal on the average.

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1 If the answer to that is yes, it does, and we don't 2

have the entwer to that yet, as Lewis has pointed out.

3 but let's assume for the moment that one could find 4

the answer to it and just for the sake of argument say 6

that the answer turns out that

yes, that on the 6

average, but there will be deviations because in b

7 looking at the safety goal they're risk-based 8

statements and there are going to be uncertainties in 9

those risk assessments because of just h w you have to 10 do it.

e 11 So, one doesn't take a p ocise measure for 12 an individual plant at this point, but what one does 13 is to take the average of the whole constellation of

~

14 these.

If the answer comes back that yes, after 15 havirs done all these studies we find that on the 16 average the collection of U.S.

plants that have 17 evolved under the regulations meet the safety goals, 18 then we will have validated the regulatirnt..

Once the e

L 19 regulations have been valide*.ed, then we have a basis 20 for taking the next step that

says, "If our 21 regulations are safe, the plants are safe enough."

22 So, therefore, you have a firm basis for 23 establishing what we've been saying all along,' that 24 our regulations d%Iine safe enough.

25 Yes?

I J

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24 1

DOCTOR LEWIS:

I have only one problem with 2

what you said, Ken.

You've made a logical structure, 3

but I have the chanticleer effect in mind.

You said 4

first that the safety goals have produced a group of I'm

sorry, that the regulations have 5

plants 6

produced a group of plants that meet the safety goals 7

and you can test that, but you really can't.

What you 8

enn test is whethe. the plants meet the safety goals 0

and whether it's due to the regulations or in sp4te of 10 them in a deeper question.

You know, Chant cleer i

i believed that he made the sun rise every morning.

11 j

it's a 12.

COMMISSIONER ROGERS:

True, but 13 good point, but I think that logical leep, is still

~

14 something that some of us might be willing to 15 consider.

16 CHAIRMAN CARR:

As you say, why are we here, 17 right?

18 DOCTOR LEWIS:

I'm not prepared, you know, 19 given the fact that I'm locked in this room with you.

20 to any that it happened in spite of the regulations, 21 but I think the degree to which the regulations have 22 contributed to it is a separate question from the 23 question of whether the plants meet the safety goals 24 and I do think it's important that we find that out

9. 5 and do it.

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1 COMMISSIONER ROGERS:

Well, I think you've 2

l got a goed point, but we still then don't have a way 3

of defining adequate protection whereas if you use 4

compliance with our regulations as defining adequate 6

protection, you've made the connection.

6 DOCTOR LEWIS:

Well, as a surrogate and 7

certainly defining, yes, as a surrogate.

8 DOCTOR SIESS:

I would utgue --

9 CHAIRMAN CARR:

Doctor?

that we do have a way of 10 DOCTOR SIESS:

11 defining adequate protection.

We may not know, and we 12 don't know.

whether our existing plants meet the 13 enfety goal or not.

We haven't, as you say, looked at.

14 enough of them.

But any plant that's operating i enn 16 say providen adequate protection on the empiric basis 16 that if it didn't provide adequate protection, the NRC 17 would have shut it down.

18 CHAIRMAN CARR:

That's a fact.

19 COMMISSIONER ROGERS:

Well, if you trust the 20 NRC.

Suppose that you don't.

21 DOCTOR SIESS:

I wouldn't touch that one 22 with a

ten foot pole.

But

again, we do

have, 23 following Bill's legal definiti'on --

24 CHAIRMAN CARR:

Well, that's our charge.

a way of doing that.

Is 25 DOCTOR SIESS:

I

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it right?

I don't know.

2 COMMISSIONER ROGERS:

What I'm offering you 3'

is a way of giving a little additional comfort to the 4

assertion that the NRC would shut it down because it 5

would require people to follow its regulations.

If 6

its regulations were not

followed, it wouldn't be 7

operating.

So, it's a

little validation of that 8

Commission.

9 CHAIRMAN CARR; There's no doubt that if we 10 knew it were not providing adequate safety, we would 11 shut it down.

It boils down to the question of do you 12 know and you may know today that it's all right and 13 you may not Itnow tomorrow.

But you do the best you

~

14 can by continual inspection and that's how we got 15 where we are.

16 DOCTOR LEWIS:

In fact, there's some virtue 17 in the vagueness of the word " adequate," because what 18 might be adequate protection under some circumstances-19 might be inadequate in other circumstances.

The whole 20 question of decision making depends to nome extent on 21 what your losses are if you make the wrong decision.

