ML20129A122
| ML20129A122 | |
| Person / Time | |
|---|---|
| Issue date: | 05/31/1985 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1411, NUDOCS 8506040474 | |
| Download: ML20129A122 (35) | |
Text
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ORigggCA' UNITE Y NUCLEAR REGULATORY COMMISSION In the matter of:
ADIVSORY COMMITTEE ON REACTOR SAFEGUARDS The Ad Iloc Subcommittee Meeting on the State of Nuclear Power Safety Docket No.
O Location: Washington, D. C.
1 - 33 Date: Friday, May 31, 1985 Pages:
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1 UNITED STATES OF AMERICA ig
'2 NUCLEAR REGULATORY COMMISSION 8
4 ADUISORY cot 1MITTEE ON REACTOR SAFEGUARDS 1-
'5 6
THE.AD HOC-SUBCOMMITTEE MEETING 7
ON-THE STATE OF NUCLEAR POWER SAFETY 8
t' 9
-Room-1046 10' 1717..H Street, N.W.
11 Washington, D.
C.
.12 Friday, May~31, 1985-13 The AD HOC Subcommit' tee on The State of Nuclear j
14
. Power Safety for-the NRC'of the: Advisory Committee on Reactu.
15 Safeguards convened, pursuant to notice, at 8:45 a.m.,
William
- 16.
'Keer, Chairman of'the Subcommittee, presiding.
17
'PRESENT:
18 William Kerr, Chairman 19 Harold W.
Lewis, Member 20 G i r.nn A.
Reed, Member j
21 ALSO PRESENT:
i 22 Anthony J.
- Cappucci, Jr.,
(DFE) 1 23
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1 PROC EED i NGS 2
3 DR. KERR:
Good rnorning.
The meeting will now come 4
to order.
5 This'is a meeting of the Advisory Committee on i
'6 Reactor Safeguards Ad Hoc Subcommittee on State of Nuclear-Safety.
This is the second meeting of 7
-power 8~
-the subcommittee.
It follows an effort to collect from 9
members of the committee, safety concerns which will form pat. t 10 of our' discussion today.
You should have a listing of those, 11 as has.been prepared by Mr. Cappucci, I think probably a copy I
12 of the memorandum, fecm various members of the committee.
13 I am Bill Kerr,. Subcommittee Chairman.
The other 14 ACRS Members in attendance are Dr. Lewis and Mr. Reed.
I 15 The purpose of this meeting is to discuss important 16 safety issues identified.by ACRS Metobers at the request of 17 the SONPS Chairman.
18 Anthony Cappucci is the cogni= ant ACRS. Staff Member 19 for this meeting.
20 The rules for participation in today's meeting have 21 been announced as part of the notice of this meeting 22 previously published in the Federal Register on Friday, May.
28 10, 1985.
a
\\s 24 A transcript of the meeting is being kept and will 25 be made available as stated in the Federal Register Notice.
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1 We have received no written comments from members.of 2
the public.
We have received no requests for.t.ime to make 3
oral statements f roin the members of_the public.
4 We will proceed with the meeting.
5 This is going to be a relatively unstructured 6
meeting.
So, let me make some suggestions, and you can follow 7
with additional ones.
8 l'm not sure that I know exactly how to judge the 9
state of nuclear. power safety, and I would be interested in 10 hearing from you, and seeing if we can'at least take some 11 start toward deciding on the criteria that we are going 1to use
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12 or formulate, and judging the state of nuclear power safety.
I
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IS I presume that is the state of nuclear power safety 14 in the U.S.
15
^
Do we have some starting point, or should we try to 16 put one together, or should we not try to put too much 17 emphasis on definitions and charge ahead?'
18 What is your view?
19 MR. REED:
Like a big brown trout in Munich, I rise
.20 to the bait.
2.1 All three of us just came back-from this 22 French-German trip, and I have logged my impressions,.and they 23 go something like this:
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24 That the health and I use the word health of 25 nuclear power and its safety -- in France and Germany
4 A'
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1 certainly you feel that there is more health, that something QJ 2.
is more. vibrant, that something is better.
And I think that I C
could see in their structuring and what they do, some of the 4
reasons for a more healthy scene and-probably a more safe 5
scene because of health.
6 I guess if.you are in healthy condition, you can 7
walk right down the road without stumbling, and therefore you 8
are more safe.
9 Ek), what can we draw from what we saw t here,. an d. ' - ^
10 does it apply to what I think is some health problems here in 11 the USA?
-s 12 I th' ink we could all agree on one right aways that NJ 18 the people.seem less involved in -- those involved in-the 14 effort seem less harassed, burdened and more motivated.
Could 15 we agree on that?
16 DR. K ER R ':
1 don't know we are necessarily.here to 17.
get agreement today.
Why don't you go ahead.
It is an 18
. observa t i on '.
19 MR. REED:
All right.
20 I think another thing that we ought to do is, they 21 are convinced that what they are doing from a design point of 22 view is pretty good.
23 in the meantime, we seem to think we have a lot of n\\,/
24 problems.
I think we do have one or two design problems.
