ML20129J445
| ML20129J445 | |
| Person / Time | |
|---|---|
| Issue date: | 07/11/1985 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 ACRS-T-1429A, NUDOCS 8507230059 | |
| Download: ML20129J445 (91) | |
Text
ORIGINAL e
UNITED STATES OF AMERICA
(~
NUCLEAR REGULATORY COMMISSION In the matter of:
Periodic Meeting with Advisory Committee on Reactor Safeguards (Public Meeting)
Docket No.
(
Location Washington, D. C.
Date Thursday, July 11, 1985 Pages:
1 - 84 0507230059 050711 PDR 10CFR PDR PT9.7 ANN RILEY & ASSOCIATES Court Reporters
'(.
1625 I St., N.W.
Suite 921 Washington, D.C. 20006 (202) 293-3950
. I p.,
1 D I SCLA I M ER 2
3 4
5 0
This is an unofficial transcript of a meeting of the 7
United States Nuclear Regulatory Commission held on Thursday, a
July 11, 1985 in the Commission's office at 1717 H Street, 9
N.W.,
Washington, D.C.
The meeting was open to public 10 attendance and observation.
This transcript has not been 11 reviewed, corrected, or edited, and it may contain 12 inaccuracles.
13 The transcript is Intended solely for general 14 Informational purposes.
As provided by 10 CFR 9.103, it is 15 not part of the formal or informal record of decision of the 16 matters discussed.
Expressions of epinion in this transcript 17 do not necessarily reflect final determination or beliefs.
No le pleading or other paper may be filed with t he Cece i s s i on in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Commission may 21 authorize.
22 l
23 l
l 24 l
25
1 6
1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
4 5
PERIODIC MEETING WITH ADVISORY COMMITTEE ON 4
REACTOR SAFEGUARDS 7
S 9
Public Meeting 10 11 Room 1130 12 1717 H Street, N.W.
13 Washington, D.C.
14 15 Thursday, July 11, 1985 16 17 The Commission met in public session, pursuant to 18 notice, commenoing at 9:30 o' clock a.m.,
Nunzio J.
Palladino, 19 Chairman of the Commission, presiding.
20 COMMISSIONERS PRESENT:
21 Nunzio J.
Palladino, Chairman 22 James K.
Asselstine, Commissioner 23 Fredertok M.
Sernthat, Commissioner 24 Lando W.
- Zooh, Jr.,
Commissioner 25
2 1
STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:
2 S.
Chilk 3
M.
Malsch 4
D.
Ward 5
W.
Kerr 6
C.
Wylie 7
F.
Remick 8
D.
Okrent 9
H.
Lewis 10 D.
Moeller 11 J.
Ebersolo 12 H.
Etherington 13 R.
Axtmann 14 P.
Showmon 15 M.
Carbon 16 C.
Stess 17 G.
Reed 18 C.
Mark 19 20 21 22 23 24 25
3 1
P ROCEED 1 NOS 2
CHAIRMAN PALLADINO:
Good morning, ladies and 3
gentlemen.
4 We have with'us this morning members of the ACRS to S
brief the Commission on two subjects:
LCRS activities related 6
to consideration of seismic events and emergency planning; and 7
then safety goals.
8 The discussion regarding emergency planning, seissio 9
considerations had originally been scheduled for a previous I believe it was the May meeting, but we did not 10 meeting 11 get to it at that time.
12 With respect to considering seismic events in 13 emergency planning, the Commission last met with the ACRS on 14 this subject in October 1944, 15 Subsequently, on December 18th, 1984, the Commission 16 issued a proposed rule.
The proposed rule offered the 17 opportunity for comment on the position of the majority of the 18 Commission that eart$ quakes need not be considered in 19 emergency planning.
20 Regarding safety goals, in early 1983 the Commission 21 pubitehed a po11oy statement that contained provisional safety 22 goals in numertoal design objectives.
The two-year evaluation 23 period for this polloy has recently expired, and the 24 Commission is presently considering what, if any, revisions 25 are necessary before issuing a final safety goal policy
4 1
statement and plan for implementation.
2 We look forward to our discussion with the ACRS.
3 But before turning the meeting over to the A C P.S chairman, do 4
any of my fellow Commissioners have any opening remarks?
5 COMMISSIONER ASSELSTINE:
No.
6 COMMISSIONER BERNTHAL:
No.
7 COMMISSIONER ZECH:
No.
4 CHAIRMAN PALLADINO:
Thank you.
9 Then let me turn the meeting over to Mr. Dave Ward.
10 MR. WARD:
Thank you, Mr. Chairman.
We also look 11 forward to our discussions, and we will get right on with it.
12 Dade Moeller will take the lead on the seismio 13 planning dis.oussion, and David Okrent will take the lead on 14 the quantitative safety goals.
So I will ask Dr. Moeller to 15 begin now.
16 MR. MOELLER:
Thank you.
17 Over the past few months the ACRS Subcommittee on 14 Reactor Radiologion! Effects and Onsite Evaluation have met 19 with the NRC Staff, and we have met with representatives of 20 FEMA, and then we have called in a number of consultants to 21 discuss the subject of emergenoy planning as related to 22 natural phenomena, and with a specific emphasis on 23 earthquakes.
24 As a result of these discussions and deliberations, 25 we have resobed certain conotusions and want to share some of
e 5
1 those with you this morning.
2 The thoughts that I will be sharing with you will 3
consist of conclusions that the subcommittee has reached, as 4
well as conclusions that the committee in general has reached.
5 The conclusions that the committee as a whole 6
reached were submitted or presented to you in our recent 7
letter on that subject.
and this was in our 8
Our first conclusion was 9
letter -- we see no technical reason for the exclusion of 10 earthquakes from the natural phenomena to be considered in 11 offsite emergency planning for nuclear power plants.
12 Many natural phenomena, including hurricanes, floods 13 and tornadoes, as well as earthquakes could impede the 14 effectiveness of emergency response.
Because the frequencies 15 and severities of these events vary over a wide range from one 16 geographic area to another, we believe that the degree to 17 which these natural phenomena should be considered has to be 16 plant-specific and site-specific.
19 Secondly, we believe that only limited consideration i
20 of earthquakes is appropriate.
21
}iaving said that they should be considered, we
't 22 believe that only limited consideration is appropriate.
23 Consideration of the impact of natural events need 24 not be elaborate, nor need it involve significant, if any, 9
25 added cost.
The major effort should be to become aware of the
6 1
problems and the alternative approaches for their resolution.
2 In some cases, such consideration may lead to a 3
decision that no specific response or action is required.
And 4
I would emphasize that a key point is what is meant by 5
consideration.
6 To us, the consideration of earthquakes does not 7
mean that you must go out and strengthen all the bridges that 8
might fail if an earthquake occurs; or it does not mean you 9
must build alternate roads for evacuation in case the existing 10 roads should be covered by landslides or so forth.
11 We believe, as I will point out in just a few 12 minutes, that it mainly means evaluating what might disturb
.13 normal emergency response in case an earthquake occurred, 14 either at some time close to the time of the accident.
15 Because of the very low frequency of occurrence of many 16 natural events, it may not be appropriate to impose major new 17 requirements.
And here is the point:
18 Rather, the goal should be to assure that emergency 19 plans as developed contain sufficient flexibility to cope with 20 the potential added impact of such events.
21 COMMISSIONER BERNTHAL:
Did I hear you just say in 22 case the earthquake occurs at some time close to the accident 23 MR. MOELLER:
We considered in our thinking two 24 possible scenarios, you might say.
One was that the 25 earthquake caused the accident, so it was the initiator.
The
7 1
other was that an accident occurred and an earthquake happened 1
2 to occur some time close to it.
3 COMMISSIONER BERNTHAL:
Do we normally consider one 4
in a hundred million events?
5 MR. MOELLER:
Oh, the probability of that is 6
extremely remote.
7 COMMISSIONER BERNTHAL:
Miniscule.
Then why are we 8
talking about it?
9 MR. MOELLER:
Well, certainly I,
in speaking of it, 10 did not mean that it had a probability of a sufficiently high 11 nature that it should be considered.
It is just simply one of 12 the two potentialities that were in fact written in the 13 Staff's material that was presented to us, and so we therefore 14 15 COMMISSIONER BERNTHAL:
I see.
You don't 16 necessarily agree that it's sufficiently probable, at least 17 that particular case, that it deserves special consideration 18 MR. MOELLER:
I persona 11'y do not.
19 COMMISSIONER BERNTHAL:
Okay.
Thank you.
20 MR. MOELLER:
Going on.
For example, for sites 21 where an earthquake is capable of severely damaging emergency 22 travel routes is sufficiently likely to occur, the local 23 offsite authorities should have the benefit of studies 24 indicating the types and potential locations of such damage.
25 The study of this kind that was performed for the
e 8
1 region surrounding the Diablo Canyon site appears to us 2
sufficient to meet the need.
3 Thirdly, a review of the history of the NRC 4
regulatory process shows that the potential impacts of 5
earthquakes have for many years been given detailed 6
consideration in the design, construction and operation of 7
nuclear power plants.
8 And the same is true relative to emergency 9
planning.
Although FEMA does not consider the potential 10 impacts of earthquakes on nuclear power plant emergency 11 planning on a formal basis, the representatives with whom we 12 met stated that for some time they had considered the impacts 13 of earthquakes on an informal basis.
14 Examples of such considerations are the requirements 15 for the development of multiple mechanisms for communication 16 and for the identification of alternative routes for 17 evacuation.
18 Fourthly, and this touches somewhat on Commissioner 19 Bernthal's remarks, although it might be possible to rule out 20 consideration of the impact of certain natural events, such as 21 earthquakes on the basis of their very low probabilities, we 22 believe that the wide range of uncertainties in such 23 probabilities compromised this approach.
24 Now this was a subcommittee conclusion, not a Full 25 Committee conclusion.
._ _~,.
9 1
In addition, we were influenced by the fact, as you 2
know, that PRAs for several nuclear power plants indicate that 3
earthquakes, despite their low probability, may be significant 4
contributors to the risk of core melt accidents, and that 5
would be the earthquake as an initiator, not an earthquake at 6
the same time.
7 The fifth item, we noted that FEMA is coordinating a 8
national earthquake hazards reduction program 9
COMMISSIONER ASSELSTINE:
Let me stop you and ask 10 you on that other point, the potential for the earthquake 11 being a contributor or a cause of a problem in a plant.
Is 12 your concern only with a very large earthquake that would be 13 1arger than the safe shutdown earthquake?
Or does that 14 potential extend to lesser earthquakes, at least as far as you 15 are considering it?
Do you think the issue should be 16 considered for emergency planning purposes?
17 MR. MOELLER:
I would probably call upon other 18 members of the committee to really respond to that, since 19 there are others far more expert in that area than I.
20 COMMISSIONER ASSELSTINE:
Well, you can defer it, 21 then.
22 MR. OXRENT:
Well, I will offer an opinion.
The i
23 studies that I have seen to date suggest that at the SSE 24 level, barring some really gross oversight, you dc-not expect 25 serious trouble at the plant.
It is for levels somewhat a' cove
e 10 1
the safe shutdown earthquake that that question starts to 2
begin to have a possibility of being considered.
3 COMMISSIONER BERNTHAL:
It seems to me also I
but it's also erroneous 4
don't know whether you agree or not 5
to attach a sharp cut-off kind of concern to SSE, that your 6
concern goes up in some exponential proportion, I suspect, to 7
the Richter scale event.
8 So i f it is a 6.5 event on Diablo, you might have 9
some minor concern.
At 7.5 you begin to have concern.
AT 8.5 10 you are seriously concerned.
And it is not like I'm concerned 11 if it's more than 7.5 or 75 g,
if you will I'm not 12 concerned if it's
.70.
It seems to me that goes without 13 saying.
14 MR. OXRENT:
I think what you say is valid, both in 15 the plant and offsite.
1 16 COMMISSIONER BERNTHAL:
Certainly.
17 COMMISSIONER ASSELSTINE:
There are certain trigger 18 points in the emergency plans for different plants that 19 require actions, emergency planning actions at certain
-, t 20 levels.
Why shouldn't you look at the complicating effects of 21 earthquakes on emergency planning at those levels, quite apart 22 from whether the event actually causes a radiological release 23 from the plant?
If in fact the emergenoy plan has been 24
. devised for the site, say, at certain levels, maybe the 25 operating basis earthquake, for example, emergency planning ey e
11 1
actions have to be taken, people have to get to the site, 2
states and local governments have to activate their centers or 3
make preparations to activate their centers.
4 Why shouldn't you look at the complicating effects 5
of earthquakes on those kinds of arrangements that are 6
specifically called for under the plans at those levels, quite 7
apart from the concern about whether that event will actually 8
trigger a radiological release?
9 MR. KERR:
I guess I don't understand the question.
10 Did the rest of you?
11 MR. MOELLER:
Well, I think I do.
12 What you are saying is let's assume that a nuclear 13 power plant is operating and an earthquake occurs which 14 damages offsite bridges or landslides over the roads, but not 15 enough to affect'the nuclear power plant.
And you are
~
16 questioning should not at that point, since the normal 17 emergency plan response could not be implemented in the normal 18 manner, should you not take that into consideration?
19 COMMISSIONER ASSELSTINE:
Yes.
