ML20135G575
| ML20135G575 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 09/13/1985 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1445, NUDOCS 8509190434 | |
| Download: ML20135G575 (407) | |
Text
UNITED STATES OF AMERICA
(~ '
NUCLEAR REGULATORY COMMISSION i/
In the matter of:
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 305th General Meeting Docket No.
% J' Location: Washington, D. C.
Date: Friday, September 13, 1985 Pages: 279 - 559 E!!W "" ': ACMRCE30W ;
Jo No~: Remove" rom ACTSO'fice x Jc ANN RILEY & ASSOCIATES g'
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Court Reporters 1625 I St., N.W.
O\ S"ite s21 Washington, D.C. 20006 4'h s
(202) 293-3950
279 SueWalsh 1 UNITED STATES OF AMERICA l NUCLEAR. REGULATORY COMMISSION 3
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 305th GENERAL MEETING 6
7 8 Room 1046 l 1717 H Street, N. W.
9 Washington, D. C.
10 Friday, Septenber 13, 1985 11 12 The Advisory Committee on Reactor Safeguards
( 13 was convened at 8:30 a.m., David A. Ward, Chairman of the 14 Committee, presiding.
15 pRESENT FOR THE ACRS COMMITTEE:
16 David A. Ward, Chairman Charles J. Wylie 17 Harold W. Lewis Jesse C. Ebersole 18 Robert C. Axtmann Chester P. Siess 19 J. Carson Mark Paul G. Shewmon 20 Forrest J. Remick Dade W. Moeller 21 William Kerr
" David Okrent 22 Carlyle Michelson Glenn A. Reed 23 DESIGNATED FEDERAL EMPLOYEE:
24 O Raymond F. Fraley
280 SueWalsh 1 99EIEEIS 2 Mr. Muntzing Page 284 3 Mr. Ahearne Page 310 4 Mr. Kouts Page 312 5 Mr. West Page 317 i
6 Mr. Hubbard Page 334 7 Mr. Hagedorn Page 341 8 l 9 Mr. Denton Page 361 10 11 Mr. Cassidy Page 394 12 Mr. Zeidner Page 418
() 13 Mr. Kleinke Page 440 14 Mr. Mascitti Page 459 15 16 Mr. Stern Page 481 17 Mr. Houston Page 493 18 Mr. Zoch Page 519 19 Mr. Sankovich Page 542 20 21 -
22 23
.s
281
- 1-1-SueW 1 PROCEEDINGS 2
(8:30 a.m.)
3 MR. WARD: The meeting will now come to order.
4 This is the second day of the 305th Meeting of the 5
Advisory Committee on Reactor Safeguards.
6 During today's meeting, the Committee will 7
meet with the panel on ACRS Effectiveness, will be briefed 8
by the Director of the NRC's Office of Nuclear Reactor 9
Regulation regarding the reorganization of NRR, will be 10 briefed by invited experts and discuss the use of natural 11 ability testing in the selection of nuclear power plant 12 personnel, will meet with the NRC Commissioners regarding 13 the ACRS participation in the NRC regulation of the DOE 14 program for management and disposal of high level radio-15 active waste, will also discuss with them the NRC severe 16 accident policy statement and human factors research.
17 And, finally we will hear about and discuss 18 the application for a full power license for the River 19 Bend Nuclear Power Plant.
20 All of today's sessions will be open to the 21 public. The schedule for Saturday is posted on the 22 bulletin board outside the meeting room.
3 This meeting is being conducted in accordance 24 with provisions of the Federal Advisory Committee Act and the Government Sunshine Act. Mr. R. P. Fraley is
282
- 1-2-SueW 1 the designated Federal official for the first portion of 5
i
\_ / 2 the meeting.
3 A transcript of portions of the meeting is 4 being kept, and I request that each speaker use ona 5 of the microphones, identify himself or herself, and 6 speak with sufficient clarity and volume so that he or 7 she can be readily heard.
8 We've received no written statements nor re-9 quests to make oral statements from members of the public 10 regarding today's sessions.
11 The first item on today's schedule is a report 12 that we have been looking forward to from the panel on r,
13 ACRS Effectiveness. That's a formidable job.
(V) 14 Just a brief reminder to the members, that at 15 a special subcommittee meeting last Fall, inspired and 16 led by Dr. Lewis, I might mention, the Committee began 17 a sort of self-examination of its role and its methods.
18 And we identified a number of things that we might do 19 differently and better. And we have, in fact, acted on 30 some of these.
21 But we also considered that it would be useful 22 to ask an outside group to look critically at what we are 2 doing and how we are doing it, and what we might do better 24 and how we might do better, and how we might do that better.
()
\v 3 So, early this year we formed -- we invited nine
l 4
I 283 l
- 1-3-SueW i distinguished persons, each with a particular background
(,,/ 2 and interest suitable to the task to serve as a panel on 3 ACRS Effectiveness.
4 We asked Mr. Manning Muntzing to head the 5 panel, and in just a minute I will ask Mr. Muntzing to 6 introduce the other members. They have labored through 7 the Spring and the Summer and they have brought forth 8 what I think is a very interesting product. It's a well 9 written, understandable report with -- depending on how to you cound them -- something like twenty-seven thoughtful 11 recommendations.
12 We plan to devote an hour and three-quarters N
) 13 to the topic this morning. I understand that Mr. Muntzing 14 plans to make some introductory remarks and then we will 15 take one chapter of the report at a time to structure our 16 discussion.
17 The appropriate panel member will make some 18 brief comments on the chapter's content and then will 19 open the floor to questions and comments from ACRS members 20 on that particular chapter. This will give us an average 21 of about ten minutes per chapter,'if that will help guide Z2 you in questions and discussions.
%I You have each received a copy in the mail,
(^x 24 and I presume you have studied it and have a lot of (v) 25 questions to ask. If not, I've got a couple dozen to back l
284
- 1-4-SueW 1 you up.
) 2 But at the end of our interchange with the panel, 3 if there is time I would like the Committee to begin its 4 discussion of what, if anything, we want to do about the 5 recommendations. If we have too little time this morning, 6
and that may very well be the case, we have budgeted more 7 time tomorrow morning for this discussion.
8 So I will now ask Manny Muntzing to take the 9
podium and lead us through the report.
INDEXX 10 MR. MUNTZING: Mr. Chairman, members of the 11 ACRS, and ladies and gentlemen, it's a pleasure to be 12 here this morning. It has been some time since I met (n) 13 with the ACRS, and I used to sit over there where Harold 14 Denton is sitting this morning as a member of the Staff.
15 And we had some good exchanges. So, it is a 16 pleasure to be back.
17 I must observe that there are changes, and there 18 are things that never change. I see some faces that are 19 still here from years ago, but a lot of new faces as well on the Committee.
I must say there is a nice change. You are 22 right on time, starting without delay. And that, of course, 23 is maybe because we are the first in the morning here.
24 ft Let me introduce the members of the panel to a 25 you. I think they are fairly well known to most f you.
. - . _~. __ - . . _ . - _- - - . - _ _
285 4
- 1-5-SueW 1 But starting on my right is John Ahearne, who is a
\s 2 former member of the NRC and a former chairman of the 4 3 NRC. Next is Ed Case, who is extremely well known to j 4 , the Committee, served on the Staff and had relations with 5 the ACRS for many, many years.
T
! 6 Homer Hagedorn is from Arthur D. Little. He 7 is the one member of the panel who did not have a parti-8 cular background in the nuclear issues but brought to us 9 organizational and managerial concepts which were very 10 helpful to us.
11 Richard Hubbard is next. He is with MH&B.
J 12 Did I say that right? MH&B Associates, who are very active
() 13 in nuclear as well as utility issues in California.
l 14 Herb Kouts is next, and a former member of 15 this Committee, former chairman of the Committee, and he 16 has worked on the Staff in the research program through 17 the years; ana he, of course, is at Brookhaven at this time.
18 And John West, who was formerly with Combustion 19 Engineering and has had a distinguished technical career 3D f with Combustion Engineering until his retirement just 21 recently. .
- 22 In addition, I would like to acknowledge two 23 additional members of the Committee who are not able to 24 be with us today. One is Myer Bender, former member of 25 this Committee and former chairman who is unable to join S
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286 i
- 1-6-SueW 1 us. And also Steve Sholly of the Union of Concerned !
2 Scientists, but now joining MH&B, who is in travel at
- L j 3 this time and also could not be with us.
4 I would like to express our appreciation, :
h 5 particularly to Dave Ward and Ray Fraley. They were very j t
6 helpful to us in providing information, gathering materials, f
7 answering our questions and assisting us as we needed [
- 8 while we conducted our business.
9 I would also like to thank the members of the i
j 10 ACRS, because each of you took the time to meet with us i l
11 and answer our questions and to review your views with us.
f I
12 And we appreciate that input from you as well. j i
() 13 As your Chairman indicated, this was an ACRS P
14 initiated project which you set in motion and selected i I
j 15 the panel. But once h'aving done that, the panel's delibera- L 1
. A 16 tions were completely independent of direction or advice.
l
-f j 17 We did, as I say, receive help from your [
t j 18 Chairman and from Ray'Fraley but that was of an informationa;
~
19 i
nature and, in fact, our proceedings were entirely inde-r 80 pendent.
{
\
21 Our procedure was to conduct interviews with a I i F 22
- large number of people. And these were people who knew f 4
23 the ACRS, were interested in its activities, and when it l
- 24 was completed we had a good source of information. However, l 25 the panel reached its own. conclusions. !
i
, 287 t
~
- 1-7-SueW 1 And it was based upon our own expertise and Am-l' 2 knowledge plus the information that we gained in the 3 interviews and the collegial discussion that occurred.
4 But the result, which is what I want to emphasize is, 5 is that it's an independent assessment that reflects the 6 personal views of the panel members.
7' Well, on nearly all matters the panel reached 8 . unanimous consensus. Where this did not occur, and this 9 was only in a few instances, we have indicated in the
- 10 report that a majority of the panel believes so and so.
11 But those instances are not too extensive.
I 12 In addition, there'is an additional comment
(
13 letter provided to you by Myer Bender, but as you know, 14 you know, you can't please fifteen people all the time 15 on all subjects. And certainly we couldn't do that nine.
16 And I observe that even with five at the Commission level, 17 l there are disagreements from time to time. .
t I8 But, on balance it's my opinion that the report 19 represents a good consensus on the major issues. The so time we considered were the years 1985 to the year 2000, 21 a fifteen year period.
22 Some of the assumptions that we made are con-23 tained in the report, particularly in Chapter 2. We all 24
} know that assumptions and predictions are never right. ;
, s/ 25 And as time goes forward and the reality appears it, of :
4 a., . - , - -- , , , . , , , , , - - - , , . - - - - - - . , - -
t 288
- 1-8-SueW 1 course, may be necessary to take a new look at the
, /~~T 2 assumptions and adjust for the realities as they emerge.
i 3 But we tried to set forth for you some of the major as-4 sumptions that we did make.
t 5 Now, I think it would be appropriate for me to, 6 if you will, have you turn to the Conclusions and Recom- l 7 mendations which begin on Page 45 of the report. And 8 here we tried to bring together the highlights of the i 8 report. And I will review these with you briefly, because
- 10 you have seen them and I think eventually it would be
- 11 better if we can respond to your questions and hear your j 12 comments.
i
() 13 The very first recommendation on Page 46 may j 14 be a relief to you. We conclude that the ACRS should 15 continue. We debated thJs to .scxm2 extent, but we came to 16 the conclusion that, in fact, during the past it has made 17 a good contribution and we think that there is no reason
! 18 why they should not continue.
18 3
But.we do believe-that it should turn to what 30 we referred to as raw technical policy questions as opposed 21 to sort of more the nuts and bolts.
22 Consistent with this, we say that we believe 23 that you should be relieved of the requirement to deal 24 with every licensing application that comes along, although 25 if, in fact, there.is something new or significant in.a P
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289 i
- 1-9-SueW 1 particular application we would expect that you would take 2 a look at-that new item, but certainly if it is routine 3 matters that you have seen before we feel as if that is 4 not the type of thing that you should undertake.
b We think that the research effort is too much, !
6 that a great deal of time and effort is put into it, and 7 that a broad overview is significant but, in fact, the 8 amount of time that you put into it, the detail, is beyond 9 what is necessary or useful to other people. And we indi-10 cate that a portion of this should be discontinued.
11 MR. MARK : Excuse me. The' effort is too much.
i 12 Do you mean on the part of the Committee --
w 13 MR. MUNTZING: That's right.
i 14 MR. MARK: -- not necessarily on the part of 15 the Commission?
I 16 MR. MUNTZING: That's right. Yes, exactly.
II
, We felt that the scope of the technical interests 18 should be as broad as the Commission itself. And I heard
! 1 j 19 the Chairman speak this morning.that you are going to be 8I discussing waste matters with the Commission. We felt l'
21 l
t that if the Commission has a technical issue such as waste !
22 that needs broad technical advice, this Committee should ;
i 23 undertake to provide that advice.
24
( We also felt that the correct approach to these
}
25 things is to try to-develop issues, point direc .ans to i
_ _ , , _ _ , . . , - . , , . , -..-, -- __ x
.. . . _ . ~ . .- - -- - ..
290
- 1-10-SueW 1 solutions but not necessarily develop the detailed solu-h V 2 tions. There is the extensive Staff that the Commission 3 has available to it, and we think that it's not'up to i
- 4 the Committee to develop the detailed solutions but rather 5 to maybe raise questions, clarify issues and point directions --
6 point towards directions that need -- that do need solutions .
3 7 We have indicated here some of the things we l 8 think you should not do, which include sort of day-to-day 9 activities, the National Transportation Safety Board in-l 10 vestigative type of things. We say you are not a second 11 regulatory staff; you shouldn't try to be one. It isn't l 12 your job to manage or oversee the NRC Staff.
13 The special relationship that once existed with 14 Congress does not exist, and we don't believe you should 15 even try to reestablish it.
16 Well, this is sort of under the category of the 17 ACRS mission, and we will go into it in greater detail this i 18
' morning as we proceed.
19 Then, we turn to the question of relations with the Commission and the NRC Staff. And here this is 21 l a point that we would like emphasize, and you will hear 22
- us say it several times today I'm sure, and that is that ,
28 !
the ACRS should think of itself primarily as an advisor
- 24 to the Commission on broad policy, technical questions.
26 We anticipate that you will also give advice i
291
- 1-ll-SueW 1 to the Staff from time to time. And, if so, we think
/~;
sUl 2 you should give that directly to the Staff and also early 3 on in the process.
4 But the principal mission should be to advise 5 the Commission. In addition to the letters that are writ-6 ten, the oral communications we feel are important. And 7 we have recommendations indicating that we think that maybe 8 they could be better managed and improved so that the oral 9 communications have a greater impact on the Commission than 10 we currently see today.
11 We also noted that from time to time individual 12 Commissioners may want to talk to individual members of
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()
13 the Committee. We see nothing wrong with that. -We don't 14 want to break up the collegial aspect, of course, but 15 under appropriate approaches to it that may well be a 16 useful thing to do.
17 We took a look at the relationships with the 18 ACRS and the NRC Staff. We didn't think it was as good as 19 it could be. We have made some cuuiuents about that.
20 And, in essence, you know the two organizations 21 are professional, technical people, and we would hope that 22 the relationships would reflect that professionalism in
- the course of exchanges.
24 Finally, if we can turn to the internal opera-
[ \
\s,/
25 tional questions, these tend to get a little more detailed.
1
. 292 i
61-12-SueW 1 In the first place, we felt that the Chairman should have (k >\ 2 a stronger leadership role, should serve for two terms
! 3 with the possibility of a second two-year term. We 4 feel as if a management committee of the Chairman, the 5 Vice Chairman, the Past Chairman and the Executive l'
6 Director, as an example, might be a good thing.to help 7 focus priorities, help. oversee the subcommittees, make l 1
8 sure that new tasks.are undertaken and old ones are drop-8 ped when the need has passed.
10 The consensus method of operation certainly is 11 appropriate, but we also felt that from time to time 12 dissents are useful and helpful.
4 It helps to make the 13 focus of the issues even better.
! 14 And we found nothing wrong with a good, well 15 '
written dissent from time to time, which sometimes appears 1
j- 16 to be more understandable than the Committee's version.
l 17 '
But that may be just the function of Committee work.
18 The letters we comment on, we hope that they f 18 could maybe be a little more clear and unambiguous, a i
30 little more self-contained.- There is a lot of language 21 i in there that you understand but nobody else does. I 22 And not even maybe even the Commissioners. And i 23 that might help if that were improved somewhat. '
" We see no trouble with the size of the ACRS.
l 36 We thought fifteen seemed to be about the right number.
e
-_ __ - ._ _ _ - _ _ . - ~ , _ . -
293
- 1-13-SueW 1 The present policy on ten years seemed to be h
~ (~)
(, 2 about right. Three terms seemed to be not unreasonable.
3 We felt reappointment of members should not 4 be just automatic, because the needs of the Committee 5 will change over time. And at this time you may need 6 certain discipline, tomorrow something else. And if that
- 7 is the case, there should be flexibility in meeting those a needs without slavish ~ reappointment just because somebody i e has served a previous term.
10 We believe that if, in fact, cosmic approaches
.i 11 are used as opposed to nuts and bolts that, in fact, a 12 broader generalist will be used and that the complete
() 13 range of disciplines, of course, should be covered.
I 14 We-also felt that some members of the Committee 15 put a great deal of time in, others less. We would hope 16 that, in fact, the time commitment is not a constraint on 17 ability to attract good people to the Committee. We did 18 not observe that that has been a problem, but we point 19 out the fact that if somebody who is a wise generalist so who could make a great contribution but not quite as much 21 time as others is available, that that should not be a E constraint on having him as a member of the Committee.-
23 The specific composition at the moment seemed 34 to be pretty good. We did make some suggestions in the 25 waste field, in the chemical process engineering. We L
. _ ~ . . - . .-
294
. #1-14-SueW 1 noted that the list of consultants is very long, but N 2 most are not used very much. We did not have a great deal 3 of problem with that.
4 The ACRS Staff, there have been comments that 5 it is large. And, in fact, as the mission of the Commis-6 sion changes, we would certainly expect the composition 7 of the Staff to change with it.
8 We indicated that a channel with research should 8 be established. It would be appropriate to have rules for 10 individual discussions of members with members of the 11 Commission, and I think maybe some work has been achieved j 12 on that. g s
( ) 13 And, finally we did not have any great 14 problem with the conflict of interest or Federal Advisory 15 Committee Act requirements.
16 Well, those are the brief recommendations which 17 I wanted to mention to you. There is a lot behind them.
18 !
There is probably a lot that are fairly controversial, some 18 you will agree with and some you will not.
80 But it highlights the particular final recommenda- ,
21 tions of the panel. Maybe I should stop and see if there 22 are any particular questions at this point, Mr. Chairman, j Or, if not, I would suggest we move to Chapter 2 24 and then sort of take it chapter by chapter, whereby the 25 details of each of these will become a little more apparent.
E t
r 295
- 1-15-SueW 1 MR. WARD: Did you care to ask a question?
2 MR. SIESS: One question, Manning, regarding 3 the ACRS role in commenting on the research program.
4 MR. MUNTZING: Right.
5 MR. SIESS: I think it was fairly clear that 6 you thought _we -- the report to Congress was no longer 7 needed, maybe a waste of time, and unduly demanding on 8 Committee time.
9 The amount of time the Committee spends on 10 preparing the actual report to CongressLis I think one 11 of the burdens, but there is a fair amount of time spent 12 by the Committee in following the research program in
- "13 general or in detail.
14 For example, we have always followed ECCS, 15 LOCA transient research. We've spent a lot of time on 16 the severe accident research program, which I think we 17 would have spent whether or not we gave a report to 18 Congress.
18 MR. MUNTZING: Right.
20 MR. SIESS: Was it the intention of the panel 21 that we severely limit our involvement in the research 22 program, or just to the report to Congress?
23 MR. MUNTZING: I think that what we envision t
I' is that the Committee will continue, and should continue,
)
25 to take a strong interest in those projects whose need and l
l i-r L
-- . ~ _ . -
296
- 1-16-SueW 1 time have passed, and say strongly: We no longer need 7
Lt
\ 2 the loft, as you did.
3 We also think that it's important for you to 4 be on the edge of the frontiers of new knowledge and say:
5' Here is something that ought to be started because it isn't 6 being done.
7 So, we envision that you are.in those modes.
8 But it is not necessary if there is something-ongoing-that 9 you take a look at its budget and whether it's, you know, 10 a million or a million and a half. I mean, that kind of M detail we felt --
12 MR. SIESS: I'm leaving budget out of it.
13 MR. MUNTZING: And, to
-- is not necessary.
.e 14 get into the budget implications we felt were not really 15 something that you needed to take your time to do.
16 It is more the principle of: - hat do we need 17 that we are not doing, and what are we doing that we don't 18 need, which is where we felt the Committee could most 19 usefully spend its time and make a contribution.
20 MR. WARD: Hal.
I 21 MR. LEWIS: Just a real quick question, Manning.
22 '
First of all, you know, I think this is a marvelous report.
23
- I didn't think it was possible for anyone to write a scrutab
- .e 24 report around here.
(} f MR. MUNTZING: We sort of wondered about that
. - -. _ . - ~ ,
297 (L-17-SueW 1 ourselves.
0)
D 2 (Laughter.)
3 MR. LEWIS: Most of which I agree with. It 4
4 -really seems beyond the realm of imagination. But this.is 5- that.
6 But on the specific point of turning the Commit-7 tee into something which, of course, advises the Commission s- and on general matters, I agree with that. On the other
) 9 hand, the word "generalist" troubles me, because most 10 generalists I know are people who don't know anything and
- 11 call themselves generalists.
12 And in the last analysis, when you deal with
() 13 general issues, they arise out of the nuts and bolts. They 14 arise out of specifics.
s l
Hi And I wonder whether you have any deep thoughts
- 16 before we get into the nuts and bolts of your report about j 17 how one reconciles the grounding in the actual facts with 18 the drawing of generalizations of value to the Commission?
19 MR. MUNTZING: Right. ~ Well, you know, everyone 30 will come from some discipline. I mean, mechanical or 21 ~ electrical engineering or physics, et cetera. Some people 22 will come from the very disciplines, and'you will look-23 around and say:
, At this time, you know, we need a chemical 24 engineering type of person. And so you are going to have 25 them coming out of what might be the nuts and bolts.
l l
2'98
- 1-18-SueW 1 But I suppose what we are saying is that you O
(-- 2 should look for the type of person who has the personality 4 3 to look at the forest instead of the trees. I mean, some 4 people and the way they operate, and people -- you know, i
5 in the community, people know people. And they can say:
6 You know, this is a guy who pushes paper and he crosses 7 i's and -- crosses t's and dots i's. And, you know, he 8 is just sort of there in the noise level.
' 8 But other people are here on a different plane.
10 And they are thinking, you know, what is the big picture.
j 11 What is the broad concept. How does it interreact with 12 other disciplines.
l j, O) i s,
13 And, you know, it is the kind of personality and 14 kind of a person and how he conducts his business which is makes, in our view, a generalist. I mean, people are 16 always going to be grounded in their specific discipline.
I 17 And in that regard, they are nuts and bolts 18 people. They have got to be. You have got to start some-18 where.
30 But it's sort of the kind of personality that i.
! 21 an individual uses. And I think that as you consider 22 membership that we would hope that you would look for 23 that individual who tends to interact with other disciplines, 24 i
(}
v thinks about the big picture, is capable of conceptualizing l 26 as opposed to simply engineering or detailed solution.
i I
- 299 i
- #1-19-SueW 1 MR. LEWIS
- Okay. So, you mean somebody with
' ./
i Q,
N- ' 2 both wisdom and knowledge instead of --
I 3 MR. MUNTZING: Oh, yes, exactly.
4 MR. LEWIS: -- just wisdom?
5 MR. MUNTZING: Exactly. It's hard to have 6 wisdom without knowledge.
7 MR. MARK: I had a question from the report 8 of exactly the same sort.
1 8 You seem to me to have suggested we needed --
1 10 I believe you mentioned two or three -- specialties 11 better represented. What you have just said would have 12 sounded a great deal'less of concern to me.
( 13 I believe you mentioned we need a gio-type --
i 14 MR. MUNTZING: Chemical process-engineer.
15 MR. MARK: Also some managers.
l i
e 16 MR. MUNTZING: Yes.
i 17 MR. MARK: Then, at the same time you said 1
18 we needed to address philosophy.instead of nuts and bolts.
19 Well, these are almost orthogonal comments.
- 80 I believe'in the one that you just emphasized, 4
21 we need people who know something but are prepared to '
22 address the general implications --
23 MR. MUNTZING: Right.
24 MR. MARK: -- of what is being talked about.
" And that is rather different from saying we need a reactor l i
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- 1-20-SueW 1 operator or a labor relations man, or a female or anything (h
(_) 2' - else.
. 3 MR. MUNTZING: That's a good idea.
4 (Laughter.)
f 6 MR.. MARK: Well, anyway I was a little troubled.
6 I put all of my own emphasis on the fact that we need l
i 7 people who, even if they were like I, a mathematician, 8 might be able to catch a vague glimmer of chemistry.
1 l 9 MR. MUNTZING: Right.
- 10 MR. MARK
- And rather than, we need a chemist, f
] 11 MR. MUNTZING: Well, right. You know, I think j 12 that it is, you know, the composition and selection process
() 13 is not an easy one. It takes a great deal of thought and 14 preparation. So we don't underestimate the difficulties.
1 2 And, you know, what we are trying to say is:
- 16 You know, you have got to have a balance of mathematicians 17 and chemists and engineers and physics, et cetera.
j 18 MR. MARK:
I don't insist you must have any 18 mathematicians.
20 j, MR. MUNTZING: Well, all right. Drop mathematicians.
21 (Laughter.)
22 l It's probably a good idea, though. And if you 23 l are dealing with probabilities. ,
8' j But on the other hand, you know, as you sort of
! 26 draw out of the disciplines to keep that balance, you know, l
l l
301 l l
l
- 1-21-SueW I what type of person are you selecting? Are you selecting I
2 the guy who is sort of in the laboratory looking at sort 3 of the test tubes and sort of, you know, he has got his i
, 4 blinders on and that's what he sees?
! 5 Or, do you have more of the man who can glimpse 6 a mathematical formula concept when he sees it and can-7 interact on a generalist basis with other people?
8 MR. SIESS: Manning, sometimes I think our 9 criterian is that we want somebody like us. And you have
, 10 carefully avoided covering that subject.
a 11 MR. MUNTZING: No, we --
J 12 MR. SIESS: Quite that specifically.
) 13 MR. WARD: I think you will find the word " clone" 14 in the report.
2 (Laughter.)
16 MR. SIESS: Clone was used in connection with j 17 replacing an individual in the specific discipline.
18 MR. MUNTZING: You know, there is that Right.
19 tendency I suppose that what we would -- what we tend to 1
30 l feel is that, in fact, the Committee has gotten a little
- 21 bit more on the nuts _and bolts side and, in fact, it ought 8 to move in the other direction to cosmic issues and, there-23 fore, more of the generalist concept.
24 And if you ask the members of our panel, which
)
26 you are free to do, I think they would tell you that we feel 1
t e
.,-...--,---._-,,.r .. - - ,4 , , , . . - . - , , e. .- . , . , , , , , , , , - . , . - - . ~ . . _y .,,--..,.r.., ..,e
_. -- _ . _ m . ._ . _ .
! 302
- 1-22-SueW 1 as if the Committee has gone too far sort of in that s
! s 2 direction and ought to move in the other.
i I
j 3 MR. WARD: I think Carson had a question.
i 1
4 MR.~ MARK: It's possible that if you were going 6 to go into detail on the chapters that my questions wculd i
6 be better then. I will hold them. .
i 7 MR. MUNTZING: Okay. Very good.
8 MR. EBERSOLE: In looking at this Committee i
- 9 that did this work, I have to say in the beginning that i
10 I look on it as a cosmic board, as one who is probably 11 unfamiliar with the hardware details which make up most i 12 of our problems. ,
l
() 13 I think there is a thought here also, and it's 14 expressed in the report here, that the plants that we are l
2 building -- I'm not talking about the new standard plants l
1
- 16 of which there is just two that I would call potentially
' 17 standardizable -- but rather it is a thought that our 18 controls and so forth have lead to a degree of standardiza-I
- 18 tion in the plants that we are currently building which, 4
so in fact, does not exist.
l 21 -
The generic issues, when one looks at them 1
88 hard, turn out to be just about maybe less than half of 8 what the real issues are because of the deviations and i 34 deviant designs that are put into the individual plants.