25 They seem to standardize and so something about it,
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1 they make hard conclusions.
I think they make good, wise-v 2
decisions, and they-move forward.
S We don't conclude and move forward with hard 4
decisions on some design vulnerabilities which I think we 5
ought to, and I have suggested in the past, such as an 6
alternative for decay heat removal on some PWRs.
And, let's 7
say such as doing something on a higher priority basis with 8
respect to BWR pipe cracking.
9 Another thing I think they have a tremendous 10 advantage over us is regulatory structuring in an interfac 11 with the utilities.
f-12 We are very much behind and very adversarial and
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19 very poorly structured as far as our nuclear regulatory 14 situation is concerned.
And I think we ought to be more like 15 the FAA and the NTSB in our structure.
16 So, that is three things to start people ta lk l' 17 DR. KERR:
The three things, if I understand them, 18 are that you think the health and safety in France and Germany 19 are better than what you observe here; that there is less 20 harassment of operations people back at the regulatory agency; 21 and that standardization has made them able to deal with 22 common problems somewhat better than we are able to deal with' 23 them.
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24 MR. REED:
At least those thoughts are in there.
25 DR. KERR:
Hal?
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1 DR. LEWIS:
I-guess I am slightly nervous about
. As 2
our making the kind of list that we have in front of us, which' 3
has, you know, 30 l'ssues rated in priority order'.
It isn't as 4
. good as the NRC Staff did.after TMI when they had 200 things 5
rated in priority order.
6 I hope that the outcome of this subcon:m i t t ee 7
recommendation to the full full committee won't be an ordered 8
list of resilient items.
9 Tony looks very unhappy about what I'm saying.
10 MR '. CAPpUCCI-The list those numbers are not.
11 prioritizing anything.
They.are just putting -- making 12 general categories.
They are saying like human factors is a
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13 general category, and those issues with that number one just 14 fall in that general category. There is no i n ten t.-to -
15 prioriti=e anything.
16 DR. LEWIS:
Thank you.
17 The only thing worse than a long prioritized list is 18 a long unprioritized list.
So, you have made the point very 19 effectively.
20 I hope that our activity won't be devoted to that, 21 because in a certain sense it is the job of the NRC, not the 22 ACRS, to make the priority list for the specific technical 23 items that they are dealing with, and we can certainly be 24 helpful and critical and suggestive and so forth, but I don't x
25 think we should do the staff work.
7
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l' So then the question is, what should'this
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2 subcommittee do?
8 I guess my view has been that what the subcommittee 4
should do is try to make a statement which we have so far 5
avoided, about whether nuclear' safety in the United States is 6
in great shape, poor shape, spectacular shape, needs 7
improvement, whether we are nervous.
- 1. don't know quite how 8
one wants to phrase such things.
9 But I would like to see us bite the bullet, or 10 whatever analogy seems to work, and say something that is 11 reasonably concise in that regard.
I doubt that we could get 12 a collegial view for the full committee about such a thing.
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13 But, I think it would be worth a try, because without thn+
14 don't know quite how hard to work.
15 The prob'lem that I have had with NRC 'is the lack of 16 a regulatory philosophy within NRC, not a lack of lists of 17 technical things to work on.
Those ' lists exist. But, there is 18 no regulatory philosophy.
And deep underneath, that suggests 19 that the question of how hard one has to work at improving 20 reactor safety or whether one has to work at it all, really 21 hasn't been resolved within the agency.
I don't see how it 22 can.
23 I see the deep problems of NRC as problems of O
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24 ossification.
That is, of slowness, of bureaucracy, 25 ponderousness,'of inability to ever close out an issue.
For
-8
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1 example I know I am talking too much -- but an example that 2
crossed my desk, in the pile of mail that I found this week 3
_ was t*
piping, Historical Seismic Piping Report.
4 And the Historical Seismic Piping Report discovers, 5
to no one's s u r p r i.s e, that earthquakes occur, the piping that 6
survives is flexible piping, and the piping that breaks is 7
rigid piping.
/
8 Now, many people.have been saying that to NRC for a 9
fong, long time.
But, there is a very ponderous program.in 10 place to discuss how one can license the flexibility of piping 11 and how one can go into the slightly inelastic dcmain with 12 piping.
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IS The fact is, the evidence is there that the cor-nt 14 regulations, which'are for extraordinarily rigid piping for 15
'llcensability reasons, is'not the way to make the piping safe 16 from earthquakes. Everyone.has known this, but nothing has 17 happened about~lt.
Now there is a historical review that 18 verifies something everyone has known, and.still nothing will 19 happen about.It 20 That.is where I see the problems.
Not in making a-21 list, the difficulty of addressing issues in terms of their 22 relevance to safety, rather than their amenability to 23 regulation.
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24 i know it is hard to quantify that comment.
But, if 25
'we come up with anything in that direction, I think it will
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.probably be better than another ordered list, or an unordered l
m 12 list.
3 MR. REED:
This is not too much different, than if a%'
you go to. root _cause, I think, than my third point, that 5
regulatory structuring has a problem.
6 H a l.
is saying, well, it ought to lean on less paper 7
and more understanding it, more wise and this kind of thing.