And in fact where 20 the plant itself requires emergency actions.
21 For example, I understand that the Diablo plant 22 requires that at the level of the operating basis earthquake, 23 the plant has to be shut down, certain emergency actions have 24 to be taken prior to licensing under the plan.
If that's the 25 case, why don't you have to ensure that those arrangements can
l 12 1
in fact take place, that they will occur?
The plan is 2
sufficiently flexible to permit those actions taking place as 3
required under the plan.
4 MR. MOELLER:
I presume that you would.
I think 5
what you are saying makes sense.
6 CHAIRMAN PALLADINO:
Well, would you consider -- let 7
me take a different situation.
Let's assume you're in a part 8
of the country where a severe snow storm happens once every 9
275 years, with some uncertainty.
Would you plan for or would 10 you take that and the complicating effect in planning for 11 emergencies under the circumstances you are talking about now 12 MR. MOELLER:
My understanding is that unusual snow 13 storms are taken into account in emergency planning.
Whether 14 a storm that occurs once every so many years, I would not 15 know.
16 CHAIRMAN PALLADINO:
Well, I don't think we take 17 into account every situation in every part of the country.
18 What I am getting at is that if you are going to make it 19 site-specific, then you do look at the frequency of the event 20 that you are considering, and there are some parts of the 21 South that hardly ever see snow, and maybe there is one part 22 there that hasn't had a severe snow storm in 275 years.
1 23 I am asking, would you protect in that situation?
24 MR. MOELLER:
I can't answer for a certain number of 25 years.
But I do agree totally with you that hurricanes are
13 1
considered where they're likely to occur; major snow storms 2
would be considered on the site.
3 CHAIRMAN PALLADINO:
Well, what I'm getting at is 4
the frequency that you expect the natural phenomena is a 5
factor.
6 MR. MOELLER:
Absolutely.
7 CHAIRMAN PALLADINO:
And I would say, well, then, a 8
similar factor would apply with regard to earthquakes?
I mean 9
not the same factor, but the same kind of consideration.
10 COMMISSIONER BERNTHAL:
I'm not sure you all realize 11 that you stepped into a simmering discussion left over from 12 yesterday.
13 COMMISSIONER ASSELSTINE:
Oh, I think they realize 14 it.
15
[ Laughter.]
16 COMMISSIONER BERNTHAL:
We were subjected to the 17 modern day equivalent of McCarthyism yesterday, directed at 18 technology and those whose job it is to regulate technology.
19 So that is what is going on here.
20 MR. MOELLER:
Right.
21 CHAIRMAN PALLADINO:
It may be a continuation of the 22 same kind of thinking, but nevertheless I think it is 23 pertinent to this discussion, the frequency of natural 24 phenomena.
It is important.
25 MR. EBERSOLE:
Well, it seems to me that the
14 1
probability of ordinary injuries and hospital cases and need 2
for ambulance services and some other things would transcend 3
by far a consideration of the need to look at transportation 4
difficulties in the course of earthquakes, even into large 5
cities like Los Angeles.
6 I hear very little about this sort of thing being 7
done.
It seems t o me we are beating a very small dog to death 8
here.
9 MR. LEWIS:
Well, the issue is, what fraction of the 10 time and facilities that you need for normal emergency 11 planning are out of service in an emergency action?
That's a 12 question you raised.
What fraction of the time they're out of 13 service and whether that's a big deal.
14 I don't think, you know, clearly if something is 15 absolutely essential, that is different from when it is simply 16 desirable.
For example, you know, an aviation analogy, you 17 fly twin-engine airplanes, and you like to have both engines, 18 but that doesn't mean that when one engine is lost and you've 19 lost your redundancy, you land instantly.
You simply -- you 20 have a reasonable chance of going on and completing your 21 mission on the one engine.
22 And isn't that the case here?
You don't want to 23 shut down the plant when you lose your capability to de 24 emergency planning on the chance that there may be core melt 25 in the interim.
15 i
COMMISSIONER'ASSELSTINE:
I couldn't agree with you 2
more, Hal, and, in fact, I agree very much with the comment 3
that Dade raised, too, about the extent of consideration that 4
this issue has to require.
But I think there's a difference 5
between saying, should we look, to a limited extent, to see 6
whether the plans have sufficient flexibility, the very point 7
you just raised, whether if communications are out for a very 8
limited period of time, this is going to make any practical 9
difficulty, or whether if a telephone line comes down, there's 10 a radio that's available, or whether if one road happens to be it impaired for some reason to a limited extent, there's another 12 road that's available.
13 That, I think, is a different question, though, from 14 saying, should we simply rule out any consideration at all, 15 and under what circumstances do we have enough confidence that 16 the uncertainties are sufficiently low for emergency planning s
17 purposes, recognizing that in essence that is the planning for 18 improbably events, that we have sufficient confidence to say, 19 "We don't even have to look at that, not to any extent, not to 20 a limited extent, not at all."
21 I think that's really the heart of the question.
.I i
22 couldn't agree with you more.
You don't shut down pl$nts; you 23 don't land airplanes or whatever wh4n you have a limited 24 impairment.
25 The question is, do you plan, though?
Do you, for
16 1
example, thing in advance, what are my procedures if I lose an 2
engine, and under what circumstances do I shut down?
Do I try 3
to land, or I continue to fly?
4 And I think that's closer to the analogy of 5
emergency planning.
What do you think about, in terms of the 6
flexibility, and that's a different question from how much you 7
have to give to the issue.
8 MR. LEWIS:
I think that's what Dade said.
9 COMMISSIONCR ASSELSTINE:
I think that's exactly 10 what Dade said, right.
11 CHAIRMAN PALLADINO:
But again, I think the 12 frequency of the postulated natural phenomenon is important.
13 MR. MOELLER:
Absolutely.
14 COMMISSIONER BERNTHAL:
I'd like to get beyond 15 instincts and feelings and what seems to be reasonable and 16 things like that, and ask'whether you gave some serious 17 thought to numbers and probabilities here and different types 18 of natural phenomena, because, as you know, that is one of the 19 considerations in the current, ongoing rulemaking?
And the 20 thought has occurred to me, as my colleagues know, that there 21 really do seem to be two rather different types of events, 22 distinguishable -- and easily distinguishable, I believe on 23 the basis of numbers, not feelings, and those are tornados 34 and earthquakes, because they are both random events with very 25 severe consequences, but at very, very limited locations, a
17 1
ver'y low probability at any given point.
2 And I'm just wondering if you gave any serious 3
thought to the numbers that are associated with such things?
4 MR. OKRENT:
May I offer an individual comment?
5 Except for a few of the old plants, tornado 6
protection is supposed to have been provided, and it's 7
supposed to have been provided such that an event which 8
exceeded the protection provided should be a very 9
low-probability event indeed.
10 The Staff has recently been modifying its 11 requirements, and in the process, that probability may be 12 increasing a little bit, but it is still, so far as I can 13 tell, the experts say, a relatively low probability or 14 frequency per year that a tornado would lead to a severe core 15 damage accident, a lesser probability, except again for a 16 limited number of plants, than an earthquake doing the same 17 thing.
18 The earthquake likelihood of producing both a I
19 coremelt accident and possibly a release ends up for many for which this kind of 20 won't say all of the plants 21 evaluation has been done in a PRA, to be in the same ballpark that might lead to frequency-wise 22 as other events which 23 a significant release.
24 So if you are going to think about emergency 25 evacuation, the tornado, on the one hand, seems to be a lower
18 1
frequency event from the chance of it producing coremelt, 2
although it may be a higher frequency event from the point of 3
view of it hitting the site, in some size, let's say.
Small 4
earthquakes, of course, are all around us.
5 So I think the committee doesn't view the earthquake 6
as being disconnected from the chance of ceremelt.
7 On the other hand, we do think it is not a likely 8
kind of accident, and I think what we try to say in our letter 9
is that with mome study of the surroundings, the local 10 authorities would have this kind of information, and one could 11 then anticipate, given an earthquake, it might be you'll have 12 a landslide here or a bridge collapse there.
You don't know, 13 in fact, which way the earthquake is going to be coming from.
14 You can't predict strictly what the damage will be.
But at the more vulnerable areas can have 15 least the vulnerable 16 been identified, and the emergency people, the police or the 17 sheriff, can say, "Well, if we need to evacuate, we'd better 18 check by helicopter or whatever to see that that route is 19 available, or call someone if the phone is up or whatever, so 20 that we can alter the route that we would have taken."
21 And there can be some of that kind of pre-planning.
22 Now they are doing that kind of pre-planning on some l
23 scale for dam failures now in California, certainly.
I don't 1
24 know if FEMA requires it everywhere.
They are trying to think 25 about it in connection with certain other kinds of things that
.., ~. - _ - -
19 1
might cause a need for evacuation.
2 A heavy rainstorm strikes me as something very 3
different.
It is very unlikely to cause a -severe core 4
accident.
On the other hand, it might hamper evacuation if 5
you need it.
6 COMMISSIONER BERNTHAL:
And it's a much higher 7
probability.
8 MR. OKRENT:
It's a higher probability.
So 9
therefore when you are planning emergency evacuation, you say, 10 well, you know, let's just say, since the chance is whatever 11 it is, one in twenty or something depending on where you live let's make sure we've thought 12
-- in Florida, maybe more 13 about it in what we're doing, but not that it's something 14 coupled to the event.
15 COMMISSIONER BERNTHAL:
But it seems to me, I'm 16 hearing everything you're saying and hearing very few numbers, 17 which is the point I was making, and it seems to me that it's 18 time to get this stuff on a rational basis, because I could as 19 well suggest that on the coast of California, you really ought 20 to be looking at flash floods coming down canyons and taking 21 out bridges and the probability of that, which for flash flood 22 type events on the West Coast, rains tend to be heavy and more 23 sustained than they are, perhaps, in the Rocky Mountains or 24 other such places.
25 But it just seems to me that there hasn't been a
20 1
very careful job done with the numbers on this thing.
I'm not 2
frankly sure that it's worth all the effort it might entail, 3
but since this has aroused such controversy, it just may be 4
that the effort needs to be made.
And you've got tornados and, 5
earthquakes, which seem to me, at least in terms of 6
probability as ev e's t s, the probability of severe damage at any 7
given location being very low in those events, whereas 8
normally in emergency planning, our benchmark has been to plan one-year, ten-year, 9
for the annual event or less, you know 10 whatever it is.
I believe that's written down somewhere.
11 COMMISSIONER ASSELSTINE:
I don't think that's 12 right.
I think that's inconsistent with what the Staff said 13 in the July 5th memorandum.
14 COMMISSIONER BERNTHAL:
Well, in any case, that is 15 somewhere in the NRC history and lexicon.
We tend to plan for 16 things we reasonably expect to occur, not necessarily every 17 year, but roughly annual events.
18 COMMISSIONER ASSELSTINE:
I think that's wrong.
19 MR. KERR:
In a sense, what we are planning for is 20 an evacuation.
21 COMMISSIONER BERNTHAL:
That's right.
22 MR. KERR:
And an evacuation should occur, I think an evacuation is needed 23
-- well, let me put it this way 24 only if one has severe core damage accompanied by a 25 significant release.
21 1
COMMISSIONER BERNTHAL:
Well, we've already agreed, 2
I think, that we're not talking about the random coincident 3
event.
I think we agree that that's such low probability that 4
we normally don't worry about that.
5 MR. KERR:
But if you look at the probability of 6
severe core damage accompanied by significant release, what is 7
the probability of the annual frequency?
It's maybe 10 to the 8
-6 per year, 10 to the
-5 or 10 to the
-6.
So we are already 9
doing emergency planning for something which we expect to have 10 an extremely low frequency.
11 Now evacuation may occur more frequently than that.
12 What I an asking is, when does one need it?
One needs it if 13 one has severe core damage followed by significant release.
14 COMMISSIONER ASSELSTINE:
Bill, I guess I would 15 disagree with that characterisation of emergency planning.
I 16 don't think that emergency planning is just evacuation.
I 17 really think emergency planning is a full range of i
18 activities.
In fact, I think we've tried to stress that on a j
19 number of occasions.
20 Ultimately, one of the things you may be most 21 concerned about is a severe core damage accident with the 22 release that would entail evacuation, or a situation in the 23 plant that has that potential that would require the various 24 preliminary steps to get ready for that kind of activity.
25 MR. KERR:
The question was not when you would do
22 1
something.
My question was, when do you need it?
And you 2
need it only if the thing occurred.
You might evacuate, you 3
might take precautionary actions, but you are really planning 4
for an event whose occurrence you expect to be very, very low.
5 COMMISSIONER ASSELSTINE:
I agree with you that that that is 6
is a major element of concern, but I don't think 7
when you need an evacuation; that is not necessarily when you 8
need emergency planning.
I think you may need emergency 9
planning in a much broader range of situations.
10 MR. KERR:
I'm not asking when you need emergency 11 planning.
I'm saying you are planning for an event which 12 occurs, we think, on the average, about once every 10 to the 13
-5 or once every 10 to the
-6 years.
14 No how often you need to plan, how often you need to 15 exercise, when you may exercise those plans is another 16 question.
17 CHAIRMAN PALLADINO:
I think Paul had a question.
18 MR. SHEWMON:
Yes.
I am some bothered by the fact i
l 19 that this discussion keeps talking about evacuation.