22 I

could envisage a situation, perhaps an enormous 23 national electricity shortage, in which you might very 24 well decide _that the definition of adequate in terms-25 of numbers ought to be changed.

Adequacy, after all, 1

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9 6

27 C"

1 we live our liven that way, is a judgmental matter and 2

we trunt these fine working people to make those 3

judgs.ents.

j 4

MR. WARD:

I think the chain of thought that S

Commissioner Rogers expressed is exactly what we've 6

tried to say.

I agree with that.

I'd add only--

7 well, I agree with Hal's comment, but I'd add only 8

that we do know something about the existing 9

populatton of plants.

t 10 COMMISSIONER ROGERS:

Yes.

11 MR. WARD:

There's a good many -- 1150 and a 12 lot of other PRAs have told us.

13 COMMISSIONER ROGERS:

We haven't just made 14 that total connection yet for the whole constellation

'~

15 though.

16 MR. WARD:

We haven't.

17 COMMISSIONER ROGERS:

Then, it seems to me, 18 the next question, if you've gotten to that point of 19

comfort, that you've found that the regulations as 20 they now exist, in the constellation of plants as they 21 now exist do, on the average, satisfy the safety goal, i

22 you will see deviations from that nevertheless.

Then 23 the question 'is, what do you do about those?

It seems 24 to me that's where they're arguing.

l 25 You've been arguing with the staff as to

'l

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whether there ought to be a backfit analysis done or 2

not.

I would submit that one should not think about that your positinn is that you shouldn't use 3

using 4

the safety goals for a regulatory purpose.

You take 5

them up to the point that you use them to validate the 6

regulations or not and stop and that the next step to 7

try to close the gap between the result of a PRA or 8

something that lends you to a slight deviation or 9

maybe some kind of deviation from safety goal average 10 is not the basis on which you would consider further 11 regulatory action, if I understand.

12 MR. WARD:

That's right.

13 CHAIRMAN CARR:

Counselor?

~

14 MR.

PARLER:

Thank you, Mr.

Chairman.

I 15 just thought that I would mention to the Commission 16 that in the last year or so there was a case involving 17 the legality of the backfit rule. in which the 18 opponents of the rule, among other things, argued that 19 there should be a more precise definition of adequate 20 protection.

21 Now, Mr. Briggs and I signed a brief that 22 was filed with the court on behalf of this Agency.

23 The government won the case, but with your permission i

24 I would like to quote something briefly from that 25 brief, which it seems to me to be in point.

Whethes i

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you agree with it or not or everybody would agree with 2

it or not in another question.

But if it's completely 3

off the wall, somebody better tell me because I've got 4

business to do with the United States Court of 6

Appeals.

6 The brief says, in part. "In fact, however, 7

there is no vagueness and ambiguity in the NRC's use 8

of the adequate protection standard.

Adequate 9

protection is the level of safety required by Section 10 182 of the Atomic Energy Act as a necessary condition 11 for licensing.

It is and has always been defined 12 operationally in NRC practice by application of a set the Commission's specific 13 of objective criteria 14 regulatory requirements for reactor licensing, 10 CFR

~

15 part 50, regulatory

guides, orders, adjudicatory 16

opinions, technical specifications and license 17 conditions, together with case-by-case exercise of the 1

18 Agency's expert engineering judgment, 19 "In deciding whether the adequate protection 20 standard has been

set, the Commission necessarily 21 proceeds case by case whether the single case he a 22 regulation applicable to all plants or a

plant-23 specific action."

24 CHAIRMAN CARR:

Stick to that.

I like it.

25 DOCTOR SIESS:

Wasn't there a

question I

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)

J l

raised that if by invoking 'the backfit rules you

~

2 revise a regulation, if something did not meet the 3

adequate protection standards, then you raised the 4

standard?

If you revise it by invoking the backfit 5

rule, which meant it did meet adequate protection, 6

right, and you could only increase the requirement by 7

backfit and you now revise the regulations, you've now 8

raised the standard of adequate protection, have you 9

not?

10 CHAIRMAN CARR:

I would -- that 11 COMMISSIONER ROGERS:

I would imagine so.

12 CHAIRMAN CARR:

We've changed the

,13 regulationa.

~

14 DOCTOR SIESS:

Now, is there something wrong 4

15 about that?

16 CHAIRMAN CARR:

No, I think we learn as we 17 nove on.

18 DOCTOR SIESS:

No, but you had to invoke the 19 backfit rule to change the regulation.

But once you

-20 got it

changed, it's the new adequate protection 21 standard.

22 CHAIRMAN CARR:

If it's applicable across a

-23 range of plants, and certainly we have changed it for 24 that plant.- If it's generic, we've changed it for the 25 whole population.