1 8
1 think that is what it is saying.
I think there is a problem 9
with regulatory' structure, too.
I agree with you.
10 I might point out something in this issue, in 11 our considorations today.
I think we ought to keep in our.
12 minds this recent Commission release, that it-is likely that
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i 18-ive will have one more major TMI type accident between now and 14 the year 2000.
Now, that is a release.
15' It seems to me if we are going to assess the state-16 of -nuc l ear power safety, we have to reflect on that and decido 17 what steps along the art of the possible, what concrete things 18 can back that. prediction down.
19 DR. L Eld i s :
'Glenn, I wouldn't take the number
.5' 20 that the Commission supplied to Mr. Markey all that 21 seriously.
You saw how.it was calculated.
It differs by a 22 factor of 8 from the ACRS estimate of essentially the same 12 8 thing.
24 Both numbers have enormous uncertainties associated 25 with it.
In both cases I hate to say it -- people used the
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2 difference.
I wouldn't take the quantitative number 8
seriously.
4 But, on the general question of whether there will 5
be another major accident, I agree with the general statement 6-that there will be.
I go around giving speeches to that 7
effect.
.O The Kemeny Commission complained that w'ithin the 9
industry.and within the NRC there.is a mindset that someMcw to large accident was impossible. And it is still visible in 11 large segments of the community.
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12 So, it is important, not in the sense of making a
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14 likely sources.of such an accident are and to see what we are 15 doing about them.
Everyone knows my candidate.
My candidate 16 isla systems interaction induced by a control system failure, 17 which I think NRC is really not handling very well 13 We have had plenty of precursors to such a thing, so 19 that when we say that we ought to learn from operating 20 experience, this is a prime candidate.
We have-seen it 21 happen.
We have never come close to a major accident, but we 22 have seen unpredicted systems interactions occur through 23 control system failures.
And on my list that is one of the l\\
24 things that we are not doing very well with.
25 MR. REED:
I agree with you, and a control. system --
t 11
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1 I am going to lay it right.out here. A control system failure p
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2 on a B&W plant -- and I will say it is level control system S
failure on a B&W plant can lead to perhaps another Three 4
Mile.lsland.
All right.
5 Now, what are.we going to recommend?
What is a 6
stop, or what is a cure, or what is something?
A hard 7i decision.
What is a cure to take care of that?
8 in my opinion, it is blowdown off the top of the 9
candy cane.
10 DR: LEWIS:
We are being very helpful to you, aron 11 wn, Mr. Subcommittee Chairman.
12-DR. KERR:
.Yes.
You are, in the sense that if the
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13 NRC: looked at us, I think they could make some of the same 14 criticisms.
15 DR. LEWIS:
I agree with that.
16 DR. KERR:
I don't disagree, for example, that we 17 ought to make some statement that means something.
And that 18 is the statement, in my view, we are convinced that the state 19 of nuclear power safety is great, that would say something.
20 And that somebody would immediately ask, well, why do you 21-think that? And we could be coy and say, that is because we 22 are a wise, prestigious, ossified group.
But, that wouldn't 28 be very convincing.
24 DR. LEWIS:
The ossified wouldn't, but the 25 prestigious surely would.
12 1
DR. KERR:
So, I think one of the things we ought to w-2 try to think about is, in what form should a statement be?
8 is it simply going to be a paragraph or so that said 4
we have looked at this carefully and we are convinced that 5
things are lousy, they are in good shape, they are in good 6
shape but they could be improved, they are great. And, 1 7
think we are trying to produce something that will be useful O
to somebody.
It may be useful to the NRC since we are 9
supposed to be advisory to it, and I think should t h e r e f o r r-10 given sort of a first consideration.
11 Now, as far as the lists are concerned, we both have 12 had experience with groups like this in our professional-A
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18 careers, and the reason, as far as I am concerned, you 14 circulate a memo asking for comments is because if you don't 15 and you go ahead and do something, people will say, but you 16 didn't ask me.
17 Now, we have asked "me" and here is what we got.
We 18 have taken care of that problem.
And what we do with the list 19 is up to us.
But that is the principal purpose as far as I am 20 concerned of that'first effort.
21 We have asked people.
Now, it seems to me, we ought 22 to l o o k' at least at the memos, because it is possible that 23 there is some seed of wisdom somewhere in one of those memos.
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24 The oppressive thing to me about them was that there 25 was no general agreement on one specific problem, or two
13
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'pecific problems that we ought to get cracking on right s
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-away.
Because if it was there, I missed t h a t '.
That either 3
means that there is no problem so outstanding that everybody 4
immediately identifies it.
Or, that we are not very 5
perceptive.
Or, none of the above.
6 DR. LEWIS:
I don't have.any trouble with what you 7
just said, Bill.
In a certain sense when you say that we are s
wise, prestigious and ossified, maybe I would buy one of. those 9
three in the last analysis.
to MR. REED:
I would like to point out for the record 11 that I don't understand two of the words.
I have used the 12 word " wise" before.
Just for the record.
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8 N/
IS DR. KERR:
The effort, when you use words like t,.