- 35 '
I suspect the bulk of the Staff's work, if you look at it 4
1 303
- 1-23-SueW 1 hard is going to be looking at individual plant problems, (r
\ - 2 because of the degree of freedom which has been afforded 3 to the AEs and utilities in the past.
4 And I think you might take a back view at the 6 characteristics of the problems we are having today as a the operational experience unfolds.
7 MR. MUNTZING: Right.
~
END #1 8 Joe flws 9
10 11 12
) 13 14 15 16 17 18 19 30 21 22 N f i
l l
'2-1-JoeWal 304 1 !!R. MUNTZING: Right.
2 MR. KERR: Perhaps the report commented on 3 this. The Commission and members of the committee in the 4 past, in many cases -- perhaps in most cases -- the Commission 5 has taken fairly seriously the recommendations of the
'6 Committee.
7 Have you given any thought to whether the -
l 8 Commission should be more active or more influential l 9 in choosing members, or should the present process be 10 continued?
11 MR. MUNTZING: Right. Well, we basically did I 12 not have a great deal of trouble with the selection probess.
13 Particularly for new members, whereby you send three or so 14 names to the Commission, a rd they evaluate and certainly is are free to use those or any others that they would like 16 to use.
17 So, we did not suggest that the Commission should 18 do more than it is doing in that regard.
19 Certainly if their inclination is to do so, 20 that would -- I think that would be their business. B tt 21 we did not really specifically suggest that they do more.
22 What we did focus on in reappointments, because l 28 they come along more of ten. I think there are six or so I 24 the nw.t several years. They come along more often than i 26 new r.ppointments, and therein we felt the procedures should 1
l
~2-2-JoeWol 305 1 be revised, and just because someone has served one or two i a terms shouldn't automatically mean they are going to serve i~
3 another.
4 In fact, the needs- of the Committee may change,
)
6 and if you don't sort of step back and say what do we need j e now and what contribution has this individual made, then i
) 7 you tend to sort of continue in the mode that you are in j e and your ability to move or change as you may think 9 appropriate is somewhat limited.
i
! 10 Well, Mr. Chairman --
j 11 !!R. .WA RD : David, did you have something?
i 12 MR. OKRENT: Well, the people have opened up 13 general kinds of topics. The strong Chairman was the
- 14 mode of the prestatutory committee. When it became i
15 statutory one of its early actions was to insist that j
- la Chairmen not be reelected for more than one term, and they l-17 in effect adopted bylaws which gave control - if they 1s l so wished -- of the agenda and so forth to the members
- 18 themselves. Although the Chairman sent the agenda for the 1
- meeting, members could, in fact, override the Chairman and 21 i say we want something on the agenda. l
\ l 28 In fact I saw that every capability used during i
i 23 one year when one chairman didn't like a particular s tbject i and wouldn't schedule it for two or three months until a
- motion was made on the floor we want this topic on the agenda 1
l 1
1
l 2-3-JoeWol. 306 1 next month.
I 2 It is not really clear to me, I must say, that i
3 the potential for a departure from a committee being some 4 collegial body to being represented by some individual j 5 voice, which is what has been happening if you have two 6 year chairman reappointed and so forth, is a good one.
! 7 I strongly question Obat particular recommen-8 dation, both based on say what I cited as an actual move 8 taken to change a situation and having watched over the 10 years.
q 11 MR. MUNTZING: Right. I would make just a few 12 observations. I think that the precedent that you mentioned
() 13 was one in which one particular individual served for ten 14 years or some great length of time, and certainly we don't 18 suggest that.
16 Secondly, certainly the membership can control i 17 its own agenda, and if it feels its interests are being over-is looked can bring that about. .
18 Thirdly, we do suggest sort of a management 3D committee, that is not just one individual, but several, so ,
81 that there is a sort of collegial aspect to the leadership 22 in and of itself, which is I think good. ;
88 But finally, I suppose we felt that in fact some
() 88 26 people are not good chairmen, and that some people are better providing technical input and wisdom than trying to be i
2-4-JoeWal 307 1 something that they really aren' t, and shouldn' t try to be, 2 and if you have somebody who is good at it and enjoys doing 3 it, why not continue to use him?
4 The present system is to nominate for vice 5 chairman the senior person who has not served as chairman.
6 I mean, this is just sort of a routine thing without 7 consideration of who would be good, and who wants to do it, 8 4.nd I must say I have observed through the years that if 9 you try to stick t.echnical people in a managerial position, 10 whether they want to or not, sometimes results aren't what 11 you would like to have.
12 So, I suppose our answer simply is: Why don't 13 you do what is right for the Committee rather than following 14 some route approach that you currently use?
15 MR. OKREllT: I can think of several occasions 16 when the Committee chose not to follow seniority rule 17 you mentioned, and of course, there have been members who have 18 declined to serve as chairman for one reason or another.
19 MR. MUNTZING: Right.
20 MR. OKRENT: So, it is not really automatic, 21 although I grant you members have more flair or ability 22 to serve as chair -- well, I have indicated my foolings.
23 MR. WAPD: I think Carson had a question.
24 MR. MARK: Since it has just been almost raised, 25 even though it might come up later, I felt inclined to wonder
2-5-JoeWal 308 ,
1 why you wholeheartly endorsed the Icss than or equal to 2 three term membership regulation that the Commission saw 3 fit to introduce a couple of years ago. Ilad that have 4 been applied at the time it was first mentioned, it would 5 have eviscerated the present Committee.
6 So, what was the advantage of saying that is 7 a good idea? If you have a three term membership, then 8 your average life on the Committee will be about one and 9 a half terms. It takes about one and a half terms to learn 10 what makes any sense on the committee.
11 Some people are quicker than I, and they might 12 do it in half a term, but it took me about one and a half, 13 and I don't really see the threat that is implied by people 14 who know what has been going on, continuing to being here 15 if they are willing, and we have some examples of that here.
16 I am not one, so I am not speaking for mysdf.
17 And it seems to me very questionable why you 18 Maybe you could have just left it would endorse that.
19 aside, without any comment, but why did it seem to you like 20 really a hot, good idea?
21 MR. MUNTZItiG: A lot of the things the Committeo 22 is doing has the benefit of having the experience and backgrour d 23 over 25 or more years, and we, I think, acknowledge that 24 and did not sort of start back at ground zero.
25 There is a certain historical momentum that one l
l
2-6-JoeWal 309 1 accepts.
2 In this process, we thought the Commission had 3 addressed. IIad adopted a policy. We didn't find it 4 unreasonable or extraordinarily unreasonable. We sort of 6 left it along.
6 Also, I suppose we did feel that, in fact, that 7 a change would occur, and there out to be -- that this 8 reflected that potential, and finally, and this is a point 9 that we would emphasize , that finally we believe that just 10 because somebody should leave the committee because his term 11 has expired, in f act the committee has used the concept of 12 consultants through the years, a;.3 certainly if there is a 13 member who will make an excellent contribution through the 14 consultant route, that we would encourage that to occur.
15 MR. WARD: Let's just have one more and then 16 we had better go on.
17 MR. EBERSOLE: Mr. Muntzing, it occurs to me 18 that -- I guess you can say there were in place certain 19 cosmic words prior to the TMI-2 incident. Ilow would you 20 suggest an alteration to the cosmic set of words that would 21 have prevented that accident occurring?
22 Without getting into the grinding aspects of how C it was built?
24 MR. MUt1TZIt1G: That soands to me like a question 25 that the Committee should address, and not our panel.
2-7-JoeWal 310 1
,7 (Laughter.)
(v) 2 Well, not being able to answer that question --
3 MR. WARD: Go ahead.
4 MR. MUNTZING: Why don't we turn to Chapter 2, 5
and John Ahearne and IIerb Kouts were the principal authors 6
here, and I would like to ask them to come forward and take 7
their beating.
8 (Laughter.)
8 XX INDEX MR. AllEARNE: Since this is the first chapter, 10 let me comment that like many of your letters, this report is II a consensus document and we worked very hard to try to get 12 consensus, which, of course, also means that at some stage p
13
- any one of us can be identified as putting the first words I4 down, but in the final stage it is a product of all of us.
15 Chapter 2 principally was to try to set. the st. age.
16 We believe that it was necessary if we are going to talk ,
II about the next fif teen years and what ought the ACRS be I8 like and what it ought to focus on, that we should at Icast I8 address what sets of assumptions were we using when un described that situation.
21 We aren't trying to say we are predictors. We 22 i
attemprod to avoid saying this is the consensus forecast, 23 but rather it was the set of reasonable assumptions that O
LJ we did reach some agreement on, so we could then go forward 25 and discuss the rest of it.
. - _ _ - , _ _ . -~ - --_ . _ -_ __ -_ -_ - .__ _.
2-8-JoeWD1 i 1 Most of Chapter 2 addresses just that. This j 2 is extracted from a more detailed discussion, which had l
3 covered in addition to greater depth in these items also 4 other items, but we extracted out what we thought would be 6 the most significant elements in trying to address the l
8 other issues that we were talking about with respect to the i
] 7 ACRS. !
l 8 Any substance that is in this chapter gets down j 9 to where we are talking about implications for the ACRS, and
- 10 after briefly outlining the background that some members i
j 11 had, we then go on to address those points which Manny i
12 stressed in some of his recommendations, arguing that the l
13 ACRS is still needed not for licensing reviews, but to provide 14 wise, broad, technical policy advice.
l 16 As we pass by, we mention, I am sure, an issue 18 that has fleetingly hit many people that it is possible that 17 the name of this Committee doesn't quite. represent the is activities of the Committee, but obviously that is not an 18 earthshaking recommendation or comment. A change of name 2
l 8 either is just symbolic or cosmetic, but it really doesn't !
- 1 i 21 address substantive issues.
L 22 f We also go on to talk about that we see greater 1
88
) stress on generic issues. Operational plants., waste M management, and future reactor design. We briefly alludo 26 l to the point picked up later than Chet and Manny aircady
2-9-Jo;Wol 312 1 talked about, namely the detailed review of the research
) 2 budget doesn't seem appropriate.
3 We pick up a comment that came up from a few 4 people we spoke with, and reflected back on.some of the 5 historical knowledge of some of the members of our panel, a namely that a general advisory committee is the type of 7 comnittee that we are recommending, s And so, in summary, we say the panel recommends 9 the ACRS be a true advisory committee to the Commission with to a charter much broader than merely reactors, particularly 11 when reactor issues are defined narrowly.
4 12 Herb?
()XXINDEE3 MR. KOUTS: Well, it is difficult to add very 14 much to what John has just said, but the context for the 2 basic recommendation of the report is set by this chapter.
Is We do point out that times have changed sub-17 stantially since the date when this committee was first is formed, and that things have changed substantially since the 19 time it first became statutory.
30 The change has progressed to a point where the il principal activities the Committee has faced in recent 22 years are probably no longer going to face it for a number 23 of years at any rate, whereas a number of problems of a 24 different content and context are facing the Commission 26 generally now, and the Commission is in need of broad,
5 2-10-JoeWel 313
, 1 technical policy advice of the kind that a wise committee 2 of this kind can best afford it.
3 MR. WARD: We have time for a few questions. I 4 think Carson is first.
- 6 MR. MARK
- Along the lines that you were. just 6 mentioning, Herb, a new thing on thic table or in this f
i 7 atmosphere is waste management.
8 It has been here all the time at some level or l
9 o ther. It is here now in much more persistent, obvious, 10 pressing way, because of the Waste Policy Act, and the 11 need of the NRC to adjust to the requirements of that.
s 12 The Committee has sort of slipped into an attempt
() 13 to deal with those questions. They sre new. Would it be 14 your opinion that the committee is the proper place, and 2 with its present variable composition, to act for the 16 Commission in that respect?
. 17 MR. KOUTS: Not at all, Carson. The Commission i
! 18 has to act for the Commission, but the Advisory Committee i
18 on Reactor Safeguards --
30 MR. MARK: I didn' t mean that we acted, but act 21 as advisors.
- 22 MR. KOUTS
- Yes, indeed.
Act as advisors. I 88 can think of no field in which good, sound, wise advice l
84 would be more beneficial than that of waste management right 25 now which is in such a mess.
I 4
4
, . - - , yp -m--<- -,,,q, e r' + ' ' ' - - -u' - -'w *-*- w---- -
y*7r T7-"' -
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, 2-ll-JoeWal 314
(
1 The Commission does not have this problem n
V 2 completely in hand. It has to act in partnership with EPA 3 and the Department of Energy in putting this; issue to bed, !
! 4 but the Commission certainly needs good, sound advice of ;
6 a kind which is more than technical as a matter of fact, '
6 which represents just good wisdom.
7 Do you design for a thousand years, or ten thousand
- i 8 years, and how can you do that kind of thing, and what is 9 the content of the technical solution that might address a 10 requirement like that?
11 MR. MARK: My question was whether the Committee 12 as you see it is a reasonable source of advice for the 13 Commission on such questions?
14 MR. KOUTS : I think the Commitee contains a 16 great deal of the informational background and wisdom that 16 '
will help advise in this way.
17 I think if I were to have formed a committee 18 that specifically addressed the waste management issue, I 18 would have picked a somewhat different committee, but it i
8 might overlap substantially. !
21 MR. AHEARNE: Carson, let me pick up on that 22 last point that Herb just made. Your question obviously 38
- can be interpreted on several levels, and on one level is, [
8' as Herb answered it, there are some people who could 26
, interpret it as saying should tne ACRS provide detailed j !
'l
._~_ _ , __ _ __ , _ _ . . _ . . _ _ _ . _ _ . . _ _ _ . _
2-12-JoeWnl 315 1 technical review of each step, and it is on that last point g3
(, 2 which we also address at another place in this report, that 3 there may be some areas of interest in which elements of 4 the NRC Staff need an advisory group such as there already 5 exists on medical isotobes, and so it is possible that the 6 waste management people need a group of people who are 7 specifically providing advice on detailed technical issues.
8 That is not wnat we propose for the ACRS.
9 MR. WARD: I think we only have time for one 10 more question. Forrest, you seem to --
11 MR. REMICK: Yes. You indicate in here that the 12 purpose of the Committee is to provide technical policy r'%) -
( 13 advice to the Commissioners and I fully and strongly agree N/
14 with that.
15 From time to time, based on my experience on 16 the Committee it has come up that part of the function of 17 the Committee is to provide oversight of the Commissioners 18 themselves .
19 Did you address --
20 (Laughter.)
21 Did you give thought to that? These words of N providing advice to the Commission, or is that kind of 23 automatic based on the act itself.
ry 24 MR. AIIEARNE : We did address at some point the N~/
M role of providing an oversight function to the NRC, and we
~. _. . . - . _ _ . _ . _ _ _ _ _ _ _ - - - - _ . _ .. _ . . _ . _..
I 2-13-JoeWnl 316 l
1 did not write in here that that isn' t appropriate, and I i
O' s guess that is about as far as you really came. It was not ;
j 3 treated as I recall in any great length looking at should 4 we become another nuclear safety oversight committee. That 5 was not addressed.
{ 6 MR. REMICK: And you did not see that as our I
7 function, is that correct?
6 MR. KOUTS: Yes, Manning just made the comment I 9 that I was about to make, and that is we believe that to the !
J 10 extent that the Committee should be free to initiate items ;
, 11 on its own, without being asked for its opinion on things, i 12 that is a kind of overshight - function, and to that extent, i'
13 at any rate, the Committee should have that freedom.
- 14 But beyond that, no, the Committee should not i
H5 think of itself as looking over the Commission's shoulders .
16 all the time.
i 17 MR. WARD: Let's sge . We want to give enough
{ l j 18 attention to this Chapter, but we have more. Glenn, did j 18 you have a real quick question on this?
t
- 30 MR. REED
- I wanted to say that.I thought Chapter 2 21 was a very fine chapter.
l The presumptions in the beginning 22 of the Chapter are fine, and on pages 7 and 8, I identify l
18 about six' major recommendations, and they are all very fine. I i
I -
24 I don't share the opinion of the panel that the -
36 title of ACRS is that bad.
-.,-.---c-, -e,- ,.r ,.-,...-,,e. ,.~,-.,.-,..-.-,,,--.%....,,,.-,.-.%,,,,,-,,-m_+-,,.._.. - c ..-3y . - - - - ,.m, . . , . - - - - , . ~ , - - r- ,,w ..-w.m..=-
, - . - = . - . -
, 2-14-JoeWel <
317 l, . 1 Safeguards, to me, many years ago, meant systems.
't Safeguard systems. And it didn't bother me -- it seems to 3 me that the materials people rather stole the use of the 4
{- 4 word, ' safeguards.'
5 (Laughter. )
6 ' Reactor' might be a word to be criticized,
)
i 7 because it is getting broader than just reactor.
~I 8 MR. MUNTZING: Mr. Chairman, Chapter 3 the 9 principal authors were Mike Bender and John West, so I j 10 would like John to carry the burden there.
j j XX INDEX 11 MR. WEST: Well, I' presume you have all read i
j 12 the report.
13 There are several key things that are said in
- 14 this Section 3. Some key words we think the commission
} 16 ought to give more attention than it appears to have given 18 in the past to highly important technical issues.
i I
j 17 And assuming you have read this Chapter, I want 18 to see if I can add -- and I hope I don't make it worse on i 18 the explanation of the generalist versus specialist.
8 We did discuss this in the panel a fair amount.
21 I think to inost of us, and to me, l't means that it would be l
8 very fine for everybody on the Committee to have a specialty.
8 lie is good at something, but not just limit
- his attention to that. If he is good on reactor physics, i
8 then he shouldn't refuse to consider any other important
2-15-JoeW31 318 1 question and somewhere else in the report it deals it dealed (O
(_,/ 2 with that, that members of the ACRS should educate each 3 other.
4 People should not turn off their listening device 5 when a subject that is not in their speciality comes along, 6 there ought to be generalists in the sense of being more than 7 a metellurgist or more than a chemist, or something like 8 that, but nevertheless they should be good at something.
9 On cosmic versus nuts and bolts, that is something 10 one can talk about forever, and I will try not to do that.
11 But I want to say a word or two about it. There 12 is nothing wrong with looking at nuts anr1 bolts if it is 13 relevant to a cosmic safety issue.
(O) 14 But, I don't -- we don't think that the ACRS 15 with only fif teen members, that the amount of time they 16 have to spend, to put a high priority sorting through nuts 17 and bolts with the thought that they might find one in there 18 in the barrel somewhere that pertains to the big issue.
19 I think it ought.Ao be the other way around; you 20 look at the big issues and those have never changed, some 21 of us have been around a long time dealing with the Safety 22 Committee or ACRS in one form or another for a long ' time, 23 and what you are still trying to do is what you set out to 24 (s try to do, I think.
(
) 26 And that is to provide an adequate level of safety
_ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . . _ _ . _ __ _ _ _ _ _ _ _ __ _._m _
i 2-16-JoeWal 319 I for the public because of the peculiarities of the nuclear i i
< 2 plant. t 3 What does this mean? There are f undamentals that l 4 you could write a lot better than I could, but you have to !
5 do things like always be able to shut down the reactor, and [
. i l 8 always cool the reactor. l l :
y 7 There are fundamental cosmic issues like that l
\ i s and now that there is a nuts and bolts somewhere that is !
r 1
- really crucial to a cosmic issue like that, then you look l
j 10 at it. t i I J
r 11 But there is a large staff of the NRC that I think 12 sorts through the barrels more than you fellows do, or could, 4 l
()
t la and being extremely unlikely in my view that something really b i
14 important to a cosmic issue would be overlooked, but perhaps 18 there may be examples of that.
I le But we think the ACRS should look at are the l
17 hard issues that for one reason or another have not had l I 18 solutions identified to them. ;
- 19 I thought for a long time that these hard issues 1
) 80 do have answers, but it is more a question of how far do you l 21 need to go in order to be safe enough on the hard issue, but !
l [
88 the thing to do on the.hard issue is not to ignore them, this i I
se prestigeous body ought to be looking at those hard issue. !
84 The big ones. The hard ones. And pointing the direction as with regard to what needs to be done now or later with regard j i :
i u _ _ _ ..._ _ _ _ __ _ _ _ _ _ _ _ . _ __ _ . _ . _ . -
320 2-17-Jo:Wal
{ 1 to protecting the health and safety of the public.
4
~
I believe every technical safety problem has
{ 3 a solution. You may know something that I haven't thought
- 4 of, but I have given quite a bit of thought through the j
5 years. Uncertainty is one of the big-ast problems facing l e the nuclear energy.
I j 7 In many instances, I think it would be better s if you simply looked at a cosmic issue and said: What would ,
l .
8 it take, if anything, to put that issue to bed?
10 And the solution might be much morn palatable I
11 in every way, including cost, than debating it forever.
3 12 The Section 3 emphasizes the belief, strong belief, la that the ACRS should be more decisive. More of a leader,
- 14 which we sometimes call more of a pro-active approach rather I
- 18 than reacting approach. It should be a little bit ahead ,
i . i 14 of any other active organization, I think, in probing cosmic j l 17 issues and providing leadership with regard to those !
i
? e issues, and since you can't do everything, we have come up j 18 with some things you should not do, like fire fighting, and !
, 2 don't spend too much time probing around in the barrel for i I i 21 nuts and bolts.
7 i End 2. 88 l Su:W fois. l I 83 ;
) l I k
! I J
321
- 3-1-SueW 1 With regard to the future, which is one of
(_) 2 things I haven't given up on, but I also think of the 3 future in the nuclear industry and I think there is one, 4 it's a matter of when it will come back and in what form.
5 But it seems to me, in line with the cosmis approach, the 6 ACRS could very well be looking at not only protecting 7 the health and safety of the public from the plants that 8 have been built, or maybe already well along in construc-9 tion, but also what the new plants should be like.
10 And my mind tells me that there should be 11 a distinction made between those. And it always irks me 12 to try to apply the same yardstick to the old plants as 13 to the new plants.
[)
L.
14 But the ACRS could be quite helpful in reviewing 15 what future plant should be like. And I believe there 16 is something already under way with regard to collaborating 17 with EPRI on its program to establish criteria for new 18 LWR plants. The ACRS could be quite helpful in indicating 19 whether they think the criteria are good or should be 20 modified as that develops.
21 The panel believes you should not do the design.
H Even that takes a little bit of claboration I think to 23 make it totally clear. A concept and a design are two
("' 24 different things. And a suggestion and a requirement are
(- 25 two different things.
322
- 3-2-SueW 1 So, I've heard some pretty good conceptual b
\ 2 thoughts expressed by members of this Committee. I 3 think they ought to be considered as one thing that might 4 have considerable merit but not a requirement insofar as 6 being the only way of doing it, nor a detailed design.
4 We put in a few examples in Section 3 of the 7 kinds of things that we thought might be fairly high on 8 a priority list. We suggested ACRS develop a priority 8 list of safety problems that need further work.
10 Actually, in our initial generation of the 11 draft, we had quite a few more items. But we decided as 12 we went along to not be presumptuous and not be all that 13 specific but to group them a bit into types of things.
14 So, that's what we have done.
la They are not necessarily We have put d,own some.
is in the same order that you would. But these seemed to us 17 like important safety issues that ought to be on your is list, and there ought to be others. 'I presume you have 19 read all of those.
E The ACRS can, if it takes a hard look at what II the real issues, it can be quite, qufto busy and very 88 highly respected as a leader in establishing the criteria 8 for the safety of nucl' ear power plants.
" And one other maybe gratuitous comment, I don't
" 'think this should be done by pouring over twenty thousand
323
- 3-3-SueW 1 documents per year but by selecting a few major issues and
(~ s' 2 being a leader and identifying what should be done about 3 those issues.
4 Thank you.
5 MR. WARD: Thank you, John. We've got time for 6 one long or two short questions.
7 (Laughter.)
8 All right. Glenn.
9 MR. REED: I certainly agree with Mr. West.
10 I think that Chapter 3 is a fine chapter. And his words 11 have been even more fine.
12 And I will never forget Mr. West in the year
[n}
v 13 about 1953 or '54 when he said some cosmic words to a 14 group of utility executives. I will tell him the story 15 later.
16 (Laughter.)
17 MR. WARD : Any others? John, I have one 18 question. On one of the suggestions for matters that 18 should be dealt with is the development of a rational 20 regulatory basis for radioactive waste.
21 Now, we've been struggling with this. And one 22 of our problems is that we perceive that the Commission 23 It's a difficult question.
does need help in this area.
24
/) But most of the questions are political and G 25 social questions and not' technical engineering, risk really
324
- 3-4-SueW 1 the -- public health and safety risk-related questions.
n/
w_ 2 And are you suggesting here that we should attempt to 3 drive the process toward being more related to a technical 4 or a risk perspectiva?
5 MR. WEST: Yes, I think so. But still we don't 6 regard you fellows as just long hairs that limit yourself 7 to calculating, I don't know, the rate at which radioactivity 8 can move through the ground, things like that.
9 We think you should provide your judgment based 10 on technical matters. And, John, maybe you would like to 11 add to this.
12 MR. AHEARNE: Well, Dave, I would say that one
() 13 of the -- this is now probably necessarily not embedded 14 in here, but just to respond to your question, one of the 15 things that the Commission can use is some respected-body, 16 such as yours, pointing out some of the things you just 17 said but in a little bit more detail.
18 Namely, that there are technical issues that can i
19 be addressed. And then there are other which are the 30 political institutional _ issues. And at times, because of 21 the way the debate is handled, that gets blurred.
22 And people will argue really-on a political 23 institutional basis as though they were arguing technical 24 issues. And it is a strong help to people who have to 4
('s)
(/
26 compete in that -- or, combat in that environment to have
325 1
13-5-SueW 1 some technical body keeping their eye on the technical C
k 2 issues.
3 MR. HUBBARD: John, I would like to add some-4 thing on that. We debated about whether you should be 5 involved in waste.
6 You know, one thing is we thought how about 7 another committee that is looking at waste. And then we 8 thought, they are going to have one perspective on risk 9 and what's good quality and what's good containment. And 10 we thought that, now if you had one group over here, 11 which you are, looking at those same questions, if you had 12 the separate group, they could become very concerned.about 13 what you-all know as a much lower risk.
> 14 And so we -- I know, myself, I was convinced 15 to get you-all involved in the waste question because you 16 are the one group that has a perspective of risk, that we 17 don't go too far on waste. And then a lot of the questions 18 are very similar, like what is the right quality assurance 19 for waste? What is the right kind of containment?
- Materials.
21 They are very, very similar questions. And 22 you-all -- the key thing to me again is the unique perspective 23 you have of putting these risks into that perspective.
l 24 And that's why in the end I thought it was very appropriate
.{O] 25 for you-all to be addressing waste.
326
- 3-6-SueW -1 MR. WARD: Thank you.
i
(""))
(- 2 MR. MUNTZING:- Thank you, John, and others.
, 3 The next chapter, Chapter 4, the principal authors are 4 John Ahearne and Steve Sholly. John.
INDEXX 5 MR. AHEARNE: Chapter 4, we attempted to, in 6 moving through this report, address to whom do you speak, 1
7 or to whom ought you to speak, or who is listening, which-8 ever. There are various ways of asking that question.
9 As you can tell from the way we structured the 10 report in general, and this chapter in particular, we-11 ended up concluding that you really should be advisory t
12 to the Commissioners. That should be your principal 4 13 focus.
! 14 And we go on to say-it would be most useful 15 when the. advice is given in a~very frank fashion, which 16 means that you have to be willing to be wrong some of the 17 time. And so a track record of being never wrong is not 18 necessarily as useful as being timely focused and clear 18 even if you are wrong some'of the times.
20 Providing advice to the Commissioners, we 21 concluded, means the ACRS as a group providing advice, 22 , .as being the most valuable form, not the consultants ,
28 speaking or not individual members.-
24 As Manning mentioned in his review of.the 25 summary conclusions, this does not mean we are saying there
- -~ ..
i i
327 '
- 3-7-SueW 1 should not be dissents. But it is the role of the ACRS
\ 2 as a group that we saw as being most valuable.
3 We did explicitly address an issue that had 4 been raised to us, should individual members discuss with 5 Commissioners on one-on-one meetings.. And, as Manning 6 mentioned, and as we go a little further here, pointing out, 7 we do not see anything wrong with that, particularly as 8 long as the individual members in so doing make clear they 9 are speaking for themselves, that these are their own 10 opinions, and they are not now providing informative 11 descriptions of what the panel, ACRS as a whole, has said 3 o therwise .