I

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1 DOCTOR LEWIS:

I don't think, Chet, that it 2

requires that you think of a changed definition of 3

adequate protection.

You may have discovered 4

something in the regulations that was ambiguous.

What 5

you're doing is giving yourself greater certainty that 6

you met the previous standard of adequate protection.

7 1 think there's a logical progression you can hold, 8

that you've not changed the atandard of adequate 9

protection, you've simply clarified the question of 10 whether somebody has met it.

11 CHAIRMAN CARR:

Or you --

12 DOCTOR LEWIS:

I think that's a better one 13 to stick with.

14 CHAIRMAN CARR:

Or you may say we've got 15 smarter and we learned something we should have known.

16 DOCTOR LEWIS:

We do get smarter.

17 CHAIRMAN CARR:

Yes.

18 DOCTOR SIESS:

I read this somewhere.

I'm 19 no lawyer.

I apologize.

20 CHAIRMAN CARR:

Any other questions?

-21 COMMISSIONER REMICK:

Bill, what you read I l

i 22 think is consistent with what I thought the Committee l

23 was.snying.

They were saying that the regulations are 24 a surrogate on an individual plant to plant basis for 25 adequate protection, if I heard you.

That was your r

j J

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32 1

argument

there, that the regulations and associated 2

engineering judgment backed up by the other documents and so forth, that's the standards.

I think that's 3

1 4

consistent with what the Committee --

5 MR. KERR:

I thought he just read that so 6

that he would have a determination as to whether he 7

should discard that brief completely.

Since there was 8

no move here --

9 CHAIRMAN CARR:

I think he was focusing the 10 conversation.

11 MR.

KERR:

Since there was no move to 12 discard it 13 COMMISSIONER REMICK:

And Jim. I think you*

i 14 were saying why does the Committee hesitate to 15 associate safety goal with adequate protection?

16 Adequate protection, in my mind, is an individual 17 plant decision.

It's a judgment on an individual-18 case-by-case basis, basically comparing it, does it 19 meet the regulations.

20 COMMISSIONER CURTISS:

But the body of 21 regulations, and I think the brief confirms it, is the 22 reflection-of what we consider to be adequate 23 protection and we're going around and around.

_You 24 still have my original question which i s ', if you use 25 the safety goal to assess the adequacy of regulations t

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i 33 1

and if we stipulate, as we argued in the court, that 2

the regulations reflect some generic standard of 3

adequate protection, why is it that you're not saying 4

that the safety goal ought to be used to evaluate 5

adequate protection in a general sense?

That is to 6

say in establishing that for the entire population of 7

plants.

8 I do agree that when you get to the question 9

of assessing the compliance of individual plants with 10 that generically established standard of adequate 11 protection, that is a plant-specific determination 12 that may, in fact, involve some considerations that 13 have been alluded to.

But I guess I stall am puzzled

~

14 and need to go back and think about why it is that 15 you're not prepared to say that the safety goal is, in 16 fact, something that ought to be used to establish 17 that general standard of adequate protection.

18 MR. KERR:

I think we have.

19 CHAIRMAN CARR:

For me it says you can' t i

20 make a technical decision on the safety goal.

You can 21 nake a technical decision on the plant.

22 COMMISSIONER REMICK:

Yes.

And-another way l

23 that I

look at it, I

think-that the adequate l=

24-protection which we

say, "Well, if you meet the 25 regulations," presumably that's kind of a

I 1

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1 deterministic type of thing.

The safety goals ir kind 2

of in risk-based in which you're looksng at your 3

regulations then from a risk s t an dpoi r.t and saying, 4

"Are we happy with those regulations from a public 5

risk?"

So, it's a different basis, I think.

6 COMMISSIONER CURTISS:

Thrt's interesting.

7 CHAIRMAN CAR 3:

All right.

Let's proceed.

8 MR.

MICHELSON:

Thank

you, Mr.

Chairman.

9 The next item for discussion is the highlights of our 10 November meeting with the Atomic Energy Control Board 11 Advisory Committee on Nuclear Safety.

I will take 12. l this ;> a r t i c u l a r discussion item.

13 As you know, the ACRS meets from time to

~~

14 time with some of its foreign counterpart advisory 15 committees.

In the case of the ACNS though, we met 16 with them last about nine years ago.

So, sometimes 17 there's a long gap.

The present meeting did conclude 18 with the observation that maybe we should be a little 19 more frequent in the future, perhaps like four years 20 would be e better timing than the nine years, which 21 was the last go-round.