14 is to use words that people either don't understand, or that 15
~are suitably ambiguous.
16 DR. LEtJ I S :
In a certain sense, the Commission has 17 been more forthright than we have on the question of whether 18 things are okay or dreadful, because -- and I blush to admit 19 that I have forgotten which policy statement it is, but there, 12 0 was some policy statement that appeared in the last year or;so 21 in which the Commission said -- is it the Severe Accident 22 Policy Statement?
23 DR. KERR:
Yes.
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24 DR. L EtJ I S :
that in our view the current 25 generation of reactors are adequately safe.
- And, it is our
14
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1 purpose in the future to use that as a base and not to go on
\\m-2 trying to improve them.
S That was a fairly direct statement without really 4
much support.
And it got a lot of criticism.
5 DR. KERR:
Well, to our credit or shame, I would-6 remind you that the ACRS is on record as having endorsed that 7
statement, and the Commission-is not.
The Commission has not 8
yet adopted that statement.
So, whatever --
9 DR. LEWIS:
I was going to go on and say I seem to 10 even recall the ACRS endorsing that comment, but I didn't knc I
11 the Commission had not yet eg _
12 DR. KERR:
1 think I am right.
The Commission has
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18 not yet adopted formally the policy statement on severe 14 accidents.
15 MR. CAPPUCCI No, not that I know of.
16 VOICE:
They scheduled it yesterday, and they 17 postponed it.
18 DR. LEWIS: _But in any case we have endorsed that.
19 So, presumably we had some basis for believing that to be 20 true.
I 21 1 blush once again to say I have forgotten what we 22 gave as a justification.
But, I think a thing like that is in 23 the correct direction if it is done in a not offhand way, b)
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24 because it provides and this was the reason why it was in 25 the proposed severe policy statement it provides a basis
15
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for a regulatory philosophy, without which_you can't function, v
2-without which you tilt at every windmill on the road, instead 8
of the ones that happen to be beating -- let me not push the 4
analogy too'far.
So, it is in that sense.
5-We always say that this business is full of 6
uncertainty.
We can't change that, but, you know, we don't i
7 have to -- everything-we do in life is' based on uncertainty
. 8 and we still have to make our best effort to guide the 9'
regulatory process, not to prevent accidents, but to reduce 10 their probability to a' tolerable level.
11 And that probability which is tolerable, may or may
.12 not include a reasonable projection for another TMl type
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18 accident before the end of this century.
There is.nothony 14 magic about the'end of the century either.
15 So, I have not been a great supporter of the effort 16 to. set quantitative safety goals by the Commission, because i 17 think it has not been done well it has been done with a kind 13 of specious regulatory philosophy.
But, safety goals set in 19 a somewhat less rigid form based on wisdom, would be helpful.
general' plan of 20 MR. REED:
Let me ask about our 21 action.
22 The purpose of this ad hoc committee, I guess, is 28 the state of nuclear power safety.
And, I don't know that it q,)
24 is supposed to exclude any foreign impressions, or whatever we 25 draw from that, or import.
'16
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1 It seems to me somewhere,an ad hoc committee is r
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2 supposed to exist for a time, and then disappear, right?
So, 8
we ought to have an action plan related to our steps or phases 4
where we are going, and what we are going to do.
5 One of the things I think we have to do, in 6
concluding this committee, is we have to address that hard 7
issue of the state of safety, and whether we agree with what 8
has been published recently or not.
I do not know.
9 Another thing is you made mention that we didn't 10 get any agreement on the priority lists that were submitted.
It' Well, maybe that is because we don't have enough rs.
12 input.
Now,.we'are planning to bring guests in to talk, and
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18 maybe we can get input from those guests.
I think we should 14 not ignore the French-German, what I thought was some input.
15 And so, we need all this input to see if we can~ come to 16 prioritizing or picking out something that m igh t be a key to 17 improvement of nuclear power safety.
10 I thought that I detected a. key from the German 19 comments of course, that again is limited to one position 20 but, I detected a key from their one DSW plant response, 21 that perhaps they felt a primary blowdown was important to 22 BWRs, some BWRs.
23 DR. LEWIS:
I agree with Glenn that we have to know
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24 where we are going before we can tell the rest of the world 25 where it ought to be going.
17
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1 And I believe, if my memory is-correct, that this V
2-subconom i t tee was set up in response to the suggestion, however S
. foolish it may have been, that ACRS ought to produce an annual 4'
or biennial ~ short letter t h a't describes the state of nuclear 5
power safety.
A kind of " state-of-the-union letter."
I have 6
always believed that that would be a good idea, and still 7
think so.
G
- And, if we could direct ourselves towar'ds making 9
one input towards a regulatory philosophy for the agency, and 10 indeed for ourselves and also an object that would be ugne-11 as a public document, that tries to lay as succinctly 4-fx 12 President doos for the whole United States each year -- rather-L) 13
.more succinctly I hope -- a statement.that we think accidents 14 are very probable, improbable, that everything is just great,.
15 or that NRC ought'to be abolished,.as one of my good 16 antinuclear friends believes NRC should be abolished, because-17
-- well, without giving reasons.