I think 20 there are some good studies which you can see which suggest 21 that the best thing to do is to try to convince people they 22 should stay inside instead of getting on crowded, deteriorated 23 roads.
24 But the other thing, with regard to Bernthal's 25 comment, the numbers you are seeking are around.
I would urge
23 1
you not to push too hard for them or to believe them when you 2
see them, because one argument on this earthquake problem that 3
we devote a great deal of effort to is that the main reason 4
that we have to devote effort to it is, is because the 5
probabilities are so uncertain that you end up defending 6
against the one end of the distribution, just because of your 7
ignorance, and I think, as you know, when you start pushing on 8
these, the problem of putting them out is, somebody might 9
believe they have some meaning.
10
[ Laughter.3 11 COMMISSIONER ASSELSTINE:
Is it fair to say that 12 what you really have is a sliding scale, without trying to 13 attach numbers?
14 If you had an initiator that had a high probability 15 of causing the worst kind of accident, and it was a relatively 16 frequent initiator, clearly you would want to study that in 17 great detail and plan for it in very minute detail and 18 thoroughly review it.
19 If you have a situation where you have a relatively 20 frequent event, but virtually no possibility of causing an 21 accident, you would want to consider that because of the 22 simultaneous independent accident plus the relatively frequent 23 event.
24 If you had a situation where you had a relatively 25 infrequent event, but a high potential or a high risk that it
24 1
would cause a very serious accident, it seems to me you would 2
want to consider that to at least a certain extent.
3 And then the last case where you have a low 4
probability event and very little likelihood that it would 5
cause
- a. severe accident, those you would discount.
6 But that. third category strikes me as the one where fairly low probability, but the need to at 7
earthquakes fall 8
least do some consideration because of the potential that it 9
could be an accident initiator at the plant.
10 Am I wrong on that?
11 MR. KERR:
I agree with you in principle, but one 12 has to be careful, because as I've pointed out to some of my 13 colleagues, that Lake Michigan contains enough water to drown 14 everybody in the state of Michigan, and yet we don't really i
15 try to do much to protect against that.
16 You know it is a very high consequence accident, so even there, one has to exercise some caution.
17 one has to be 18 COMMISSIONER ASSELSTINE:
But if you add substantial 19 uncertainty on the probability question of that event 20 occurring, ;t seems to me that it's a matter of prudence that 21 indicates that you want to at least take some look at it, 22 maybe a limited look, maybe only to assure yourself that there 23 is sufficient flexibility there to accommodate those kinds of 24 problems.
25 MR. SHEWMON:
I don't think there's any disagreement
25 1
with that.
2 CHAIRMAN PALLADINO:
Let me ask a question.
In 3
considering natural phenomena and the impact of the natural 4
phenomena on emergency planning, especially for a circumstance 5
where there is some event at the plant, not radiological, for 6
which you have to get people there, do we consider scrub 7
fires, forest fires?
8 As a matter of fact, I just came back from 9
California, and they're having a lot of them, and they seem to pretty frequently.
-In my lifetime, I I don't know 10 occur 11 have read a lot about them.
12 Is that considered in emergency planning?
I mean, 13 should it be?
They extend for some duration of time, so the 14 probability is better than an earthquake that they will 15 encompass a period of time where you need to get something to 16 the plant.
17 MR. SIESS:
I suspect if you looked at it, you'd 18 find that they are considered in California.
19 CHAIRMAN PALLADINO:
In emergency planning?
20 MR. SIESS:
I would think the FEMA people would do 21 it.
They would not in Illinois.
22 CHAIRMAN PALLADINO:
I see.
But do they 23 MR. SIESS:
I don't know.
But I said, if you 24 looked, I'll bet you they do.
25 COMMISSIONER ASSELSTINE:
Or should be, if they
26 1
aren't.
2 MR. MOELLER:
I can't cite a specific example, but I 3
recall that brush fires have been considered for certain 4
plants, yes.
5 COMMISSIONER BERNTHAL:
It is an annual event in 6
7 MR. LEWIS:
Well, I haven't been to California in 8
two weeks, but my wife told me it is pretty had around our 9
house.
10 COMMISSIONER BERNTHAL:
But that gets back to the I am sorry to be unwilling to give up on data, and I 11 point 12 think I have been in the business long enough that I have a 13 healthy skepticism about numbers, especially when it is black but I just don't think, 14 art like seismic prediction 15 based, frankly, on a look at some of the numbers that this 16 agency has adopted for toinadoes, for example, and some of the 17 numbers that the experts even on tornadoes use, I just don't 18 think there has been a very careful job done in doing a 19 quantitative evaluation of the various natural phenomena, 20 including brush fires, I am sure.
21 The argument we are in right now really comes down 22 to a procedural argument, but I think that from the standpoint 23 of the ACES, it would be in my judgment maybe worthwhile to 24 really try and do a more rigorous job in looking at soma of 25 these numbers
27 1
I don't know whether that can be of assistance in 2
the current rulemaking or not.
3 COMMISSIONER ASSELSTINE:
Has the Committee looked 4
at the Staff's July 5th memorandum or not?
It is fairly 5
recent, so I'm not sure you-all have seen it.
6 MR. WARD:
No, we have not, unless some individual 7
has.
8 CHAIRMAN PALLADINO:
Which memorandum?
9 COMMISSIONER ASSELSTINE:
Bill Dircks' July 5th 10 memorandum to us.
He has got some numbers in there.
Perhaps 11 it would be useful in connection with the earthquake and 12 emergency planning rulemaking.
The argument that the Staff 13 seems to make is that the probabilities, to the extent that 14 you can rely on the numerical probabilities for the 15 earthquakes, even larger earthquakes above the SSE, are within 16 range of the other occurrences that are routinely considered 17 for emergency planning.
18 It might be useful for the Committee, if it hasn't f
i 19 done so, to the extent that it is going to pursue this issue, 20 to look at the memorandum, look at the numbers and try and, I 21 guess, address Commissioner Bernthal's question within the 22 context of the numbers that are there.
23 But I guess I would also like to know whether your 24 feeling is this should be based very heavily on that kind of 25 probabilistic approach or whether one ought not to place very
28 1
heavy reliance on the numbers.
2 MR. LEWIS:
Well, you know, just speaking for 3
myself, obviously the numbers are important.
You don't take for example, in the case of tornadoes, which !
4 into account 5
did look at a while back, we are talking about numbers which 6
are comparable with the probability of the extinction of the 7
Earth by the Nemesis star which has been postulated by i
8 people.
That's the kind of thing we are talking about.
9 So if you look at the numbers, I just want to 10 reemphasize what I think Paul Shewmon said a while back.
You i
in particular numbers provided 11 have to be very careful that 12 by your Staff tend to be conservative numbers, and if you are i
13 trying to really make an estimate of whether something is 14 important, you have to look a little bit beyond the numbers 15 that you find in the normal NRC literature.
16 COMMISSIONER ASSELSTINE:
The point that the Staff 17 makes is that one of the issues they are having difficulty in 18 grappling with is dealing with the question why emergency 19 plans should not consider the complicating effects of very 20 severe earthquakes, i.e.,
two to four times the safe shutdown 21 earthquake, whose return frequency is 10 to the minus 4 to 10 22 to the minus 5,
while current emergency plans concern 23 themselves with plant accidents whose estimated return 24 frequency are also in this range.
25 So that is at least one of the difficulties the j
l 29 1
Staff is having.
2 COMMISSIONER BERNTHAL:
Yes.
I am trying to get 3
away from the argument about earthquakes, and I hope it is not 4
being lost here, Mr. Chairman.
The request that I would 5
suggest at least lodging with the ACEG is to support the 6
Commission's decision to carry through with the generic 7
rulemaking here, and t o me a generic rulemaking means that we 8
take a generio look at natural phenomena and try and get some 9
sensible numbers for these things, and numbers that put things 10 in the proper perspective by relating them to other natural 11 phenomena that are equally improbable, perhaps.
12 I don't know whether those are brush fires or being 13 hit on the head by a meteorite or what they are, but I think 14 some sense needs to be made all of all this, and tornadoes 15 comes to mind because when you look at the numbers in any 16 detail at all, one becomes very suspicious about the overall 17 treatment that has been made, particularly in some areas of 18 the country.
19 But we have a generic rulemaking going on here, and 20 it seems to me that it deserves a generic look.
21 COMMISSIONER ASSELSTINE:
Well, that is a very 22 different rule than the proposed rule.
What you are talking 23 about now is saying here is a numerical out-off, and the rule it could 24 would say whatever accident the initiator may be 25 he natural phenomena, it could be any other accident initiator
30 below a certain probability you don't consider those at 1
2 all.
3 But that is very different from what the Commission 4
proposed in its proposed rule.
5 CHAIRMAN PALLADINO:
But it is not outside the scope 6
of the rulemaking.
7 COMMISSIONER ASSELSTINE:
No, it's not.
8 CHAIRMAN PALLADINO:
As a matter of fact, that is 9
the kind of comment that we would look for, possibly.
10 MR. REMICX:
For clarification, I ask is this the 11 rulemaking that the Commission indicated it woul'd do after its 12 San Onofre decision?
13 COMMISSIONER BERNTHAL:
It is out for public 14 comment.
15 COMMISSIONER ASSELSTINE:
It is the one the 16 Commission did after the Diablo Canyon decision.
17 MR. REMICK:
But it was the one that was discussed 18 at the San Onofre 19 COMMISSIONER ASSELSTINE:
Yes, but that is 20 different, I think, from what Commissioner Bernthal has just 21 described.
The issues are related, but 22 CHAIRMAN PALLADINO:
Well, there was a proposal in 23 the rulemaking, but the proposal doesn't exclude other 24 alternatives, and I think that is what Commissioner Bernthal 25 is trying to explore, to try to get some data so we can put
31 1
the whole thing into perspective.
2 COMMISSIONER ASSELSTINE:
But as I understand that 3
proposal, it would be to say here is a standard that we will 4
use to decide what accident initiators should and should not 5
be considered. If you meet the standard for a given site, then 6
you will examine those contributors, whether they be 7
earthquakes or rain or hurricanes or fog or human error or 8
equipment malfunction or whatever.
You will consider those 9
for that particular site if they fall within the bound.
10 MR. OKRENT:
What is the date of the Diroks 11 memorandum?
12 COMMISSIONER ASSELSTINE:
July 5th.
13 CHAIRMAN PALLADINO:
It doesn't have a lot of 14 data. It has a couple of numbers.
15 MR. LEWIS:
That was a Friday when no one was 18 working.
17 COMMISSIONER BERNTHAL:
It was a Friday when no one 18 was working, and a few numbers in there also illustrate why 19 one shouldn't always trust the Staff, but I won't go into 20 that.
21 MR. OKRENT:
How about the date?
Was that accurate?
22 COMMISSIONER BERNTHAL:
There is an interesting 23 logical piece there that, nearly as I can tell, relates two 24 things because they happen randomly to have similar numbers 25 and for no other reason whatsoever that I can see.
l 32 1
MR. OKRENT:
What I am getting at is since it was 2
known that this was going to be a topic between the ACES and 3
the Commission, it would have been helpful 4
COMMISSIONER ASSELSTINE:
I'm sorry you didn't have 5
it.
6 MR. WARD:
Fred, I guess your concern is, given 7
doubts about really getting quantitative about this sort of 8
thing, you are concerned that there really isn't even a l
9 logical consiste.1cy.
10 COMMISSICNER BERNTHAL:
No, I don't believe there is 11 because there is no credible set of numbers.
What does appear 12 to be clear based en numbers is that at least two types of 13 natural phenomena stand out as different from the others, just 14 like being hit on the head by a meteorite stands out as being 15 different from others.
16 But the fact is that I don't believe there has been 17 a serious attempt to really quantify the probabilities of 18 these different things.
And I'm not saying that you look for 19 a sharp cut-off, necessarily.
It's your job, I guess, to make 20 a suggestion.
You probably recommend some sort of sliding 21 scale of concern.
But I don't think it has been a very good 22 job generically on this issue.
23 MR. MARX:
I am a little surprised at what you say, 24 Fred.
The earthquake numbers may be not very good numbers, 25 but there has been millions of dollars spent in trying to get
- - =
33 1
numbers and to draw curves of earthquake frequency at various 2
locations for every plant, and those numbers may not be worth 3
the paper they are written on, but new ones wouldn't be 4
either.
5 COMMISSIONER BERNTHAL:
No, you are misunderstanding 6
me.
I am not suggesting that new numbers on earthquakes would 7
he any better.
The problem is that for this issue, this and I grant, as 8
particular rulemaking on natural phenomena 9
Jim suggests, I an extending the specific director of the 10 rulemaking, which is toward earthquakes as a natural phenomena but if you look across the board and ask has there been a 11 I
12 relative bordering or sense given to all natural phenomena, 13 maybe earthquakes have been done as well today per se as they 14 possibly can be, and in fact that was the basis of a recent 15 Commission decision, but that doesn't answer the question of i
i 15 whether earthquakes have been placed in proper perspective I
17 relative to tornadoes, for example.
18 I won't approach the question of whether tornadoes 19 and the NRC's treatment of those quantitatively is accurate or i
20 not.
I suspect it is not as well studied as earthquakes.
But 21 then one gets to things like, well, what about brush fires?