With some of the other 22 advisory committees, we meet a little more frequently 22 than every four years, although of late it's been 24 gett.ing back apparently to about that mode of 25 frequency.

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1 The Advisory Committee on Nuclear Safety 2

advises the Atomic Energy control Board and this 3

advisory committee is free to work on issues that is 4

of common interest to their members.

Of course, keep 5

in mind now in our discussions today, we've met with 6

individual members.

Although the Board was there, it 7

was not a meeting of the Board.

So, we picked up 9

views of individual members and to some extent today 9

you might hear these individual views, but you can't 10 treat them as a position of the Advisory Committee 11 because they weren't presented in that fashion.

12 Like the ACRS, the ACNS reviews general and 13 policy type documents through a standing committee, an 14 ad hoc committee arrangement.

Again, as with the 15 ACHS, the ACNS has a companion committce called the 16 Advisory Committee 'on Radiological Protection.

So, 17 they have something comparable to our ACNW.

18 On occasion, the two committees in Canada do 19 hold joint meetings on items that might be of mutual 20 interest to both parties.

We discussed during our 21 meeting several areas.

Among them were institutional 22 QA, software QA, personnel training and licensing, 23 severe accidents, containment design criteria, ALARA 24 and diminimous dose rates and emergency planning.

25 Now, we come prepared today to discuss in l

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1 detail any one or all of these.

However, I'm not sure 1

2 you want to necessarily hear all of them.

So, let me 3

do it this way.

First of all, I'll have Hal Lewis 4

present what we learned from the ACNW on the software S

QA.

Then, as your interests may indicate, we would be 6

prepared to discuss any of these other subjects in 7

whatever depth.

8 So, Hal?

9 DOCTOR LEWIS:

The Canadians were concerned 10 about software reliability for the following reason, 11 that a site they have, Darlington, has for the first 12 time a

digital computer operated shutdown

system, I

13 -

reactor protection system, with which they've had no

~

14 experience in the past.

They're concerned that IS because of the need for extreme reliability of the 16 shutdown system, that taking it out of human hands is 17 just a nervous thing to do.

They're more concerned 18 about the functioning of these computers than they 19 would be 2f they were in less critical positions.

So 20 that they've tried to understand for themselves where 21 the failures are and how they can best protect 22 themselves against the failures.

23 As you know, t'ere are two things that can 24 go wrong with a computer system.

One is hardware.

l 25 That's not what we're talking about now.

The other is i

I

]

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software.

There are even two things that can go wrong 2

with software which require a different remedy.

One 3

thing that can go wrong is that it's been written 4

wrong.

There's simply a bug in the code.

When codes 5

get pretty complicated, it's sometimer very, very hard 6

to debug them or to be s it r e when you're finished 7

debugging them.

And their ideas for how t., handle 8

that are really not unusual ideas.

That is, they've 9

had the codes written in two different computer 10 languages by two different groups and seen if they 11 gave the same answers and they've debugged them 12 according to fairly well established principles for 13 quality assurance on software.

14 There's another class of problems with 15 software of which they didn't seem to have thought 16 very much.

That is a class of problems that go under

~

17 the name of formal specification or something like 18 that-in the computer business.

That is, in fact, what 19 it's called.

That has to do with the question that 20 even if the software is written correctly for its 21 purpose, one never has explored all the things that it 22 will do if it gets inputs that were unexpected.

Many 23 of the computer hacking successes have to do with 24 discovering that if you press the Q,

Z and B buttons 25 while you hold the control key down, nobody thought I

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l you would ever do that and therefore the consequences

- ~

2 are sort of unexpected and strange things can happen.

3 It's extremely hard.

Courses are taught in 4

how to protect against that, but it can only be done 5

with relatively simple systems.

In particular, 6

methods for avoiding that don't work very well on 7

closely interlinked computer programs.

So, for 8

example, if you have many gr.-to statements in a

9 program which take you out of one element of a thing 10 and push you down here, it's almost impossible to 11 really analyze what the progtam does under different 12 circumstances.

But a cure to that is just don

use 13 go-tos and I think most writers understand that.

14 But in any case, they really haven't found a 15 way to be entirely comfortable with this, with the 16 question of whether they've protected their software 17 for this shutdown system.

They're holding - up the 18 licensing of a plant, incidentally, for this reason.

I 19 They haven't found a way to become comfortable and I 20 think they cane' to un more for confort than for 1

1 21 technical advice on the subject.

We gave then 22 comfort, but we couldn't give them much more.