( 13 In addressing relations with the Staff, in a 14 later section we go into more detail about some of the 15 problems that we see and that has been pointed out to us.
16 In this particular section we merely address that if you 17 are going to be writing to the Staff, you ought to explicitly 18 say you are writing to the Staff as opposed to writing to 19 the Commission with the underlying knowledge that, well, E the Commission isn't going to understand it but the Staff 21 giyi, 22 As an issue that had come up several places, we 8
addressed what relationship ought you to have with the f
(- 24 CRGR. This was one of the more debated issues on our 25 7
panel. We ended up putting in a conclusion that you do P
L - . . _ ._ - ..
328
- 3-8-SueW l review the process that the CRGR uses to review items O 2 brought to it, in particular the methods of technical 3 analysis used by the CRGR, but we opposed the ACRS assuming 4 the responsibility of reviewing each CRGR decision.
5 So we focused on the process rather than each 6 decision.
7 Relating to Congress, as has been mentioned, 8 we don't recommend trying to reestablish the many years 8 ago very close relationship, and we do address with the 10 point that we believe that the report on research could 11 just as well either be removed entirely or satisfied by 12 a letter report with a substantial reduction in the detail.
- 13 There is nothing new about saying that you I4 should not get heavily involved with the licensing boards.
15 We point out that relationships with industry and intervenors, 16 you should not be serving as advisor to either groups but 17 understanding what each group is saying, and particularly 18 if you decrease the insulation from the proponents and 18 opponents on particular safety issues it will help your principal advice.
1 A unique contribution which the ACRS can make, 22 unique across the whole NRC, is relationship with inter-23 national groups. Because of your reputation, your credibility and your previous professional experience, you have an
~
25 opportunity to get much closer with other international
f 329 3-9-SueW 1 groups and thereby get a better sense of what is known 2 internationally.
3 And as far as relationship with the general 4 public, we point out that your focus in writing your 5 reports ought not to be the general public, it really 6 ought to be the Commission. And we believe that your 7 principal function in providing sound advice to the Com-8 mission will in the long run be your best service to the 9 public.
10 That's a quick summary.
11 MR. WARD: Any questions? Dave.
12 MR. OKRENT: It seems to me that the CRGR, to a
() 13 considerable extent, has taken over many of the former i 14 activities of the ACRS and, in fact, not in an advisory 15 role if somewhat maybe not in a final decision role.
16 I'm wondering whether it's sufficient to look 17 at the methodology? It would seem to me that it would 18 be relevant to look at least at a reasonable sample of 19 . the major pieces to see whether -- how will I say it --
i 20 the philosophical approach taken by the CRGR was what 21 the ACRS thinks is appropriate.
22 And I didn't' find that in your write-up.
23 MR. AHEARNE: Well, as I mentioned, Dave, I' this was one of the more contentious points in our
(~s}
25 And, since my co-author of the section, Steve report.
i
330
- 3-10-SueW 1 Sholly, is not here I ought to fairly represent it was
(.
2 one in which he would have agreed definitely with you.
3 I think he would probably have even gone farther and had 4 put preferred ACRS to .look more closely at more of the 5 issues, the decisions.
6 There is clearly a reflection in your remarks 7 which I think several members of the panel would agree 8 with, namely a concern that the CRGR perhaps is the key 9 decisionmaking body within the NRC. On the other hand, 10 other members of the panel would argue, myself being one, 11 that it is an element in the internal workings of the 12 NRC.
,() 13 And if you have a strong disagreement with the 14 CRGR's role, if you believe that it is having a -- if you
, 15 do believe that it would have a negative impact on the 16 effective functioning of the NRC, then that's a point I 17 think you ought to raise with the Commission.
18 So, we ended up concluding that you ought to 19 look at the process by which the CRGR makes its decisions.
30 We carefully worded -- we say that you oppose the ACRS 21 assuming the responsibility of reviewer of each CRGR 22 decision. But'your point of selecting a few key ones and
, 23 looking in detail at them would be consistent with where 24 the panel ended up coming out.
25 I think that's a fair reflection but since this s
l L - -. .
331
- 3-ll-Suew I was a --
2 MR. WARD: Yes. Thank you. Paul.
1 3 MR. SHEWMON: Manning said something which I t
4 didn't understand, and this was oral communications could 5 be better managed.
6 MR. AHEARNE: That will come up in a slightly 7 later section. It really talks about the way the ACRS, 8 when you plan your meetings with the Commission, how --
9- MR. SHEWMON: Fine.
10 MR. AHEARNE: -- that ought to be structured.
11 . MR. SHEWMON: I will wait.
12 MR. WARD: Hal has a question.
() 13 MR. LEWIS: Just one thing. On the issue of 14 congressional relations, it is certainly true there is 15 uno joint committee anymore and probably ACRS is not held 16 in as splendid repute as it was in the old days over on 17 the hill.
18 On the other hand, there have been a few 19 instances in which an ACRS recommendation has been -- I i
3D won't say ignored -- not diligently obeyed by the NRC and l 21 its Staff, and the issue has been picked up on the hill.
22 And, in a sense the ACRS position has been enforced through 23 -congressional action.
24
('s I have in mind things like the nuclear data 25 link, the regionalization issue, and the good old, long
l l
332 i #3-12-SueW 1 lasting NTSB issues which keep getting raised on the hill.
'x
- 2 And I wonder whether it's your view that we 3 should let those things happen or whether if frustrated 4
4 within this building we should go screaming to the hill?
5 MR. AHEARNE: I rise to-your great health.
6 (Laughter.)
7 MR. LEWIS: I-never doubted that you would.
1 1
8 MR. AHEARNE: The word " obey" in your 8 description --
10 (Laughter.)
4 11 I think we would all agree that the advice 12 that you provide to the Commission or to the Staff is not
() 13 something which they must obey, of course. So that it is 14 advice.
N I think our points were first, in addition to 16 the one that you mentioned, namely the.old structured 17 joint commission, et cetera, is disbanded, the Congress really does have several bodies that can look in detail i
18 j 19 at issues when they are assigned function. And one might 8 say, well, OTA, for example, does not have the level of 21 expertise represented here but the OTA style is to then
. 22 go out and hire consultant panels to look into issues.
23 So, as far as some of those issues are concern-
" ed, Congress does have'substantially other resources
)
. that they can focus on issues'if Congress is initiating, l
l
, . . .. . .. . . - - . = -. - -. - -- . _ = . .
333 l e
1 whereas the Commissioners don't. .You are the guys who l.#3-13-SueW
'I send the advice if they are going to get that kind of 3 advice.
l 4 As far as your point is, should you go to the 5 Congress if the Commission isn't listening to you, that's 1
6 really a question that I think -- the way we addressed i
i 7 that was to try to focus what is your principal role, 4 8 which should be advice to the Commission. And at this 4
8 stage then, let me go on, because obviously at this stage 10 we didn't go much further.
11 I will point out, my own view of that would 12 be, going around people you are advising, to then go to
~
a l 13 someone else to get someone else to then pay attention 14 to the issue is a short term gain and a long term loss.
E People you are advising then, once they recognize L
F 16 -that's a format, it isn't normally that then they pay more i
17 attention to you, it's they pay less attention to you and i
18 then try to make sure that you are excluded from those i
19 really sensitive issues that they want advice on.
88 So, I'm --
i 21 MR.~ LEWIS: No, I agree with that, John'. The l 22 cases that I mentioned were cases in which without any 88 initiative on our part -- recommendations are public, of 24 course, have been picked up by the hill and in each of 25 the cases I mentioned, somebody on.the hill has initiated
334
- ,3,-14-SueW 1 questionning to find out what is going on. It's hard to
- 2 know what our role is under those conditions.
3 MR. AHEARNE: Well, we've both been around 4 Washington for a long time, Hal.
6 MR. LEWIS: Yes.
6 MR. AHEARNE: If they pick up something, really 4
7 pick it up and ask questions, obviously then you respond. ,
8 But there is a difference between them picking 9 it up and their being pointed, here is something you 10 really ought to pick up.
11 MR. LEWIS: Yes. Okay.
12 MR. WARD: Chapter 5.
O) i, ,
13 MR. MUNTZING: Thank you, John. Chapter 5 j 14 authors were Ed Case and Richard Hubbard.
]
INDEXX 15 MR. HUBBARD: We have already talked a lot a
16 about Chapter 5, so there are just going to be a-couple of 17 things I'm going to add.
16 On composition, we didn't think we could say i
,o
- 19 this is the right mix so that we would leave that up to 20 the Committee.
1 21 However, having done that we then said that 22 we thought that you should have somebody from the NSS 23 vendors with that type of system experience on the 24 Committee, probably a BWR and a PWR type person. We 25 did think you should have some additional help in waste.
l
335 (3-15-SueW 1 And then also membership from an operations
(
^ 2 standpoint, management of operations, which is a little 3 different question than the nuts and bolts of operations.
4 In terms of length of service, we recognize 5 that as you have more turnover you lose some experience 6 and history. And we have a recommendation on Page 20 7 that both the NRC and the Committee -- and that was put 8 in there, NRC and the Committee -- figure out how to make 9 use of these retiring members. And they develop the 10 methodology for doing that.
11 So there is really two recommendations. One 12 is that you have a little more turnover in membership and,
() 13 two, though that the members that are leaving, that both 14 the NRC and the Committee make use of that knowledge. And 15 that you figure out a format to do that.
16 On appointments and reappointments, the main 17 emphasis was on reappointments, because we said if you 18 continue business as usual then you are not going to get i
19 that new blood in reappointments. So, we had a great deal 1
30 of debate in that area.
21 And it was the majority's opinion that re-22 -appointment-should be looked at the same way new appoint-23 ments are. That is, with a slate. But we all agreed that r
24 the discussion with the members being reappointed, that 25 should take place well in advance. This shouldn't be l l ;
336 e i #3-16-SueW 1 happening at the last moment.
2 In terms of-conflict of interest, one of the
~
3 things there that we talked about is that there are members 4 who have technical skills in other industries that could 5 be on this Committee that would not have a conflict of '
6 interest. t 7 And so, while it might be harder to get somebody j 8 that is active doing BWRs, PWRs, or gas. reactors, there l 9 are people in other industries who are active in their l
10 careers that could be added to the Committee that would j 11 not have a conflict.
i r 12 Ed, what would you add? l
() 13 MR. CASE: I think that's it.
14 MR. WARD: Let's see, Paul.
I 2 MR. SHEWMON: One short comment. There are a ;
i f 16 fair number of people who serve only one term. And I l 17 hope that as part.of your consideration you went back and l !
~
18 looked at what the statistics were. j 19 Many people decided there must be better ways I
20 to spend their life than here. Whether they were smarter 21 or' dumber, I won't comment.
22 The other thing, when ycu talked about people [
l
- 38 who-had BWR and PWR experience, is it your feeling that 24 those might come'from the vendor or that we had to get peopl e e l
25 who weren't. tainted in that way?
l 1
?
. . , ,.-c -- n., . . . , , ,---,,,,n-, . . - - , , - - - , -- ,
337 43-17-SueW1 MR. HUBBARD: We discussed that, but I thought 9 2 that, you know, that that could come from a vendor.
3 MR. SHEWMON: Retired?
4 MR. HUBBARD: Retired.
5 MR. SHEWMON: Yeah.
6 MR. HUBBARD: But there is something about 7 having a system types person, or persons on your Committee, 8 that have been used to making those decisions, of conceptualiz-9 ing new reactor designs and so forth that I think would add 10 much to your discussions.
11 That's a personal opinion.
12 MR. SHEWMON: I guess it's sort of -- whether
() 13 it comes from the lawyers that such a person would be 14 impossible to cleanse or what, I don't know. But it 15 certainly is a strong tradition which we would blame on 16 the lawyers, you know, until I hear differently.
17 MR. WARD: Glenn.
10 MR. REED: I certainly agree with the recom-19 mendation that there ought to be a vendor type BWR and PWR 20 person on the ACRS, because we frequently get bogged down 21 in design arguments of which we know little about.
22 And I think that would be a great help. But 23 I do see a problem in that, because I've gone through the
',' 24 problem, coming from a utility, and I think Mr. Wylie has, and that is in this cleansing perhaps thing, one of the
338
- 3-18-SueW 1 things that is insisted upon is that you generally
- 2 liquidate all of your earthly holdings, such as stocks.
3 You may have had a lot of benefits from a company, long 4 time service in the company, in stocks and benefits. That 5 is a real hardship.
6 And I don't know how we accomplish this PWR/BWR 7 expertise in the Committee and also overcome the tre-8 mendous financial losses. ;
i 9 MR. CASE':. It's difficult, but we think you i
l 10 should try hard to do that.
11 MR. HUBBARD: And we -- you know, I would be 12 one that would be a strong proponent of that idea. You
() 13 would say, well, why didn't we say intervenors should 14 have somebody on your Committee. We didn't say that.
i 15 I mean, we are not trying to say that all i
16 points of view need to be represented on your Committee.
17 We were looking at it from a technical basis, that if 18 we were putting together a committee we would want some 4
j 19 people with that type system and pressure boundary knowledge ,
l I
30 the ASME Code and so forth.
t' 21 And we are not suggesting, you know, the other l
22 l question.
i 23 MR. WARD: Okay. Dade, and then Carson and l N then Carl. That's all the time we have.
(
" MR. MOELLER: You mentioned in your report that t
l
339 93-19-SueW 3 we should, you know, expand our efforts to bring women sJ 2 and members of minority on to the Committee. And you 3 also recognized that we have tried to do that unsuccess-
., 4 fully.
~
5 Do you have any suggestions as to how to really 6 accomplish that?
7 MR. CASE: No more than hard work. And keep 8 at it.
! 9 MR. MOELLER: Uh-huh. We have sought them, 10 and we have even approached them and been declined, you 11 know. They said they would not serve.
12 MR. HUBBARD: John.
() 13 MR. AHEARNE: I have one suggestion. I 14 don't know how effective it would be, but having been a 15 participant in trying to get some people to apply for the 16 ACRS membership, I would suggest that one of the recom-17 mendations which we have is to say that the average amount ,
18 of time served by the current member should not be viewed 19 as, this is a basic requirement.
- 20 I know, for myself, in approaching people and ,
21 asking them would they be interested in applying, that 2 turned out to be a significant hurdle which many were ,
23 unwilling to take. It doesn't mean that they couldn't ,
24 have made very significant contributions to the ACRS with 25 a fewer amount of days.
4 m a y g. g--,. .g, w e s t +
. ~ . . - . .. . . - . . . . . . . . - . - - _ . . . . . . - . . - -
i 340
.#3-20-SueW . 3 And I suspect that.particularly as you go off x 2 toward the type of individual who because of the structure
! 3 of the United States society is also heavily sought.after ,
4 to serve on many individual groups, then that time re-5 striction, if you did make explicit that it need not be 6 that heavy load that most of you now carry, you might 7 have greater success, t j END #3 a j- Joe flws
! 9
, 10 11 i
12 O >>
14
, 4 I
, l
! 16 4
- 17
,I 18 l
19 30 4
21 1
l 24 I
l l
l
4-1-JoeWcl 340A 1 MR. WARD: Unless it was a direct followup to
'C\
V 2 this , Chet' --
3 MR. MARK: Well, I am really repeating things 4 which have been said, I guess. Your concurrence in the 5 cange of terms on the committee seem to me to ignore the 6 fact that the average age on the committee of the people 7 present now is scarcely eight years.
8 And you seem to be afraid you want new blood.
9 Well, new blood takes a little time to cure.
10 MR. SHEWMON: Certainly new wine.
11 (Laughter.)
r 12 MR. MARK: And I couldn't really feel that you (j 13 are saying anything importantly worth saying in subscribing 14 to that, because as the Committee has gone without any
- 15 regulations at all, its average age isn' t all that over-16 whelming.
17 MR. HUBBARD: That is why we pointed out the 18 eight years. '
19 MR. MARK: As Paul said, there are people who 20 after a couple of years on board here say: I really have 21 something better to do.
22 They guy is too dumb, so he stays here. That 23 might have been the intend. . Anyway, I question that.
24
'3 I guess the harmoniousness. of .sayihg we ne d a (G 26 PWR, a BWR,-vendor-type experience, and the conflict of l
'4-2-JonWal 341 1 interest provisions are just fine.
~- 2 There really isn't a need for subscribing to 3 the conflict of interest provisions as they are when they, 4 in fact, work hardships on some members, and particularly 5 on the kinds of members you mentioned.
6 Another thing which I believe has also been 7 said before, you asked the Committee to drop its nuts and 8 bolts fascination, and become more philosophical, and that 9 is also somewhat orthogonal to say you must have a guy like 10 this, and a guy like that, and a guy like that.
11 MR. HUBBARD: We recognize that. ;
12 MR. MARK: Those are the things that disturb
) 13 me most about.the report, but by and large I thought it ,
14 ' was great.
15 MR. CASE: I think it is important to recognize 16 that most of these aspects should be considered. The need f l
17 for new blood. The philosophicainess of older members. Both 18 aspects are important. !
t 19 MR. WARD : Unless we have a really burning one, I 30 let's move on to the next chapter. ;
21 MR. MUNTZING : These are tough questions that ;
6 22 do not have easy answers, i 23 Chapter 6, the authors were Homer Hagedorne and I
j r% 24 Steve Sholly. Homer?
N~s *
$ /#h 26 MR. HAGEDORNE: Good morning, gentlemen. This
, i l
l
\ -. - -
4-3-JosWnl.
342 1 chapter is founded on the observation that there is a very
- fs w- 2 complex culture and tradition that has built itself up. over 3 the last thirty or forty years of activity by the Committee,
-4 and that this culture, which is literally palapable.
5 You can't come into this room without beginning 6 to notice some of the values and some of the habits of the 7 Committee that make it really unique.
8 And that that set of values has come to include 9 a few more tendencies toward divergence than toward con-10 vergence among the members. I will give you a couple of 11 examples, one literal and one metaphorical.
12 The literal example is that you have over the
() 13 years developed the practical therogative on the part of 14 any individual committee member to propose and have authorized 15 a subcommittee with almost no reflection, and almost no 16 resultant commitment on the part of the committee as a 17 whole to do anything with the work that the subcommittee i 18 might come up with. Permitting people to cultivate gardens 19 as they choose is perhaps a little bit too strong a way of so putting it, but I want to emphasize what it is that I mean 21 by divergent tendencies.
22 The metaphorical example is an antedote that 23 we have picked up three or four times as we tried to talk l
24 divergence to various people ~, that is the committee going-I 25 through the London subway, each member clutching his own
- - , r-
4-4-JoLWal 343 1 direction, amiably disagreeing with one another about what N- 2 is to be done, and who is going to follow, and so.
3 The point being that there are some things that 4 it really is possible to come to a' collective judgment as 5 to who might really speak for the Committee in that regard, 6 and provide a little bit of specialized direction and 7 leadership.
8 Another way of saying this is that we have here 9 a set of high quality, very able people, who over the years 10 have created a tradition that cannot be changed merely 11 by the infusion of a few new people from time to time.
12 The tradition and culture is just too strong,
() 13 and the point of that is that if you seriously believe that 14 as a committee you wish to improve your effectiveness, that l L
15 is the amount, the quality, the-intensity of your work e 16 product, that you probably will have to change that culture, 17 that set of traditions, and develop some slightly new ones, !
18 and it.is in that spirit that we offer you a series of !
19 practical suggestions in this chapter that we think ' could ,
i i
l 30 shift the balance just enough toward convergence.
21 Now, we are quite sensitive to the kind of risk 22 that Dr. Okrant mentioned a while ago, and we are certainly !
23 not advocating that you become a rubber stamp for anybody.
(
\
24 The Chairman of the committee, or the Commissioners, f 25 or anybody else. We value the individualism and the integrity i
i _ _ _ _ - .
4-5-Jo Wal ,
344 1 of the members individually, and it is a very important
\/ 2 quality.
3 However, we are saying that there are a number 4 of things that you could do that would make it possible to I
5 pull together just a little more easily than is presently 6 the case.
7 Some of these are the change in the choice of 8 a _ chairman, giving the chairman just a little bit more of 9 a perogativc; not a lot. Equipping the chairman with a 10 management committee, who can both be a protection against 11 abuses by the chairman, and a way of mediating between i 12 wherever the chairman wants to go, and the rest of the l'
( 13 committee , and allow a mechanism for more quickly coming 14 to grips with issues about priorities and resource allocation
~~
15 within the committee, and other things which seem to us to be 16 very, very highly decentralized, if not individualized at 17 this point, almost to the point that it has got to interfere la with the orderly concentration of resources when you want 19 to get something done.
20 In the same spirit, we are suggesting that you 21 could make a somewhat better use of those valuable resources 1
22 you have in your consultan ts by training them a little bit 23 better.
4 24 That is, equipping them as you work with them 26 with a clear set of ground rules about what their role really l
m
345 4-6-JoeWnl 1 is.
/~
i !
i' 2 They don' t speak for the Committee, and they 3 have to yet be informed very much, more clearly that some 4 appear to have been, according to reports, about what it is 5 the particular subcommittee they are working with, is really 6 intended to do and what kind of technical and political 7 ambiance they are entering into when they come to work with 8 the subcommittee.
9 There has already been a good deal of talk this to morning about broadening your standards with respect to 11 bringing people into the committee, unwilling to commit 12 themselves to a hundred days , or unable to commit themselves
() 13 to a hundred days or more of service per year.
14 We suggest, concomitent with that, that you 15 almost have to get a prior, arrangement with each individual 16 as to roughly what he is going to do, and how much time he 17 is going to spend during the year, otherwise you fall back 18 into the set of values you now have which seem to suggest 19 that anybody who doesn't put in a certain rather high level 20 number of days per year, isn't really a good citizen of the 21 committee.
22 You have to have some substitute, some standard, 23 by which people will know that they are doing a good thing,
(j 24 and that the committee itself will reccgnize the contribution c
LJ 25 of that kind of person.
l
- - . . - . . . - . _.. . = . . - .- . . - - ~ _ .
4-7-JoeW21 346 i
1 This committee also -- our panel also felt that
(-s)
' Sw / 2 you have equipped yourself with a good staff over the years, 3 and we are suggesting at one point in this chapter that 4 perhaps you can make a little better use of the wisdom 5 and experience that the senior part of that staff has a 6 little more formally to help you keep yourselves on track 7 a little bit more than seems now to be the case.
- 8 I am ready for your questions.
8 MR. WARD: I think Chet had one.
10 MR. SIESS: I am assuming when you are talking 11 about the effort required, that if we followed the other
- 12 recommendations in the report the average effort would drop s
13 somewhat below the present value.
14 ~ MR. IIAGERDORNE: Not necessarily --
15 MR. SIESS: Decause otherwise it means that if 16 we take on people that can only put in 50 or 60 days a year,
- 17 that others are going to have to make it up, unless the 18 average goes down.
l 18 MR. HAGERDORNE: Furthermore you bump up against 30 the maximum which is possible, I think, under current 21 regulations.
23 MR. SIESS: Well, the maximum possible I think
- is 260, but -- the 130 is not a real limit.
84 MR. HAGERDORNE: I think we are assuming two
- as things. That perhaps where it is necessary, someone else i
l
4-8-Jo;Wal 347 i 1 might pick it up, but I think we are also saying that
(.
i K1 2 maybe there are some things you are doing that don't need 3 to be done with quite the intensity they are done.
4 MR. SIESS: That is what I was assuming.
5 MR. WARD: Paul?
6 MR. SHEUMON: I appreciate and was intrigued 7 by your comments of the culture. I won't say I am uncultured, 8 but I am untudored in that sort of a viewpoint, let's put it 9 that way.
10 The thing that bothers me some is seeing whether 11 you don' t understand the situation, or I don't understand 12 t he situation, or whether we both could, rm, I 13 MR. HAGERDORNE: Well, let's find out.
b' 14 MR. 3HEWMON: If you say -- let's take your 15 person who is going to devote 50 days a year, and I guess I 16 start this out as being one of the members who devotes less 17 time to this committee than most of the rest. I think Hal 18 and I may have the low record.
19 If you take four days a month, you are up to 50 20 without any homework, and that is just coming to be part 21 of the collegial group and one day of subcommittee, maybe, 22 -- or immediately associated with it.
2 There is a fair amount of reading to be done, 24 f'sx and you also talked about the f act that committees tend to U M be one or two man affairs.
348
.4-9-JoeWal 1 Part of that is it is tough to get somebody ;
2 else to attend, because they have other demands on their 3 time in addition to other interst, and so let's say if we 4 are going to do what you do, we are cut the number of 5 subcommittees in half as a start, just to try to free up 6 some time.
l 7 I have a' lot of trouble seeing where we would e free up the times to indeed do what you are doing, or 4
8 suggesting might be done, or seeing how these generalists l
4 10 who would sort of drop in and impart wisdom, which I think 11 we would resent if we felt they were dilettante at it, 12 would really get to do enough work on the committee so
() 13 they understood what the heck was going on.
14 MR. IIAGEDORNE: Well, we did that arithmatic 2 too, and came to the same kind of conclusion you are talking 16 about.
17 j There would probably be a rainimum of 70 or 80 18 days that would be required before anyone could make a 19 significant, positive contribution beyond just trying to keep 30 up and learn something.
21 I think that puts a kind of relative concrete 22 floor, although we imagined such a person as had spent in 23 life in some of these activities, and already knew enough 8' that we didn't want to preclude the possibility that somebody as could be useful putting less time than that into it.
l
, , . -r , _ . , e _ . . - . - .. -
i 10-JoeW 349 1 We don't see.it as being very practical on the y
s ,)
s 2 whole, but we would strongly urge you to change your attitudes l 3 just a little bit in this regard. 'Does that answer your 4 question.
5 MR. SHEWMON: Yes.
6 MR. AHEARNE: This was another one of the areas 7 you know, which we had a fair amount of discussion and 8 debate. There is no explicit number in the report that here t
9 is the minir..um that a member has to agree to provide in order 10 to provide an effective member, but I think your principle 11 force is quite right.
12 We essentially are saying that there is a possi- ,
<~
(3) 13 bility of having less time spent, but as Chet also pointed 14 out, unless there is a fundamental change in the coverage 15 level of what you do in the areas you do work in, and how 4
16 deeply you go into it, then the only way you are going to get :
t 17 the same amount of work is to have other people s~ pend more, ;
18 and as you certainly know, if someone isn't carrying their i
19 weight, it isn't that other people just pick up a little bit; i
, 20 they have to pick up a lot.
i 21 But you have to look -- I think the report as a 22 whole, we attempted to have this report be a whole, and so 23 when we say you _can have people spending less time, it is ,
t
~'s 24 with the assumption that some of the other items are also !
N_/
26 addressed, namely the different focus in particular less l
l
$-ll-JoeWal 350 1 digging in great depth, in some areas.
\ss/ 2 As Homer points out, managmement committee which 3 tries to focus more clearly where are efforts to be spent?'
4 So, it does have to be seen as a whole rather 5 than can one piece of the recommendation stand by themselves.
6 MR. WARD: Let's move on to the next chapter.
7 MR. MUNTZING: All right. Homer, stay right 8 here.
9 Chapter 7, the autors are Homer Hagedorne again, 10 and Jim Hubbard.
XX INDEX 11 MR. HAGEDORNE : This chapter deals with a few 12 simple and homely aspects of communication and a few other
<~w
( ) 13 operational matters. I am sure you recognize that we are 14 all for consensus, but we are suggesting that consensus 15 building be more of a means toward the end of what we call 16 issues clarification, than an end in itself.
17 That the days when consensus for its own sake, 18 in order to provide a truly unified view of some safety issue 19 had in one sense passed.
20 The commissioners would have to finally come out >
21 with that kind of view now. And, if indeed that what it is 22 dhat you do that can be most useful is to express what the 23 uncertainties are about, what the disagreements are about,
~
24 what really is unified in view of the technical community 25 about some of these issues, you can make those clarifications, i
I
$-12-JoLWnl 351 1
That is a huge step in the right direction, and an extremely
/ \
(- / 2 useful product in itself, and there is no device better than 3 consensus building to try to get those kind of things sorted 4 out.