22 What about flash floods in certain areas?
What about other 23 natural phenomena?
And where do they stand on the spectra of 24 relative risk, and which ones of these deserve consideration i
25 for the country as a whole of for separate parts of the w.,.wn.n-.
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34 1
country or whatever we happen to come up with?
2 MR. MARK:
Well, I don't want to pretend the 3
situation is good and clean and clear, but there has still a 4
great deal of thought been put into massive rainstorms, 5
hurricanes, and some of the things that one is used to 6
seeing.
About brush fires I suspect there is perhaps not as 7
much known, and perhaps in none of these cases are actual 8
solid, financially useful numbers available.
9 COMMISSIONER ASSELSTINE:
It does seem to me that 10 the point Commissioner Bernthal is raising, though, is sort of 11 at the h e a'r t of consideration of which way we go if we go with 12 the rule.
The assumption, I think, that underlies the 13 proposed rule that has been out for comment is that we know 14 enough both about the absolute probabilities of earthquakes 15 and tornadoes and the relative probabilities of those two 16 natural phenomena as compared with other natural phenomena to 17 say that these two should be excluded all together from any 18 consideration as to their impact on emergency planning.
19 If you cannot say that, then another alternative may 20 well be to address the kind of question that Commissioner 21 Bernthal raised, which is is there some threshold for all 22 phenomena that should be applied, recognizing that you are 23 going to have to look at each site and decide which phenomena 24 may meet the threshold or may not meet the threshold for that 25 particular site. But I think that is a very different question
35 1
than was put forward in the proposed rule by the Commission.
2 That was that we know enough both about the absolute 3
probabilities and have sufficient confidence in them and their 4
relation to other natural phenomena to say that the two can be 5
ruled out all together for every site in the country.
6 CHAIRMAN PALLADINO:
Chester Siess had a comment.
7 MR. SIESS:
I would like to inject a note of 8
cynicism.
I think the Commission is overestimating the 9
effectiveness of its policies or regulations on the actual 10 effectiveness of offsite emergency preparedness or offsite 11 emergency plans.
12 I don't care what you get wri.tten into those 13 emergency plans; if the local officials really don't think it 14 is going to happen, they are not going to be as prepared.
I 15 think the people out there, whether it is Illinois and 9
16 tornadoes or California and brush fires, or California and 17 earthquakes, know what their natural hasards are.
They 18 probably haven't got the slightest idea what 10 to the minus 5 19 means, but they know what their natural hazards are, and those 20 are the ones they are thinking about.
21 Now, you can't make them think about the others 22 effectively.
You can get something written in the plan, but 4
23 they won't believe it.
I have seen it in a number of other 24 instances.
25 So the numbers I don't think mean a thing to them,
36 1
and I' don't think your regulations are going to make that much 2
difference when it really comes down to what they practice, 3
what they plan, what they think about and what they worry 4
about.
5 COMMISSIONER ASSELSTINE:
That sounds more like the 6
common sense approach which I think the Staff was taking in 7
previous years.
8 MR. SIESS:
Which is very difficult to take 9
legally.
Fortunately, I'm not in a position where I have to 10 take it legally.
11
[ Laughter) 12 COMMISSIONER ASSELSTINE:
That is simply to say what 13 is it that people recognize as a concern in this particular 14 area and are the plans flexible enough, have people thought 15 about the issue enough to be able to deal with it.
16 MR. WARD:
Mr. dhairman, I would like to suggest 17 that you can assume that the Committee will give some 18 additional consideration to this.
I think that there are some 19 things, information we need to develop and discuss among 20 ourselves.
21 I had hoped that we would be able to devote more 22 than half the time to the second item on the agenda today.
23 I would suggest that we move on to that, if it is 24 agreeable to you.
25 COMMISSIONER BERNTHAL:
Let me just make a comment
+
37 1
about Carson's remark.
If what you suggest is true, then it 2
seems to me the job is easy.
If there is a large body of data 3
and numbers that just haven't been ranked and properly i
4 collated, then it's an easy job.
5 MR. MARK:
Well, some are such better based than 6
others.
N o n e1. a r e really well based.
1 5
i 7
COMMISSIONER BERNTHAL:
Right.
Okay.
l 8
COMMISSIONER ZECH:
Mr. Chairman, if 1 may make one l
l
~
9 comment he' fore you move on to the next subject.
10 First of all, I appreciate what the ACRS has done to 11 date on this;very important matter, and I hope that you will 1
12 continue after you receive the Staff paper and other papers, I I
s' cme. k i nd of a report or 13 hope you will continue to give us 14 recommendation or some kind of a f'u r t he r review of this i-15 subject, because what you say.does mean a lot to me.
16 I think we ought to take a common-sense approach to 17 the whole subject.
It seems to me thiiswe are dealing with 18 uncertainties and probabilities and statistics, that we can't 19 really, bet on 100 percent.
But just because of that, I think 20 it itjimportant that we try to come up with the most 21 reasonable, prudent and commendsense rule that we possibly 22 can.
23 It may not be^ perfect, but'I think it should at 24 least,s tisfy most of us that at is the right thing to do.
So 25 what you come up with, I just want to say I will review, as I
,y
1-38 c.
p<-
\\ fy 1
have in the past, but I would like to get a further report 7,'
2 from you, and I will review it very carefully, and it will be 3
very meaningful to me.
4, COMMISSIONER ASSELSTINE:
I again apologize that you
.5 all did not get the Staff's memorandum, but I would like to
-6 ask you to take a look at the alternatives that are described
'7 there.
It sounds to me like the direction you are moving in 8
is very close to the alternative that Mr. Dircks indicated he t
9 is thinking along the lines of.
But I think that that would 10 useful to look into.
11 COMMISSIONER ZECH:
And just one last thought, if I 12 may.
You didn't tell us whether you had a unanimous vote on 13 the ACRS, and perhaps that is not too important, but I know v'ews.
But it would seem to me that if i
14 that there are diverse li "J '1 5 you can, to pound out those views as best you can, to give us 16 not only consensus but as close to unanimous as you can, even 17 though recognizing that there are different points of view.
18 I'd kind of appreciate knowing that we had a pretty strong 4
\\
-19 consensus from the ACRS.
20 MR. WARD:
Well, our letter of June 10th, of course, l
21 didn't address all of the issues discussed here today, but it 2%
was a strong consensus.
There were no minority opinions and
.r..
23 so forth.
24 COMMISSIONER ZECH:
Oh.
Well, that's good to know.
l 25 CHAIRMAN PALLADINO:
Well, we will look forward to
)
.~. ~,. - -. -. -.
39 1
the additional information you can provide us.
2 MR. WARD:
- Okay, Let's go on to the next topic, 3
then, and I ask Dave Okrent to take the lead.
4 MR. OKRENT:
Since I have the floor, I offer the 5
last comment on the previous subject.
6 MR. WARD:
Oh, you're out of order.
7 MR. OKRENT:
My own opinion is that hurricanes and 8
earthquakes are the two I would look at as having the 9
potential for disrupting large areas from the evacuation point 10 of view, and having the potential for being an initiator of an 11 accident.
For whatever that's worth.
Rather than tornadoes.
12 The issue of safety goals.
The committee has been 13 reviewing this quite actively during the last two months and, 14 in fact, had some meetings before then.
It was relatively 15 close to a committee position at the last ACRS meeting, but 16 did not quite reach it, and what I will try to do today is 17 speculate on what a committee position may be.
Recognizing 18 that as of now, I do not have a recommendation, or at least we 19 don't have a copy of a recommendation from the EDO to you.
20
[ Laughter.3 21 COMMISSIONER ASSELSTINE:
I was wondering what your 22 position was going to be based on.
23 MR. OKRENT:
We have seen a draft, but they say that 24 is strictly a draft and not to be viewed seriously.
25 MR. MARK:
It's based on wisdom, uncorrupted by the
40 1
Staff position.
2
[ Laughter.3 3
MR. OKRENT:
We do have the benefit of various 4
met randa written by senior members of your staff, such as 5
Mr. Denton, Mr. Minogue.
6 COMMISSIONER ASSELSTINE:
That includes the June 12 7
Denton memorandum?
8 MR. OKRENT:
Yes.
And, of course, the report of the 9
safety goal steering group.
And I should note that we at the in one case representatives 10 subcommittee meeting yesterday 11 came in and presented different points of view.
12 We also heard yesterday from Lester Lave, who I 13 think is a well-known economist who consults both the NRC and 14 the ACES, and Prof. Douglas McClain from the University of 4
15 Maryland, in the area of philosophy.
They both were 16 participants in the first and second panels reviewing NUREG 17 0880 in its early formative years.
So they are familiar with 18 what the NRC has been going through in this.
And I will come 19 back to some of their comments in a minute.
20 Again, remember, I will be speculating, but in 21 summary my guess is that the ACRS will say it thinks the NRC 22 is not now ready to reaffirm and implement the 1983 safety 23 goal policy in its original or some slightly modified form.
I 24 CHAIRMAN PALLADINO:
Did you say the NRC or ACRS?
l 25 COMMISSIONER ASSELSTINE:
The NRC is not.
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41 1
MR. OKRENT:
That the NRC, the Commission is not now ready.
We believe progress has been made.
The effort needs 2
3 to continue.
But the form of the goals and the plan for 4
implementation are not yet well enough developed.
5 In part, this view I think arises from an ACES and again 6
examination of the situation, but I think in part 7
now I'm speaking for myself -- if one looks at the very 8
considerable differences that exist among members of your 9
senior staff with the original proposal, one might use that to 10 say you are not quite ready.
11 But the ACRS independently agrees.
12 COMMISSIONER BERNTHAL:
That we are not ready?
13 MR. OXRENT:
That you are not ready; right.
I will 14 go on.
15 COMMISSIONER BERNTHAL:
We are very used to not 16 being ready.
17 COMMISSIONER ASSELSTINE:
Or we should not be ready.
18 MR. OXRENT:
I anticipate now again that the 19 committee will emphasize-that greater attention be placed on 20 working toward an adequate core melt objective.
And by 21 working toward, I mean working the reactors towards.
22 CHAIRMAN PALLADINO:
What do you mean, a better core 23 melt criteria?
You mean like 10 to the minus 24 MR. OKRENT:
An adequate core melt objection.
I'll 25 come back to that.
42 1
CHAIRMAN PALLADINO:
Oh.
Okay.
2 MR. OKRENT:
And the identification and use of a 3
containment performance objective, and that the committee will 4
be concerned that the safety policy statement doesn't give 5
sufficient emphasis to defense-in-depth, and there is concern 6
that inappropriate reliance maybe placed on benefit-cost 7
analysis.
8 Now, again, I should note that if the committee 9
writes a letter this meeting, it would be based on the 10 information that it has now, and try to offer such advice as 11 they can, expecting that we would offer comments again when it 12 had the recommendations from the EDO.
13 CHAIRMAN PALLADINO:
Why will the ACRS not wait for 14 the Staff document on the safety goalf 15 MR. OKRENT:
I think 16 CHAIRMAN PALLADINO:
Because I haven't seen the 17 safety goal document.
I have had briefings, we have had 18 discussions, but I don't know where the Staff is going to 19 finally come out.
20 MR. WARD:
I think one reason that we expressed in 21 our discussion prior to this meeting was that we think it 22 might be useful for us to try try to influence the Staff 23 document through a letter this month, or a report this month.
24 That opinion is not unanimous among the committee members.
25 COMMISSIONER BERNTHAL:
Yes.
I want to support that
43 1
attitude.
In fact, I want to commend you.
I don't know 2
whether it was your idea or ours, but you have come before us 3
prior to meetings of the Full Committee and prior to coming 4
down with the Full Committee recommendation and thinking on 5
this matter, and in my judgment, that is the kind of thing 6
that we need.
And I certainly hope that we can continue a 7
discussion here very candidly and, you know, we all get used 8
to speaking on the record with a transcript, but that's okay, 9
and get your views on this matter.
10 Part of the reason I would like to encourage you to 11 go ahead independently, especially on one aspect of this, is 12 that it is almost a matter of philosophy and, in fact, the 13 stage is being set already by the media.
14 One of the newspapers a few weeks ago picked up in a 15 very negative and highly partisan way, I would say, on the i
16 fact that an attempt is being made now finally, for the first 17 time in this Administration, to reach some uniform consensus 18 on risks and what Congress should ultimately accept and the 19 country should be willing to accept in risks-in all areas.
20 That was viewed as somehow being inappropriate and 21 was viewed in a most negative way when, in fact, two members 22 of the House of Representatives a couple of years ago Jim Martin, who is now governor of North 23 introduced a bill 24 Carolina and, as you know, a certified chemist, I believe was 25 co-sponsor, along with Mr. Ritter, I think, of that bill,
44 1
where they attempted to approach the same question.
2 The first.part of this question of safety goal 3
should not in fact be the responsibility of the NRC.
It is 4
just that we are having to go ahead with it because Congress 5
won't do it.
That is a question of should we accept an 6
additional tenth of a percent or 1 percent o,r whatever it is 7
of risk associated with operation of nuclear power plants.
8 That shouldn't be our judgment, that should be the Congress' 9
judgment.
10 MR. KERR:
For whatever it's worth, one of our 11 consultants, when we were considering this question early on, 12 said of course Congress should do this, but Congressman are 13 much too smart to get involved 14 Chaughter.3 15 MR. KERR:
And they are going to insist that the 16 Commission do it.