23 I would only add that they are probably 24 ahead of the United States in worrying about these 25 systems because there may well be capability within F

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I the NRC on the subject but I haven't found it 'yet.

2 So, I can only ray that ACRS has taken the first 3

monumental

step, we've set up a

subcommittee and 4

that's about as far as we've gone on the subject.

But 5

I think it's one that is simply going to be more 6

important.

Some of the advanced reactor systems will 7

have digital computers within the control structures 8

and we ought to get ahead of the game and they were 9

concerned about it and that's more or less the end of 10 the story.

It's a deep and important subject.

11 CHAIRMAN CARR:

Do they use this system as 12 only a shutdown system?

It's a go/no-go system or is 13 it a control system?

~*

~

14 DOCTOR LEWIS:

No, people have been using 15 digital computers in lots of other areas.

They only 16 became very concerned in the shutdown system.

They 17 had used the digital computers elsewhere.

18 MR.

CARROLL:

Historically, the Canadians 19 have used computers in the control systems at the very 20 beginninc of their program and Darlington is the next-21

step, where they move it into their protection or 22 safety system.

23 CHAIRMAN CARR:

It sounds like 24 MR.

CARROLL:

So, they've got a

lot of 25

concerns, i

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the concern that they've 1

CHAIRMAN CARR:

2 got is it might not shut them down when it should?

3 DOCTOR LEWIS:

That's correct and that's a 4

serious event.

They would like to get the kind of 5

assurance for it -- see, there are two reasons --

CHAIRMAN CARR:

What does it do for them?

G 7

Does it say them an operator or is it an operator 8

backup?

9 DOCTOR LEWIS:

I don't remember.

I'm sorry.

10 MR.

SHEWMAN:

It stays awake when the 11 operator sleeps, I suspect.

12 CHAIRMAN CARR:

Beg your pardon?

13 MR.

SHEWMAN:

It stays awake when the

~

14 operator sleeps.

15 CHAIRMAN CARR:

So, it's an operator backup?

16 MR.

CARROLL:

No, it's the basic reactor 17 protection system, the SCRAM system.

One of the major 18 incentives to go from the historic analog channels and

- 19 relay logics and stuff to computers is that you can do 20 a much better job of maintenance and surveillance 21 testing in the digital world than you can with the 22 historically used equipment.

Diagnostics, all that 23 stuff works such better.

24 CHAIRMAN CARR:

I'm trying to figure out, 25 does it run all their indications as well as their I

~ _

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41 is it just 1

SCRAM system or does it only run the 2 I sitting there looking at the indications that would 3

say SChAM and does it SCRAM?

4 MR. KERR:

No, it performs a SCRAM function.

)

5 DOCTOR LEWIS:

They have computers that do 6

the other things too, but this is the only one they're 7

genuinely concerned about.

I think the reason it's 8

different from valve failures, one of the reasons it's 9

different from valve failures is that for valve 10 failures the failure consequence is reasonably clear.

11 The mode you're in when it fails is reasonably clear.

12 With a

computer, when it

fails, you really don't it may not just fail.

It may do something bad 13 know

~

14 and that's hard to predict.

15 CHAIRMAN CARR:

I'm not making myself clear.

16 lf you get a low level in the reactor vessel and the 17 computer is supposed. t o shut the reactor down, does 18 the operator also see low level of f of the same signal 4

19 that tells the computer to shut it down?

20 DOCT0h _EWIS:

Well, that's what I don't 21 remember.

I assume the operator has backup 22 capability, but I don't know that.

23 MR. CARROLL:

The level sensor would provide 24 intelligence both to a control and indication system.

25 CHAIRMAN CARR:

Independent?

\\

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._q 1

MR. CARROLL:

Isolated.

It probably is the 2

same one sensor and it also supplies 3

CHAIRMAN CARR:

Well, then I'm worried about 4

their problem too.

5 DOCTOR LEWIS:

But, you know, for example, 6

at Rancho Seco during the famous light bulb incident, 7

the same sensor gave bad information to the operators 8

that gave bad information to the ICS.

9 CHAIRMAN CARR:

Yes.

Okay.

10 MR.

CARROLL:

We may not be adequately 11 describing it.

I'd hate for you to get a bad feeling 12 about the CANDU system from our description of it.

13 CHAIRMAN CARR:

It just depends on whether

'~

14 you believe basic instrumentation is better than 15 electronic transmission or not, I guess.

7 16 MR.

MICHELSON:

The reason,

perhaps, you 17 should be interested in this problem is that, although 18 I'm not acquainted with the details of how they're l

19 doing it at Darlington, we have been getting the 20 details on how the APWR and the ABWR will do these l

l 21 same things.