But, something that does'not 18 contain a plan for action, but simply a state of mind, a 19 document reflecting a view about where we are.
20 if we could do that in a meaningful and thoughtful 21 way, I think it would be a real contribution.
I don't know if 22 we can.
23 DR, KERR:
Nell, something of the kind to which you 24 refer would say, I assume, if one uses what we have got as 25 input so far, we see no major crisis in the immediate future.
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there are certain areas that we think deserve further
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2 consideration, and here they are, and here is why we think 3
they deserve further consideration.
4 DR. LEWIS:
Bill, if we could make that first 5
. statement, if we had a collegial view on that first statement, 6
l think it would be a very useful thing to put into the 7
record.
7 8
DR. KERR:
What I was saying was, that I would draw 9
a conclusion either that there are about 30 major issues from 10 this list, er that there isn't any one that everybody would 11 immediately pick out and say here is what.we will be working 12 on tomorrow.
I didn't see that sort of thing from the list.
13 DR. LEUIS:
That's right.
That didn't appear from 14 the list 15 DR. KERR:
The list is incomplete, because I think 16 we have responses from what, six members of the sixteen 17 possible.
18 DR. LEWIS:
There was certainly nothing-that came 19 in, and I haven't heard from anyone even in private
.20 conversations, a statement to the effect that
'I would be 21 comfortable about the present state of reactor safety, were it 22 not for the dreadful failure record of the widget on the 23 doojigger.
Nobody has said that kind of thing to me either I
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24 privately or publicly.
25 And if that is a collegial view that there is really
_ _ _ -,. _. _ _ _. ~. - _,.
7 19 V)
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1 no outstanding issue, technical er organizational issue, that 2
greatly impairs our visceral. comfort about the current. state 3
of reactor safety, if that were a true statement, it would be 4
a remarkable one.
5 DR. KERR:
I would be surprised if we could develop 6
such a collegial view.
Because I think if we then asked each 7
individual, then the individual might pick out some things, o r-O one thing that to that individual looked as if it were 9
extremely important.
And yet, it hast come out as being of n
10 the same importarce to two or three people with the limited 11 input that we have had so far.
12 So, the difficulty is -- or a difficulty is to get-fs
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19 some sort of agreement that either ther.e is no single 14 outstanding issue that is of overriding importance, or select 15 one or two that are.
16 DR. LEWISr I tried to phrase what I said in such u.
17 way as to avoid this question of importance.
Because to each 19 individual there is one, or are two or'three or whatever the 10 small. number is, issuas that are most important.
Otherwise 20 you go crazy.
21 I tried to phrase it by saying let me do it by 22 the converse and kind of repeat myself.
23 No one says, were it not for this issue I would be 24 comfortable about reactor safety.
If one were to write the 25 converse of that, and even so to say nonetheless, we think the
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things that come closest to being in that category are such
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2 and such, that is a different statement from saying that i S
believe such and such is an important question.
4 1 don't know if there is any collegiality on it or 5
not, a consensus on a comnant of that sort.
6 MR. REED:
- Well, I,
obviously, was not very 7
convincing in my paper given in France and Germany, to my-G fellow ACRS people.
But, I have to think that what I have in 9
the record with respect to decay heat removal reliability, to sort of says that for my opinion,'I agree with Dr. Kerr, if 11 you polled the members you would get almost every member to 12 say that he had one thing that was very important, he ps
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18 considered, that was urgent with respect to pursuing in ti 14 interest of nuclear reactor safety.
15 I think the record shows what my feeling is.
16 DR. KERR:
Let me try to approach what I think is at 17 least part of this question, from a slightly different 10
. perspective.
19 in some sort of ideal world, one might expect that 20 after a certain interval, one migh't reach a point at which one 21 would say, things are okay now, we don't have to do any more, 22 except at least keep people alert, make certain that 23 maintenance is well dono, and that a present level is Ak,)
24 maintained.
25 1 2ee no evidence that we are close to that yet.
21
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Are we?. Should we expect to be able to reach that state at h) 2 which we now say things are safe enough?
8 Or, is it the nature of organi=ations and technology 4
and people that in this business one will never reach this 5
state at which things are safe enough, and that the 6
operational significance of that at luast is that one 7
continues to try to improve them?
8 MR. REED:
Ours is a nation of critics.
And, even 9
in bodies like our own, we are critics of each other's 10 positions.
11 L.le just came from Germany where there are not many 12 critics with respect to unified common feeling, at least to
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13 the outside.
14 So, we live in a nation of critics..
Everybody is a 15 critic.
I wish we had more performers, more workers and.less 16 critics.
But, that isn't the way.
Our society apparently can 17 afford all its critics.
So, I don't think you are going to 18 achieve this idea you are talking about, safe enough plateau, 10 1 do think wo should do better.
20 DR. KERR Let me try'to explain a bit better than i 21 did, what I had in mind.
Let me take the automobile industry 22 since I live close to some of
.t.
23 (Je certainly don't claim operating automobiles is a D
q,/
24 very safe endeavor.