17 COMMISSIONER BERNTHAL:
Well, but there is hope 18 because there was that introduction of the bill.
And I don't 19 know whether it cleared the committee.
I don't think it 20 cleared the full House, but there is hope, I think, that i
21 better heads may prevail and that there will be some 1
22 uniformity and order in this process.
23 But, anyway, that's a long story, and I commend you 24 for getting started early on it, because some of us, I don't 25 think, need to wait for a Staff paper.
Your thoughts are, if
45 1
anything, going to be equally as useful as the Staff's, if not 2
more so in certain areas.
3 CHAIRMAN PALLADINO:
Well, the reason I raised the 4
question, we had been getting input from the ACRS periodically 5
on this subject, and I thought the focal point was now to be 6
the results of the implementation s,t u d y.
I would never deny 7
the ACRS the opportunity or certainly the privilege of sending 8
us information any time they have it, or even comments and 9
opinions.
10 MR. WARD:
Well, I think that was our original 11 intent, but things have gotten a little more complicated than 12 that.
The Staff is obviously having difficulty pulling 13 something together, so some of us at least think it would be 14 useful for us to put in our advice.
15 Let me ask Forrest 16 MR. REMICK:
I would like to make a couple 17 comments.
I would like to emphasize that the committee really 18 hasn't decided its position, and there are strong differing 19 views, and I hope that the Committee does not come out with 20 what we have just heard.
They might.
21 I also question whether we should be writing you a 22 letter at this meeting.
I welcome the opportunity to give you 23 our views here, but we are at the stage in my mind that there 24 has been a two-year evaluation program and the Staff would 25 evaluate that and provide their judgment to you.
And it seems
46 1
to me at the moment we don't know what that is.
2 We do have this steering group report, and we could 3
provide comments on that.
We do not have the Staff's 4
position.
They came and they talked to us yesterday on what 5
their thinking is, but we don't know what the target is to 6
make comment.
7 It seems to me that if we take all these various 8
things, including some of the consultants' comments that we 9
might differ with, if we tried to write you a letter with all 10 of our views and all of these possibilities, I think it's 11 going to be very confusing at this stage.
12 My own personal preference would be to give you a 13 letter when we know what has been recommended to you.
14 CHAIRMAN PALLADINO:
Well, you will have to decide you will have to decide whether you are going to send us a 15 16 letter or not.
We always welcome advice from the ACRS.
My 17 question related to what I thought was the focus of the new 18 effort, and that was the Staff's implementation plan.
19 COMMISSIONER BERNTHAL:
I would like to talk about 20 something today, though, in the time that remains on what your 21 opinions are.
22 MR. OKRENT:
Well, if I could have proceeded, I 23 would have said 24
[ Laughter.3 I would have said that in large part 25 MR. OKRENT:
47 1
we will comment on the safety goal steering group report, but 2
we will bring in some aspects of the additional memoranda from 3
Minogue or Denton and so forth.
4 But in the process we will be trying to formulate 5
committee opinions.
So with regard, in fact, to the safety 6
goal steering group report, we agreed with many of the 7
findings and conclusions.
8 In fact, we think that group deserves commendation 9
for having come out with a fairly good product for such a 10 difficult task, even though we are going to disagree here, at 11 least tentatively with some of the things they have 12 recommended.
13 But we agree with them, for example, that PRA 14 methods and insights have been very valuable in prioritisation 15 and in development of regulatory positions on generic safety 16 issues and on plant-specific safety issues.
17 And we agree with them that PRA has limitations that 18 must be understood when the results are used, and that the 19 results of a PRA should normally be used in conjunction with 20 traditional safety review methods in making regulatory 21 decisions, 22 We agree, at least tentatively, with them that the 23 statement of the qualitative goals in the 1983 safety policy 24 statement appears to be satisfactory.
25 There may be further ACRS discussion about the
-y
._,.._,__.--__--_s..
48 1
concern raised by, for example, Mr. Denton's memo, and also 2
earlier raised by Commissioner Asselstine about, does one's 3
estimate of the likelihood of a coremelt by the year 2000 or 4
2020 have some special significance or warrant some special 5
consideration?
6 The committee has not really addressed this yet, so 7
I will just say that that is one of the topics it just hasn't 8
addressed.
9 We agree with the Steering Committee that for sites to where no people reside within a mile of the plant, for 11 purposes of the calculation, ordinarily an individual should 12 be assumed to reside at one mile from the site boundary, and 13 in applying the latent cancer fatality safety goal, we agree 14 with the Steering Group, it is better to consider the 15 population within ten miles rather than fifty miles, as 16 proposed in the 1983 policy statement.
17 We don't look upon this goal as a societal risk 18 goal, the ACRS.
It's really some kind of an individual risk 19 goal.
It averaged over fifty miles, now over ten miles, and 20 as Mr. Denton said, perhaps if it's an individual risk goal, 21 you should make it over one mile.
That's something that the 22 committee has not yet addressed for a final time.
23 The Steering Group proposed to use the general 24 prinolple that no more than about ten percent of any 25 quantitative design objective should be accounted for by a
i 49 1
single major issue or accident.
We know that many other 2
regulatory groups are using that approach.
3 On benefit / cost analysis, the Steering Group 4
proposed that averted onsite costs in a ceremelt accident 5
should be included in benefit / cost analysis.
Several senior 6,
Staff members have expressed concern that benefit / cost 7
analysis performed under the 1983 safety policy statement will 8
support only minor expenditures for reduction of coremelt 9
frequencies, relatively large compared to 1 times 10 to the -4 10 per reactor year, and that hence " defense in depth" was 11 Jeopardized.
12 They recognize that the inclusion of averted onsite 13 costs and benefits is controversial, and in some cases 14 suggested possible alternatives.
And now I am being perhaps a 15 little more speculative as to where the ACES will come down, 16 but certainly I expect the ACES to state that the limitations 17 of benefit / cost calculations are such that these calculations 18 should not be the only, nor necessarily the most important 19 criteria in decisionmaking concerning safety and the 20 accomplishment of " defense in depth."
21 I am not sure whether the committee will make any 22 recommendation on a specific recipe for cost / benefit 23 analysis.
I won't try to predict that.
l 24 I will note that at the subcommittee meeting 25 yesterday, both Mr. Lave and Mr. MoClain stated very
50 1
positively that the only way to do cost /bonefit analysis 2
analysis in their minds, if you do it, is to include all 3
significant costs and all significant benefits, and that the 4
1983 was deficient in that regard.
5 My personal opinion is that the majority, if not the 6
bulk of the social science community would support that 7
position.
Certainly all that I know support that, the points 8
of view that Mr. Lave and Mr. McClain expressed in that 9
regard.
They don't view that as exactly economic regulation, 10 and we have their statements, by the way, if you would care to 11 have copies of them, and we can make them available.
12 CHAIRMAN PALLADINO:
Yes.
I don't know; I 13 COMMISSIONER BERNTHAL; You might 14 haven't thought this through very carefully, but it came up 15 recently in the context of the severe accident policy.
You you might I hate to say this 16 might want to look, though 17 want to get a lawyer and see how that approach squares with 18 our mandate under the law, under the Atomic Energy Act, 19 MR. OKRENT:
In. fact, I invited a lawyer and a they 20 psychologist as well, but the lawyer was traveling 21 were both traveling.
We invited people who had participated 22 in the workshops on the 1983 safety -- well, on NUREG-0880, so 23 that they had familiarity with the development, They weren't 24 coming in cold.
25 It turned out, as I say -- Mr. Baron, who is the
51 1
lawyer, was traveling, and we couldn't get him.
2 CHAIRMAN PALLADINO:
Have you looked into the 3
industry point of view on this one?
4 MR. OKRENT:
I am very conscious of the industry S
point of view.
I don't think -- my recollection is that it's 6
not unanimous, bu t-there's a very large majority which has a 7
direction which I would expect.
8 MR. REMICK:
None of them came to address this 9
yesterday.
10 CHAIRMAN PALLADINO:
Are you talking about the 11 industry?
12 MR. OKRENT:
The industry.
13 CHAIRMAN PALLADINO:
I am not sure that I would have 14 necessarily expected it, but I will wait to see.
15 MR. OKRENT:
But I think, my own opinion now is, 16 industry may not be representative of the country, and the 17 responses that you got may not be a representative sample of 18 the country either.
But that's a personal opinion.
19 CHAIRMAN PALLADINO:
No.
But I think understanding 20 their rationale would be very important, because if they have 21 a good one, it's worth considering, but if they don't, then we 22 wont' consider it.
23 MR. OKRENT:
Well, again, one of the feelings I had 24 was, we are engineers talking only to engineers in this 25 building.
In another life, I am forced to talk about people
52 1
in other parts of, let's say, the arts and sciences.
And 1 let me put it that way 2
find a very illuminating 3
perspective that I have to balance against the perspective 4
that one gets around this table and the table downstairs.
5 MR. KERR:
There is a viewpoint that cost / benefit 6
analysis is immoral 7
MR. OKRENT:
In effect, one hears that one also.
8 COMMISSIONER BERNTHAL:
That was the essence of the 9
article that I referred to a bit earlier, and I think that the 10 failure in the philosophy and the ethics, I guess, is to 11 understand that you use dollars for want of a better 12 normalization.
There are other normalizations I'm sure one 13 could use.
You could choose to use life-shortening, !
14 suppose.
and I don't 15 MR. OKRENT:
No, but there are people a large body of 16 mean the Union of Concerned Scientists 17 people who have written that you really should not use 18 cost / benefit analysis of even decision analysis in arriving at 19 this kind of decision, and there is a man named Lee Merkoffer, 20 who wrote a rather interesting report on decision analysis 21 methodology and devoted a whole chapter to all of the articles 22 which say why you shouldn't use decision analysis.
23 COMMISSIONER BERNTHAL:
Well, they are just arguing 24 for ALARA basically, aren't they?
25 MR. OKRENT:
I am saying there are differences of
53 1
opinion.
But let me go on, because I'm getting more towards 2
some important areas.
3 I expect that the committee will come up with a 4
recommendation that the Commission, when it develops a new that the Commission could state 5
statement of safety policy 6
that near compliance or even better, with a mean coremelt 7
frequency of 10 to the
-4 per reactor year, is an NRC 8
objective for all but a few small existing reactors.
9 CHAIRMAN PALLADINO:
I missed the sentence.
Could 10 you repeat it again?
11 MR. OKRENT:
Yes.
I expect that the committee may 12 well recommend that the Commission should state its policy --
13 is that near compliance with a mean coremelt frequency of 10 14 to the
-4 per reactor year or better -- that means a lesser is an NRC objective for all but a few small existing 15 number 16 reactors, and that prudence will tend to take priority over 17 benefit / cost analysis in working toward this goal.
18 Now this is not unlike the recommendations of 19 Mr. Minogue.
Mr. Denton went much further, I would say, in 20 his memo.
But this is something that has evolved within the again I'm speculating 21 committee.
It's not a final 22 COMMISSIONER BERNTHAL:
10 to the
-4, you said9 23 MR. OKRENT:
A mean. 10 to the
-4.
I want to 24 emphasize mean.
And to go on --
25 COMMISSIONER ASSELSTINE:
Well, the safety goal that
54 1
has been out is a median 10 to the
-4, isn't it?
2 MR. OKRENT:
Well, if I recall correctly, the safety 3
goal just say to to the
-4, and the Staff 4
COMMISSIONER ASSELSTINE:
Interpreted it as a 5
median.
Oh, that's right.
6 COMMISSIONER BERNTHAL:
Let me make sure 1 7
understand what you're saying.
You're saying that the 8
committee is evolving toward that position, or am I 9
MR. LEWIS:
Well, you shouldn't take this quite so 10 seriously.
You know, Dave is reading from a draft letter that 11 has not been approved by the committee, and will not in the 12 form that he's reading it.
13 CLaughter.3 14 CHAIRMAN PALLADINO:
We'll put you on notice, then.
15 MR. LEWIS:
Well, you shouldn't quibble shout the 16 numbers.
17 COMMISSIONER BERNTHAL:
Well, that's all right.
But 18 I will quibble about the principle, then.
It's not a 19 quibble.
That's why I think this kind of exchange is useful.
20 isn't it true that Britain has sought to achieve a 21 10 to the
-6 coremelt goal?
How I gather they are backing off 22 from that and that Europeans in general have sought to achieve 23 10 to the
-5.
I 24 MR. OKRENT:
I will come to that later in my 25 comments.
4
55 i
COMMISSIONER BERNTHAL:
All right.
2 MR. OKRENT:
I'm sorry to have to use that line.
I 3
will rush through them quickly.
4 I already said that I expect the committee to 5
recommend development of a containment performance guideline, 6
and I will reiterate that.
7 I expect the committee to come down strongly that 8
the Staff should not use median and should use mean values 9
when it is assessing coremelt frequencies or cost / benefit 10 calculations.
And Dr. Lewis will go further into that topic 11 later.
12 COMMISSIONER BERNTHAL:
Is the difference 13 signiftoant?
14 MR. OXRENT:
I will let Dr. Lewis go into that 15 topio, and I will try to stay very 16 COMMISSIONER BERNTHAL:
This is like the speech that 17 never ended.