We're talking about a

significant-l 22 extrapolation of this technology into a new area.

23 Now, there's a lot of advantages to what's been done, 24 but there's some shortcomings that have to be 25 carefully understood and that's what the Canadians are l

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working on in that area.

2 CHAIRMAN CARR:

But certainly the nuclear 3

industry is not the leader in this field.

Space, the 4

entire launch of the --

5 DOCTOR LEWIS:

I think that's just a minor 6

understatement.

7 CHAIRMAN CARR:

I mean there is a body of 8

technology out there that you could tap.

9 MR. MICHELSON:

But we do have to look at it i

10 now because reactors are coming forth as next 11 generation for review and the staff has to be capable 12 of looking at these questions and answering a number l

1 13 of different considerations, including the sof tware -

~

14 QA.

15 DOCTOR LEWIS:

I did some research.

I 16 looked at the NRC ad in Nuclear News t o find out what 17 kind of people the NRC is advertising for and computer 18 scientists was not in the list.

19 COMMISSIONER ROGERS:

Just turning back to 20 the Canadian situation, it is my recollection from the 21 visit that I made up there a couple years ago that the j

22 ordinary operation, certainly at Pickering, was under 23 computer control.

I 24 MR. CARROLL:,That's correct.

25 COMMISSIONER ROGERS:

And that it was l

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emergency functions which are under human control.

2 T h a *. ' s just the opposite from what we've been doing in 3

the U.S.

Now, what it sounds to se is that they're 4

extending that computer control off into the emergency 5

area.

That's where the concern now is.

6 MR. WARD:

Well, no, I don't think that's 7

quite right.

8 MR. C ARRO Ll.:

I disagree with the emergency I

l functions being under operator control.

My impression 9

i 10 is that they're done with analog systems and --

q 4

11 11 MR.

WARD:

Yes, more traditional analog 12 hardwire relay logic and that's the change that the 13 computer is replacing.

~~

14 CHAIRMAN CARR:

With an operator backup.

15 COMMISSIONER ROGERS:

Oh, I see.

Okay.

13 DOCTOR LEWIS:

Well, I'm glad he asked the 17 question on that.

18 COMMISSIONER ROGERS:

I see.

So, it's an 19 introduction of a digital system.

20 DOCTOR LEWIS:

Right.

21 COMMISSIONER ROGERS:

Oh, okay.

Well, my 22 understanding is that the Canadians have had problean 23 like this for a long time, that one of the most 24 serious medical problems of several people being 25 killed by over exposures from x-ray machines came from.

I

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a 9

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l a software glitch, it was in an automatic automated 2

software automatic machine.

They could either 3

deliver a

beam exposure or an x-ray

exposure, 4

depending upon how the target was in or out and the software was written with the assumption that 6

something would be flipped out before a button was 7

pushed and if you did it the other way around you got i

8 a full exposure to the bene instead of x-rays and that 9

several people died as a result of that.

That was 10 purely a software problem and that was some time ago.

11 So, I would imagine that they've worked pretty hard on 12 this kind of a probles.

13 DOCTOR LEWIS:

Well, there's considerable

~

14 history.

We know dozens of anecdotes of software 15 problems that have done bad thinga.

16 COMMISSIONER ROGERS:

It wasn't that there 17 was a bug in it, it just didn't follow all the logical 18

_ possibilities.

19 DOCTOR LEWIS:

Well, that's the hard job.

20 CHAIRMAN CARR:

What was item 27 21 MR. MICHELSON:

Beg your paroon?

22 CHAIRMAN CARR:

Where we're going with the 23 Canadian meeting.

24 MR. MICHELSON:

Oh, you mean what were the 25 other items in that Canadian meeting?

The s

1 NEAl. R.

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institutional QA, personnel training and licensing, 2

novere accidents, containment

design, AL4RA and 3

diminimous and emergency planning.

We're prepared to 4

discuss any or all.

5 CllAIRMAN CARR:

Can you hit the highlights 6

or the significant things that came out or was it more 7

or less routine and you didn't learn a lot?

8 MR.

KERR:

If the reactor system is 9

significantly different from the ones that we're using 10 tu this country, so that what we learned was not 11 directly applicable 12 CHAIRMAN CARR:

Personnel training, that's 13 pretty standerd.

~

14 MR. WARD:

I think they came expecting to 15 learn from us on personnel training.

Their opera tor 16 licensing training is really considerably less 17 comprehensive than --

18 CHAIRMAN CARR:

llow about QA?