And yet, although we have our National 25 Highway Safety Transportation Board, or.whatever the correct
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22'
-n J
't string of titles is, 1 don't see it as saying the design of 2.
. automobiles needs to be changed _ drastically.
.S What 'It'does mostly is to look for things that g
4 develop after the automobile has been put on the street and to 5
-say, ahai the brakes in car'X are a. safety problem.
- But, i
6 doesn't.say'we need to redesign all the brakes on all 7
automobiles.
It just'says, exper ler co' ind icates that this 8
-particular set.i s causing problems.
Or, that another widget 9
is causing overheating in the engine or something of this 10
- sort, 11 In a sense, therefore, it seems to me we have
,-s 12
. accepted the current state of-automobile safety as adequate.
LI 18
.That doesn't mean we. don't do anything about specifi'c models
'14 of automobiIes..-or 'lf a prob 1em turns up, we don't try to fIx g r e a't national concern, at least.
'15 it But, we don't have a 16 from my point of view, about the safety of automobiles, even 17 though we know that the operation is not very safe.
10 Now, you are right, we-have a nation of critics.
19 There are people who criticl=e automobile safety and other
_20-facets of automobiles, but there is not any groundswell of 21 opposition to autc4 mobiles because they are unsafe.
22 is it likely that we will reach the same state with 23 reactors?
Should we expect that?
A 24 MR. REED ' You have interested me so much with this 25 automobile comparison, because i use the same thing.
23
['N 1
It is a very nice thing to. talk about because 2
automobiles, in my opinion, in the last ten years in the 3
United States of America have reached what I call optimum.
4 They are optimum.
You have got little things, always have 5
little things.
6 But, the engine is in the front, the drive train is 7
in the front, the weight mass is located essentially in the O
front.
It's stability, capacity, so on and so forth --
9 But, let's go back a few years. ; There were 10 au t ernob i l es that had not matured to what I cali the optimum 11 general design.
One was the Corvair.
It was en unstab 12
. automobile.
It would turn around at any time.
I used to A) t\\/
18 drive one.
14 DR. LEtJ 13 :
I disagree with you, but we can discuss 15
' cars on somebody else's time.
16 t1R. REED:
I think we are all beyond the Corunir, 17 with the engine and everything in the rear, to putting the 18 engine and everything in the front.
And now we have reached 19 general design, optimum plateau.
20 But, how many yours did it take?
Let's say it 21 happened ten years ago, the realization, it took seventy 22 years.
23 All the critics want nuclear to reach optimum
.-s 24 instantaneously, because there is always those people who 25 don't see the potential or any advantages, so they want
r ts-3, g
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1 instantaneous achievement.of the optimum.
A.,/
-2 I an willing.to accept that is not going to happen.
3 I would like to give nuclear Fifty years.
It is a pretty 4
complicated thing, anyway.
How many years has it had?
Well,'
5 it has had thirty from beginning to now.
6-I think part of our job is to push it on to this 7
optimum that you have drawn as a parallel of the au t omob iil e O
industry.
9 Now, I happen to have some feelings that we have 10 both people pushers that we have to make structured peop, 11
.and a few parts; a few locations of maybe say whether'the 3
12 engine is.in the rear or the engine is in the front.
R)
~
18 DR. LEWIS:
I'm not so sure I don't know whether 14 the analogy with automobiles in general is good or bad.
- But, 15 It is true that ACRS has a public record for each reactor that 16 is out there, as saying that it.can be operated without undue 17 risk to the health and safety of the public.
10 We are on record as saying that, We, and our 19 predecessors, going back into the mists of time.
20 l'm not sure'whether we could get a collegial 21
' comment out of the committee'saying that about the assemblage 22 of reactors, although we say it about each one, it would be 23 an interesting exercise to see if we can.
(
24 But, what I have in mind is, is an effort to do i
25 that.
And, if we can't get it, to find out why.
Because that
25
. /~~
(
1 is not a statement that there are not-important issues
(
'2 remaining.
ft.isn't a statement that there will never again 3
be another accident.
It is just a statement that reactor can 4
be operated without undue risk.
5 Obviously, it begs the question what risk is due the 6
public.
You mentioned General Motors.
I had a correspondence 7
with a good friend who works there, not long ago.
And I wrote 8
a' letter and put a PS on it and said, by the.way, how safe is 9
safe enough?
10 And he answered -- and I have to apologize to "
11-transcript, but I have to be accurate in my reporting -- he fs-12 said safe-enough is safe enough when people stop bitching.
13 And, in a certain sense, that is your comment about 14 the automobile.
There are violent critics of the. automobile 15 industry just as there are violent critics of the nuclear 16 industry, who' contend that autcmobiles are not safe 17 enough.
- And, in fact, from t i rme they get the upper-hand when 18 something happens.
19 But certainly it is true, that by and large we have.
20 accepted 40- or 50,000 deaths per year from automobiles, in' 21 return for the benefits they provide.
I think we wouldn't 22 accept it if there were not benefits.
23 You speak about the French.
people overseas make 24 jokes about how in love Americans are with their cars.
- But, 25 the fact is when given the chance, they also fell in love with
-. =.