18 MR. OKRENT:
The Steering Group of Safety Goals 19 proposed a number of detailed implementation procedures.
The 20 committee believes that the operating limits proposed as 21 professional guidelines are in some instances not suffiotently 22 conservative and in some cases not clear.
The committee has 23 questions on these proposed operating limits and wants to 24 discuss them in more detail with the Staff and recommends that they not be adopted at this 25 and now I'm speculating
~
56 1
time.
2 In a letter dated back on September 15,
'82, the should be 3
committee stated that mean -- median, rather 4
used, and that an operational level for coremelt of 10 to the 5
-3 per reactor year is too large.
That number reappears in 6
this implementation as a median number.
So that gives you an 7
example of one of our difficulties.
But it's not the only 8
one.
9 I might note that if the Commission were to decide 10 as a matter of policy that it would try to seek achieving a 11 mean coremelt frequency of 10 to the
-4 per year or better for 12 existing reactors, the systematio methodology to be used in 13 review of various reactors as part of the severe accident 14 policy might be a mechanism.
15 Now the committee, I expect, will give emphasis to 16 the Commission's policy that future reactors be safer.
17 CHAIRMAN PALLADINO:
Whatt 18 MR. OKRENT:
That future reactors, reactors to be and, for example, in Franoe, the stated safety 19 designed 20 objective is that the chance of serious release from all 21 sources should be less than 10 to the
-6 per reactor year.
22 And during the course of the inquiry on Stuewell B in the 23 United Kingdom, the Nuclear Installations Inspector has 24 defined a similar goal, and the Italians have for their future 25 plants.
4
57 1
CHA!EMAN PALLADINO:
And what was the goal, aside 2
from the number?
3 MR. OKRENT:
10 to the
-6 per reactor year for a 4
serious release.
5 CHAIRMAN PALLADINO:
Oh, for a serious release.
6 That is different, though, from a coremelt.
7 MR. OKRENT:
From containment.
8 CHAIRMAN PALLADINO:
Yes.
It's more like out 9
limiting dose, in a sense.
10 MR. OKRENT:
Now there was a time when the Sisewell 11 was recommending 10 to the
-6 for ooremelt, but I think they 12 have gone to 10 to the
-5 for coremelt, as I think the 13 Italians and, in fact, I think the ACRS may well recommend 14 that for future reactors, reactors to be designed, that the 15 target ooremelt frequency mean, again, be 10 to the
-5 per 16 reactor year.
17 1 think that is probably enough speculation on my 18 part.
19 MR. WARD:
Thank you, Dave.
20 I think we have two or three other members who would 21 1the to comment.
22 Forrest, why don't I give you a chance first.
23 MR. REMICK.
All right, fine.
24 The comment was made that defense in depth would be 25 compromised.
I personally do not see that because I think at
58 1
least in the study group they are recommending that the safety 2
goals only be used in conjunction with normal judgment, and !
3 think prudent normal judgment would maintain that defense in 4
depth.
So I don't see'that argument, although I have heard 5
it.
6 CHAIRMAN PALLADINO:
This is the argument on using 7
defense in depth in what way?
8 MR. REMICK:
Well, that because of the fact of the 9
benefit-oost, there would be some cases that perhaps you could to not justify modifications which you would need for defense in 11 depth, and I do not follow that argument unless you are going 12 to use the safety goal as your only mode of decision making, 13 and I do not foreses that, nor is it recommended to you.
14 As far as the two consultants, I don't differ with 15 them from an economist's viewpoint of how you do a 16 cost-benefit analysis.
You look at all benefits and you look 17 at all costs.
But I don't think that is what we are 18 considering here.
This regards the question of whether the 19 Commission has the authority or the mandate to get into 20 averted costs to the licensee and so forth.
It overlooks 21 that.
It is an idealistic view.
22 The question came up did we have any industry 23 views.
No, we only had views of two individuals and no views 24 of those who might have opposing views to that, and there are 25 some.
I think the question of whether it amounts to economic
59 1
regulation or not is a red herring, and the question really is 2
how far goes the authority and what mandate does the 3
Commission have.
4 My own personal view is that the Atomic Energy Act 5
says that you are to protect health and safety of the publio.
4 That is your primary function.
7 COMMISSIGNER ASSELSTINE:
It also says minimise 8
danger to life and property.
9 MR. REMICK:
Yes.
10 COMMISSIONER SERNTHAL:
But we have never practiced 11 that.
12 COMMISSIONER ASSELSTINE:
That may mean we are not 13 carrying out our statutory mandate.
14 COMMISSIONER BERNTHAL:
Well, that is clearly ALARA, 15 and ALARA has been manifestly rejected in most quarters by the 16 Congress.
17 MR. WARD:
Well, you haven't practiced that.
16 can't really agree with that.
19 COMMISSIONER BERNTHAL:
Well, to minimise to me 20 means ALARA, and the fact is the Congress in a number of forum and I have*i't figurea nut yet what the plural of " forum" 21 22 is, but many times has, I think, rejected the idea of ALARA 23 now as being an impractical objective.
24 COMMISSIONER ASSELST!NE:
Well, I am not aware of 25 one.
[
60 1
COMMISSIONER SERNTHAL:
Well, that was the old 2
debate that I thought at least was partially settled by now.
3 MR. OKRENT:
I believe the British policy is that a 4
private company is responsible for safety to the extent tuat 5
it should be as good as is practical.
6 MR. SIESS:
Well, practical is an engineering term.
7 MR. OKRENT:
Right, but they can be taken to court, 8
for example, if they have not used something in that sense.
9 COMMISSIONER SERNTHAL:
On the basis of practical.
10 MR. OKRENT:
Yes.
11 COMMISSIONER BERNTHAL:
They must have better ooter t s 12 than we do.
13 MR. OKRENT:
They may.
14 CHAIRMAN PALLADINO:
Well, why don't we let Forrest 15 go ahead.
16 MR. REMICK:
That's fine.
I just wanted to give you 17 some examples of where I would differ with what ! believe 18 Da**e's personal views are, and I'm telling you what my 19 personal views are.
I don't think we have any Committee 20 position on this.
21 MR. WARD:
Dr. Lewis has something.
22 MR. LEWIS:
I would appreciate a couple of minutes 23 just to emphasise two points that have been brought up earlier 24 whleh are issues of a little bit of contention.
I think it is 25 reasonable to speculate that there will be changes in the
61
! Just want to say that 1
numbers that Dave has spoken about 2
again -- before you get a real letter from us.
3 The second point.
A question has been raised as to 4
why we should be talking to you now before the Staff comes in, 5
and I just want to emphasise my strong view that we should.
6 We have a responsibility to advise you, and in fact, I think 7
that there are sufficiently severe problems within the Staff 8
on dealing with some of these issues that I am about to talk 9
about that unless we advise you now, it is guaranteed that 10 there will be an even more difficult conversation later 11 when you do get the Staff recommendations.
12 With that proviso, we have heard a great deal from 13 the Staff, and 1 may still have 2-1/2 friends left and I am 14 about to lose them.
15 CHAIRMAN PALLADINO:
Where, on the Staff?
16 Chaughter.3 17 MR. LEWIS:
No.
18 MR. WARD:
I think you are optimistic.
19 MR. LEWIS:
You are right, I may not lose any, and 20 that is consistent with what I just said.
21 The Staff has had a great deal of trouble coming to 22 grips with all the things that go with the questions of 23 uncertainty whloh are bound up with the issue of the safety 24 goal and with the adoption of the safety goal, and I don't 25 think -- you know, it has been said before.
I don't think you
62 1
are ready to issue a statement.
That is quite clear.
But !
2 don't believe that the Staff is ready to make a recommendation 3
to you on a statement to be issued because of these questions.
4 I will go through a couple of them very, very 5
quickly.
6 The issue of uncertainty is absolutely bound up with 7
how you interpret a goal.
A goal has to be computed in a 8
reasonable way, and reasonable is not a legal term, and then 9
what you do with it has to be interpreted in a reasonable 10 way.
And at the Subcommittee meeting yesterday, we heard all 11 sorts of views about the question of whether the goal is just 12 something you look at, applaud at and pat yourself on the back 13 and then put into a closet and go on about your normal 14 business, or whether it is to be taken seriously in the 15 regulatory process, to We heard such a* divergence of views that it is.
17 again, clear to me that the issue hasn't been grappled with 18 sufflotently well, Perhaps it never can be, but you have to 19 grapple with it; otherwise, this will all be an empty, 20 time-wasting exercise.
21 And the safety goal is, in my personal view, part of l
22 a whole package that you are involved in which knoludes the l
l 23 backfitting rule and the severe polloy statement, whtoh is an
{
l 24 effort to somehow Ilmit the open-endedness of the regulatory 25 process; and to treat the safety goal as if it is something to l
l
63 1
be put onto a shelf is to abrogate that really laudable 2
responsibility you have taken on, obviously, as you said, 3
Fred, well ahead of the rest of the game, but that is the way 4
it is with leadership.
5 But the quection of uncertainty permeates it.
I and I feel that way very 6
said yesterday for the record
! regard it as a real disgrace that your Staff 7
strongly 8
members come in still talking about medians after all the 9
water that has gone over the bridge and under the dam, or 10 maybe the reverse of that, on that subject.
11 There is absolutely no legitimate reason for people 12 to be talking about medians if they are really talktng about 13 the probabilities of sooidents.
Obviously, if you know a 14 distribution extremely well, you can define it in terms of the 15 median, the mean, the 95 percent point or the 6.87 percent 16 point.
You can do that if you know it very well.
17 But the whole issue that you are dealing with, the it great uncertainty in which you don't know these distributions 19 very well, there is only one measure of a distribution that 20 survives addition, and that is the mean.
There is no other 21 measure that does.
And your Staff continues to come in l
22 talking about medians, although there has been notable 23 progress.
I regard it as really a disgrace that the issue 24 didn't end when it was first brought up because ! see no merit 25 to continuing it.
64 1
COMMISSIONER BERNTHAL:
Could I ask a question?
2 am going to reveal my thorough ignorance, I'm afraid, but 1 3
am not sure what you are talking about when you talk about 4
sean and median.
With respect to what, is my question.
5 Are we talking about the universe of reactors, and that for 6
that universe of reactors, the calculated, if you wish, PRA 7
core melt or something is on a distribution curve, and is it 8
the mean and median, then, for that group that we are talking 9
about, or am I talking about a calculated curve for a single 10 reactor where you are defining a mathematical -- more mean and 11 mathematical, at least, if that is possible 12 median?
13 I'm not sure what I'm talking about here.
14 MR. LEWIS:
Okay.
Let me respond to that.
First of 15 all, I don't think mathematical is a dirty word.
I don't 16 think academic is dirty word, either.
But that is, of course, 17 a defect in me.
No, we are talking about both, Fred.
We are 18 talking about both the distribution associated with the i
19 divergences among reactors, but w'e are also talking about 20 uncertainties that come from genuine ignorance about 21 individual reactor component failure probabilities, s
22 probabilities for particular containment disruption events, 23 probabilities for all sorts of things in which there is no 24 precision and there is a great deal of uncertainty.
25 When all of these things are put together, they
t s
65 1
produce a distribution of possible probabilities, and it is 2
that distribution af possible probabilities, if you will 3
forgive the term, on which we are talking about median versus 4
mean.
That's the issue.
5 COMMISSIONER BERNTHAL:
But it would be an entirely 6
different thing to demand that for a given reactor, you carry 7
out a calculation and then put in all your uncertainties, and 8
then you end up with some probability distribution and attach 9
your safety goal for each and every reactor requiring that 10 that be, let's say, 10 to the minus 4 for core melt, as 11 opposed to saying that you are only going to demand that of 12 the universe of reactors where some are going to be much 13 better and some are going to be, presumably, considerably 14 worse.
15 Which one are we talking about?
16 MR. LEWIS:
We are talkin3 abcut both because the 17 issue of the distribution of probabilities arises within a 18 given reactor both from a distribution of the qualtty of parts they come from different factories and things like that 19 20 and also from just plain ignorance, from the fact that we l'
21 don't know things and have to estimate them.
22 In addition, you can_convolute that with the 23 distribution of reactors, and then the question of whether you 24 apply a single criterion for the population of reactors or 25 different criteria for individual ones is a regulatory issue, 2
1 66 1
not a probability issue.
2 COMMISSIONER BERNTHAL:
I understand that, yes.
But 3
which should it be?
4 MR. LEWIS:
What do you mean, which should you be 5-dealing with?
That is a regulatory issue.
6 COMMISSIONER BERNTHAL:
I don't understand why you if you set a safety goal, it seems to me you require 7
8 everybody to cross the goal.
9 CHAIRMAN PALLADINO:
Well, you can define it as a 10 safety goal where you say, look, just so long as the group on 11 the average meets it.
12 COMMISSIONER BERNTHAL:
How can you possibly do 13 that, because that would mean accepting in principle 10 to 14 the minus 1 for a given outlier reactor?
s 15 CHAIRMAN PALLADINO:
Well, I would put some bounds 16 on it anyhow, but it depends on what you are seeking.
But i f-17 you are seeking freedom from pollution, it is the average that 18 may be the right one.
19 COMMISSIONER BERNTHAL:
Well, sure.
20 MR. LEWIS:
Well, this isn't entirely pertinent, 21 although you will have to grapple with it.