5 We talked quite a bit about the letters. And 6 that is where the question of oral communications really 7 comes up.
8 Where people on the committee feel strongly about a some particular issue diat is embedded in a letter to the 10 Commission, it was our thought that you ought to pursue 11 -that, and make sure that the Commission knew how strongly 12 some of you felt about it by asking for a chance to discuss i l
~
13 it with the Commission after they had your letter, and that 14 that might emply not that the entire committee went to see 15 the Commission on that particular issue, but that only a I
16 handful . We kind of describe who those people might be.
17 We are making a series of suggestions here about j 18 examining what it is you intend in those letters, suggesting
> s e
19 that times have changed in enough ways that it is important 30 and possible to make the letters a good deal more compre-21 hensible than most of their readers seem to find them a lot !
22 of the time, and are suggesting also that in your relation- i
%I ships with the NRC Staff that if the majority of the
/ 24 - Committee will excuse me, you be a little less prophesorial. l
(.s [
25 They aren' t your graduate students. ;
i i
r
k-13-JoLWal 352 1 One of my colleagues thinks I need to explain 2 that, and one them thinks I don't need to explain that.
3 (Laughter.)
4 MR. MARK:
But supposing, just for the sake of 5 argument, we found a Staff member saying dumb things. What 6 do you suggest one do?
7 MR. HAGEDORNE: Well, it is almost more in the 8 way you do it than what you do, and it depends on circum-9 stances. If he is clearly the wrong person to be there, 10 he is not there as a volunteer, somebody sent him.
11 It is important to deal with the person who 12 sent him. Don' t beat up on the messenger in a case like
/~TI 13 that.
14 On the other hand, he is the one that ought to be is the one who can speak clearly and knowledgeably about 16 some issue and he isn't, of course you should disagree with 17 him, and of course you should express yourselves.
18 What we have observed a little of is the kind 19 of -- again forgive me -- browbeating behavior that cerainly 30 doesn't do a thing for the willingness of the Staff to appear 21 here and to have free and candid interchange with you.
22 I_ guess I am sounding a little prophesorial
! 23 myself.
(" 24 (Laughter.)
(]' 26 ~ MR . WARD: Okay. Let's see. I think Dave --
N~
$-14-JoeWal 353 i
1 you had something you wanted to say? ,
2 MR. OKRENT: Well, I was going to say --
3 MR. WARD: You don't have to say it if you I
4 don't want: to. Go ahead. l l
5 MR. OKRENT: I don't think that that is the 6 reason the staff is less than candid when they come here.
'7 MR. WARD: Bill?
8 MR. ICERR: I must say I agree with your recommen-9 dation. I think we should listen to it.
10 MR. LEWIS: I want to agree with both of those 11 guys, disagree with each other, just to make things simple. I 12 But I think Carson has raised a very serious thing. Of course i 13 we sometimes browbeat the staff people, and of course 14 sometimes they are the wrong people to have come here.
l 15 On the other hand, there really is a deep problem.
i 16 Say things that are wrong. Our meetings are in the public 17 record, and if the things they say that are wrong go l 18 unchallenged, it is just not right for us to let that happen.
19 And that does sometimes show up as browbeating, 2 and I know some of us are meaner than others, and some l l
21 leopards have problems shedding their spots, others don't, l l
22 ' but there is a problem with our public record and keeping 23 it honest and technically correct.
24 MR. HAGEDORNE: We recognize that, and acknowledge
! 25 what you are saying.
l l I 1
I L
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-1 MR. REMICK: I just want to add that I strongly
/
( The thing I disagree is your 2 agree with the recommendation.
3 calling it prophesorial. I don't think I browbeat graduate 4
4 students. I hope I haven't, like sometimes we browbeat 5 the Staff.
6 MR. KERR: I would say that the doctoral student 7 at the big universities represents the last ventiges of
- 8 slavery in the United States.
! 9 (Laughter.)
I '
10 MR. MUNTZING: We have one last chapter, and 11 Mike Bender and John West were the principle authors.
12 John?
i XXX 13 MR. WEST: Sorry Mike couldn't be here. He
! 14 would have a better way of summarizing -this Section 8 than !
) 15 I, t
16 It is actually a fairly long section, and I 17 would rather not sumarize it. I didn' t even summarize i
18 Section 3, but touched on certain items.
19 Have all or most of you read Section 8?
- 20 MR. WARD: You could just leave i to questions
! 21 if you like?
22 MR. WEST: I wanted to make just a comment or 23 two. We conducted a number of interviews, and you know that, 24 and some of the people raised'the question and reminisced ;
26 a bit that the ACRS used to be a wonderful body. They were [
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- 5-1-SueW 1 But it was done, and we thought about that i
.T (' '
s/ 2 quite a bit. Is that an incorrect conception on their 3 part? Are you making as many contributions as you ever j 4 did? And there is a gestation period. It takes a while 6 for things to be accepted,' soaked in and recognized.
6 We don't quite know, and I don't think we came 7 down with anything like a comfortable opinion with regard 8 to that. But you know, without me telling you I think, 9 that there is a fairly prevalent opinion, if you go out 10 and contact the people with whom you interface, that you are not doing what they think you used to do, not doing t
11 l
12 all the things you should do.
l () 13 This gets a little bit back to Section 3.
14 Sometimes it looks to other people that maybe in the 2 process of trying to cover everything, you don't do a t
16 really superlative job on anything. I'm putting it in 17 as plain a language as I can.
18 But that seems to be something that comes 18 through, that if you concentrate on the major issues, the 30 things that you are good at -- and there are plenty of 21 them. This is a highly regarded body.
22 It has capabilities that you find either not 23 at all or not concentrated and organized like this one 24 is. So, you could be a real leader. And whether you 25 used to be and lost it and have to regain it or not, I'will i
357 L
- 5-2-SueW 1 leave for you to ponder. But we think you clearly have s
ws 2 been a valuable organization and still are, but have made 3 -some suggestions about how your contribution could be 4 more valuable, or at the very least would be perceived to j
-5 be more valuable.
6 And I think it's not just a matter of. perception.
7 And in trying to provide advice, as we've talked about so 8 many times, advice should be to the. Commissioners. But 9 I think one of you mentioned that sometimes you may have 10 to tell the Commissioners what they need advice on.
11 And I would be surprised if that weren't the l
12 case. They don't know as much about reactor or nuclear
() 13 safety as any of you do, except maybe -- well, I won't 14 mention names, but there are some people there that know is quite a bit about technical. safety, not very many.
16 Just one, I guess, further thought. Be a 1
17 leader. And think boldly. There are new things that i 18 come out that should be very interesting to safety bodies a
i 19 like you. The source term, you all know about. But
. 30 what are you going to do about it?
21 I think you could do a lot with some useful 22 advice. And, although I wouldn't want to predict that i
- this is a hundred percent probable outcome, the possibility '
+
4
(%
8' of a breakthrough in reactor safety, taking advantage of i d 36 the information related to the source term, such that a f
358
- 5-3-SueW 1 nuclear plant could be viewed as insurable, onsite, risky (3
\-) 2 Project rather than some thing that the public has to get 3
involved in evacuation procedures where, on the one hand, 4 they are told nothing to worry about and on the other hand 5 they are given a revised evacuation procedure every few a months.
7 I think there is a possibility of getting rid a of. genuine public concern, and that is something that a 9 cosmic body like this ought to look at.
10 And on research -- we touched on that a little 1
11 bit earlier -- I believe you should certainly be concerned 12 about research needs to be done and whether it's being f
) 13 done properly. But, consistent with our other recommenda-14 tions, don't burn yourself with a lot pendatie things, 15 look at the big important things.
4 16 And then the ACRS will be viewed with admira-17 tion on almost all that I remember some time ago.
18 MR. MUNTZING: John, let's see if there are 19 some questions.
30 MR. WARD: Yeah. Are there questions for John?
i f
21 Bill?
t 22 MR. KERR: Did it occur to anybody that one of 23 the reasons this Committee is not doing as much is because !
24 it previously has solved all the important problems?
2 (Laughter.)
i
359
- 5-4-Suew 'And there are none left to be dealt with, t
2 MR. WEST: I think I heard one or more remarks 3 of a semi-cynical nature. But it was mostly with regard 4 to the NRC, if we can have a little fun here.
5 (Laughter.)
e The idea was if you have X people, they are 7 going to come up with live problems everyday. And as a they solve all the old problems they are going to como up s with some new ones.
10 But I think in the case of at least ACRS, most 11 of us feel that the backlog of important problems -- and 12 I underline important problems -- is so creat that you
() 13 fellows will-never run short of anything to do if you 14 really concentrate on those, really concentrate on the H5 hard ones.
16 MR. WARD: Glenn.
17 MR. REED: I think what Mr. West has said is 18 very, very fine. I think the thread through this panel le report is a fine thread and a wonderful one.
SD And it relates to leadership. If we develop 21 more leadership along the cosmic issue line, then in 32 - my opinion the nuts and bolts and problems and issues 33 will work out more for themselves and not have to cause 24 our attention to be diverted to them.
- MR. WARD: Thank you.
I
3 o 360
- 5-5-SueW 1 MR. WEST: Thank you, i Well, Mr. Chairman, that is a
\s / 2 MR. MUNTZING:
3 brief overview of the final chapter we have been through.
4 Herb Kouts and I were the authors of that.
5 I would also like to say that we owe a great 6 deal to Herb, who took all the products of the different 7 authors and made it look like a cohesive whole --
e (Laughter.)
9 Are you going to rebut that?
10 MR. KOUTS: No. I just want to say that I 11 studied at the knee of Hal Lewis.
12 (Laughter.)
() 13 MR. MUNTZING: Well, we think the ACRS has made excellent contributions in the past and should and 14 is will do so in the future to the safety questions.
16 We have enjoyed looking at it. I might say 17 that as one looks at an issue such as this it sometimes 18 tends to be -- appears to be sort of critical and negative.
19 And, in fact, we are making recommendations for improve-30 ments so it carries that connotation.
21 But, on balance, I think I speak for the panel 22 when I say we certainly found a great deal more on the 23 positive side than the negative. And we simply wanted 24 to help accentuate the positive so that the future would 26 be as the past has been, excellent.
I t
361
- 5-6-SueW 1 Thank you.
(s-'/) 2 MR. WARD: Thank you, Manning. We don't want 3 to take much more of your time. And one of your comments 4 was that we shouldn't keep the Staff waiting by letting 5 the agenda slip.
i 6 So, I think that's a good point.
f 7 (Applause.)
.8 Let's take a ten minute break.
1 9 (whereupon, a recess is taken at 10:28 a.m.,
10 to reconvene at 10:40 a.m., this same date.)
11 MR. WARD: Our next topic is a briefing by 12 Mr. Harold Denton, the Director of the Office of Nuclear 13 Reactor Regulation, on the reorganization that he has 14 planned and has underway of his important office.
15 Harold.
INDEXX 16 MR. DENTON: Thank you, Dave. We have had a 17 desire to change NRR for about a year and have spent about is that time looking at ways to reorganize to prepare for 19 the future. ,
So The main driving force for changing is the i
21 recognition of the fact that the work load has changed.
' 22 And I've handed out some handouts. And what I will do as 13 - propose to go through them. Everyone has this package 84 perhaps.
26 I wasn't going to read them, but I was just l
L.
362
- 5-7-SueW 1 going to talk from it. .For example, there are only about p
l Y- 2 ten cases for full power licenses left to come to the 3 Commission, I mean to come to the ACRS. There are about 4 ninety-five plants now in operation.
5 You have done a great deal of review of our 1
6 SERs. And our whole work load is shifting from that of ;
7 processing construction permit applications and operating 8 licenses to dealing with operational problems.
9 We have been in a matrix organization. The 1 10 matrices corresponded roughly to the chapters in an 11 application, and we find that sort of organization just
- 12 is not that effective to deal with operating problems.
() 13 It seemed to work great for reviewing applica-14 tions, where the application was split into fifteen parts, f
1 is each part went to a branch and they knew exactly what to a
16 review, and it all came back together.
- 17 If you look at the first slide, you will see 18 the number of plants that are still under review for
' 18 operating licenses is very small. And, in fact, the number 88 as I mentioned coming to you is smaller.
21 Still, we've had a change in the disciplines I 22 required. You need some types of disciplines to do re-6 23 views, you need another type to deal with operating problems .
84 Another major factor is that the industry is l )
88 And you will find a strong I organized along vendor lines.
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363
they tend to work along that line and standard designs 3 for getting along vendor lines.
4 So we saw a great deal to be gained by organiz-5 ing ourselves more along vendor lines. I've got some i 4 6 examples of recent Owners Group activity, but we are
- 7 working with Westinghouse on the integrity of pump seals s during a station blackout, Westinghouse with regard to g- equipment qualification in the event of steam line breaks.
I 10 GE, of course, we are working with them on pipe cracking l
! 11 sort of issues.
f 12 Combustion Engineering and B&W, we are talking
() 13 about trip breaker performance. Overall, the amount of attention that the Staf f is giving to operating reactors 14 is is going up. The case work is going down. Safety t
16 technology-is remaining about the same.
4 17 If you look over at the slide labeled " Scenario is for the Future" you will find that by the end of ' 86, we ,
i !
Ig will be putting six percent of our Staff effort on operat- :
i j 20 ing plants, twenty percent on safety technology, and the j j
21 remainder on either new plants or on TMI cleanup.
I 22 So, we have directed this organization toward
- 23 vendors. Everyone is encouraging standardization, and ,
34 this would provide a natural home for standard plants to j t
25 fit into.
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364
- 5-9-SueW t Another real factor is our resources are not
! O J In fact, there is a great deal of
\d 2 likely to increase.
3 pressure on NRR to do its job with fewer resources. We 4
are down about a hundred FTEs from our peak of a few 5 years.ago. ,
6 When we go to the --
7 MR. MARK: Why is it necessary to plan to keep 8 on paying the attention to TMI?
1 9 MR. DENTON: We are diminishing the attention 1 10 to TMI as the cleanup gets better and better. We are 11 reducing the size of.the Staff.
12 And in 1986, there won't be as many people-() 13 assigned to that effort as there was in '85. We are 14 trying to cut it down as the cicanup improves.
15 MR. MARK: How about zero for '877 le MR. DENTON: We will have to look at it and
! 17 see how far they have come. They have made a lot of 18 progress.
19 I was up there a few weeks ago, and standing 20 on the platform that is being built to do the cleanup, 4 21 dose levels in that area are down to 15 and 20 millirem 22 an hour. And lots of tools have been developed.
4 23 We are still very interested in seeing how some 24 of these tools and the cleanup actually moves.
l 26 Let me talk about the objectives of the i
f
I 365
- 5-10-SueW g objectives of the proposed organization just briefly.
3 That's a few slides in. Of course, we've got to continue i
3 to complete the existing OL reviews. That's in the i
4 Commission's PPG and the program goals that I work under.
5 We have got to provide for contin'ulty of the a reactor reviews that are underway and safety issues where we have made a lot of progress. It needs to be an organiza-
, 7 i e tion that should stay in place for.maybe another four or i e five years.
1 10 The matrix organization has existed for at 1
- 11 ~ least a decade or longer.
! 12 We need to increase the operational expertise
() 13 on the Staff, because more and more problems come in the area of maintenance and testing. These sort of areas as 14 4
un opposed to a fundamental design sort of review. -
i 16 We are going to separate --
! 17 MR. WARD: Harold, could I ask you a question 18 about that increase in the operational expertise?
l 19 How is the reorganization per se helping you 30 do that?
21 MR. DENTON: Two ways. We are going to allow l
te people to concentrate on a type of reactor instead of I t
23 having people in the branch like, say, Mechanical Engineer- [
l 34 ing, spread over all designs. I hope that by specializing ;
l ~~
- by vendors they can become better.
i i.
366
- 5-ll-SueW 1 Plus we are creating vacancies in the organiza-
~
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\l 2 tion and are going to recruit people with SRO type ex-3 perience in those areas. So, we have made special 4 vacancies to get people into the organization who have 5 actual operating expertise. That's always a tough battle, 6 but we are trying that.
7 Under shorten line of authority and responsibility ,
8 we are going to enhance the role of the project managers.
9 It is a feeling that the project manager doesn't have 10 sufficient authority to set the priorities on these plants 11 or that he is not close enough to upper management to 12 really get the attention that he needs.
/G
( ) 13 And another facet of this is an administrative 14 matter. We are reducing the amount of management over-15 head, that as my staffing level went down I didn't change 16 the structure so I ended up with fairly high overhead.
17 This gets me back down to a lower overhead of managers 18 to workers.
19 We also had some branches that had gotten 20 fairly large. I think the largest branch was up to about 21 forty people. We had some branches that had dwindled to 22 just a handful of people, because the need for those 2 types of skills was going away.
24 And what this will do is, I intend to give
(~'3 C'
M sufficient people and dollars to each unit so they can
1 1
367 l
- 2-SueW 1 handle problems in their area without having to form up 2 task forces. During the past several years, we've had 3 to put together special task forces.
4 If you turn to the next slide about the 5 functional responsibilities, what we are doing is 6 creating out of the existing staff three project divisions.
7 Each project division is going to be dedicated to a certain 8 type of plant.
9 So, we've got one project division that has 10 all the resources they need for Westinghouse type plants.
11 That means both the project managers and the technical 12 staff.
7
( '
13 Another likewise for GE plants. Another for 14 B&W and Combustion type.
15 So we are dividing up the Staff so that each 16 group should be able to function and have internally 17 under their direct control, and someone I can hold 18 accountable, for problems that come up in that area.
19 We are going to maintain the Division of Iluman 20 Factors, because I think that is still an evolving area.
21 They will continue to be responsible for operator licens-22 ing activities, human factor design issues, tech specs, 23 maintenance issues, surveillance, these sort of things i 24 that we have given increasing attention to over the past 25 few years.
368
- 5-13-SueW 1 The Division of Safety Technology is being 2 renamed the Division of Safety and Oversight. That 3 group will be the forward looking group. We are putting 4 about twenty-five more people in that group than are 5 there today.
6 So, their -- they have basically three jobs 7 now. They will be the technical focal point for all 8 major technical subjects. That is, changes through 9 regulations, to pick up ASME-Code changes, or their focus 10 for PRA, for Part 20 changes.
11 So, in any new evolving NRC or NRR requirements, 12 that's the group that has the key role. They are also
- m
( ,
) 13 in charge of implementing the severe accident policy, 14 safety goals, severe accident phenomenology, resolve 15 safety issues.
16 Basically, that's the group that resolves the 17 difficulties that are on the table. And I think you will 18 be seeing a great deal of that group in the future.
19 A third very important role they have is over-20 sight, to assure that the other three groups are not get-21 ting too far out of line with the way they implement 22 policy in each area. So, they are also in charge of 2 providing me the assurance that the other three are
~, 24 functioning consistently in a technical manner.
25 If you go to the first sort of block chart,
1 369 A
- 65 1 it's organizational, the people are all people that you r ,14-SueW
^
%- 2 know. Hugh Thompson who has been in charge of the
- - 3 Division of Licensing is being assigned the Group-A 4
4 which is the Westinghouse group.
5 Bob Bernero will be in charge of all boiling 6 water plants.
7 And Frank Miraglia will be in charge of all 8 CE and B&W plants. He will also have ISAP responsibility
(
9 in special projects such as research reactors.
! 10 Themy Speis continues as the Director of
~
i 11 Safety Review and Oversight.
J 12 Bryan Sheron becomes his Deputy.
( 13 Joe Russell continues as the head of the 14 Division of Human Factors, and Dennie Ziemann is his i
15 Deputy.
16 I will go through these pretty fast in order 4
17 to stay within the time frame.
18 The next chart shows how it breaks down within 19 one group, for example. And if you notice, on the left 80 of the group we've got five project directorates and no 21 assistant directors. This is to make it clear that the j 22 role of the project manager is enhanced.
i !
! 23 He is closer to the division director. Wo i
24 have put an assistant director on the technical side 26 figuring that needed more pulling together. The span of 4
370
- 5-15-SueW 1 control also was getting too large for one person to
,- \
xY 2 supervise.
3 Each directorate then has those plants which 4 have a lot in common. They are either plants -- let's 5 take Group Number 1. They are the older, smaller 6 Westinghouse two-loop plants. So if you look in the 7 first group, you will find Yankee, San Onofre, groups 8 which have a natural -- they were designed in the same 9 time frame and they have a lot of features which look 10 alike.
11 So, I hope that by combining these things in 12 such a fashion the group can stay on top then of that
/-
(m) 13 class of plants and can learn more about that one class 14 and become the NRR experts in problems and performance 15 in that class.
16 And they would be the one I would look to for 17 any problem in a two-loop Westinghouse plant. I would 18 look to Number 1.
19 They also would be setting the priorities for 20 the technical projects that are done by the technical 21 side. What are the real technical issues? What do we H want to do in the next year with that group of plants?
23 And they would be the technical side, who has
("') 24 got all the capability they need to support it to provide t
'n .J.
25 those services.
l
371
- 5-16-SueW 1 The technical groups continue to be quite large t/ 2 and the big groups. And Engineering Branch, for example, 3 has containment design, mechanical engineering, they 4 retain the effort that we are putting into seismological 5 aspects, for example.
6 MR. LEWIS: How many people will there be in 7 each engineering branch?
8 MR. DENTON: We have tried to keep the branches 9 about the same size. Let me ask Drew if he knows how 10 many are in a typical branch or Jesse.
11 MR. FUNCllES : Yeah. There is twenty-one in 12 the Engineering Branch. That's the largest one. So, it (D would be in the range of fifteen to twenty.
() 13 14 MR. SIESS: liarold, the geoscientist people 15 would end up where?
16 MR. DENTON: They would end up just a -- we 17 have more than is work load, number one.
18 But we would be putting some of those people 19 into the Engineering Branch. So, each Engineering Branch 20 would have a few specialists in those areas.
21 MR. SIESS: And then that's the only places 22 they would be, or would some of them be in Safety Review 23 and Oversight?
24 MR. DENTON: Safety Review and Oversight would 25 then have the people working on unresolved safety issues
372
- 5-17-SueW 1 or the adequacy of seismic design today. But the day-to-day
/
\- >J 2 activity of coping with, say, ice floods on the Ohio --
3 ice flows, and that sort of thing, would come out of 4 this --
5 MR. SIESS: And a geoscientist includes your 6 geologists and seismologist?
7 MR. DENTON: But not a lot. Very few in each 8 group, because that's not an operating plant so there is 9 very little need for such skills.
10 MR. SIESS: Well, where are the rest of them 11 going to -- not be there or are they going to be somewhere 12 else?
() 13 MR. DENTON: They --
14 MR. EISEN!!UT Can I answer part of that, lia rold?
15 I think the general philosophy was to follow the lines to that liarold laid out, that where it can be split up, 17 that there is a routine function the three projects could 18 do, we would split the function.
19 Yet, at the same time you always need to 20 maintain --
21 MR. SIESS: Yeah.
E MR. EISEN11UT: The Leon writers of the world 23 have to have a home. And those kind of disciplines where
(~) 24 you keep the experts, those end up in GSRO. So that
\ __/
25 there is a home to turn to if you have --
373 65-18-SueW 1 MR. DENTON: But we have not -- the Commission O 2 has approved the reorganization but it has not been put 3 into effect yet, because there are some --
4 MR. SIESS: Okay. I see.
5 MR. DENTON: -- personnel issues still to be 6 worked out, because we have excess skills in some areas 7 and we have vacancies in others.
8 MR. SIESS: If I wanted to know where the 9 structural people were, can I eventually find out that 10 some of them will be in the --
11 MR. DENTON: They will be scattered among 12 the --
() 13 MR. SIESS: -- project directorates and some 14 of them will be in DRSR or whatever you call it?
15 MR. DENTON: Yes.
16 MR. SilEWMON : This means the materials people 17 are ended up, the number you have now, divided between 18 four places, the three engineering group and presumably 18 there is somebody in GSRO, is that --
20 MR. DENTON: Yes, let me explain that.
21 MR. S!!EWMON : That's dividing eight people M pretty fine.
23 MR. DENTON: No, it turns out to be seventeen.
', 24 MR. SilEWMON : Seventeen materials people?
25 MR. DENTON: We went through, what do wo need
374
- 5-19-SueW 1 to cope with tomorrow's work load? That was how the 2 organization was started. What are the types of 3 operating actions coming in? What are the unresolved 4 safety issues? What are the generic issues?
5 And what types of skills do we need in '86, 6 '87 and '89? That's where we really began to identify 7 the skills. And then we have a lot of people who are 8 classified materials engineer or metallurgical engineers 9 who may not be working in that today, but who have that to as their discipline.
11 So, we have taken the job classification of 12 people and matched it up to that which we need. And I I 13 think we did end up with something like seventeen people 14 in that category. So, they are placed in each division 15 plus safety technology according to how much skill in 16 that area is needed.
17 It does get away though from having who in 18 in charge of DWR pipe cracking. It is not the metal-19 lurgical engineer por se; it's Dob Bernero for GE pipe 20 breaking as the person I hold renponsible, and I've 21 given him people and dollars to solve that problem.
22 Dut if you vant to talk about new fracture 23 mechanien approaches, you go to Dob Donnak. So, the
( )
24 forward looking component in each discipline remainn 25 within the specien group.
375
- 5-20-SueW1 The names of the branches are fairly descriptive b t and each group has the same elements in it to support a their type of plant based on the number of plants they 4 need and that sort of thing. But just to give you a feel 5 for that first group, I've got a list of all the plants e in there. That's Ginna, Kewauneo, Point Beach, Prairie 7 Island, San Onofre and Yankee, for example.
8 You will find in the GE plants they are clumped 9 by, are they MARK Is, MARK IIs, and MARK IIIs. And I 10 think that will enable us that when we impicment new 11 resolutions of issues, to really know who is in charge 12 of implementing it, whorc does it go and where doesn't it la go.
14 MR. EBERSOLE: Mr. Denton, may I ask a question?
Hi- Where I would find on any one of these plants the party le who would be in charge of system integration?
17 MR. DENTON: System integration remains in 18 Themy Spics ' group. That's a USI, it has a project 19 manager, and he has all the peopic --
30 MR. EDERSOLE: Even though it's on onu project?
21 MR. DENTON: Yes.
28 MR. EBERSOLE: Okay.
88 MR. DENTON: Maybe I didn't understand your N question.
88 MR. EDERSOLE: I say, system integration, for
. . . . - . _ _ . . _ _ . _. . _ _ _ _ _ - _ _ - . _ ._ . _ _ _ .. . _ _ _ _ _ _ _ - . - .__m 376 i
,45-21-SueW 1 instance, at one project.
2 MR. DENTON: Oh, you are talking about -- you ,
3 are not talking about'the unresolved safety issues?
f 4 MR. EBERSOLE: No, no. I'm talking about 6- system integration.
4 6 MR. DENTON: Oh, system integration is -- L 7 MR. EBERSOLE: A case in point, we found CO 2 i
$ 8 systems weren't compatible with building structural i 9 strength.
f 10 MR. DENTON: I'm trying to build that role to i i l 11 make the project manager the person responsible for all i
)
12 aspects of his project.
1'
() 13 MR. EBERSOLE: So, there is a project manager r~
i 14 that would be in charge of system integration on his >
1 15 project?
i 18 MR. DENTON: Well, he would be in charge of [
l 4
17 everything on his plant. In other words, he is someone li I
1 18 that I can hold accountable for the safety of that plant.
! 19 And it's his job to bring to bear all the 3D disciplines that we need.
1
, 21 MR. EBERSOLE: He has got to be a lot more i
i
- than just a social chairman, then. t 1
f
- 33 MR. DENTON
- That's right. l 1
i 94 MR. SIESS: Are you going to expand on the 36 project manager role, because I'm more interested in that i
- i
377
- 2-SueW 1 than I am in the project director role.
2 MR. DENTON: Let me flip through maybe the next 3 two or three and then we will come back to all of them.
4 The one that -- the smallest number of plants 6 are the CE and B&W group, so in that area we gave other 6 activities, such as the integrated safety assessment and 7 the TMI cleanup comes under that because it's a D&W plant.
8 And as I mentioned, special projects, coordina-9 tion with the navy and that sort of thing.
10 Let me go to one of the back slides, second from 11 the back, is Themy S.pcis ' division. Zoltan Rosztoczy 12 becomes in charge of implementing the source term and lie will be in charge of the
( 13 severe accident activities, 14 interaction with INPO.
15 Frank Congol assumes the Risk and Reliability 16 Assessment Branch. lie keeps responsibility for Part 20 17 and that kind of thing.