Were they the 19 tenchers or the-learners?

20 MR. WARD:

Well, QA -- one of tiie members of 21 the Committee is looking at what he calls 22 institutional QA and he's addressing what he sees as a 23 problem that most of the major accidents which we had 24 in the nuclear business, in fact most,of the major, 25.

serious accidents you see in

,any industrial, r-

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technological activity, seem to be related more to 2

institutional failures than to engineering system 3

hardware failuren.

By institution, he means not Just 4

the operating plants, but all the human organir.ations 5

associated with it, particularly the regulatory body, G

for example.

7 CHAIRMAN CARR:

Procedures?

8 MR. WARD:

That would be part of it, yes.

3 That would be part of it.

The institutional failure 10 might give you bad procedures.

What he said is, 11 "Look, we've had something called QA in art or science 12 or something which we've applied to systems and 13 hardware and we think that may have given us better

~

14 systems or hardware.

Why can't we take those 15 principles, that art of QA, and apply it to how 16 institutions function and maybe it will give us better 17 institutional performance where we won't have these 18 institutional failures?"

I 19 So, I think most of the rest of us, perhaps 20 including some of his colleagues, or maybe I shouldn't

?

21 say that, agreed with his premise, that institutional 22 failures are extremely important.

We have some 23 problems with attempting to apply what I call the art 24 of-QA to deal-with those because it's not at all clear 25 to us that in the area of hardware and systems that QA I

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had practiced

~

at least in the U.S.

nuclear power 2

industry, has been particularly successful as an 3

instrument in providing safe and high quality plants.

4 I think it's a questionable exercise.

5 CHAIRMAN CARR:

How about the emergency 6

planning area?

7 COMMISSIONER REMICK:

Excuse me.

Before we 8

leave that, Commissioner Rogers will be interested 9

that in that he not something they didn't en11 it 10 that, but'the kind of principles of good regulatton.

11 He had principles applied to the regulator, to the 12 operatcr and so forth.

He had laid out a couple of 13 levels of principles that he thought that w-re

~

14 important to express from the regulator standpoint.

15 CHAIRMAN CARR:

Emergency planning, how did IG that look to you?

17 MR.

CARROLL:

Well, I

think they were 18 coming, seeking information from us and we made an-19 apparently lengthy - p r es en t a t :,on on the history of 20 emergency planning and the current state of 21 regulations and agencies and whatever

hat are 22 involved in it in the United States.

I think they're l

23 looking to improve their emergency planning in Canada 1

1 24 and they're seeking information along those lines.

25 The one thing I did find interesting was the 7

.a l

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emergency l

/ planning zone around their plants, I helieve, war 2

approximately ten miles, which does not take them into 3

the United States in any case.

But they did believe 4

that we were somewhat remiss and that we hadn't put 5

the effort into helping them with emergency planning G

around Termi, which is greater than ten miles away 7

from the Canadian border.

So, there seemed to be a 8

little political inconsistency there.

9 CHAIRMAN CARR:

Okay.

10 CCMMISSIONER ROGERS:

Just before we leave 11 this, do you think that their research support for 12 understanding of severe accidents for CANDUs has been 13 adequate?

Did you get into that?

14 MR.

KERR:

We did not talk to them in any l

15 depth about their research support.

I don't know.

16 CHAIRMAN CARR:

How about their severe 17 accident approach?

Are they --

18 MR. KERR:

They do not take severe accidents 19 as seriously as we do, partly because they think that 20 they can remsve heat.

21 CHAIRMAN CARR:

Chopped liver included, huh?

22 MR.

KERR:

And so, I

don't think that 23 they've done the research, nor s icy look in as much 24 detail as we have.

They're pros y correct.

I think 25 they probably do have heat removal capabilities and r-NEAl. R.

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they don't have the fission product accumulation that.

2 we have in our cores because of the feed-through 3

system.

4 CHAIRMAN CARR:

Continuous refueling.

5 COMMISSIONER REMICK:

In the training area, 6

if I recall, they were what I'd call pre-TMI in the 7

United States.

Traditlonal treining.

It's not 8

CHAIRMAN CARR:

Simulators?

performance based.

9 COMMISSIONER REMICK:

10 Yes, I think they do have simulators.

11 MR. WARD:

Yes, they do.

12 COMMISSIONER REMICK:

Not performance based,

~-

13 not systematic, not accredited, that type of thing.

14 So, they admitted that they probably were far, fnr 15 behind the United States in that area.

16 CHAIRMAN CARR:

Any other questions on that 17 subject?

Let's move on.