22 CHAIRMAN PALLADINO:
But is there that much 23 difference between the median and the mean?
24 MR. LEWIS:
I am coming to that.
Allow me to come 25 to that.
As Dave said, had I been allowed to continue
67 1
(Laughter) 2 COMMISSIONER ASSELSTINE:
Oh, please continue.
3 MR. LEWIS:
Yes, there is.
There is a big 4
difference.
And these things we have just been talking about 5
are extremely interesting and I will be happy to talk to you 6
about them privately or publicly anytime because they are 7
important.
They go to the question of how you set a safety 8
goal in the face of the inevitable uncertainty.
9 Now, the difference between median and mean.
There 10 seems to be a widespread impression in your Staff that there 11 is a factor of 3 difference between the median and the mean.
12 I have no idea where that came from, but it is absolutely 13 widespread, and you referred earlier, Jim, to I think, Harold 14 Denton's June 12th letter. It suffers from that defect because 15 although it is laudable in the sense that it recommends going 16 to medians, in the first paragraph it calculates 17 MR. WARD:
You misspoke.
18 COMMISSIONER ASSELSTINE:
It recommends going to 19 means.
20 MR. LEWIS:
Oh, gosh.
One day in this building does 21 that to me.
22 ILaughter]
23 But it recommends going to the means, and that is 24 absolutely laudable, but in the first paragraph, there is 25 quoted a median core melt probability, and then the
68 1
calculation of the probability that there will be one or more 2
than one core melt event.
I had trouble following that 3
calculation until I realized that what he had done was to 4
multiply the median by 3 and then calculate it as if it were 5
the mean, and that is a widespread misapprehension.
6 The difference between the median and the mean 7
depends on the shape of the distribution.
If you follow the 8
normal practice around here, which has no basis for it, of 9
assuming that all distributions are log normal, then I can 10 give you some numbers.
I can tell you that if the log normal 11 standard deviations are plus or minus a factor of 4,
then 12 indeed you do get a factor of 3 between median and mean.
If 13
'they are plus or minus a factor of 10, you g,e t a factor of 14 14 between median and mean.
15 It really depends on the distribution.
So to state 16 a median and translate it to a mean suggests that you know the 17 distribution, which in very few cases do you know.
18 Now, I have to say that one of your Staff people 19 yesterday, who was defending the median, said that it is a 20 better measure because it is independent of the width of the
^
21 distribution, and that is simply not true.
22 MR. WARD:
I think you meant defending the median.
23 MR. LEWIS:
Defending the median.
Am I doing this 24 constantly?
- Well, I'm just trying to defend the issue.
25 MR. WARD:
No, just every now and then.
69 i
MR. LEWIS:
Well, three times and I am out.
2 He was defending the median and said that the median 3
was independent of the width of distribution.
That's simply 4
not true.
And I mention this not to castigate him but to say 5
that your Staff has yet to come to real grips with this issue.
6 The question came up yesterday, one of my old 7
favorites, of whether your one-tenth of one percent is meant 8
to be changed as the rate of cancer in the normal population 9
changes, and one of your Staff people said yes.
I said, well, 10 as the population ages and more of us begin to die of cancer, 11 are we going to relax nuclear regulation?
The answer I got 12 was yes, and that means again that you don't have it in the
+
13 pocket there, 14 I'm not going to go into great details, but again, 15 in Harold's letter of June 12th he recommends a factor of 10 16 reduction in the core melt objective.
He doesn't say whether 17 he means median or mean, and it is not all that clear what it 18 is, and it could be a very big difference.
19 CHAIRMAN PALLADINO:
But I thought his difference 20 was based on whatever you met before, he wants to go 10 21 lower.
22 MR. LEWIS:
Well, of course, one didn't know what 23 one met before.
I believe that you should instruct your I will make one constructive comment.
You should 24 Staff 25 instruct your Staff not to come to you with any number that
70 1
doesn't specify whether it is a median or a mean.
It seems 2
like a simple enough requirement, and you haven't got it yet.
3 COMMISSIONER BERNTHAL:
Let me ask one additional 4
question.
5 MR. LEWIS:
I am finished.
A 6
COMMISSIONER BERNTHAL:
I guess I am skeptical that 7
with the kind of errors we typically talk about in this 8
business, or uncertainty is a better word, which tend to run 9
into orders of magnitude rather than factors of 3,
who cares?
10 A factor of 3 is lost in the weeds, it seems to me.
11 MR. LEWIS:
Not at all Not if you specify it as a 12 safety goal it's not lost at all.
I must say I agree with you 13 that there are uncertainties on the order of a factor of 10, 14 but that is no excuse for not doing things logically.
15 COMMISSIONER BERNTHAL:
Okay.
Well, I don't i
1 16 disagree with that.
17 MR. LEWIS:
But in fact, just these orders of i
18 magnitude of uncertainty are what you have to deal with if you 19 decide how to use a safety goal They are there They are not i
20 going to be erased.
21 COMMISSIONER BERNTHAL:
They are in the curve, true.
22 MR. WARD:
I guess I would just like to say one 23 thing, although I think Dave may have mentioned it.
I think 24 the developing consensus of the committee is expressed in the 25 draft letter from last month.
I think it is accurate to say
71 1
we think that the implementation plan is not ready to be 2
used.
But I wouldn't want to that be misinterpreted.
I think 3
we do believe that a lot of progress has been made, and we 4
continue to believe that it's very important the effort be 5
continued, 6
And I think we retain the expectation that something 7
practical is going to come out of this.
So I don't want the 8
whole tone of this to be discouraging as far as the concept of 9
the safety goal.
10 MR. LEWIS:
I agree with that.
11 CHAIRMAN PALLADINO:
You are basing your statement 12 they are not ready on the steering group report?
13 MR. WARD:
No.
14 CHAIRMAN PALLADINO:
Well, you don's have the other 15 one.
I don't know how you could base it 16 MR. WARD:
That's right.
Well, we based it last 17 month on the steering group report.
18 CHAIRMAN PALLADINO:
You see, what I'm worried about 19 if you say that, well, they might agree with you and say, oh, 20 yeah, you're right, we had better not get anything out right 21 now, and I think we would lose something if they didn't at 22 least cope with the issue at the present time.
23 COMMISSIONER ASSELSTINE:
The sense I was getting, 24 though, was that it was not just the steering group's report, 25 but the various viewpoints that seemed to be held within
72 1
various quarters of the Staff about there are some fundamental 2
questions about the elements of the goal 3
MR. KERR:
It seems to me that the committee is 4
taking a bit of a risk in writing at this point, and they 5
might make a mistake.
But we have talked about this, whether 6
we should write now, and as has been pointed out, it is not think and I am one of them 7
unanimous.
But several of us 8
that our concerns that we have, we would hope you would listen 9
to and profit from our comments.
And they are real 1
- 10 fundamental issues.
11 CHAIRMAN PALLADINO:
I wasn't arguing that you 12 shouldn't write a letter.
I said your statement about w h e t.'. e r 13 we are, ready or not is based on the steering group report.
14 MR. KERR:
But it is also based on extrapolation of 15 where we think the Staff now finds itself.
16 MR. SIESS:
To say you are not ready to issue a 17 final policy statement is not saying that you are not ready to 18 go ahead with work on the safety goal.
And if we say that you 19 are not ready for a policy statement, that really doesn't tell 20 the Staff to quit.
I hope not.
21 CHAIRMAN PALLADINO:
Well, that's what I hope.
22 MR. WARD:
No, that's the point I was trying to 23 make.
24 CHAIRMAN PALLADINO:
Yes, it's based on their 25 present state of knowledge, and they may come up with some gem
73 1
between now and then.
2 MR. WARD:
This is a pioneering effort.
It is 3
complex.
4 MR. LEWIS:
I want to support that very strongly.
5 All my negative comments were not meant to stop doing it.
I 6
think it would be absolutely magnificent if this agency took 7
the leadership in actually coming to grips with the question 8
of quantitative goals and with the. uncertainties of how to 9
feed them into decisionmaking.
It would be magnificent.
10 COMMISSIONER BERNTHAL:
I'm glad you said that, 11 because for all the brickbats this agency takes that people 12 tend to forget whether it has been the Price Anderson, I think 13.
coming to be landmark legislation, or whether its consistent 14 analysis of risk in pioneering that effort and now the safety 15 goal issue, or even whether it's the widespread use of what 16 amounts to scientific courts in our hearing process, we don't 17 get the credit we deserve in this agency.
And I say we.
For 18 those of us who are contemporaries for the last 20 or 30 19 years.
This agency has pointed the way in many of these areas 20 and yet many folks in this city fail to recognize that, as we 21 learned again yesterday.
22 MR. WARD:
I am glad to hear you say that, Fred.
I 23 certainly agree with it.
24 COMMISSIONER ASSELSTINE:
I think Carson has a 25 comment.
74 1
MR. MARK:
I was hoping to address the question on a 2
slightly different matter to Dr. Palladino.
We hear a lot 3
about cost-benefit analysis.
We find many times written down 4
a change will be made if it is cost effective.
Let's stretch
. 5 the imagination and suppose you have a really good 6
cost-benefit estimate and you are inclined to believe that the 7
estimate was done right.
That is perhaps asking quite a bit.
8 But to wht extent under such conditions do the 9
Commissioners or you, Mr. Chairman, regard yourself as bound 10 to either act or not act according to the value of this 11 cost-benefit analysis?
Is it only one of the things which you 12 feel needs to be looked at?
And you are perfectly free to say 13 it says it isn't worth it, but in my bones I am darned sure it 14 is so I'm going to say yes.
15 CHAIRMAN PALLADINO:
Well, I always reserve the 16 right to use my deep instinct and not be bound by a 17 cost-benefit analysis.
But it is one factor.
18 However, I haven't seen one yet that on which I had 19 to make a decision.
20 COMMISSIONER ASSELSTINE:
Carson, I would also say 21 that that is at the heart of the question of what to do about and 22 the backfitting rule.
Do you adopt a rule that says l
l-23 this will have to be your basis, and that's one of the 24 potential pitfalls of a very strict rule that ties everyone's 25 hands.
I
75 1
MR. WARD:
Joe, could you clarify "you haven't seen 2
one yet"?
3 CHAIRMAN PALLADINO:
Oh, I haven't been confronted 4
with a cost-benefit situation where I say, well, by golly, now 5
I've got to make a decision whether it's cost effective.
6 COMMISSIONER BERNTHAL:
I think that's true, except 7
in' the broadest sense.
8 MR. WARD:
Oh, you mean there's never been an issue 9
where the cost-benefit analysis was pivotal?
10 CHAIRMAN PALLADINO:
We talk a lot about 11 cost-benefit analysis, but we haven't faced the decision where 12 they say, well, now, our deterministic approach says we ought 13 to move on this side of the issue, our cost-benefit says we 14 ought to move on that side of that issue, and we had to weight 15 them.
16 I don't think I have even had a good cost-benefit 17 that came into the equation except in general terms.
18 COMMISSIONER ASSELSTINE:
I do seem to remember, 19 though, the case of the FORV on CE plants where I think your 20 intuitive judgment was that that is something that should be 21 there, but the cost-benefit analysis went the other way.
22 MR. WARD:
But the Commission would only postpone 23 the decision, only to accept a delay in a final decision.
But 24 that's the one I was thinking of, too.
25 COMMISSIONER BERNTHAL:
That's right, that's
76 1
probably the only case, certainly, that's been in my 2
experience.
3 MR. OKRENT:
Well, first, let me note that this 4
question of the status of the safety goal thing, the words 5
that I had were that the NRC is not ready to reaffirm and 6
implement the 1983 safety goal policy statement in its 7
original or even some slightly modified form.
That leaves 8
room for a modification, in other words.
9 As you say, EDO may come up with a formula that in 10 fact keeps everybody convinced.
I do want to note that if you 11 read what your own senior staff are writing, I think you can 12 sense a rather deep sense of disquiet with what the situation 13 would be if the 1983 safety goal policy were to be retained 14 with the cost-benefit calculation as so defined.
15 And I think that's what you see in Mr. Minogue's and 16 Mr. Denton's and Mr. Ernst's and, in fact, in the steering 17 group's report, for different reasons, sometimes, but 18 nevertheless similar.
19 In fact, I have that same feeling.
I guess in a 20 sense I am the one who pushed the ACRS to recommending to the 21 Commission that they institute this and they prepare a 22 proposal, and I must say if I thought the 1983 policy were 23 going to be adopted as it was, a look at the backfitting 24 amendment were going to be strictly implemented on 25 cost-benefit in that way, the severe accident policy would
77 1
have worked all that way, I would feel like I had done the 2
country a disservice by raising the question originally.
3 I feel that strongly.
4 I think it does need change, in my opinion.
5 CHAIRMAN PALLADINO:
Well, I don't know what's 6
behind your thinking.
Are you going to propose something else 7
besides cost-benefit as an approach?
8 MR. OKRENT:
Well, I'll give you one example.
I 9
find myself, in estimated core melt frequency 4 times 10 to 10 the minus 4,
for reactors at the most populated site in the 11 country, disquieting, as something to be left for the rest of 12 the plant life.