18 We used to have just one branch on unresolved 19 safety issues. This time we have two. Warren Minners 20 is in charge of all the reactor safety issues, generic 21 issues, USIs, plus the oversight of the other three if 22 they hit reactor systems.
23 Bob Bosnak, who you know, is in charge of
( )
24 the Engineering issues; and Karl Kniel is in charge of 25 our Research and Standards Coordination, changing standard
378
- 5-23-SueW 1 review plan, the EPRI standard plant review that we talked r~
s/ 2 about that was mentioned earlier;today.
4 h, 3 And the last slide --
4 MR. REMICK: Let me ask a question. You 5 mentioned that.Zoltan would have liaison with INPO.
6 Would that be in the accreditation area?
1 7 MR. DENTON: No, that would be Bill Russell.
l 8 And the last slidenis Division of Human Factors. We have l
9 taken Human Factor people and put them into each one of 10 the vendor shops, so there is a few people who can review 4,
a' 11 procedures and are familiar with human factor type issues.
i 12 We keep operator licensing in Human Factors.
That program is regionalized anyway. You know, there are
!() 13 14 very people in Headquarters to oversee the regional is In fact, that's one of our few programs that activity.
16 is completely regionalized.
i
! 17 The Human Factors Issues Branch, they are the 1 6 j 18 ones who review control room design,' developing better ;
i i 19 generic procedures.
20 The Cleaning and Maintenance Branch is a d P 21 group that'is trying to look behind the type of maintenance i t 22 and testing and surveillance that is done today. l
!- 23 And'we are putting the Tech Spec Branch under 24 - Bill, because that's the.most natural tie. You know, 25 yeve had a group looking at Tech Specs and I will have a ;
i i
,..n ,n- -
r - . , . . ~ - - - - , . - . - - . - - - - -,,---,.e , ,-,- -,- , , .,-,-n,.. --.--,er., -
n--- .---,.--nn, ,
379 65-24-SueW1 report on a new approach to Tech Specs by the end of this 2 month.
3 So, in a nutshell, this is the scheme we have.
4 It has been widely supported by all the managers who were 5 getting increasingly frustrated with the level of coordina-6 tion that had to go on in our matrix organization. I 7 thought the matrix organization was the greatest thing 8 around five or six years ago when we put it into effect, 9 but the level of coordination that has to occur in the 10 competition for resources has gotten to the point where 11 if you can't find how it's a mistake.
12 MR. SIESS: Two questions and one general.
j '13 Where does advance reactors end up and where does Fort 14 St. Vrain end up?
15 MR. DENTON: Advance Reactors ends up under 16 Themy Spies. In other words, all new designs like the EPRI effort 17 coordination will be under --
18 MR. SIESS: That's in DSR?
19 MR. DENTON: Oh, yes. So, that's the forward 20 looking --
21 END # 5 Joe flws 22 23 24 25
6-1-Jo3Wal 1 MR. SIESS: Under which' branch?
y
(%-) 2 MR. DENTON: I believe it is under Karl Kniel, 3 Advance Reactors.
4 MR. SIESS: And-Fort St. Vrain comes in there 6 as an operating reactor?.
6 MR. DENTON: I don't think so.
7 VOICE : It is in special projects.
8 MR. DENTON: The distinction being if it is a 9 project then. an application has been submitted, and the to standard review plans are in place, it goes into that group.
11 MR. SIESS: This is an operating reactor.
12 MR. DENTON: This is an operating reactor, so 4
( 13 it falls within an operating line.
14 MR. SIESS: Now the general question. Who do 18 we go to now to find out where something is, and who to 16 talk to. You -- have you designated somebody .who knows 17 all of this, and when the ACRS has to hold a meeting, we la will know who to talk to?
19 MR. DENTON: I think you would have your staff 30 go to our Coordinator, Ron Hernan.
21 !!R. SIESS: That is what I wanted to know.
22 MR. DENTON: And With tim 6 it?should be clear SS again.
24 MR. SIESS: And in a couple of years he will know 26 where everythina s.
t.
6-2-JoeWcl 381 1 MR. WARD: Carl, and then Dave.
l
- 2. MR. MICHELSON: Yeah. You show here an operator j 3 reactor's assessment staff.
1 4 Could you tell us just e little bit of how many l
! 5 people are in it, what does it do, how does it relate to the t
6 rest of daat division, and how does it relate .to the rest of l 7 those activities in the agency?
i 8 MR. DENTON: That group has human factor people .
i i
i 9 in it, for example, on standard procedures, and how the 10 operators should act, and that is where I hope to get' j 11 experienced former. reactor operators into that branch.
f 12 MR. MICIIELSON: The operating reactors assessment ,
w 13 staff, .which is shown on the organizational chart.
14 MR.. WARD: Where is that?
H5 MR. MICHELSON: It is in the Office of Nuclear 16 Reactor Regulation, about in the middle of this package.
! 17 The first slide.
J HB MR. DENTON: That is the group that I am going i 19 to rely on to keep me informed about current problems that 30 I need to direct resources and make decisions.
21 It is the same group that does that job now;. they 23 interact with I&E and AEOD, and they run -- we meet every 23 week,- and this group puts on a presentation on _ what is i-24 happening in every plant-in the U. S.~during the past week, ,
p 25 and based on - that we managers decide what else- needs to i be l
I___________._.... _ . _ . . , _ _ . , _ . _ . . . . _ , . _ _ , _ . ,
6-3-JodWal 382 1 done, or where we need to direct resources.
2 MR. . MICHELSON : Is there a staffing --
3 MR. EISENHUT: Total staff, I think with the 4 branch chiefs -and the secretaries .and everybody, it is 5 about 15, so there are about 12 technical staff, I believe.
6 MR. MICHELSON: Just a little bigger than what 7 you already have in that area is all.
8 MR. EISENHUT: It is essentially the same group 9 that we have, and it is basically Gary Holahan and the 10 same people for continuity.
11 MR. DENTON: You know, we have always had the 12 operating staff split around the agency. There are
.(m t
) 13 fire fighters, I would say,- in' I&E for immediate response.
14 But then any time the instant response center 15 gets activated, Mr. Holahan gets called, and he calls me i 16 to tell me what is going on, and then the AEOD effort is 17 a longer term.
18 So this group functions for us in sort of that mid-19 time-frame group who responds to generic issues on plants, not 30 in the ' time frame that I&E does, and not in the time frame 21 the AEOD does.
2 MR. MICHELSON: And I guess it will function in 23 relationship to your project managers like it is presently N 24 functioning.
i (b 25 The project manager is still kind of the lead i
I l
6-4-JosWal 383 1 Person, f%
s- 2 MR. DENTON: This provides me a little staff 3 to make sure that we are doing things properly.
4 MR. MICHELSON: The 15 clarifies my concern as 5 Opposed to a hundred or something.
6 MR. DENTON : And I had thought of putting them 7 into the human factors group ultimately, but I felt like s with the shuffling that is going on, I didn't want to lose 9 any of the issues that are presently on the table, so I will 10 keep it reporting to me until things get stable, but then 1 . 11 we might well put it under the human factors organization.
, 12 You had asked about project managers. I think (s,/) 13 this raising the status of ' project managers is one of our 14 number one goals in this.
15 We need a person who is a project manager who 16 does this integration function, because otherwise we have 17 sixteen, or twenty-five diverse technical people, all wanting 18 to do various things, and I guess the Davis-Besse event was {
19 a good one where in order to avoid hydrogen line breaks we f 20 had racked out the breakers for a pump. ;-
21 Well, if you stand back and look at that in an 22 integrated fashion, you would have to say which was --
23 MR. EBERSOLE: Well, you impose on him, however, fg 24 a technical burden which many times managers don't care.
, b 26 MR. DENTON: And it is not going to change over :
l i i t
6-5-Jo Wnl 384 1 night, but by enhancing that role, and giving it more
- fm, management attention, you will find people volving into l
) 2 3 that group who maybe in years in the future can do it.
4 I would love to have people in there who were 5 the project managers of the' type that Milt Saul used to have 6 back when they were project managers in his program.
7 MR. EBERSOLE: Will we get an expanded version 8 of these blocks sooner or later?
9 MR. DENTON: And we can give you the breakdown.
10 Wa are negotiating with the union now on some of the 11 intricacies of people reassignments, and I expect it to all 12 be in place about the end of the month.
j 13 MR. OKRENT: 'Did I hear you say you would love
{G' N, 14 to have project managers of the type Milt Saul had?
15 MR. DENTON: Yes.
16 MR. OKRENT : That is what I thought you said.
17 (Laughter. )
18 MR. DENTON: The few I know are Tom Early, and 19 individuals like that.
30 MR. MOELLER: Since the overall goal, of course, 21 is to protect the health and safety of the public, I was 22 somewhat surprised not to see a focus for radiation protection, 23 or maybe it is here and I overlooked it.
24 MR. DENTON: There is not a focus any more on
)
's / 25 a branch by that. Each vendor group has health physicists 9 -
.- . . _ . _ ._~ - . .-
. 6-6-JonWal'- 385 l
1 in it, and DST will have the coordination for new changes j
-'s
\/ 2 in Part 20 and that kind of thing.
3 It is not a demunition at all, and I was somewhat 4 worried that every one of those technical branches I had 5 you know has an important role, but we -- there is not enough 6 need for health physicists to create a branch and have eight 7 or ten health physicists per vendor, so they are in there 8 in one of the existing branches.
9 ME. MOELLER: So, each division has health 10 Ph ysicists, -- not every branch, but --
11 MR. DENTON: Each division has health physicists, 12 and let me ask someone who knows which branch they are in.
) 13 MR. EISENHUT: I think we put the HP folks in tne 14 Plant Systems Branch, because we have seen the situation 15 where on one hand you set up the expertise of having an HP 16 group that worries about radiation, yet on the other hand 17 you have the plant systems people - doing things to the plant 18 that actually cost a lot of man rem exposure.-
19 We put it in each division so that it is sort 20 of integrated into the technical groups.
21 MR. DENTON: So, they are in the plant system 22 branch in each of the vendor groups, and then they are in 28 - Frank Congel's group.
'*g 24 MR. MOELLER: And who maintains like liaison 25 with IfiPO, the NCRP and so forth?
l i
l l
- ~ . , _ _ -, -
6-7-Jo WD1 386 1 MR. DENTON: That would become Themy's responsi-
\w ' 2 bility in this organization.
3 We have made a big push on trying to get exposures 4 down in plants, and we are going to continue that. But 5 I think the whole trust of this is to get a more integrated 6 approach.
7 I was out at Davis-Besse recently, and very 8 impressed there that the dose rate inside the containment 9 was less than -- was about 1 mr an hour. It shows what 10 you can do.
- 11 MR . KERR
- That was with the plant not operating 12 that day.
() 13 MR. DENTON: Yes.
14 MR. WARD: Carl?
15 MR. MICHELSON: In the case of a matrix organizatior ., l 16 you are assuring cross-furtilization by putting certain f 17 specific subject areas in a single group, so that they can .
t 18 deal with how things are going on both boiling and pressurized 19 water reactor, or whatever the inner-disciplinary mix has i t
20 to be.
21 When you go into a vendor or an organization --
i 22 keep in mind in the old way you still had a project manager !
23 who worried about everything on that project, so you had j l
/'N 24 the combination of the cross-furtilization in one area with I h,
25 the project manager focusing on his project. ;
i e
_ , , _ _ m - .,
6-8-JoeWnl 387 1 Now, you have pooled -- put even more of the
- )
\~J 2 activity under the project manager, and you have destroyed 3 I think some of the cross-furtilization potential that 4 once existed with a matrix organization, so how are you going 5 to enhance it or assure that it is still continuous?
6 MR. DENTON: I think that will be Themy's job, 7 to have periodic meetings across disciplines to be sure that 8 say fuel pellet interaction and fuel design -are still being g handled consistently.
10 As you know, there is no perfect organization.
11 The problem with a matrix is'-- my staff told me they were 12 spending all their time coordinating, and just trying to
,y (y ) 13 schedule, and never getting any work done.
14 We have a large number of backlog actions that we 15 need to move out.
16 We are struggling to produce 2500 operating actions 17 a year on these operating plants, and this is what I hope will 18 provide a focus, plus when the owners groups come in, they 19 don' t know who to meet with any more in the matrix kind of 20 organization.
21 This gives them a clear focus, and if one of my 22 groups doesn't hate the resources, then it is all under his 23 perrogative to ask for more.
,'] '
24 MR. MICHELSON: I would like to say I=think this (v
25 looks like a clean way to do it. I just wondered though --
i
6-9-Jo Wal 388 1 I would have some concerns about the inter-mix.
t \
- 2 For instance, in the case that I am somewhat 3 interested in at the moment, valve operability, that is 4 across all the projects. Is Themy, for instance, going 5 to be worried about valve operability across all projects?
6 MR. DENTON: Any change in our present practices 7 have to go through Themy, so he is the one who will interact 8 with the CRGR, for example, do the cost benefit studies and 8 those kind of things.
10 But a new issue always goes to Themy, and we have 11 a branch over there where anything can be thrown over the 12 branch, over the transient, into Themy's group, and he
( ) 13 decides in the first instance: Does it require action by 14 us or not?
15 MR. MICHELSON: ,So that is going to be the cross-16 fertilization division, really.
17 MR. DENTON: That is right.
18 MR. MICHELSON: Thank you.
18 MR. WARD:
, I think we have time for one more 20 question. Well, two more. Forrest, and then Charlie.
21 MR. REMICK: -Harold, you mentioned a large number 8 of operating actions per year. Is there any hope that revised 23 tech specs will reduce the number of those actions that are r l
24 required by licensees? E
, (]N
\~-
25 MR. DENTON: It depends on where we come down, l
w e - w - r -
6-10-JoeWal 389 1 and how much we want to micro-manage changes.
~
x ,) 2 If we restrict the tech specs so they don't 3 contain as much, the licensee would have more freedom to 4 make changes under 50.59.
6 My own view is that we should make tech specs a less than 500 pages. They are beginning to defocus safety, 7 so I would hope if we do that, then they wouldn't have to be 8 coming to us for as many changes, but that remains to be g seen.
10 There are arguments in that field.
11 MR. WARD: Charlie?
12 MR. WYLIE: Where is the liaison with nuclear 13 research?
14 MR. DENTON: That is in Themy's group, - and it has 4
15 always been in there, and what they do, they collect up the 1
16 whole organization's views on needed research, and they 17 are the coordination point with research.
18 Bill Russell is the coordination point with IMPO is on all hunan factors activities.
20 The one other factor that was hard to define, and 21 it was interesting to think about'it while listening to the 22 previous presentation, most of the people in NRR have been n in the same job for a long number of years; at least five s 24 years in many branches, and.we all feel the need to do G
25 something different, and so if nothing else, what the
- 2 6-ll-JoeWal 390 1 they have done is assigned the science people a new area, 7
C 2 given them a chance to grow a little, and I wonder sometimes 3 if ZI haven't kept people in the same job too long and 4 the definition of what is good, acceptable performance kind 5 of gets flat, and that kind of thing.
6 So this in a sense shuffles everyone. Everyone 7 is very enthusiastic about it, and we will see how well it 8 goes.
9 If it doesn' t work right, we will change around 10 in a few more years, but at the moment I think the management 11 staff is excited about this, because it is clear lines of 12 authority, clear lines of responsibility, and it remains to f%
13 be seen whether it is actually more effective use of the (v) 14 resources we have or not, but we think it has a high chance 15 of increasing our productivity, making public health and 16 safety better.
17 MR. MARK: I am uneasy, but I don't know enough 18 to say it is a real concern. You have boiling water 19 reactors, pressurized water reactors, and in those divisions 20 you have a health physicist here, and a health physicist there, 21 and there is a meeting in Seattle to which the group should 22 certainly be represented by the attendance of a health 23 physicist, who would normally be one of the broader members p 24 of the group, the one with the most broader perspective.
b 25 And you can't send three, so what are you going i
l
6-12-Jo:Wal 391 1 to do now, send none?
.f~h
\s% 2 MR. DENTON: You will-find many of our --
3 MR. MARK: Same for materials. And there is a 4 hydrogen burn problem. It is not a boiling water reactor 5 hydrogen burn problem. It is reactor hydrogen burn problems.
6 Where in the devil is he?
7 There ought to be three of them, or five. If 8 they are in separate divisions, talking to themselves, it 9 is very worrisome.
10 MR. DENTON: It does de-emphasize the concentration 11 by technical disciplines, but the advantage of that is we 12 get a little bit more focused lines of authority and
() 13 responsibility for actions.
14 MR. MARK: I am not really terribly sensitive to 15 lines of authority responsibility. I am much more sensitive 16 to technical know-how and comph.
17 MR. DENTON: I would hope that solving hydrogen 18 burn for boiling water reactors would move along faster under 19 Bob, and for PWRs under Hugh, than maybe it has moved in the 80 '
- past.
21 I think what we are really looking for in this i
22 group is not hydrogen burn as an experimental field. '
23 MR. MARK: Neither am I.
(~' 24 MR. DENTON: But I want to be sure it is not
\
25 a safety threat the plants, and I think-this way I have !
1
~ . -
6-13-JoeWal j 1 got someone at least I can hold accountable for the safety 2 of those plants, and that includes hydrogen and health 3 physicists and every other discipline.
4 MR. MARK: I think you. have got to watch this 5 care fully. Some of these disciplines are just marginally 6 viable.
7 And if they are split, the margin is gone.
8 MR. DENTON: You know, I find in many of these 9 disciplines what is needed, at least in NRR, ~ i.s a decision.
10 Often we have massive amounts of information on 11 topics, and an inability to come to a conclusion partly i
12 because Jesse of what you mentioned, the diversity of
() 13 reactor designs, and we try to make a global decision that 14 fits no plant in particular. And what I am hoping by at 15 least breaking the disciplines into some groups of things, 16 they will be able to come- to grips with it-for their class 17 of plants and it has been awful tough for us to approach 18 things like station blackout and systems interaction because i
19 of the diverse nature of the thing, and this does provide 20 an opportunity.
21 Maybe we can solve some of these long-standing
'M techical problems for at least some plants, if not for all 23 plants.
I 24 MR. WARD: Okay. Let's make it real quick.
26 All right. Ilarold, thank you very much for coming down, and I h
6-14-JoeWal 393 1 think it has been a very effective explanation, and we 2 wish you well with the ' reorganization.
3 MR. DENTON: 'Thank you.
4 MR. WARD :' Thank you. Just a short break, 6 five minutes, while the room clears and come back.
8 Don't go far.
7 (Recess taken at 11:20 a.m.)
8 (11:20 a.m., the meeting resumes) 9 MR. WARD:
Our next' topic is a discussion -- really a briefing for the full committee on the basis for selection 10 11 of personnel who operate and maintain nuclear power plants.
12 We have four guests that we have asked to come w
13 in.'today and address us.
14 - I think we should view this as an important-15 educational session for us, which Mr. Reed has been urging 18 on the Committee for some time.
17 The four speakers will' cover first -- Mr. Thomas 18 Cassidy will cover.an overview of the' selection testing 18 process as is actually in use in nuclear. power plants today, so with emphasis on his experiences at his. utility, which is 21 Wisconsin Electric.-
22 - And he has also prom.ised to give us his perspectives 23 'on'the significance of selection testing to the safe operation M of' nuclear power plants.
j 25 Our second speaker will be Dr. Joseph Zeidner, L
1 1
1 6-15-JoeWal- i j 394
- 1- who is a research professor of public policy and behavioral
- 2 sciences at George Washington University, our neighbor a 3 few blocks'away. ,
3 4' He is going to give us a briefing on the state !
5 of the art of natural ability selection in afgeneral sense, 6 not just from the perspective -of the nuclear power industry,
-7' but.from his experience and his research and academic 8 experience, discuss the potential'for.and the limitations i
9 of selection- testing.
- 1EL And then third we will have a pair of speakers, 2
i j 11 ' Dr. David Kleinke, from the Edison Electric Institute, and i
- 12 Mr. Alfred Mascitti, from Wisconsin Electric, who will
( - 13 ' discuss and-describe to us some particular selection tests 14 that are in use in the industry today.
i.
j 2 We have a little bit -of an awkward arrangement i
l i 16 'for the ' agenda, in that we break right in the middle for 17 lunch, but I guess we will have to do that unless something
! +
- 18 remarkable happens in the next hour, but -- so let's .go ahead, N and Glenn, would you like to say --'I know you know Mr. Cassidy 30 very well.- 1 i
i 21 Would you like to say a~ word in introduction of 3
i 4
It Mr. Cassidy? ;
25 MR. REED:
- Probably the'less I say the better. !
< +
! 24 That is a cosmic observation.
XXINDEX 35 MR. CASSIDY: Thank you. Good morning. Glenn i
I i
- , ,,. - ,, .- L , a-, , . , , , , _ . - - - - - . - - - _ . . . - - - . - - ,- ..- ~ --.
6-16-JoeWul 395 1 and I have known each other for many years, and worked !
f V 2 collaboratively on the staffing of the Point Beach nuclear
< 3 plant, and that is part of the experience that I intend 4 -to talk about today.
5 Of the four people who will be visiting with you, 6 I am the layman in the group. It happens that I am a 7 graduate mechanical engineer, who has been in the human 8 resources business at Wisconsin Electric for thirty-nine 8 years, for the last twenty of which I have been .the officer 10 of Wisconsin Electric who is responsible for human resources 11 matters, including employment, selection for promotion, 12 training, and the like.
13 I should say that Wisconsin Electric has used 14 psychological testing for the purpose of employing and 15 promoting individuals for a period of at least seventy-five 16 years, so we are not Johnny come lately to the subject.
17 In that period of time, we have. employed 18 individuals having the appropriate' credentials to be able 18
, to carry on the process in a very professional way.
- ~
I think it is important to begin my presentation 21 looking at this entire matter from the management responsi- ,
22 bility, by pointing out and emphasizing to you that selection 23 -
i testing is simply a process, or means of making distinctions 24
, between people for the purpose of determing what kind of a
= role they are going to play in the employment setting.
l r
6-17-JoLWal~
396 1
To do that, I would like to simply and perhaps 2 quickly use a job applicant. Joe Smith, who goes to four 3 different locations for employment, and location number 1, 4 the process that is used for employment is first in, first 5 hired.
6 Nothing more and nothing less.
7 At our employer number 2, to be a little facetious, 8 determines who it will employ on the basis of such things e as the size of the shoe that the person wears, or the 10 length of their nose, or the color of their hair, or the 11 color of their eyes, or what have you.
12 Employer number 3 uses interviews and reference
() 13 checking and the like.
14 And employer number 4 does the same as employer is 3, but adds the matter of psychological testing for the is determination of native ability.
17 And I would propose to you that in making the is distinctions between people, that an employer should 11tilize 19 all of the resources that are available, not just first in, 20 first employed. Not just interviews. But all of the resources 21 that are available, and then make decisions upon a consideration 22 of all the information that flows out of the process.
23 Employment, if done properly, or promotion for
-~g se that matter, is a device that requires discrimination in the V
25 good sense. In the good sense.
l
6-18-Jo:Wal 397 l
1 And quite certainly I don't think there is anyone
,r}
\ _/ 2 who would argue with the concept that the more difficult the 3 assignment, that the person to perform that assignment should 4 be the more capable.
5 And I don't think anybody would argue with the 6 concept that there are differences in the native abilities 7 of individuals.
l 8 I don't think there is anyone that would argue 9 with that 10 MR. LEWIS: Many people argue that, but they are 11 wrong.
12 MR. CASSIDY: Depends upon the point of view I i
( 13 guess, 14 Now let me broaden on Wisconsin Electric's 15 history if I may.
16 As I indicated, we have used' psychological 17 testing for a period of at least seventy-five years, and 18 we have a professional staff that does that.
19 It probably is a more expensive process than 20 the employer who does not utilize psychological testing 21 incurs, but nevertheless we believe that the exercise of 22 that is very worthwhile in terms of its economic 23 opportunity and advantage.
24 We at Wisconsin Electric are totally unionized.
(-s v 25 And not withstanding that, we have been able to reach
6-19-Jo:Wal 398 1 understandings and accommodations with the various unions rN
=
/ 2 that are on our property tha't permit this process to go on 3 in such a way so that the individual employees have an 4 ability to challenge determinations made under the system ,
5 and the Company has the opportunity and benefit of being 6 able to select individuals who have the qualifications to 7 fill the job.
a We, incidentally, for our rank and file type jobs 9 do not follow a process of selecting the best individual.
10 We have reached an understanding with all the unions on the 11 property that standards are established for the various 12 occupations, and individuals, on the basis of seniority,
() 13 are selected if they r. met those standards.
14 So it is not a question of the best for our rank 15 and file jobs; it is a matter of meeting the standard.
16 And quite obviously there is a great deal of 17 consideration that needs to be put forth in order to establish is what that standard is, and I think our professionals will is provide more information for you, as to how that process 20 takes place.
l 21 We are quite obviously also cognizant of the 22 - various laws and regulations that affect the matter of 23 discrimination, if you will,- and the system is designed (rs in such a way and carried out in such a way so as to be j 24
,)
25 in compliance with those laws and regulations.
l i
6-20-JoeWal 399 1 Now, I indicated that I would use some experiences
' )
' / 2 out of Wisconsin Electric to demonstrate why we believe that 3 the use of psychological testing is important.
4 And I want to recite two examples. One that 5 occurred many years ago in a fossil plant and one that is 6 of more recent vintage that occurred in our Point Beach 7 plant that indicate what is the advantage of using all of 8 these different processes for the selection of individuals.
9 I don't want to leave you with the wrong --
10 MR. WARD: Dr. Shewmon has a question.
11 MR. CASSIDY: Yes.
12 MR. SHEWMON: You offend me every time you use (v) 13 the words, ' psychological testing.' Because obviously you 14 are thinking of something that is beneficial, and my 15 education goes back to the organization man, in which 16 psychological testing had to do with definities, or things 17 one would like to do: Would you rather walk in the park or 18 to stay in an office.
19 Are you going to define what you mean, because 20 what I think of as psychological testing probably doesn't 21 reflect native ability as I do it, yet to you those words 22 are the same.
23 MR. CASSIDY: Okay, and I am glad you brought.
24
('~^) that up, because I have used the term in a broad, general Q) 25 sense to describe a whole body of things.
i
6-21-JonWal 400 1 I think you are probably -- in your sense of 2 psychological testing, are considering a personality 3 inventory type of thing.
4 I am using the term to describe a measurement 5 of intelligence, a measurement of mechanical comprehensive, 6 a measurement of supervisory adaptability, as well as the 7 matter of determination on the personality value.
End 6. 8 Suet fols.
9 10 11 12 i \ is t
i 14 15 4
16 5
17 4
18 4
i 19 1
- M i
21 i
22
) N
/
25 t
i 401 67-1-SueW 1 Maybe there is a better word to use. There is
- rn 2 one that has been in my vocabulary for a long time. And 3 I don't guess everybody would determine it that way.
4 MR. WARD: Dr. Axtmann has a question.
5 MR. AXTMANN: It would help me if I knew what 6 the size of the work force you are describing is.
7 MR. CASSIDY:
Oh, I'm sorry. Wisconsin i 8 Electric and its subsidiary, Wisconsin Natural Gas, has 9 slightly in excess of six thousand employees.
10 MR. AXTMANN: Thank you.
11 MR. CASSIDY: And incidently, I'm sure you-12 are familiar with the characteristics of the two unit 13 plant, Westinghouse. It is what, nine hundred and eighty 14 megawatts, Glenn?
15 (Mr. Reed nodded in'the affirmative.)
! 16 There are two examples if I may. Oh, I wanted 17 to make this point and this is an extremely important point 18 in the consideration. And maybe the professionalists can 19 describe this better than I can. But I'm telling it to
- # you as an officer of Wisconsin Electric.
21 All this process does is to give us a better 22 reading, a better predictability on the probability of 28 success. It does not establish a process by which you can 8'
say that person who is selected under the process will never 8
fail. It simply improves the selection process.
I
402
. #7-2-SueW s
1 It improves the selection process. Okay.
2 Now, the two cases. We had a situation in 5
3 which there was an electrical failure in the fossil plant 4 and the shift electrician who was on duty was assigned to determine what that electrical failure might be. And he s
6 was unable to analyze the problem and to resolve the dif-7 ficulty in an orderly fashion, I
a And finally he determined that he would remove, I
=
9 remove, some of the safety installed equipment in order to
! 10 try to resolve it. And in the process of removing it, he i
} 11 created an electrical shorteircuit which was a distinct <
12 hazard to himself and other employees.
i
( 13 Fortunately, nobody was injured in the process. '
14 But there was about a million and a half dollars' worth of j 15 damage done to the plant. '
i
)
16 And after this had occurred, we went back and 17 t we looked in to the file to see what kind of characteristics 18 and aptitudes and skills this person had. And the file 19
' revealed that this was a person whose talents were ap- ,
30 '
parently at the best marginable.