26
/-
.(m)
I their cars.
There is something that makes for an affair s_-
2 there, and it is not just utillty, it provides other benefits 8
that people have written humorous' articles about 4
But those are the things that made us somehow accept 5
the death toll for cars.
6 So, there is a social issue as everyone knows, in 7
terms of what is acceptable.
We
..e not the ones to make O
those social judgments.
In a certain sense, the comment "when 9
people stop bitching" is the correct comment.
It sort of 10 measures tho' fact that society has accepted whatever rish 11 there is, i
_.s 12 The nuclear case is really different in.many ways 18 because nobody in the public knows what the risk is.
You 14 know, many polls have shown that.
It is because the risk is 15 configured as very rare, very damaging. accidents.
Whereas in 16 cars, you can do the statistics, you know -- and they are 17 always done wrong.
people always quote how m'any people get 18 killed on the Memorial Day weekend, and it turns out because 19 it is usually a three-day weekend, it turns out to be 50 20 percent more than are killed on the normal weekend.
21 The rate really doesn't go up very niuch, but there 22 is a lot' of publicity about it.
23 in the nuclear case it is even worse, because there
- \\_s 24 hasn't been a lethat accident, and yet the risk is there.
25 So, it is harder for the public to make the
27
[,
t 1
reasonable judgment,,and that is why we do have an obligation
\\s
-2 to try to do it, presumably being wiser than that.
But in the
,3 end what we have to do is produce something for or 1 think 4
.we have to produce a reasonably forthright comment in order to 5
elicit a societal reaction to it, which may be favorable or 6
unfavorable, that measures whether the society is willing to
~
7 accept the risk of reactors.
I-think society is.
G We have a small number of -- really a small number 9
-- of extremely active and articulate antinuclear people who 10 would never be satisfied.
But, I don't think that is th-11 measure of whether the technology is acceptable.
The measuro 1
12 is whether the broad mass of the public or the Congress accept 18 it 14 I think it would be useful for ACRS to make a 15 reasonably understandable comment that would then be usad 1,
16.
elicit a response frce the people to whom we are responsibie.
17 1 don't know how to do it.
18 DR. KERR:
In our effort to assess the state ~of
~
.19 nuclear power safety, how t*Jch of an ingredient should 20 acceptability, our. perception of acceptability, enter that 21 assessment?
22 DR. LEWIS:
1 personally think it is essential i
23 know people always say that that is not our job.
But, unless
,m
(,)
- 24 you have a measure of.that as an ingredient to what you 25.
do, you are running wild.
There is no way of knowing how to
28
{'
1-do-it.
N_j 2
l'm'one of the' few people who believes it was a 3-terrible-mistake to break up the AEC into NRC and ERDA, 4
because I believe it is possible to regulate while promoting.
5 1 know that is an offensive statement to some 6
people, but.the FAA, which has the dual responsibility of
?
regulating. aviation and of promoting civil aviation, has at.
O least within the same housing, the. responsibility to consider 9
the effect of what it does on the health of the industry.
10 The critics of the nuclear business say t h'a t NRC 11-should not consider the health of the. industry at all, it' 12 sheuld just' regulate away.
And-that is so open ended that.
't OV 18-m'akes it impossible to have a corporate philosophy, which 14 the thing 1 see missing in NRC.
15 But that is not the job of this subcommittee,.I
'16 don't think.
Maybe it is.
17 DR. KERR:
Well, from.our deliberations so f a r,~ l 18 would conclude that we propose to the conn i t t ee at some poirat 19 a letter which would say sorne t h i ng' ' l i ke the following:
20 We have looked at our previous letters and have 21 concluded from the closing sentence, that the committee is 22 convinced that each operating reactor out there can be' 23 operated without undue risk to the health and safety of the
,0
(,,)
24 public. - And that therefore, for this t il e, reactors are m
25 appropriately safe.
s c
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29 1
However, we think improvements can be made without
\\_
2 excessive expenditures of resources.
Here are some.
3 DR. LENIS:
I think one could try such a thing.
4.
But, if I were your opponent, I would instantly point out that
'5 the letters say that the reactor can be operated without undue 6
risk to the health and safety of the public at the time that-7 it was written.
And, such a letter was, of course, written 8
for TMI Unit 2 by ACRS, and events --
9 DR. KERR:
One, I think, would have to argue that 10 TMI-2, up to now, has been operating without undue risk to the 11 health and safety of the public, if one took that approach.
12-
.DR.
LEWIS:
Yes.
I think it would be interesting to
,f g
18 try out such a sentence on ACRS.
14 MR. REED:
Let me add
- a. phrase to the sentence and
- 15 '
say, without undue risk - - - - and your proof is in the TMI-2 6
16 thing.'-- without undue risk to the health'and safety of the
~
17 public, but not without financial risk to the owners.
1G DR. LEWIS:
I would be reluctant to ask ACRS to say 19 it.
My concern about the ponderousness, rigidity and all 20 those things I said earlier of NRC really don't have to do 21 with the financial damage to the utilities who own the 22 reactors.
l am not a stockholder in any reactor or anything 23 like that, but with the fact that it makes the NRC really not s
' (,,
24' direct its efforts in support of safety, 25.