13 I as a Commissioner would not sit still for that and of course 14 situation.
I wouldn't shut them down, but 15 that's the es:timate with some, as Mr. Lewis has said, big 16 uncertainty on both sidesI 17 But, nevertheless, if that is the average prediction 18 of a core melt by the year 2000, that is sizeable and the 19 flagship, if you will, has got such a high number, it seems to I'm not speaking at all for the ACRS -- well, 20 me personally 21 not a good 22 CHAIRMAN PALLADINO:
Incidentally, I share your 23 view.
24 MR. OKRENT:
But in reading the Commission position 25 on any point, I couldn't find any hint of that.
You were
78 1
faced with certain specific yes-or-no things, but that 2
question in fact wasn't one directly raised to you, I think 3
you might say.
4 COMMISSIONER BERNTHAL:
I just remembered another 5
cost-benefit thing that had slipped my mind.
That was the 6
ATWS thing which seemed to be small cost for substantial 7
benefit.
8 COMMISSIONER ASSELSTINE:
Dave, if I could ask you, 9
the sense I get is that there are fundamental questions and to disagreements within the Staff on the committee about some of 11 the key issues involved in the safety goal 12 The typical approach that we use here is we sit 13 back, all of this goes on, and then finally we get the paper 14 dumped in our laps and we have to make decisions about is this 15 acceptable, do we want to make some modifications here and 16 there.
All right.
17 The question is so fundamental Are the 18 disagreements so significant that perhaps the Commission ought 19 to get more directly involved now before that process works 20 its course?
Or do you think that the process can deal with 21 these kinds of issues in the manner in which we have 22 approached these kinds of things in the past through our 23 typical process?
24 MR. OKRENT:
Well, that is a hard -- I'm not sure I 25 have a basis you should change your process.
I must say I was
79 i
surprised, pleasantly surprised to learn of the depth of 2
opinion among your senior staff, that they wanted to work the 3
core melt -- their estimates of core melt frequency to a lower 4
number than on the average, and for each individual one, and 5
in fact, you know, this includes essentially I don't know 6
where the EDO sits, but as far as the bulk of your other 7
senior staff, every single one that I have heard express an 8
opinion was concerned that way.
And the steering grop 9
included a lot of people, 10 COMMISSIONER ASSELSTINE:
Yes, I was surprised at 11 that, too.
In fact, when I looked at Mr. Denton's letter and 12 then I looked down the concurrence list, virtually every one 13 of the senior technical people and the people whose technical 14 judgment we rely on, the same with Research, that's right, 15 appear to feel very strongly that there are some fundamental 16 questions here that are not addressed by the earlier safety 17 goal and should be.
18 MR. OXRENT:
I have to assume when the EDO 19 recommends something, it will either somehow have worked this 20 out or there will be a different professional opinion.
21 MR. REMICK:
Could I attempt to respond to that?
22 If I were to advise Mr. Asselstine on that at the 23 moment I would say no, the Staff is trying right now and i
24 stepping in might interfere with that.
I think when they come 25 to you with their recommendation, they should tell you what j
I 80 1
the various views on this are, and at that time you shouldn't 2
hesitate, if you aren't satisfied, to explore all those views, 3
But I think at this particular moment my personal
(
4 advice would be it's probably a little premature.
5 COMMISSIONER BERNTHAL:
Well, I think the real value and I hope we will do this more in the 6
of your coming here 7
future, and frankly, I was going to suggest, Mr. Chairman, 8
that we try and plan for more than two hours when this group 9
is in town and spend maybe three hours, half morning, half 10 afternoon or however it best works, to do just this kind of i
11 discussion.
Because what you achieve by it, at least for the 12 Commission, is -- what shall I say, a willing suspension of 13 belief, maybe, when the Staff comes before us and 14 COMMISSIONER ASSELSTINE:
At least an appreciation 15 o f-the issues.
16 COMMISSIONER BERNTHAL:
That's right.
17 I had one question that I'm not sure we're going to 18 have time to discuss, but let me toss it out and we can not 19 discuss it if we don't have time.
l l
20 It is my understanding that there is at least one i
21 school of thought in the Staff that wants to move away from a 22 definition based on core melt, to a definition based on loss 23 of primary system, I guess is the way it was put to me, loss 24 of primary system integrity, or something like that.
25 MR. OKRENT:
Core melt through the primary system.
j
~ _ _
81 1
It's with the release of radioactivtty.
2 COMMISSIONER BERNTHAL:
Well, however.
It's a 3
different definition.
Whether or not we have time, I was 4
curious as to how that would square with the international 5
community, and my concern is that we not come forward with a 6
number that is a funny number compared to what the 7
international community has adopted.
And I understand the 8
difficulties with the core melt criteria.
Nobody is quite 9
sure what a core melt is right now.
10 Is there any comment on that?
Or do we have time?
11 MR. SIESS:
The British criteria must assume that it 12 is out of the primary system.
13 MR. OKRENT:
And the containment.
14 MR. SIESS:
I think they assume that the containment 15 isn't there.
16 MR. OKRENT:
Well, in fact, originally, you are 17 correct.
NII did not want to take credit 18 MR. SIESS:
I personally like the idea of 19 considering the core in the containment, because now you have if you look from the outside in, you've got the 20 the core 21 containment, which is there to protect the environment.
As 22 long as that core is inside the primary system, it's got two 23 barriers between it and the public.
But once the core gets 24 into the containment you are now up against your containment 25 barrier.
82 1
And I think it puts some emphasis on containment 2
performance criteria that you don't get if you lump core melts 3
into this whole mishmash of 40 different kinds.
4 So it makes a lot of sense to me to put the core 5
where it is challenging the last barrier, and then start 6
looking at that barrier.
7 COMMISSIONER BERNTHAL:
I thought a fair part of the 8
argument in favor of what you are apparently also suggesting 9
was that you also get a cleaner analysis, that the numerology 10 is very difficult because of the uncertainty in the core melt 11 phenomena itself.
Is that wrong?
{
12 MR. SIESS:
Well, it puts you one more step in the 13 calculation to where the coolant goes.
Now I don't know 14 whether that simplifies something or complicates it.
15 MR. KERR:
I would say that it does introduce 16 uncertainty here.
You can come closer, I think, to 17 calculating the conditions under which core melt is likely to 18 occur and that's in effect what one now does, than you can in 19 calculating the likelihood that given that set of conditions, 20 one is going to melt through say the vessel or get into the 21 containment or whatever.
22 COMMISSIONER BERNTHAL:
So you are saying it's more l
1 23 difficult to calculate the loss of primary system integrity?
I 4
24 MR. KERR:
Yes.
25 MR. WARD:
Yes.
83 1
MR. SIESS:
And then the Staff tells us it's even 2
more difficult to calculate the contaiment performance.
But 3
if you really want to give the consequences --
4 CHAIRMAN PALLADINO:
Paul has a comment, then I have 5
one.
6 MR. SHEWMON:
It may be more difficult, but it's a 7
difficulty that one should not spurn because where you really 8
get in trouble is not when somebody thinks they have lost 9
their last pump.
It's after you find that you can't restore 10 that pump and the core has melted and it gets out into the 11 countryside, and so if you talk about only core melt and when 12 you lose the last pump, you are likely to end up putting your 13 emphasis where it really doesn't help protect the public as 14 much as you could with a more realistic description and 15 analysis of what will lead to public health problems.
16 COMMISSIONER BERNTHAL:
I see.
And it becomes more 17 complex, among other reasons, because of human intervention.
18 That has to be taken into the mix.
If you've got a core melt, 19 too, and now breach the primary system.
20 MR. SHEWMON:
It's one of the things that isn't 21 taken into the mix now.
And there's also the thing that Chet 22 has leaned on of, gee, we've got a containment, we ought to 23 make sure it's a good containment and then take some credit 24 for it.
And you make people worry more about that if indeed 25 that came in as part of the consideration.
84 1
CHAIRMAN PALLADINO:
Let me make a comment.
I think 2
this is a very worthwhile discussion and I expect we could go 3
on for at least another hour.
I will point out we have an 4
affirmation, we have agenda planning, and we have to be on our 5
way to the Hill by 1:30, and so I would suggest that we thank 6
the Committee.
We look forward to your submittals and adjourn 7
the meeting.
8 Before we adjourn, I would suggest that the 9
Commission meet in about five minutes, prepared both for 10 affirmation and agenda planning.
11 CWhereupon, at 11:35 a.m.,
the meeting was 12 adjourned.]
13 14 15 16 17 18 19 20 21 22 23 24 25
1 CERTIFICATE OF OFFICIAL REPORTER 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 Commission Meeting 8
9 Name of Proceeding:
Periodic Meeting with Advisory Committee on Reactor Safeguards (Public Meeting) 10 11 Docket No.*
12 place: Washington, D. C.
13 Date:
Thursday, July 11, 1985 14
~
15 were held as herein appears and that this is the original 16 transcript thereof for the file of the Unitad Statos Nuclear 17 Regulatory Commission.
18 (Signature) 39 (TypedName'ofReprter) [Suzaqfe B. 16dng 20 21 22 23 Ann Riley & Associates. Ltd.
24 25
6/14/85 SCHEDULING NOTES TITLE:
PERIODIC MEETING WITH ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS)
SCHEDULED:
9:30 A.M., THURSDAY, JULY 11, 1985 (OPEN)
DURATION:
2 HRS
- PROPOSED
- ACRS ACTIVITIES RELATED TO CONSIDERATION OF SEISMIC EVENTS
' TOPICS:
IN EMERGENCY PLANNING (POSTPONED FROM 5/10/85 ACRS-COMMISSION MEETING).
- SAFETY GOALS DOCUMENTS:
6/10/85 LETTER FROM D. WARD TO CHAIRMAN PALLADINO 9
=-
_ ~ -
/9
,o etcg Y
<f o
UNITED STATES NUCLEAR REGULATORY COMMISSION
[
,, 7 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS y
s.... /-
WASHINGTON, D. C. 20555
. O,
+
June 10,1985 Honorable Nunzio J. Palladino Chairman U. S. Nuclear Regulatory Commission Washington, D. C.
20555
Dear Dr. Palladino:
SUBJECT:
ACRS C0PelENTS ON THE CONSIDERATION OF EARTHQUAKES IN OFF-SITE EMERGENCY PLANNING During its 302nd meeting, June 6-8, 1985, the Advisory Comittee on Reactor Safeguards completed its review of the proposed amendment to 10 CFR 50, " Emergency Planning and Preparedness for Production and Utilization Facilities."
This topic was also considered during the 301st ACRS meeting on May 9-11, 1985, the 297th meeting on January 10-12, 1985 and during a joint meeting of our Reactor Radiological Effects and Site Evaluation Subcommittees on January 3-4, 1985.
During these reviews the Committee had the benefit of discussions with the NRC Staff, representatives of the Federal Emergency Management Agency, and invited experts.
The Comittee also had the benefit of the documents referenced, including the public coments submitted to the NRC on the proposed amendment.
On the basis of these discussions, we offer the following coments:
1.
We see no technical reason for.the exclusion of earthquakes from the natural phenomena considered in off-site emergency planning for nuclear power plants.
However, we believe that only limited consideration of earthquakes is appropriate.
For sites where an earthquake capable of severely damaging emergency travel routes is sufficiently likely to occur, the local off-site authorities should have the benefit of studies indicating the types and potential locations of such damage.
The study of this kind already perforrr.ed for th_e region surrounding the 'Diablo Canyon site would clearly i
meet the intent of this coment.
2.
In the ' assessment of the impact of natural events on emergency planning, the major effort should be to identify potential problems i
and to devise alternative approaches for their resolution.
This would include requirements for assuring appropriate means for communication, for identifying alt 1rnative routes for the evacu-ation of the local population, and for identifying circumstances under which sheltering might be a more effective response than evacuation.
In many cases, such assessments may lead to a decision that no further response or action is required.
The goal should be 1
-..-v
,..--.---.---=.-___.m_._
,,m
A s
y s
Honorable Nunzio J. Palladino June 10, 1985 to assure-that emergency plans, as developed, contain sufficient flexi-bility to cope with the potential added impacts of such events.
We hope you will find these comments useful.
Sincerely, David tf Chairman
References:
1.
U.
5.
Nuclear Regulatory Consnission, 10 CFR Part 50, " Emergency Planning and Preparedness for Production and Utilization Facil-ities," Proposed Rule, Federal Register, Vol. 49, No. 247, pp.
49640-49643 dated December 21, 1984 2.
Sixty-one public consnents received by S. J. Chilk, Secretary of the Commission, in response to Reference 1.
3.
Correspondence from the following in response to requests for information regarding this subject:
a.
Andre Messiah, Ministry of Industry, Service Central de Surete, des Installations Nucleaires, France, dated March 29, 1985 b.
I. A. Breest, Federal Minister of the Interior, Federal Republic of Germany, dated March 22, 1985 c.
Thayer from Taipei, Taiwan, dated April 24, 1985 (Limited Official Use) d.
T. Taniguchi, Ministry of International Trade and Industry, Japan, dated April 20, 1985 e.
M. Wakasa, Reactor Regulation Division, NSB, STA, Japan, dated April 19, 1985 f.
G. Mandeus, Director Infonnation Services, Swedish Nuclear Power Inspectorate, dated April 16, 1985 4.
TERA Corporation, " Earthquake Emergency Planning at Diablo Canyon,"
Volumes 1-3, dated September 2, 1981 e
4
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