21 Nevertheless, the Operating Department in that I
It
] particular case had made a decision years before that they l
- 23 would permit this individual to reach the level of shift ;
l i
M clectrician. The point of it is, had they followed the j 35 predictability that had been established at the time the
\
l' i i 1
I
- _ . _ . _ . _ . _ _ - __ _. ~ ._ _
- 403
- 7-3-SueW.
1 person was processed, they would not have promoted the I d 2 individual to that level of responsibility, complexity if 3 you will.
4 MR. REMICK: Could I ask a question? I think i
5 it would help me. On this point you are making about the 6 process gives better predictability of success, but you !
- 7 must know success of what.
, 8 How do you determine -- how have you determined 9 what knowledge, ability and skills are required to be l
- 10 successful and, therefore, whether you can predict it?
, 11 In other words, to know what did that person --
12 not specifically that case, but my -- is my point clear?
j
- 13 Somebody has had to determine what skills, abilities, 4
l 14 knowledge could lead to success?-
15
! How is that done?
16 MR. CASSIDY: I will give you an answer and
- 17 then I wish you would ask the question again when the profes-18 sionals are on and get perhaps a better answer from them.
18 It's a matter of simply making a job and task j
- analysis as to what is involved in the given position or 21 occupation.
22 MR. REMICK: And you've done that at Wisconsin 23 Electric?
MR. CASSIDY: Yes.
MR. REMICK: Okay. l
~ _ _ .. -
1 404 MR. CASSIDY: Yes. This is really a part
- 7-4-SueW 1 f~y
\~ / 2 of the whole validation process.
3 Now, I have to also make an observation that i
1 4 there are types of jobs in which you can -- you know the 5 level of complexity that is involved, the level of 6 responsibility that is involved, and the level of prepara-7 tion that is involved, that you don't have to go over the a positions little item by little item.
9 You can make some judgments about that and 10 determine what kind of standard ought to be applicable to 11 that kind of situation. The lower level jobs are the ones i 12 in which it is perhaps easier by task analysis to establish
() 13 a level of competency or distinctions in levels of competence.
14 The other case that I think Glenn is aware of, 15 it involves an auxiliary operator at our Point Beach Nuclear i 16 Plant who, during a situation in which there was some 17 level of difficulty in the plant, volunteered for an assign-18 ment. And supervision gave him direction to follow through 19 on a certain task.
30 It happened that at that time one of the units 21 that the plant was operating was done. And the instruction j 22 that was given was to perform the task in the unit that was 23 not at power.
24 The employee, for a reason that later on he l'~J}
N.
35 And in could not explain, went into the operating unit.
l
405
- 7-5-SueW 1 order to do that violated several safety procedures. As
, j7
% 6 4
1
(_/ 2 I recall, there were four or five distinct errors that 4
3 the individual made as a part of what was occurring.
. -4 Once again, what he did was put the plant at 1
6 hazard and put the employees at hazard as well. Fortunately, 6 nothing occurred that resulted in either plant damage or 7 'in employee injury. But the potential was there.
8 MR. MOELLER: Excuse me, though. What does 9 that have to do with the predictability of success?
10 MR. CASSIDY: I will tie it back now.
I 11 MR. MOELLER: Oh, okay. It seems to me poor 12 communications or maybe it should have been given to him
() 13 in writing instead of orally and so forth.
14 MR. CASSIDY: Once again, looking back at the 16 file, the file revealed that this was a marginal candidate i 16 that had been hired at a time when there was great difficulty
! 17 in finding fully qualified individuals to staff nuclear 18 plants.
19 And a chance had been run with the individual, 30 and he had been employed. If we had followed the predict-
- 21 ability, he would not have been employed and would not, 22 consequently, have been in a position to.be able to make 23 the mistake that was made.
24 And what we did in that case was to reassign 25 the_ individual to another facility. We took him out of the l . . _ . _. .
406
.#7-6-SueW 1 nuclear setting completely.
s_,) 2 Now, there are'other examples I am sure that I 3 could recite. But I think those are the two most dramatic.
4 And once again I want to emphasize the point, that we are 5 simply talking about predictability and we are not talking 6 about anything else.
7 MR. KERR: Excuse me. Could I ask a question?
8 ' Suppose that you had gone back and had found that this 9 person's score had indicated that he was pretty good, would 10 you still have reassigned him?
11 MR. CASSIDY: Yes, I think so. And I tell you 12 why we would have done it.
() 13 Simply because it is a nuclear facility, and 14 we wanted to make very sure, very sure, that the individuals 15 that are in the plant are able to always carry out their 16 assignments to the best of their ability.
17 In talking about my presentation today, I have 18 been asked to comment on the relationship of this process 19 to safety, with the understanding that that is'one of the 20 principal interests of yours. I guess my response was, I 21 am unable to separate out safety as a consideration that 22 is distinct from other. considerations.
23 In other words, from the Wisconsin Electric's 84
/"'g point of view, to have this process in place not only gives V 25 us better assurance as to the human safety in the plant, but r
407
- 7-7-SueW 3 it also gives us better assurance as to the efficient r~s
'( ,/) 2 operation of the plant. It gives us better assurance 3 in terms of all of the things that management is concerned 4 about.
5 In other words, you cannot take-these items 6 and split them into pieces. So, all I'm saying is that 7~ simultaneously you get a distinct advantage from a safety a point of view in terms of having a better selection process.
9 You get a distinct advantage from the point of view of 10 efficiency of operation. You get a distinct advantage from 11 all of the other considerations that supervision reviews 12 in terms of employee performance.
[}
13 I can't though, in saying that, in any way 14 suggest that safety is not a major consideration. And I 15 think the example that I used is indicative of that.
16 In that case, it was nothing else but the safety of the 17 place.
18 I think a good place to probably conclude here 19 is to quote from a publication that perhaps you have all seen 30 .by INPO back in August of this year, in which they indicate i
21 that human performancG p.oblems accounted for fifty-two 22 percent of the rott ev_.,s of INPO's significant event 23 report in 1983 and '84.
(-g 24 And I simply call that to your attention to
^~
25 demonstrate the importance of having a proper staff, a
408
- 7-8-SueW 1. qualified staff operating a nuclear plant.
b>
x- 2 One last concluding comment, and this is very 3 important from the way Wisconsin Electric sees it. There 4 are some people who believe that if-you apply enough train-4 5 ing, if you apply enough training, the recipients of that 6 training will be able to perform the tasks that are involved.
7 We do not believe that. We feel very strongly 8 that you have to have adequate ability in order to be able 9 to accept training, and that the more complex a job is and 10 the more responsibilities that are involved, the greater the
! 11 amount of native ability that is required.
12 MR. REED: Mr. Cassidy, some people will think m.
(v) 13 that we staged this but I was going to ask you about the 14 training issue, the importance of training versus natural 15 ability, because four years ago I.was at a very prestigous 16 meeting in which a very prestigous speaker at the podium said that, give me your warm bodies through this door and into 17 18 _this training facility and I will turn those warm bodies into 19 expert operators and auxiliary operators and licensed person-30 nel in certain periods of time.
21 I asked that gentleman to repeat that statement 22 in front of the audience. He repeated it, and he said that 23 training does it all and warm bodies is what he wanted.
1 24
( /'s) An interesting thing about that utility is that I N~/
25 it seems to have all of its nuclear plants shut down at this
(
l
409
- ?-9-SueW s
1 time.
\- 2. (Laughter.)
3 MR. CASSIDY: I don't want to be misunderstood,
. 4 and that is that I'm not in any way trying to diminish the 5 importance of training. That's not what I'm trying to say.
6 Nor am I trying to diminish in any way the 7 activities that are going on within the-industry with regard 8 to training and the~ accreditation of training. These are 9 all important things.
10 I'm simply making the point that you've got to 11 have a staff that has the ability to accept the training 12 in order to get the results from it.
) 13 MR. WARD: Dr. Shewmon and then Dr. Kerr.
14 MR. SHEWMON: One thing that, if this is the i
15 end of your talk, I would like tu) have your comments on, 16 or we can put it off later.
j 17 I think I can't imagine any corporation which 18 would not like to have a capable, efficient work force and 19 a safe work force which is all wrapped up in that. I would 30 like a comment some time in the presentation on why it is i
21 that other utilities don't go the same way that Wisconsin 22 Electric does?
- You have brought up one of those possibilities, f (~'\ 24 and that is that they have great faith'in the trainability
( \m l j 25 of any human being. Are there other philosophies?
410
- 7-10-SueW 1 MR. CASSIDY: I think that information that
't ) 2 will be presented to you this afternoon will indicate that 3 the use of these devices is on the increase in the industry, 4 first of all.
5 Secondly, there in some cases are perhaps union 6 restrictions that make it difficult for an employer to now 7 embark upon a testing program, that they have developed over 8 a long period of time, a history and, of course, some 9 collective bargaining considerations that would have to be 10 removed as an impediment.
11 There are people who simply have a belief that 12 they, you know, believe the opposite that we do. But 7-( ) 13 we have been at it for such a long period of time that we've 14 had an opportunity, a clear opportunity, to make a determina-15 tion as to the value of it.
16 I suppose it would be not inappropriate for 17 me to say that we believe that the Point Beach Nuclear Plant 18 is a highly successful operating plant, and I think it's 19 appropriate to say that Wisconsin Electric Power Company 20 is considered to be a very well managed utility.
21 MR. SHEWMON: Fine. Okay. Thank you.
22 MR. WARD: Are there any other -- let's see, 23 Dr. Kerr has --
/ ') 24 MR. REMICK: I have one, Dave. Mr. Cassidy, V
I was interested in the fact that you were a mechanical
-. .. . .- - .. . - . = - . . .
i 411
~
- 7-ll-SueW 1 engineer and-apparently immediately went-into the human O
V 2 resources area. If there had been such a test, would it 3 have predicted your success in human resources?
4 (Laughter.)
1 5 MR. CASSIDY: Yeah, I.think so. Just to fill
!. 6 out that history, I got the mechanical engineering degree 7 courtesy,of the United States Navy in World War II. And 8 I think if I had attempted to pursue ~ engineering that I
<- 9 would-have difficulty in earning a living. '
10 That's how I got to where I am.
11 MR. REED: One other question, and you've gotten 12 close to it. You said that some union resistance might be ,
l 13 met with some companies trying to adopt testing.
14 Do you think some companies are reluctant because is of, let's say, other government regulations and rules like 16 the EOC or something like'that?
2 17 MR. CASSIDY: Well, yeah. There are -- there 18 from time to time can be conflicts between the consideration 19 of affirmative action goals and time tables and the like and
) the issue of adequate qualifications to perform jobs.
21 Those things though need to be resolved, and i
4
' I 22- they are resolved.. From time to time, we receive some i 28 j challenge through a decision that we've.made, and we go ahead !
24 and defend it before whatever forum might be involved. !
, 26 If it happens to arise as a result of a grievance , l f
i l
412
- 7-12-SueW 1 a union grievance, we've had cases where these matters have
(~%
(.,~) 2 gone to arbitration and an independent judgment has been 3 made as to whether or not the proper decision has been made.
4 I think in almost every case that I can think 5 of that the Company position has been sustained. There have 6 been a fair number of occasions where we have been charged 7 with discrimination because of race or sex. Again, where 8 the use of the process has been a focal point of review.
9 And again, by and large, because we have taken a lot of pains 10 to do the process right.
11 And I think again this afternoon there will be 12 some emphasis by the professionalc on the matter of, if 1
13
) you are going to use the process do-it the right way. Don't 14 do it the wrong way. Make sure that it complys with the
- 2 standards that have been' established for, if I can use the 16 term, psychological testing.
17 MR. WARD: Yes. Let me --
, 18 MR. LEWIS: Go ahead.
1 19 MR. WARD: Okay. I'm first.
20 MR. LEWIS: Yes.
21 (Laughter.)
2 MR. WARD: You mentioned that -- I hate to put r 23 you on the-spot with a question like this, but --
24 l MR. CASSIDY: Go ahead.
26 MR. WARD: I will, right. You mentioned that,
413 67-13-SueW 1 you know, fifty-two percent of INPO's significant event
(~'\
1
(_ l 2 reports are related to human = performance problems. And 4
3 we've heard similar numbers like that before. Okay.
4 Wisconsin Electric has an effective ability 5 selection program. What is the number for Wisconsin Electric?
6 MR. CASSIDY: You have put me on the spot, and i
7 maybe Glenn can give you an answer to that better than I 8 can.
9 MR. WARD: Yeah.
10 MR. CASSIDY: I'm quite sure it's less than
=11 fifty-two percent.
12 MR. WARD: Okay. But, you see, this is the
( 13 point we sort of have to grapple with. I think we recognize 14 that this is certainly a good procedure. I think we also is suspect that many -- maybe for all I know, all utilities 16 are using some sort of procedure.
17 Or, has Is there really a problem out there?
18 it already been fixed and fifty-two percent is just the 19 residual?
20 Or, are there data out there which could be 21 i collected somehow which would show a significant difference i
~
22 in, for example, that number between utilities that have
'# effective selection programs and those that don't?
-w 24 MR. CASSIDY: I think the latter is the case.
E But I'm sorry, I don't have the data. And I don't know whether
_ . . _. _ . . _ . , _ ~
i 414 1 :47-14-SueW- 1. the data is available.
2 MR. WARD: Yeah.
A 3 MR. CASSIDY: I don't know that anybody has 4 done that kind of research.
6 .And I have to point something else out, and e I emphasized.this, or made the point, that the fifty-two 7 percent, there are other problems that are reported to INPO 8 which are the result of ' equipment design or what have you, 9 and that again could be related to human beings, t 10 The point I was trying to make is that human
- 11 -beings are obviously a very intrical part of the operation i
12 of a nuclear power plant, and employers ought to take the
()
i 13 - fullest opportunity to ensure the adequacy of that work 3
14 force. And that has not always been the' case.
16 That has not always been the case. A nuclear 16 -plant, as you well know, is quite different-than a fossil i 17 plant. And there are different skills required in operating Mi a nuclear plant, i Hi - And we feel that very strongly.
- 30 - MR. WARD: Okay. Hal.
21 MR. KERL: One might, it seems to me, have a Et good bit of confidence in and indeed want to see that some as sort of selection process was used.
24 But there is another issue, and that is whether
- - the NRC'should specify the kind of selection process to be .
b t
415
- 7-15-SueW 1- used. My impression is that Wisconsin Electric has fre-
'\4f} 2 quently taken the position that it would like to manage 3 its own plants rather than having the NRC manage them.
i 4 Would you want the NRC to specify the kind of 6 selection process that you used?
6 MR. CASSIDY: It's interesting that you asked 7 the question, because when I came in this morning Glenn 8 asked me the question in the back of the room.
9 And I guess my response to Glenn was something 10 like this, that we feel very strongly about having an 11 ability to manage our own facility. And when you put rules 1
12 in place, et cetera that that begins to interfere with our
( 13 responsibilities to manage.
14 However, there would be nothing wrong, in my 15 opinion, providing some guidance, if you will, guidelines, 16 if you will, to the industry in terms of the importance of 17 the selection pr6 cess and the alternatives that are available, 18 and let the industry make up its own mind.
19 MR. WARD: Okay. A quick question.
30 MR. LEWIS: Just a very quick one. I'm curious 21 about one thing, and I may have misheard you. You emphasized M a few minutes ago the importance of doing the thing right 2 if you are going to do it at all. And I understood that.
24 You also, if I understood you right, at the
)
. 25 very beginning made a big point of the fact that you are not c.
Y 416
- 7-16-SueW 1 looking for the best person but you are setting job standards
~ (\~)N 2 for the particular job and within those standards, not look-3 ing for the best person.
4 Is that because you think that's the right 5 way, or because you think that's what the traffic will bear?
6 MR. CASSIDY: Probably more is related to the 7 latter. There is a -- you know, there is a lot of influences 8 that affects this. There is such a thing as, you know, and 9 that is having overqualification at certain levels.
10 And particularly when you are in the rank and 11 file area of plant operation, not supervision, not manage-12 ment, or not professional. But in the rank'and file area,
() 13 it seems to me that if you always went for the best person, 14 you would end up in many cases with people that are over-15 qualified for the work to be performed.
16 And when you have overqualified people you run 17 as much hazard, it seems to me, of potential for failure 18 on the job as you do if you've.got inadequate people, be- l 18 cause the job is no longer of interest to them. I hope I 3D make myself clear. I 21 MR. LEWIS: So, you are saying that in your view j 22 it is wrong to look for the best person for a job?
23 l MR. CASSIDY: At the' lower levels. Not wrong. !
24 Wrong would be the wrong word to use.
(-~}
v #
MR. LEWIS: I'm trying to quote what, you said. ;
L b
i
417
- 7-17-SueW 3 MR. CASSIDY: I think what I'm saying is that m
s- 2 we are responsive to the social needs of the world we live 3 in as well.
4 MR. SHEWMON: If I could'put words in his mouth, 5 it also might be a reasonable compromise with the union.
6 MR. LEWIS: Oh, that's what I was groping for, 7 of course, a MR. WARD: Okay. Mr. Cassidy, thank you very 9 much. We certainly appreciate the --
10 MR. CASSIDY: Appreciate having the opportunity.
11 Thank you.
12 MR. WARD: -- informative presentation.
() 13 Let me say another word in introduction of our 14 next speaker.
15 Joseph Zeidner has a doctorate in experimental 16 and industrial psychology from the Catholic University of 17 America. Let's see, he must be about my age. That was back 18 in 1954.
19 As I said earlier, he is presently a research 20 professor at The George Washington University. His past i
21 experience from 1978 to '82 was as Technical Director of 22 the U.S. Army Research Institute for the Behavioral and 23 Social Sciences. And he also had the title of Chief 24 Psychologist for the U.S. Army.
4 as Prior to that he had what appears to be a i
L
i 418
- 7-18-SueW 1 distinguished and interesting career in positions leading e s r i
\_/ 2 up to the job of Technical Director.
3 And we are pleased that Dr. Zeidner is here at 4 our invitation, and we look forward to your presentation.
5 MR. KERR: Would you say he qualifies as one 6 of them pointed headed academics?
7 (Laughter.)
8 MR. WARD: Yeah, I think so.
9 MR. SIESS: Does the U.S. Army use this 10 technique?
INDEXX 11 MR. ZEIDNER: I might say that the United States 12 Army Research Institute is the oldest behavioral science (ex( -) 13 research institute in America and was probably in the world; 14 it started in 1917.
15 And currently, it's certainly the largest. It 16 has a staff of over four hundred people, two or three hundred 17 Ph.Ds and an equally large number of research professors in 18 industry and academia supporting its program.
19 My remarks come from a reference paper on 20 ability testing and personnel selection which I prepared for 21 this Advisory Committee. So, that will be available to you.
22 Now, this talk will highlight four issues. And M I want to get a lot of points across, and I will stay close 24
[j to this notes. I'm not accustomed to doing this.
( '
E But the first of these four issues concerns t
. , . . . . . - . . . ~. .-- .- . - . . - -- - ._.- -. ... -.. -.-_..-. . .. .-
1 419 ,
19-SueW 1- current concerns surrounding personnel-selection testing, !
2 the validity of selection tests, validity generalization, and i
3 the utility of tests.
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420 8-1-Jo:Wnl 1 Now, one of the effects of World War I military t
\ss/ 2 personnel selection program -- incidentially, have you a handed out, John,the two tables. You will be getting some 4 empirical information here.
6 MR. SIIEWMON: I~ hope you read them correctly.
8 One can' t be read, the other. can. Go ahead.
7 MR. ZEIDNER: One of - the more enduring .ef fects e of this military selection program must be the impetus 9 it gave to mental testing in the civilian sector, as was 10 mentioned in the seventy-five year history of Wisconsin 11 Electric.
12 The Army Alpha tests were the first written
() 13 - tests of mental ability to gain respect, and they still serve
- 14 as the model of scientific selection today.
- 15 Because these tests were administered to groups, le they represented a convenient means of ranking everyone for 4
- 17. nearly every purpose.
18 Employers were quick to utilize tests as one means 19 of increasing productivity, especially since they were i~
so perceived as being objective and predictive of later 21 performance.
1 22 over the decades, numerous validation studies l 23 attested to their effectiveness as predictors of training l
24 and job success.
x) l 26 !!owever, in recent decados, the last two deocdes, l
8-2-Jo;Wal 421 I there has been much social and scientific controversy
[\ >) 2 surrounding testing. Critics have focused on tests fairness 3 and their adverse impact, the limited predictive powers of 4 tests for long term job performance, and the often narrow 5 range of skills covered by the tests.
6 In short, tests are criticized as inadequate for 7 the purposes they were designed to serve. At the same time, a scientific critics began to question the theoretical bases 9 of measuring individual differences in cognitive skills, 10 the inability of researchers to bredak the asymptomatic 11 barrier of job validities. The .3 validity problem. Not 12 going beyond that when correlating tests with job performance.
r~b And the limited advancement in theory and practice.
(s -) 13 14 I would like to elaborate on several current is issues of major concern in the employment testing community 16 today.
17 We have already mentioned the EOC issues, and 18 that has been a continuing concern that selection tests deny 19 qualified applicants access to jobs. Title VII of the Civil 20 Rights Act of '64 has been the primary legal basis for 21 protecting employees against employment discrimination.
22 The Tower Amendment to that Act, however, 23 expressly permits the use of professionally developed ability g~) 24 testing in selecting employees. The Supreme Court laid down
( )
25 '
a series of rulings on test usage that together with the
I 1
8-3-JoeW31 422 1 EOC's Uniform Guidelines define acceptable practices,
/ 1 YJ 2 particularly for demonstrating job-relatedness and equal 3 effectiveness in prediction for minorities and non-minorities.
4 The legal challenge to testing stimulated an 5 interest in evaluating differential prediction in academia, 6 industry and military through a comparison of ' regression 7 systems for different groups.
8 If individuals from two groups, say race or sex, 9 have the same score on the employment test, but then predicted 10 performance scores based on subgroup regression systems are 11 different, differen'tial prediction has occurred.
12 However, in general results over the last decade O)
! 13 showed that there are no differences in predictions based 14 upon minority or majority group data.
15 Case law also awakened the long dormant interest 16 in validity generalization.or transportability of tests.
17 The prevailing view, through the years was that employment 18 test validations were situation-specific and that empirical 19 data were needed for each new situation.
20 Recent work, correcting for various sources of 21 artifactual, between-study variance, strongly supported the 22 utility of validity generalization, and thus makes it 23 possible to develop general principles for linking' ability
(~N 24 tests to classes of jobs.
O M However, long-standing aspiration of researchers
1 j-4-JoeWal 423 i
1 was to use something more comprehensive and relevant than s 2 training indicators or supervisory ratings of job performance 3 as criteria for evaluating selection tests.
4 Again, because of the legal emphasis on empirical 5 measures of test validity against job performance, 6 researchers turned their attention to the difficult, time 7 consuming, and expensive task of measuring job performance 8 through hands-on performance measures and behaviorally-anchored 9 rating scales.
10 Although research on tailored testing started 11 several decades ago, the overyday application of computerized 12 adaptive testing, known as CAT, only became possible with
,m 13
() advances in micor-computer technology and in item responce 14 theo ry .
15 CAT permits automated testing using a display 16 screen and light pen or other device for responding. The 17 questions are tailored by the response to the previous ,
18 question, and computer-scored af ter each response.
19 The terminal used by the examinee is designed 20 expressly for testing purposes. The sequence of items in 21 a tailored test has as its principal goal equal precision of 22 estimating ability for the total distribution of examinees, 23 not just at the middle or at the given cut score.
'm 24 In the military, the cut score is sensitive at
(
n 25 the lower rang-e of distribution. Of course, they are limited
'8-5-Jo;Wol 424 1 to paper and pencil tests.
2 There are other advantages of CATS such as test 3 security, simplicity of tst revision, scoring the accuracy, 4 and efficient use of time.
5 And the Department of Defense has an on-going, 4 large-scale implementation program at this time to,xeplace 7 traditional paper and pencil tests with CAT.
t a On a more technica'l side, we deal with the issue i 9 of the theory of cognitive abilities in differential 10 selection.
11 Now, until recent times the test theory depended i
, 12 upon factor analytic theory. Thurstone's prinary mental l () 13 ability structure or variationc of it, with its seven 14 relatively independent factors.
4 15 Today, cognitive psychologists however are looking L 16 for a deeper understanding of individual differences in 17 information processing based on an experimental rather la than a correlational approach.
! .19 The hope is that such testing can supplement
{
30 current information, but the critical question remains to be ;
4 .
21 demonstrated if there is improved validity. ,
u I think it is worthwhile to briefly mention that !
23 current issues just described are being actively addressed l I
r3 24 programati.cally by researchers in the military setting !
! (_-} {
25 through an analysis of a common selection and classification i
I L w_-_-_.
8-6-JoeWal 425 1 battery.
2 The armed services locational apptitute battery, a commonly called the ASVAB, and this is administered to one 4 million military applicants each year in all four services.
5 A version of tue ASVAB is given to high school 6 students for vocational sounseling and recruiting purposes.
7 And I think it is interesting to point out that 8 this ASVAB is a direct lineal descent of the Army Alpha of e 1917, and the reason that the services are now more active 10 than others in seeking improvements in the ASVAB can be 11 traced to such theories as I have just mentioned. The 12 ddvances in computer technology and also because of 13 Congressional directives that the ASVAB be shown to be 14 valid against job performance rather than training performance.
Is And the social concerns surrounding testing.
16 Now, I would like to say a few words about' 17 the critical issue of validity, or the effectiveness of to tests for a given purpose.
le I am going to first present data obtained within so the military setting. The reason for this is that the data 21 are generally based upon much larger sample sizes than 22 comparable data obtained in the civilian sector.
23 How, you have before you this Table 1, and it is 24 sort of blurred, but I think I can get the main points before 26 you, and you can study it a little later, too.
I
8-7-JoeWal 426 1 It gives examples of validity obtained with the
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- 2 Army General Classification Test, the AGCT, administered to l
3 ten million soldiers during World War II.
4 The AGCT consists of four subtests; reading, !
5 vocabulary, and arithmetic computation, arithmetic reasoning 6 pattern analysis.
7 Now, although the data in Table 1 are more than a four decades old, there is still important generalizations 9 that can be made.
10 For example, a scan of validities in that Table 1 11 show that the AGCT was quite successful in general in 12 selecting individuals for Army specialist training.
13 Since most of the samples --
[U) 14 MR. WARD: Dr. Zeidner, would you help us with 15 that. You said a scan of it, and my scan doesn't tell me 18 that, but -- you need to help us. We are laymen here.
17 MR. LEWIS : You can start by telling us what 18 the letters are that define the columns on the right there.
19 MR. ZEIDNER: The N?
20 MR. LEWIS: N is the number of people?
21 MR. ZEIDNER: N is the number of people, the Mean 22 is the mean on the test itself, test incidentally in the 23 general population of mean of a 100; standard deviation
-') 24 of course is the variance around that mean, and the R is the
~
25 relationship between the test and the particular criterion
8-8-JoeWal 427 1 cause or iob being correlated.
4 b
d 2 The R then is an index of the effectiveness of 3 validity. For example, on the very first line the R is 4 .40, which represents the relationship between the AGCT 5 and administrative clerical trainees in the Army Air Force 6 using school grades as the criterion.
7 Now, if you scan that last column, which is the 8 the critical column, you will find these.are generally e around the 40s and 50s, and I will say some more words about !
10 them, but they key now is that R.
1 1
l 11 Uhen your first speaker said that his tests 12 work, he most probably has data relating his individual 13 tests, and his test battery, against some kind of criterion t
j 14 measure or criteria.
18 MR. WARD: Against some sort of performance?
]
l 16 MR. ZEIDNER: In this table, there are three 17 kinds of criterion measures, or performance measures used.
18 MR. WARD: All right.
19 MR. ZEIDNER: One of them is performance in the 30 school set-up, which is cross-grades, not very much dis-
- 21 similar to what we do in the university. A series of tests 22 and the grades that you receive on them.
i 23 These are generally paper and pencil' test
! 24 criteria.