18 MR. MICHELSON:

Okny.

The last subject we 19 have should only take a

moment.

It's on the 20 reevaluation of the ACRS role in how we will look at 21 nuclear operating plants.

The Committee, in its March 22 letter of

'89, indicated to you that we were in the' 23 process of this reevaluation.

We're now giving it 24 very, serious attention to get closure on it.

25 At this point, I am not prepared to say what

~~)

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the Committee plans might be.

We're in the process of 2

deliberntion.

We'll do so at this full committee 3

meeting and perhaps next and then we will certainly 4

give you a response on where we're at.

5 CHAIRMAN CARR:

Okay.

Any questions, 6

Commissioner Remick?

7 COMMISSIONER REMICK:

No, thank you.

8 CHAIRMAN CARR:

Commissioner Roberts?

9 Commissioner Rogers?

10 Well, I thank you gentlemen for your time.

11 COMMISSIONER REMICK:

I'd like to add, Mr.

12 2hairman, I'm sure glad to see the Commission has such 13 a distinguished body as this providing advice to it.

~

14 COMMISSIONER ROGERS:

You mean it gets 15 better all the time?

16 CHAIRMAN CARR:

And there's no telling how 17 much untapped talent there is over there, right?

18 COMMISSIONER REMICK:

That's right.

19 DOCT0" LEkis:

I'm impressed that the newest 20 member of the Commission doesn't get a set of the CFR, 21 which much mean he knows them by heart.

22 CHAIRMAN CARR:

I think they're a general 23 use.

24 Thank you very much for this briefing.

25 I would also like to acknowledge receipt of l

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1 the ACRS' views on tne systematic assessment of 2

licenbee perforrance process, which is a SALP process 3

that you recently provided to the commission.

In your 4

letter, you requested the Commission to consider 5

suspension of the program and the issuance of no new G

SALP ratings until reforms are mnde to the process.

7 The Commission is considering this matter at 8

this time.

I have carefully reviewed your views and 9

have prepared a memorandum for consideration by my 10 fellow Commissioners.

Although I do believe that a 11 reassessment of the SALP proceas is in order, I do not 12 believe that suspension of the SALP program is 13 justified at this time.

14 As you may be aware, a reassessment of the 15 SALP process is in progress by the staff.

The staff 16 is planning to send two papers to the Commission.

The 17 first paper will address SALP issues raised by the IR Inspector General and is expected in mid-January.

19 The second paper will include results of 20 discussions on the SALP process from the senior 21 management meeting to be held in Region 5 at the end 22 of this month in which senior D C' management will 23 consider the applicable results of.he just completed 24 senior management survey and the ACRS comments on the 25 SALP process in the analysis.

The analysis and

?

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1 recome.endations are expected to be presented to: the 2

Commission in the March. April time frame.

3 I believe the Commission consideration of 4

any changes to the SALP process should await the staff 5

assessments and recommendations.

The Commission will 6

inform you of its finni position in the near future.

7 As the Commission has said in the past, we value the 8

advice of the Committee in areas of its considerable 9

technical expertise.

I encourage you in establishing 10 the priority of your activities to focus on providing 11 advice on the highly technical issues facing the 12, Agency, such as advanced reactor designs and technical 13 criteria for licenso-renewal.

Also on issues such as 14 reactor aging.

I ur, y r:,u to structure your reviews 15 involving many technical discipiines in such a. way.

16 that the advice to the Commission is well integrated.

17 Do any of my fellow Commissioners have any 18 additional comments?

19 I f not, we stand adjourned.

20 (Whereupon, at 3:04 p.m.,

the above-entitled

.21 matter was concluded.)

22 23 24 25 i

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CERTIFICATE OF TRANSCRIBER This is to certify that the attached events of a meeting of the United States Nuclear Regulatory Commission entitled:

TITLE OF MEETING:

PERIODIC BRIEFING BY ADVISORY COW.ITTEE ON REACTOR SAFEGUARDS PLACE OF MEETING:

ROC):VILLE, MARYLAND DATE OF MEETING:

JANUARY ll, 1990 were transcribed by me. A furthee certify that said transcription is accurate and complete, to the best of my ability, and that the transcript is a true and accurate record of the foregoing events.

\\

$. L vt1 /

]

Reporter's name:

Peter Lynch l

l L

1 1

k HEAL R. GROSS COURT RfD0aftts AND TsANSCelsit5 1323 RH006 ISLANo AYINU(, N.W.

0 02) 234 4433 WA$6pMOTON 0.C.

20005 (202) 732 6

.

ML20058C608

Text

SUMMARY

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