People have said -- I know I have often said that
30
,~'
[
1 NRC has as-its function, regulation, almost
'\\ ))~
'ndependently i
2 or sees its function as regulation almost independently of 3
safety, and it is very inadequate in relating what it does to 4
the assurance of safety of reactors.
5 That is a philosophical. comment that I could 6
document with examples.
I gave piping as an example.
7 Now, it is true that all the snubbers and supports 1
8 that were the subject of-so much controversy at Diablo Canyon, 9
cost pG&E, and inferentially the rate payers of California, 10 bundle of money.
But, that is in a sense secondary, in my 11 view.
-~ -
12 What I fear is that if there is an earthquake there, s
13 we will discover just as historical experience shows, that all 14 those damn snubbers and rigidifying to make the plant 15 analyzable, will make it more vulnerable to earthquake.
It is 16 that kind of philosophical issue that --
17 MR. REED:
Let me make a. point.
When I said that 18 phrase " financial risk to the' owners," we must recognize from l
19 financial risk comes an indirect threat. to safety of 20 operation.
l-21 Now, how does it come about?
tJe l l, it comes about l
22 because if a utility's finances are jeopardized, then their l_
_23 ability to attract or hold appropriate personnel, or to O
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24 function to do other' things that they should do, that is also l
i 25 jeopardized.
i I
(
l
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1 So, there is an indirect safety threat to a 2
financial risk.
8 DR. KERR:
The only disagreement I would have is 4
that I would think it is rather direct.
5 I agree with you.
I think this is important.
We 1
6 can't separate the two.
7 MR. REED:
But it is not a direct threat to public G
health and safety, with the containment redundancies and other 9
things that exist.
10 l'm not satisfied that we should not better 11 financially protect the core from melt.
12 DR. KERR:
From what you said, Hal, I would expect 18 that after the preamble in this letter, the principal emphasis 14 in the "est of the report, might be on suggested changes of 15 the way in which the NRC operates, including its philosophy.
16 DR. LEWIS:
I believe that is actually more 17 important than the list of technical issues, because I don't 18 believe that NRC. operates in such a way as to do the best job 19 with this' vast pool of skilled, experienced and educated 20 people to assure the safety of.the reactor.
21 And_it is not just the emphasis on regulation.
Even 22 at the Commission level, people have been talking for years 23 about the extraordinary legalistic rigidity of the ex parte f%k) 24 rules and the separation of powers rule, which are well within 25 the power of NRC to change within the law.
And, nothing ever
_=
32
.,x 1
1
- happens,
]
w 2
is it conceivable, for example, that a Commission 8
with the responsibility for the safety of nuclear reactors, 4
when an issue really comes to a head, the first thing it does 5
is to erect a barrier between.Itself and its staff, who are 6
the repository of all the technical information about the 7
subject at hand?
8 it rnakes on the face of it, no sense at all
- And, 9
it is not even required by law, in my view, as a documented 10 amateur lawyer.
11 There are a lot of things like that.
12.
DR. KERR.
.Glenn, I am not sure that you would go g
13 along with that as a first priority.
14 MR. REED:
I guess the first. priority -- I guess i 115 was sort of drifting off in a thought here -
.is that.your-16 suggestion is structuring, regulatory structuring.
'Is that i
17' It?
Or, motivation?
Or interfacing?
l 18 DR. KERR:
Concerns about the way in which the NRC 19 operates to do good,- structured --
20 MR. REED:
I protected myself, you,see, by making l
l 21 many lists, and coming up number one on the latest list:--
22 and I had to think long and hard I put motivation of 28
. licensing skilled personnel in the workplace.
l
.rh
- i. (,,
24 Well, that really directly relates to how well 25 the NRC is organized to efficiently, and without undue t-
j' i
i j'.
83' 1
1 adversariaIism, do its job.
So, it is number one on my Iist, i-j 2
' I guess 'although i t is said difforently.
3 CR. KERR:
Why don't we, since.we have been carrying-i.
{'
4 on this strenuous discussion for about an hour, take a I
1 i
5 ten-minute break.
6-tRecess) s 7
(Whereupon, at 9:40 a.m.,
the recorded session of 8
the conference was concluded.)
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1 CERTIFICATE OF OFFICIAL REPORTER I
2 3
4
)
5 This is to certify that the attached proceedings 6
before the United States Nuclear Regulatory Commission in the 7
matter of:
Advisory Committee on Reactor Safeguards 8-9 Name of proceeding: The Ad Hoc Subcommittee Meeting on the State of Nuclear Power Safety 10 11 Docket.No,
[J
\\
12 place: Washington, D.
C.
13 Date: -Friday, May 31, 1985 14 15 were. held as herein appears and that this is the original 16 transcript thereof for the file of the United States Nuclear 17 Regulatory Commission.
is
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' i>i
[
(_ Signature) g 39 (Typed Name of Reporter)
Mimie Meldzer 20 21 22 23 Ann Riley & Associates. Ltd.
24 25
.