26 A second and very frequently used kind of l
l __-_
8-9-JoeWni 428 1 performance indicator used, and it is the one that is used (D
AJ - 2 most widely in industry is supervisory ratings.
3 And the third kind of performance measure is a hands-on performance, that is the output of the activity 5 of doing the job itself.
1 6 For example, if you are speaking about pilots, g 7 they have classroom in the training - situation. They have a classroom grades. When they graduate and are flying, they 9 generally get supervisory ratings that deal with the skill i
i 10 in which they handle their aircraft, and there are many, many 11 attempts to do something more objective, and more relevant, 12 and get even more objective measures of their proficiency
() 13 in flying, and hopefully the military get something about 14 flying and combat effectiveness.
. I
- 15 MR. MICIIELSON
- You named three performance 2
l 16 criteria that were used. Was there some kind of a magic 17 weighted mix of these three in determining relationship to 18 the rest?
i 19 MR. ZEIDMER: Generally, the way this is done, i
so the test in this case, the Army AGCT or its composites, '
j 21 are relative individually and in composite form against a et particular critorion measure, and that is one of the great i
j ss weaknesses. ,
i 34 From time to time, you could take a composite
- 36 of the criterion neasures, weighted in some way, and relate l
- *
8-10-JoeW31 429 1
the test to the composite itself.
! '1 is/ 2 And I will come back, because that is one of 3 the great criticisms here.
4 MR. MICllELSON: But you can't come back. You 5 have to tell me at least what this R means. I am not at 6 all clear yet what it means.
7 For instance --
8 MR. ZMIDNER: I will give you three examples.
9 !!R. MICHELSON: Yeah, but let me tell you where 10 my concern is. Among the three criterion are supervisory 11 ratings, almost entirely subjective.
12 !!R . ZEIDNER: That is correct.
(m) v 13 MR. 11ICIIELSON : My experience a long time ago 14 in the military was these aren't really done very well or 15 mean very much, and if you gave that ni mty percent of the 16 total weight or something, then I would say this whole thing 17 is crazy.
18 If you gave it ten percent of the weight I would 19 say it is probably all right.
20 MR. ZEIDNER: These supervisory ratings have 21 enormous weakness in the military and they have possibly even 22 more weakness on the job, because in the military you get 23 possibly a composite of supervisors, g-'S 24 When we show a relationship between the test score
( ,/
25 and a supervisory ratina, it is just that, it answers the l
8-ll-JoeW21 430 g question to what degree do tests predict the ratings of
() 2 supervisors and employees.
3 Those supervisory ratings have an enormous degree 4
of shortcoming, and I want to come back to that point, but 6 it is a very, very key point, because it really -- what you 6 are really asking me, if your evidence for validity of test 7 is based upon the degree to which these tests could predict 8 the ratings of supervisor and employees, I may not be very
, interested in these ratings as a measure of performance, 10 and that is going to be a key point that I would like to make.
11 MR. MICl!ELSON: On the R you show, that ic an 12 R based on a mix of these three criteria -- okay, you haven't
(h 5 /
13 told me yet what E is.
%J 14 MR. WARD: Apparently, it is sort of the best that 15 can be done with the data that are available.
16 MR. ZEIDMER: No, no.
17 MR. WARD: Okay.
18 f1R. "CIDNER: This is very simply in each particular gg study -- each particular study taken separately rates the 73 test against one of these criteria; one at a time.
21 ,
There are a few differences -- there are a few 22 exceptions to this. If you are down to one, two, three, four, a five, six -- the seventh block, where you look at aircraft
, 24 warning trainees, you see there a mixture of grades and
( )
'/'
s performance being used as the criteria.
S-12-JoeWal l 431 1 Some compositing of both of those.
(_-) 2 But in general, to answer your question, sir, 3 they are the individual relationship of a -- of the test 4 composite to a single type of critorion measure.
5 There are a few others. Maybe there are one or 6 two more.
7 And this is a very small sample of hundred and 8 hundreds of validity studies that were conducted during g World War II.
to MR. LEWIS: I wonder, since you are interrupted 11 already --
12 MF. ZEID!TER: Sure.
[R ,/') 13 MR. LEUIS: I wonder if I could ask a question 14 about a different column, which is the column on standard 15 deviation.
16 That really is the population standard deviation 17 of the --
if it is not the population standard deviation, 18 what is it?
gg MR. "EIDNER: The AGCT was standardized on 20 total Arny population, with a mean of 100.
21 MR. LEWIS: Yes.
22 MR. ZEIDNER: And a standard deviation of 20. Now, a thene people in these various courses, and on the job, have g-'s 24 boon pre-selected, generally on the AGCT itself.
' w ./
25 So, it represents in many cases a restricted
432 8-13-JoeWal 1
standard deviation because that the validities themselves 2 are restricted.
3 MR. LEWIS: Okay. So, this is the standard 4
deviation of the sample --
6 MR. ZEIDNER: Sample.
6 MR. LEWIS: That you showed in the line. That 7 was not clear.
g MR. ZEIDNER: That is exactly correct.
g MR. LEWIS: So it is a reasonably narrow 10 selective group.
11 MR. ZEIDER: I am going to come to that very 12 point in the next sentence.
13 MR. LEWISt If we let you.
14 MR. WARD: Can I just remind the Committee we is have an agenda problem. Right now, the only way I can see to to solve it is to recognize that cvory question we ask is 17 eating into the lunch hour. I really don't know what else 18 to do.
3, MR. ZEIDNER: I have for you more than seven g decades of information, and it is empirical information, gg and it is the best extant, and because I had so much to say g I have tried to compress it into an uninterrupted twenty a minutes worth, but I will be willing to spend any and all 34 the time.
g MR. WARD: Well, I wish we could, but we didn't
8-14-JoLWal 433 1 plan for it, so we will have to kind of barrel ahead.
/%
k -)
m 2 I would like, if we could, let Dr. Zeidnet finish 3 up by 12:30.
4 flR. ZEIDNER: I can't do that.
5 MR. WARD: You can't? If we keep quiet can you?
6 Why don't we keep quiet for a while, then. We need to hear 7 what you have to say.
8 MR. ZEIDNER: I will do the best,.but I was 9 prepared for 15 or 20 minutes of my comments.
i 10 MR. WARD: Yes.
! 11 MR. ZEIDNER: And I think I can stay within that.
i 12 MR. WARD: Okay.
() 13 MR. ZEIDNER: But I will try to do it.
14 The point that liarold made, could be -- shows that the [
15 -actual effectiveness of these tests are much larger than the 16 Rs indicated when you go to an unrestricted standard 17 deviation.
18 The example of that is if you go to bombardier it training, where the standard deviation is very close to 20 20; it is 18.6, you get a very high validity of .62.
21 But I want to make the point that Mr. !!ichelson 22 -- that focuses on what Mr. Michelson says, that the validities i 23 are highest when grades are used as the criterion measure.
4 24 Validities are much lower when either supervisory i 26 ratings or hands-on performance measures are used.
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8-15-JoeWal 434 1 These differential validity results are the
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~l 2 three different types of criteria -- for the three different 3 types of criteria as a general finding confirmed in later 4 studies through the years.
6' Now, in 1949 the AGCT was replaced by the 6 Army Classification Battery, which made possible differential 7 assignments to jobs, and cutting my prepared remarks as p 8 brief as possible, I could say than an estimate o'f the mean range of validities obtained in the training situation 9
10 corrected for restriction ranges, is about .4 to .6, and 11 the near. range of validities obtained in the job situation, 1
12 corrected for- range restriction, is estimated to be . 35 O
Q 13 to .40.
14 These estimates are based upon hundreds of 16 studies. They tell you how effective tests are for.the 18 training situation and the job situation.
17 Now, moving rapidly on to current information 18 by the Army Research Institute, collected 1984, where the 19 ASVAB was validated against 81 different jobs, using sample so sizes of 1500 to 16,000, across nine occupational clusters.
21 That is your Table 2, okay?
22 And Table 2 shows the validities for a general
- 2 composite and a best compositive test from among the ten 24 sub-tests of ASVAB.
4 v
26 The time is very pressing. I have the ranges, i
f
. , -----,-e, , . - - ,-
l.
8-16-JoeWal 435 1 the means, the standard deviations for all those things, t
(~/,\
- s. 2 but these are very impressive validities.
3 But I must note one thing about these validities, 4 if I can find it.
5 (Pause.)
6 That they were based upon written paper and pencil l
7 criteria. Both the ones for the training situation, and the 8 SQT itself is a written paper and pencil test.
9 So, any time you correlate ability tests against 10 written paper and pencil tests saturated itself with i 11 numerical and cognitive abilities, you get a slightly 12 inflated relationship, and that is what we found here.
() 13 Now, moving on to the point -- the second of three 14 points, validity generalization, historically these tests U5 -- ability tests were validated in school-job settings, 16 considered to be quite similar, yield validity coefficients 17 that were -- that varied widely.
18 Such findings were the basis of the almost I
is universal belief in the situational specificity of so psychological requirements in training or on the job.
21 The discouraging fact, then, was that test validities did 22 not, generalize the different situations.
23 obvious"y, this placed a severe practical
-s 24 constraint on the proper utilization of tests since each 25 new test application required a new empirical validation.
l -
8-17-JoeW21 436 1 It is important to say that in the industrial 2 setting there are a number of severe limitations establishing 3 a relationship between a predicting criterion, such as the 4 availability of only a small sample size, and adequate ,
o Performance measure, and cost factors.
6 For the most part, then, except in the military 7 it is difficult to provide evidence of test validity.
3 In recent years, however, two investigators e in particular, Schmidt and Ilunter, have applied new 10 meta-analysis techniques, and have found quite a bit of 1
11 generalization across many different jobs.
12 The reason they got that result is they found
() 13 that there are a lot of artifactural cross-study variances; 14 that is unrealibility in tests, and the measures of 5 performance and restriction in range.
16 So, this offers a very new hope in testing.
17 However, the fate of 'this concept of broad generalization 18 really depends in part on the acceptance of a general is factor, commonly called intelligence.
End 8. 30 SusW fols.
21 22 23
~
34 i
s)' 25 I
437
- 9-1-SueW 1 Another factor concerns the nature of the
-(m-p/ 2 criteria, and this is the point -- coming back to Mr.
3 Michelson's point, the criteria employed in the studies 4 showing validity generalized so widely. Supervisory ratings 6 are the main criteria used in many of these studies.
6 And such ratings reflect only broad abilities 7 that are essentially all that supervisors recognize in 8 employee behavior. The only answer then is carefully de-9 signed research involving performance measurement of general 10 _ group of specific factors to be able to be manifest.
11 I'm going to cut the rest of this discussion 12 short and make just one last point that concerns the utility 13
[V) or value or cost effectiveness of test.
14 Now, it's my own personal belief th'at no leader 15 of an organization should accept a test basically -- on the 16 basis of validity effectiveness only, that is the relation-17 ship of the test to the criterian. They have to show what 18 it means to the firm in terms of cost effectiveness.
19 The same standard ought to be applied in so accepting the test that we place against any engineering 21 innovation. The developmental cost on the one hand against 22 the benefits on the other.
U So, this is the new concept in testing called fg 24 utility. Now, it has a three-step evolution which I think 25 I can finish in one minute, to take that pained expression
438 i
- 9_-2-SueW 1 off of your face.
J _ *
\/ 2 Since 1939, the major index of utility were 3 based upon the table of the Taylor-Russell tables, which 4 'in effect said if you had a test of certain validity then 5 you selected people, one out of every ten people, and the 6 current percent of employees was considered successful, 7 or fifty percent. Then, if you use a test with validity, 8 point five, and selected only one out of ten people, you 9 would raise the percent of employees considered successful, 10 say, to sixty-five percent.
11 In 1949, my predecessor, once removed, developed 12 the notion of dollar criterion, a way of measuring the 13 benefits of the test directly in dollars. And this technique 14 had been perfected, particularly by a student of his. He 15 is down at Perdue University now.
16 And the trick is to obtain the standard devia-17 tion of performance in dollars. It compares with value of 18' average performance compared to the performance, say, at 18 one standard' deviation above the mean, a superior performer.
l Now, Schmidt-and Hunter, for example, did this 21 for computer programers in the Federal Government. They 22 estimated the dollar savings of selecting one out of ten 23 people applying for this job, of ninety-seven million dol-f~N lars in the Federal Government. They then went on in a very
\
26 grandiose style and computed the savings fcr the program in
439
- 9-3-SueW 't the United States using the census data. They then
,-~
k-) 2 generalized that procedure to allocating man across jobs 3 on the basis of tests across all the occupational specialities .
4 And although the figures are crude, it shows 5 a savings in the billions of dollars. So, I would make 6 two points in conclusion. You have my fuller written re-7 marks.
8 And they are these. The seven decades of the 9 use of the test points at very meaningful, practical utility 10 that can be made by the employment of tests for both the 11 school and the job situation. And that it has tremendous 12 impact on national productivity.which lots of researchers
( ) 13 use, of course.
14 MR. WARD: Okay. Well, Dr. Zeidner, we 15 appreciate very much the presentatiou. I think it has given 4
16 us a good background for the talks we will hear this after-17 noon.
18 Thank you. I hate to say it, but we need to 19 come back by-1:15 and start up at 1:15.
, 20 (Whereupon, the meeting is. recessed for lunch 21 at 12:35 p.m., to reconvene at 1:17 p.m., this same 22 day.)
23 MR. WARD: The meeting will come to order. Our
/}
G 24 next speaker is Dr. David Kleinke of the Edison Electric l 25 Institute, and he will give us -- describe the Edison Electric a
440
- 9-4-SueW 1 program for development of selection tests.
,~
t 4
\msJDEXXXX 2 MR. KLEINKE: That's a performance test. There 3 is also a performance test for the equipment.
4 Is this thing working?
5 MR. WARD: Yes.
6 MR. KLEINKE: Okay. Edison Electric Institute, 7 as you know, is the association of investor-owned electric 8 utilities. oon its behalf, and my own, I welcome the opportu-9 nity to discuss our projects this afternoon with you and 10 caution that any conclusions or generalizations that I make 11 are limited only of those to our member companies.
12 We have seven employee selection testing pro-() 13 jects that were all developed on a consortium basis. Con-14 sortia of member companies voluntarily elected to band to-15 gether to sponscr the development and validation and subse-16 quent use of employee selection tests.
17 -
This came about -- and the historical reason I 18 think is important -- back in the late 1960s, early 1970s, 19 there was generally a~ lot of assault on testing in this i
- l nation, in particular on employee selection testing. The 21 first and most important landmark case that found against 22 an employer under the Equal Employment Opportunity Act of E
- 1964, the Civil Rights Act of 1964 rather, was in fact Greggs l
l f}
%/
24 versus Duke Power Company, U.S. Supreme Court 1971.
25 Because of this and other cases involving some
441
- 9-5-SueW. t of our members, a lot of our member companies became some-
/T . However, by the mid 1970s, occupations for
(._ / 2 what test shy.
3 which training was highly sensitive began to notice that 4 the work force had diminished in quality overall.
5 This shows up best and first of all in training.
6 It's no surprise that Dr. Zeidner should have been reporting 7 a good deal of training criterion ~ reports. It's common first 8 when you pull someone in when you are training them to find 9 out where the deficiencies are.
10 The interest began with nuclear operator selectio n.
11 However, to have developed a consortium project for nuclear 12 operators alone would have proven extremely costly. So, our e-( w) 13 first project, the plant operator selection system, which we 14 call POSS, was designed to select operators for fossil and 15 hydro plants as well as for nuclear.
16 This was followed by a maintenance project, 17 a physically demanding job projects, which includes mainte-18 nance jobs, and first line blue collar supervision, all of 19 which are used in and for nuclear plants. We also have 20 clerical positions and meter reader project, system operator, 21 power dispatching positions project, and first line white 22 collar supervision,~which in general are not nuclear jobs.
23 As a response to, and in preparation for, this 24 meeting I informally surveyed the forty-seven member companies
('-)}
25 which operate nuclear plants. Of the forty-seven member
442
- 9-6-SueW 1 companies, thirty-nine participate in our employee selection n
s- 2 consortium projects. This, by the way, is a significantly 3 higher proportion than of the non-nuclear companies. It 4 reflects perhaps the size of the companies as well as interest 5 in and need for improved employee selection.
6 Of the forty-seven companies I surveyed --
7 MR. REED: Dr. Kleinke, when you say thirty-nine 8 participate I guess in the selection process, do you mean 8 that they use selection tests on a reasonable basis?
10 MR. KLEINKE: No. I mean that they participate-11 in the EEI projects. That is, the projects to develop and 12 to use the tests.
(/ ~) . 13 MR. REED: Well, would you have any idea of how 14 many use a reasonable basis of the testing, let's say, for 15 nuclear plants?
16 MR. KLEINKE: Okay. Of the forty-seven, we 17 surveyed all of them. There are thirty-nine companies, not 18 the same thirty-nine by the way, although there is great over-18 lap, there are thirty-nine companies who do use some form 30 of aptitude testing for selecting operators.
21 The number for maintenance workers is almost as 22 large. Our own maintenance project is much newer than our 23 operations project and many companies will be coming on line
/~ 24 late '85 or some time during 1986.
N ]J 25 So, these numbers are confined.
i i
__ _ _ _ +
443
- 9.. SueW 1 MR. SHEWMON: Participation means they send
(
k~/ 2 money, they send data, they read your reports?
3 What do you mean when you say thirty-nine 4 participate?
6 MR. KLEINKE: Okay. I have two thirty-nines 6 now, unfortunately.
7 MR. SHEWMON: I know.
8 MR. ~ KLEINKE: I really wish those numbers were 9 one different.
10 MR. SHEWMON: I understand the difference.
11 MR. KLEINKE: Yeah.
12 MR. SHEWMON: But.the first one you used, you
' ) 13 (s. used the word " participate." What does it mean?
14 MR. KLEINKE: To participate in one of the 16 studies means, first of all, you do send rc.oney in order to 16 support the effort.
17 Second, and equally important to us, you send 18 subject matter experts, line supervisors, to initial meetings 19 to help decide what the task and job analyses shall be.
I E You then -- I'm going to extend my answer to 21 your question, because it fits my agenda. Okay.
22 MR. SHEWMON: Fine.
23 MR. KLEINKE: You then have your employees parti-i PT 24 cipate in the extensive job and task analysis surveys-. These i.
\g 25 things are essentially questionnaires that ask, do you do this l
l l
444
- 9-8-SueW i on your job.
r,
() 2 Then, you also have your employees participate 3 in the experimental testing. And their supervisors -- in 4 our case, two supervisors for nearly every incumbent --
5 rate their performance using a behaviorally anchored rating 6 scale of four such rating. So, the companies participation 7 was quite active during the development and validation.
s We find that currently we have twenty-six 9 companies actively using POSS, the plant operator selection 10 system, and another two gearing up to use it right now.
1 11 Eleven companies ushgameasure of aptitude for 12 selection other than POSS, and eight companies that do not
() 13 report use of aptitude tests for selection at all. These 14 eight, of the eight the general selection seems to be the 15 use of interview and rating of training and experience, and 16 they report relying very heavily on nuclear navy experience 17 for initial recruitment.
18 In other cases, we have some companies who are 19 listed as active nuclear companies who are not hiring opera-20 tors because of the state of construction of their plants.
21 Companies,-as I indicated, and as Mr. Cassidy H indicated before me, are still very much concerned about the
- EEO implications of using selection testing, that validating I
24 gs a test, demonstrating its job relatedness, is under the law 25 an adequate defense when charged with illegal discrimination.
-- ~ .n- -- .-
445
- 9-9-SueW g However, that defense can in and of itself be g
(_ 2 quite expensive. I earlier on outlined the sequence of J
3 tasks that we go through in developing any one of these 4 projects. And I would like to repeat it somewhat, emphasiz-5 ing that the development of an employee selection aptitude 6 battery is not a casual or light activity.
7 First is the job and task analysis which leads 8 to two activities. One is the identification of the tests 9 that should be used in the experimental battery and the other 10 is the construction of the performance appraisal system. In 2
11 our case, we did use behaviorally anchored rating scales.
12 Dr. Zeidner correctly suggests that performance
,m 13 appraisals on a company-by-company basis do not provide (s ))
14 adequate criterion data.- There is too much variance between 15 companies, too much variability between companies, in which 16 forms they use. We find even within companies there is 17 variability.
18 Also, ratings tend to suffer from lack of 19 spread among the individuals, that to a psychometrican 4
20 spread or variance-or variability is the mother's milk of i
21 correlation. And we_need that separation in employee 22 performance.
23 Far too often, performance appraisals in all 24 occupations, public, private, tend to find far too many 25 people who are wonderful, satisfactory and not far enough i a
v - s -_
w a -- --n-
446
- 9-10-SueW t people who are marginal or unsatisfactory.
ss/ 2 This then led to the testing identification 3 and testing and performance appraisal of incumbents actually 4 on the job. In our own plant operator selection system 5- project, we had about eight hundred nuclear operators from 6 among the approximately thirty-four hundred operators over-7 all. They were randomly selected in plants with another 8 layer of sampling at the plant level.
, 9 So that we randomly selected plants and within 10 plants randomly selected people, except that we included 11 all of the protected group members we could find. Protected 12 group in EEO log means minority, female, handicap, Vietnam (n) 13 veteran, veteran, and last we did not necessarily say: Go 14 for everybody over age forty and under age eighteen. But 15 that should have been done as well.
16 That enabled us at the next stage to conduct 17 the analysis, the differential prediction study that is 18 one of the issues that Dr. Zeidner suggested before lunch.
19 I must say that in contrast to his findings 20 where there is no differential validity, which he says 21 that he found that in general the same predictor performance, 22 the same performance on the test, does not have different 23 predicted performance on the job.
24 We found in nuclear as well as non-nuclear v
25 for our operators, and indeed in all of our projects, that
447 I
- 9-ll-SueW. 1 if we were to use the separate regression lines for each
.2 of the protected groups we actually would have hired fewer 3 members of those groups, so that using the overall regres-4 sion line based on everybody, we find that that really 5 overpredicts ever so slightly the performance of members 6 of protected groups.
7 Dr. Zeidner would be delighted to hear also, i a by the way, that utility analysis was performed for both
- 9 the plant operator selection system as well as for the 10 maintenance system, found that a nuclear plant level 11- operator saves the company on average approximately --
12 Dr. Mascitti, I'm groping, eight thousand dollars for
~
,) 13 plant level and twenty-five thousand for control room?
- 14 MR. MASCITTI
- Well, twenty-six thousand 15 dollars for --
16 MR. KLEINKE: For control room operator.
17 Per hour, per year. Now, I've got to tell you something 18 about that twenty-six thousand dollars.
19 That is such an underestimate that it's un-20 believable. In every case, we took every assumption possible
, 21 and took the conservative side.
i i'
22 Had_we took even the. average assumption, we 23 would have ended up with an annual savings so great nobody
'~N N would have believed us.
s t 25 MR. EBERSOLE: What is this savings compared
448
- 9-12-SueW 1 to?
3 s
2 MR. KLEINKE: Compared to the previous selection, 3 whatever had been going on.
4 MR. EBERSOLE: You mean, if he has gone through 5 this test, that's the anticipated savings?
6 MR. KLEINKE: Yes, per job, per year. And this 7 is cumulative. So that you fill a job in 1985, that twenty-8 six thousand per year per savings goes on forever.
9 MR. EBERSOLE: Tell me, these tests start at' 10 the supervisor level and go downward, you know, into the 11 peon structure. Do they-go upward into the managerial 12 structure as well, any of these tests?
() 13 MR. KLEINKE: The highest we go into managerial 14 structure is a separate battery for -- or a separate program 15 for blue -- first line supervision. We don't go above 16 that.
17 MR. EBERSOLE: And that's still much below 18 the management and Executive Secretary, isn't it?
19 MR. KLEINKE: That's right. It's the first 20 one out of the represented class.
21 MR. EDERSOLE: So, there is none for the manage-22 ment and executive sector?
i 23 MR. KLEINKE: None sponsored by EEI.
24 l
.f-}
\,,/
MR. LEWIS: Do I understand this twenty-six 25 thousand going on forever, is that on the. assumption that
1 449 1
- 9,-13-SueW' I without the system you make a bad selection, he stays in C'# 2 the job forever?
3 MR. KLEINKE: Yes. Or, if without the selection 4 you make a good one and he stays on the job forever.
5 It's against the base of what was.
6 MR. LEWIS: Sure. But if you make a good
. 7 selection anyway, then you are not saving very much so the 8 gain.must come from discriminating against the bad choice 8 with the old system and the assumption that the bad choice M stays on the job forever may be a little bit unrealistic.
11 MR. KLEINKE: But the assumption.that the good 12 choice stays on the job forever -- see, the measure is against 13 the mean of what went past.
14 MR. LEWIS: I understand that. But the mean of 15 what went past was either that you got a good choice by 16 mistake, which is just fine, or you got a bad choice and 17 that he stays on the job forever.
18 You can't keep collecting twenty-six thousand dollars forever without assuming that your bad choices stay on the job forever.
21 MR. KLEINKE: Or are replaced by an average choice.
23 MR. SIESS: The good guys may go do something O' else, too.
26 MR. LEWIS: Yeah. Okay.
450
.#9-14-SueW 1 MR. KLEINKE: You know, I live in the world
/ i
\ /. 2 of symmetric distribution, so if you tell me something is 3 .three points below I will automatically think of what goes 4~ on three points above.
5- MR. LEWIS: I live in a world in which we try 6 to get rid of inferior people.
- 7. (Laughter.)
8 MR. KLEINKE: And we try to select superior 9 ones.
10 (Laughter.)
11 We then use-the data collected at the experimenta l 12 testing and appraisal phases and analyzed in order to select m
13 the final test battery. The final test battery, while 14 some concern is given to keeping it relatively brief, the 15 great concern is twofold, is to increase the job-relatedness, 16 to increase the validity to-the maximum extent possible.
17 ~
And also with an eye on the adverse impact with 18 the differential -impact of the selection of majorities or 19 '
males versus minorities or females.
l 20 Now, for our mairitenance project we have very --
21 we gave what turned out to be an impossible charge to our 22 contractor. We told the contractor, we want you to select 23 four batteries and we will pick which one~of the four bat-I ['*s 24 teries we are going to use. One of the batteries must be
's_
26 the most valid battery possible, the most job-related one u-
451
- 9-15-SueW 1 possible. The second one should be a short version of that
,m.
k--} 2 that's nearly as valid. The third one should be the one 3 with the least adverse impact that also is job-related.
4 And the fourth one should be a short version of that.
5 So, we had most valid, long, short and least 6 adverse impact, long, short. In trying to assess the --
7 or trying to select tests having least adverse impact but 8 some validity, the consultant was dismayed to find that 9 reducing adverse impact against women increased it against 10 minorities or vice-versa.
11 So he threw his statistical and logical hands in 12 the air, and we accepted the surrender and said: We will,
() 13 therefore, go with the most valid battery, a finding that 14 I've been able to share informally with some other colleagues.
15 One -- the final point in the selection --
16 MR. REED: Before you leave that maintenance 17 test, you confuse me a bit with the four tests and stuff.
18 But for our interests, many times we refer here to all-19 thumbs mechanics doing things wrong in the work place which 20 are very highly safety-related and can lead to problems.
21 Now, in these tests, do you think you can 22 separate the all-thumbs mechanics from those who could 23 fu'nction well if trained for the work?
24 MR. KLEINKE: On average, yes, t 25 MR. SHEWMON: And you do it all with a paper I
l
452
- 9 6-SueW 1 and pencil test?
2 MR. KLEINKE: That's correct.
3 MR. MICHELS: On an average means that you 4 would be right what fraction of the time?
5 MR. KLEINKE: Sixty-five percent.
6 MR. MICIIELS: Sixty-five. Thank you.
7 MR. KLEINKE: Sixty-five percent. My interpreta-8 tion of the validity of point three is about a thirty percent 8
improvement over chance, where given a fifty / fifty situation 10 you are now right sixty-five percent of the time and wrong 11 thirty-five percent.
12
~
That's a thirty percent improvement and the 13
_.j best I can say is that I would dearly love to go up to 14 Atlantic City this weekend with a sixty-five percent chance 15 of knowing whether it was going to come out odd or even, or 16 red or black.
17 MR. SIESS: Yeah, but that's only thirty-five 18 over chance. And bow many people are hiring by flipping a I'
coin?
20 MR. KLEINKE: Anyor.e using reference checks 21 only, or nearly almost ratings of training and experience.
22 Such things tend to have validity coefficients in the 23 neighborhood of about point zero three.
r~1 24
- ! Interviews tend to be at about point one. So, 25 pitting an interview, say, against a test the interview would
453
- 9-17-SueW 1 then be fifty-five right versus forty-five wrong, while
^w-
~
2 the test would be sixty-five right versus thirty-five 3 wrong.
4 MR. SIESS: Now, how about just hiring navy 5 men against non-navy?
6 MR. KLEINKE: If you have hired nothing but 7 navy men in the past and use your criterion of success as 8 the top half of your performers, then half of them will not
- 9 be successful.
10 MR. SIESS: It's obvious I can't argue with 11 that.
12 MR. KLEINKE: That's right. All I said was C)
( 13 the average is at the fifty percent level.
14 Half the world is above average by most i
15 definitions and medians. And that's the view if you look 16 at --
17 MR. SIESS: And your sixty-five then is compared 18 with navy men as a fifty / fifty base?
19 MR. KLEINKE: That's correct.
20 MR. SIESS: Okay.
21 MR. MASCITTI: But people coming from the 22
- nuclear navy are tested quite extensively though in order i 23 to get into the program.
- s 24 MR. SIESS: But your base is the navy, then?
! gh 25 And you are doing two to one compared to fifty / fifty on l
1
--% r - - - ,, --w-w --, -
y . x - ,,A - . . - --A, a _
454
- 9-18-SueW g the -- you've moved well up on the percentiles?
s 1 i
+
2 liR. KLEINKE: . Yeah. Sixty-five/ thirty-five is 3 about two to one. Yes.
4- MR. SIESS: And that's using those screening 1
5 criteria on non-navy people?
6 If you use navy plus screening, would you end 7 up somewhere still higher?
i 8 MR. KLEINKE: I expect so, because any time 9 you add a variable -- any time you add another criterion 10 into the -- another selection. device, you improve the 11 prediction.
12 MR. SIESS: Only if the criterion is pertinent N
13 to the job.
}
14 MR. KLEINKE: Yeah. Sorry.
15 For the -- a final point I noted during 16 Dr. Zeidner's presentation, his comment about sample size 17 and performance appraisal weaknesses being in general the j
li reasons why in the past we have had problems with validity 19 generalization in the private sector, consortium projects l
l 20 like this, of course, address the sample size problem, 21 in that we are able to get menbers that approach and indeed 22 exceed those on Table 1 in his presentation.
23 In terms of validity generalization,.which is c 24 . a very hot topic in the business right now, our plant 25 operator selection project was cited in the 1984 Annual
4 1
1 455 69-19-SueW 1 -Review of Psychology as being an example of a practical 2 ~ test, a field test, and demonstration of validity generaliza-l I
3 tion done the right way. Something that we are rather E 4 - proud of. ,
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And we are surprised by finding that cite.
\_,/ 2 Thank you for your attention. Are there other 3 issues before Dr. Mascitti -- yes, sir.
4 MR. REMICK: Your basis of 47 people, I think 5 IMPO has 55 members. What is the difference between the 6 full membership of IMPO and the 47 nuclear utilities --
7 is that with operating plants, or --
J 8 MR. KLEINKE: No. That difference would be g publicly owned, or not investor-owned, such as TVA or 10 Bonneville, and I believe IMPO also might include some 11 research reactors..
12 I am not certain'of IMPO's membership list.
) 13 MR. REMICK: There are 55 nuclear utilities 14 that are members. I was wondering what the difference 15 was.
16 MR. KLEINKE: Then the difference is the difference 17 between investor-owned and total, plus or minus the possibi-18 lity I didn't get exactly all of our members.
19 Give me a standard error of the survey of about 30 ltwo companies.
21 MR. REED: I expect that you don't, perhaps, 22 understand the importance of nuclear plant safety, and 23 perhaps the human tie to nuclear plant safety in its 24 importance, but do think, as an opinion -- I am trying to 25 get an opinion from you -- that aptitude, natural ability l
457 10-2-Jo3Wal 1
selection testing is important to the safety issue, and how
(- .
important is it compared to training.
hs 2 MR. KLEINKE: First of all, your assessment of 3
4 my not aptitude, but achievement in the field of nuclear 5 Pl ant operation is correct.
6 I don't purport to be particularly knowledgeable in nuclear operation, okay? I am a testing person who is 7
8 affiliated with the electric utility industry.
g
!!owever, as a psychomatician, I am interested in 10 more than just the narrow field of. employee selection, 11 testing. I have to say that I recognize that training in 12 any complex area has to rest on some floor of ability.
() 13 14' Th at one , the' trainees must come in with some basic ability, and the greater amount of that basic ability, 15 the more readily they are trained.
The more effectively training can go on. I 16 17 know this does -- is not directly related to safety, but I 18 must mention anecdotely that one of our companies has found 19 that it has to hire far fewer entry level trainees using 20 POSS than they had projected on the basis of pass experience, 21 simply because they get fewer people failing out of 22 training.
23 Now, to the extent that the training is valid, 24 and the training promotes safety, it means we are putting 25 a better product -- we are putting a better -- a work force l
l l
10-3-Jo3W31 458 1 with better potential into training initially, and i
j 2 therefore the content can go more directly toward safe 3 operation.
4 That is all I feel --
5 MR. ZEIDER: If your question asks whether a 6 selection battery could effectively predict the people 7 that would have accidents versus those that would not, and if 8 you tell me the percentage of individuals who have accidents 9 are very small, the probability of a test with a high ~ degree 10 of validity improving that situation is not very great.
11 One of the most -- for example, in the military 12 setting, one of the most common questions in 30 odd years
[v ') 13 that the Army Research Institute was asked, is how we could 14 reduce the number of individuals that might defect in 15 intelligence work.
16 But the number of those individuals are very, very 17 small.
I 18 If you examine something like the Taylor-Russell 19 tables, if would take almost a perfectly predictive test M to improve that situation.
21 MR. REED: But it is sort of the opposite, because 22 we are talking about human errors in the magnitude of fift; M or more percent in incident.
24
,e N MR. ZEIDNER: If that is the case, there is a lot
~
M of room for valid test to improve that situation.
= .
10-4-JoIWal ~ 459 1
MR. REED: Classification on incident.
k,,/ 2- MR. SIESS: Not half the actions taken by operators 3 are wrong.
4 MR. REED: Of the wrong actions, fifty percent.
1 5 MR. KLEINKE: The question has to be, what 6 proportion of the operators take wrong actions? Ones that
~
7 result in the incident reported this morning.
8 That for me is a. completely rhetorical question, 9 because I have no idea what the answer is.
j 10 Again, thank you for the opportunity, and it is 1
11 my distinct ~ pleasure to unhook this thing, and introduce 12 Dr. Mascitti of Wisconsin Electric.
<g 13 MR. WARD; That you.
.( )
XXX INDEX14 MR. MASCITTI: We have gone from the general to 15 more specific, and maybe with that trend of the more 16 specific, maybe we have also taken a trend toward a little 17 greater boredom.
18 I hope that what I will now present to you won't 19 increase that to a great extent.
20 However, when we talked about meeting with you 21 today and the kinds of things that we felt it would be 22 important to pass on, we wanted to also cover one area of U -- which would involve a little explanation of the actual 24 test.
s 25 ' There are many, many different types of tests i
i
~
1 10-5-JoeWal. 460 1 out there in the academic setting.
1 r 2 There are psychological tests in the broad sense, 3 personality tests, aptitude tests. I will use the termi-4 nology or the term selection test, because there are many 5 differenti types of tests that can be used for selection.
6 The test that we use, the EEI test, are paper 7 and pencil tests in a multiple choice format. They are 8 machine scoreable, or they can be hand scored.
9 The operators test that was mentioned earlier, 10 the POSS, are comprised of three components; the aptitutdc 11 index, and experience index, and a personnel index .
12 The first component is comprised of five 13 aptitudes; reading comprehension, spacial ability, mechanical 14 concepts, mathematical usage, and perceptual speed.
15 The first test in the aptitute component is a
! 16 test of reading comprehension. It measures a person's 17 . ability to read and understand the type of material found 18 in power plant training manuals.
19 The reading comprehension test consists of five 20 reading passages, each followed by several multiple choice 21 questions about the passage.
22 The examinee is instructed to read the passage 23 and answer the questions by choosing among a number of 24 p different alternatives.
25 This test not only measures a person's recall of
10-6-Jo Wal- 461 )
.g the specific facts presented in the material, but also
- <w k ,) 2 evaluates a person's ability to apply a technical or 3 scientific concept which is explained in the material.
4 This test is very similar to the type of task 5 a new employee encounters in training. In fact, the 6 reading passages are actual subject content taken from 7 power plant training manuals.
8 It includes material on instrumentation, 9 measurement, and physical and mechanical principles.
10 This test in included in both the POSS operations, 11 and MAST maintenance tests.
12 MR. REMICK: ' Question: On that reading 13 comprehension, is there a time limit?
[U~')
14 MR. MASCITTI: Yes, there is; a twenty minute 15 time limit.
16 MR. REMICK : What do you do with people who are 17 dyslectics, anything special, or are they screened out?
18 MR. MASCITTI: They would do very poorly on the 19 test.
20 MR. MASCITTI: The second test, spacial 21 relations, measures the ability of an individual to visualize M the proper assembled form of an object.
23 This test has twenty problems. At the beginning s 24 of each problem is a picture showing the component parts of s
%_ 25 an object, each component part is marked to show how the 1
, . -. . _ _ ~ .
I i
- 10-7-JoeWel 462 1 object is to be assembled.
- t. 2 This is followed by'five pictures showing five 3 different ways the parts could be assembled. The examinee 4 must determine which form the object would take if it were.
5 properly assembled.
6 The spacial relations test is a crucial measure 7 of an applicant's mechanical ability . , since many mechanically 8 related tasks require individuals to follow instructions
'9 in assembling and disassembling parts of machinery, tools, 10 et cetera.
11 Spacial relations is also important for employees
! 12 who must understand the inner-workings of a system. To
> p) v 13 read instruments and gauges, and conceptually visualize 14 what is happening inside of a system. This test is used in 15 both the'POSS and the MAST batteries.
16 The third test, mechanical concepts, is also 17 a measure of mechanical comprehension. This test measures 18 the ability of an examinee to understand mechanical
. 19 principles.
" Each item contains a pictorial description of 21 a mechanical situation'followed by a question and three B
22 possible answers. The test is intended to measure the 23 ability of a person to perceive and understand the relation-24
- /'~s ship of physical forces and mechanical elements in practical 25 .
situations.
l i
I
! . , - ,, . . _ _ ~ - - -
8-Jo:W21 463 1 The test was constructed based on an analysis
\ 2 o'f .the task performed in the job and the pictures deal with 3 gears, levers, pulley systems, valves, centrifical force, 4 water flow, gravity, pressurized air, et cetera.
5 Tests of mechanical comprehension have a long 6 and very successful history when used for selection of 7 manual jobs. Previous research has shown that manual 8 workers who have a good understanding of mechanical principles 9 have fewer accidents, and are less prone to error.
10 The mechanical concepts test is used for both 11 the POSS and the MAST.
12 The next test, mathematical usage, measures skill f% -
There t
(
) 13 in solving and manipulating mathematical relationships.
14 are three sections covering formula conversion problems, 16 algebra problems, and story _ problems.
16 The mathematical usage test was developed based 17 on an analysis of the job duties and training material.
18 Therefore, it measures the level of mathematical 19 aptitude required to complete training successfully, and 20 effectively function on the job.
21 The maintenance battery also includes a math test.
22 The last test in the aptitute series is a 23 perceptual speed and accuracy test. It measures the speed and 24 accuracy in reading tables and graphs.
.b(~N M This series of aptitute teste measures the important
.10-9-JoeW21 464 1 abilities that are needed to perform power plant work.
,s-k)y 2 They measure an individual's capability to learn 3 the technical aspects of operations and maintenance work.
4 Therefore, they can be used for applicants who 5 have previous power plant experience, and they are particularl: r 6 useful in selecting among applicants who do not have prior 7 power plant experience.
8 The aptitude tests focus heavily on mechanical 9 comprehension and spacial relations. The research validation 10 found that these abilities are the most significant requisites 11 of successful performance -in operating and maintence work.
12 The next component of the POSS is a previous 13 experience questionnaire. It contains questions related to
%)
14
-a candidate's previous experience in school, work and 15 recreational situations.
16 A candidates answers to the. experience questionnaire 17 are scored according to a number of scales that measure 18 past patterns of overall effectiveness in the areas of 19 vocational interest, work orientation, stability, and 20 tendencies towards potential weaknesses in coping with 21 stress.
22 The third component of POSS is called the 23 personnel questionnaire. It consists of statements requiring l 24 true or false answers.
/]J N 25 Appli~ cants indicate whether they agree or disagree I.
r
10-10-JoeWal 465 1 with statements that describe an opinion or personal
( )
N ./
2 circumstance.
3 The personnel questionnaire measures aspects of 4 temperament found to be related to emotional stability.
5 I should note that the personnel questionnaire did not 6 statistically validate for the nuclear jobs. This is 7 probably due to the fact that nuclear plant personnel 8 participating in this research study were already closely 9 screened for emotional stability.
10 The personnel questionnaire is still administered 11 to nuclear applicants for the purpose of research to 12 determine its actual effectiveness in on-going selection.
,a
() 13 I should also mention that many utilities use 14 an additional test which is not part of the EEI battery, 15 such as the MMPI to measure emotional stability.
16 The maintenance battery also has an additional 17 componont to the aptitude test. It is called the background 18 and opinion questionnaire.
19 The background and opinion questionnaire for 20 maintenance is similar to the experience and personnel 21 It measures personal characteristics index for operations.
22 which was shown to be related to effective power plant 23 maintenance work.
24 For both the POSS and the MAST, composite scores
,/ ]
i !
25 are calculated for each component and for the overall test
10-ll-JoeWal' 466-g
. battery, thus the' tests provide a measure of ability or I) 2 aptitute and a separate measure of adaptability.
3 A candidates standing on the aptitute index is c
4 interpreted as a measure of the person's mental abilities 5- -that are important to learn -power plant work and to effectively -
6 function on the job..
- -7 Candidates with high aptitude scores should be
- 8 able to understand mechanical principles, comprehend written i
g materials, use-and understand mathematical relationships, 10 and perceive details quickly and accurately.
11 The experience and personnel questionnaire for the J
12- plant operator battery, and the background and opinion
() 13 . questionnaire for the maintenance battery provide an account of a person's history and personal characteristics.
14 4
- l 15 The scoring of these questionnaires is based upon 16 the relevant history and personal characteristics that were i
17 found in successful- power plant workers.
18 Whereas the aptitute tests measure the ability 19 of a candidate to learn and perform the technical aspects of 4
20 the job, the experience and background questionnaires measure l 21 the personal characteristics of the candidate to determine i
l 22. whether or not'e person can effectively adapt to the job e j 23 demands of power plant work.
, s 24 The POSS project was initiated in mid-1978, and ,
i 25 was completed in September of 1981. The research was ;
i r r
F
10-12-Jo Wal-467 1 conducted by very prominent industrial psychologists at t
"% 2 personnel decisions research institute. A total of 70 3 investor-owned electric utility companies participated 4 in the project, representing fossil, nuclear and hydro 5 power plants.
6 MR. REED: Dr. Mascitti, you said it was 7 initiated in mid-1978?
8 MR. MASCITTI: Right.
9 MR. REED: Does that have any relationship to 10 the Three Mile Island incident?
11 (Simultaneous conversations.)
12 MR. MASCITTI: Research information was obtained A)
(y 13 and analyzed from thousands of company officials, supervisors, 14 and plant operations personnel working in hundreds of 15 plants.
16 Three thousand four hundred operators were 17 tested with a battery of experimental tests and measures of i 18 work performance were collected for these individuals.
18 Statistical analysis reveals that the POSS
- test significantly correlated with performance. The validity 21 was found for all race gender groups, as Dave Kleinke
~
22 mentioned earlier.
23 Thus, the POSS tests are valid for minorities and 24 We obtained similar findings for the MAST.
females.
('s}
25 Our experience with the POSS test has been very t
. , . , , ,n , , . - y - --
10-13-JoeWal 468 1 favorable. Wisconsin' Electric first started to use the POSS g3 j 2 test . At the same time, we went to a new program of 3 selecting and training entry level operating personnel from 4 the local community.
5 These individuals had no k rowledge or experience 6 in the nuclear plant facility. Some were right out of high 7 school. The POSS test identified a group of candidates who 8 were able to successfully complete a rigorous power plant 9 training program .
10 We found that these candidates had exceptionally 11 high aptitute, primarily in the area of mechanical compre-12 hension, and they adapted well to plant work. Other companies
[~)
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13 have had similar experiences.
14 One company reported that they were able to reduce 15 the number of trainees by twenty percent, because there were 16 fewer dropouts as a result of using the POSS.
17 Another company reported that the quality of the 18 candidate who has the POSS was so high that the trainees 19 were challenging the instructors for more demanding material.
20 Our overall feedback from companies is quite 21 positive. Supervisors from the nuclear power plants have 22 commented in numerous situations of the high caliber of 23 employee they are receiving as a result of the application 24 of POSS, and we expect this trend to continue.
7s L i
\/
M What I just covered here related primarily to L.
469 10-14-JoeWal the POSS and the MAST test, which is for the operating 1
r s.
/ i A.m / 2 and maintenance areas.
3 There are other tests that EEI has sponsored and 4 developed. One other test that is used for the nuclear 5 setting is the first line supervisor test , as Dave mentioned 6 earlier.
7 But I did want' to get back to one other comment s' that was made regarding are there tests out there available 9 for higher level management, and yes, there are.
10 EEI does not sponsor any test probjects, but at 11 Wisconsin Electric we have been using selection testing for 12 all levels of management for quite some time.
()
~
13 MR. SHEWMON: Do'you feel that given the positive 14 feedback, and your. conviction that this is a good thing, 1
15 that there are things which the Government ' regulators could 16 do to, or should do to help -- to help in this area?
17 MR. MASCITTI: Based on the statistics that Dave
- . 18 had mentioned, it sounds like a number of companies -- a 19 vast majority of the companies are using selection testing.
20 I am not familiar with the different types of 21 vehicles available to-you to encourage nuclear facilities H -to use selection testing.
M My position would be one of encouragement, but 24 not necessarily rulemaking, and the reason why I say that 25 is that rulemaking, the areas of testing and test validation
470 10-15-Jo Wal:
1 research is a changing field, and in order to keep up with
,a .
x- 2 what is going on, we at EEI are constantly looking at our 3 . test batteries for refinements and making changes when 4 appropriate, and I think if there was maybe something like 5 a . guideline or some sort of other encouragement, that that 6 would be helpful.
a 7. MR. SIESS: From the regulatory point of view, 8 and perhaps even from a safety point of view, it would seem ,
9 that.one measure of effectiveness might be based on licensee 10 event reports, which is the number that keeps coming up, 11 47 percent due to human error, is that what the ' figure is, 12 or 57 percent?
O)
( 13 You said the vast majority of the utilities 14 are using some sort of selection process, and I assume that-0 - 15 ' is natural aptitude selection, is that right?
! 16 MR. MASCITTI: Yes.
17 Well, if we knew which ones were MR. SIESS:
18 using it, and which ones weren't, we could certainly look 19 for a correlation between the -- either the number of 20 LERs due to human error, or the percentage of LERs due 21 to human error.
22 t
That would be a rather gross but not too' difficult 23 '
correlation -- validation.
24 MR. WYLIE: 47 percent use --
25 MR. WARD: Charlie, would you use the microphone,
10-16-Jo:Wal 471 1 please?
O.
'q /' 2 MR. WYLIE: Just for clarification, the 47 percent 3 .using some type of natural ability. selection was for operators 4 wasn't it? .
5 MR. KLEINKE: It was not 47 percent. It was 6 39 companies out of 47.
i 7 MR. WYLIE: Okay.
8 MR. SIESS: That would make the correlation very 9 easy.
l 10 MR. WYLIE: But that was for operators only wasn't 4
11 it?
12 MR. SIESS: Who else makes mistakes?
MR. WYLIE: Well, maintenance people.
[x )\
s 13 14 MR. SIESS: Well, okay. We know maintenance 15 errors. But you can separate LERs out from operation and 16 maintenance.
17 MR. WARD: Mr. Kleinke,.would you clarify the 18 39 out of 47. Are the 39 using both POSS and MAST?
19 MR. KLEINKE: No.
20 MR. WARD: Can yod break that down.
21 MR. KLEINKE: 26 right today using POSS, 2 about 22 to implement POSS within the next month; 11 using something 23 else.
- 24 I hope that adds to 38. 8 not using testing.
25 This is for operators.
1'
- 10-17-JoeW21 472 1 The numbers for maintenance are at about the s_/ 2 80 to 90 percent level of _that, but rising because the 3 maintenance project is newly instituted.
4 MR. SIESS: That is still a substantial sample.
5 MR. KLEINKE: However, I must caution that that 6 is the current state of affairs, and of course"by and large 7 that is for hiring people who may be currently trainees.
8 One would have to look at historical data in 9 order to find out who was associated with an event. We 10 have a history where particularly in the early '70s and 11 mid '70s, far fewer companies were using selection testing.
12 MR. SIESS: But if we even had 25 percent -- if I there were even ten percent of the companies had all their
(-) 13 14 operators qualified by natural aptitute testing, and is selected on that basis, that would be a pretty good sample is to see whether it shows up anywhere in the criteria that 17 affects safety.
18 MR. KLEINKE: I agree. Also, the very, very 19 informal criterion of favorable mention in the Wall Street so Journal article of about a year ago, correlates extremely 21 highly with participation in EEI testing.
22 All of the companies mentioned favorably in that 23 - article were very actively engaged in the EEI projects.
24
/-s MR. SHEWMON: And the basis for the selection N-]g 25 by the reporter was --
i
10-18-Jo;Wal' 473 1 MR. SIESS: NRC people. I think that was the 2 interview with Region III.
3 MR. MICHELSON:How do you sort out the other 4 considerations. You know a company that has these testing 5 programs also probably has a lot of other forward looking 6 personnel policies and programs and training and all the 7 good stuff.
8 Collectively it shows up good, but how do you J
9 sort out testing as being the element that caused it to be 10 good?
11 MR. KLEINKE: I would not allege that testing 12 causes a well known Florida company to have excellent
! b v
13 weather, i
14 MR. WARD: Thank you, Dr. Mascitti.
15 MR. MASCITTI: There are a number of pieces that i 16 one can contribute to accidents. Certainly lack of-mental 17 ability or natural ability would be one. But you would 18 have to consider other things such as a good behavioral 19 reliability program, physical ability. We have found that 20 we have a number of accidents because of a lack of physical.
21 MR. ZEIDNER: Can you give us a validity range ,
22 that you have been obtaining with these several battery, 23 and the kind of criteria employed in obtaining those? ;
24
, g' 3 MR. MASCITTI: Our validities are in the 30s if
(/ t 25
- I recall. The type of performance measures that we use were
.10-19-JoeWal I
i quite extensive.
/O
( ,) 2 of course, the rating form itself was developed 3 based on a task analysis, so many of the statements included 4 in the rating form are task-specific.
5 It also included ability. Employees were rated 6 on abilities that were judged to be important_ aspects.
7 And it was set up in a behavioral-anchored j
8 weighted format, which is considered to be one of the better 9 formats.
10 MR. ZEIDNER: I would just like to point out 11 that that is the classical seventy-five year finding of the I
12 .3 validity asymptomatic, not breaking that barrier. Although l(}
is m-13 it is' kind of low compared to what other groups are getting i 14 when employing more sophisticated ratings, behavioral-anchored j 15 ratings.
c 16 MR. KLEINKE: Excuse me. Were you referring to 17 it as the lower asymptomatic, or the higher --
18 MR. ZEIDNER: Typical.
19 MR. KLEINKE: But as an asymptode, it is a lower 20 limit, or higher limit.
21 MR. ZEIDNER: It is about the range obtained with 22 ratings.
M MR. KLEINKE: Okay. Because ours are the .3 to 24 .45 range on uncorrected, so .3 is asymptomatically low.
O 25 MR. ZEIDNER: Obviously, that means for these i
4
10-20-JoeW21 475 1 tests to have an important impact, with the .3 validity, (j 2 you have to have a good selection ratio.
3 That is, select the top 50 percent of the people 4 or have a current situation where most of the employees --
5 there is room for a great deal of improvement in the perform-6 ance of employees. That is not -- these results are very, 7 very typical, and very believable, and very respectable, 8 and reflect the problems in the field by using weak criteria, 9 but the kinds of gains that could be achieved by them are 10 modest, unless your utility analysis shows somewhat 11 differently.
End 10. 12 Su,W fols 14 15 16 17 18 19 20 21 22 23
,_ 24
, )
25
I 476
- 31-1-SueW 1 MR. KLEINKE: The utility analysis you heard,
.( \
(l 2 BDRI.was the contractor. If we really reported what we found 3 to the utility analysis, the zeroes would drop off the right-4 hand side of the blackboard.
5 MR. ZEIDNER: Well, I have to look at the study.
6 MR. WARD: Let me a'sk you a little bit of an 7 abstract question. Let's say that we knew that either Case A 8 or Case B were true, and I would like to ask you in one or 9 the other of these cases would this sort of testing be more 10 effective? 4 11 Let's say that Case A is the' situation. Let's 12 say that we knew that under Case A that most human error
() 13 of significance to nuclear power safety was caused by 14 average performers occasionally committing errors. And let's 15 say Case B, if we knew to be true, was a situation where 16 most sig...ficant errors were caused by poor performers i 17 frequently making errors.
18 Now, we don't know which is true but if one --
19 l if we knew one or the other is true, would we know whether l
! 20 testing was important or not?
21 MR. ZEIDNER: If you could just give me one 22
( other assumption. What proportion of poor performers did i
l 23 you have?
24 Was it a normally distributed distribution?
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25 l it was normally distributed --
1 I
1 I
477
- 11-2-SueW 1 MR. WARD: Yeah, let's take that.
[~h xl 2 MR. ZEIDNER: Then, Case B would clearly give l
3 you -- Case B would clearly give you the advantage because 4 tests always more effectively differentiate people on 5 extremes.
6 You could expect the validity of those tests --
7 MR. WARD:. Okay. So screening out detail is 8 more important than raising the average?
9 MR. ZEIDNER: Always.
10 MR. WARD: But I thought your statement about 11 defecting spies --
i '
12 MR. ZEIDNER: That's a very different situation.
l' /~
13 MR. WARD: Okay.
'(~N) 14 MR. ZEIDNER: In this situation, in the national is security arena, you have.ninety-nine and nine-tenths of 16 everyone performing well. In other words, not divulging 17 secrets. There is no room for improvement, because the 18 number of poor performers is less than one percent.
19 In the instance that you described, I asked 20 you if you had a normally distributed distribution of
- 21 abilities, which indicates that you have thirty-four percent 22 of the people falling in one standard of deviation and below, 1
23 and it's very, very easy to improve that situation.
24 i /s That's about the easiest situation where you
)
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( 26 have got people at the extreme.
e
. - - , - . . _ - , . - . - - - - - - - , , - - - -- ~ , - - - - - - - -
478
- 11-3-SueW
/ \
1 MR. WARD: Okay.
( }
N/ 2 MR. KLEINKE: I don't want this to become a 3 discussion of specialists, but I must point out that 4 although the abilities may be distributed normally the 5 cut is cet necessarily at one standard deviation. It 6 may be two, two and a half standard deviations below the 7 mean where we find incompetent operators.
8 I would not accept a characterization that 9 either incompetence in this industry is at one standard 10 deviation below the mean or that it is at the thirty-fourth 11 percentile.
12 MR. ZEIDNER: It's not relevant to my argument.
O 13
( ) As long as you tend toward the tail of distribution, it 14 generally becomes an easier problem in making distinctions.
- 15 MR. WARD
- Yeah.
16 MR. KLEINKE: The very thing that you said I
17 about the spread.
18 MR. WARD: Okay.
19 MR. KERR: What you are saying is that where 80 the decision is easier to make almost any system can make 21 it?
i 22 MR. KLEINKE: That's right.
23 MR. WARD: Charlie?
t 24
(~ MR. WYLIE: Yeah, two questions for clarifica-
\s_
25 l tion. As I understand it -- and correct me if I'm wrong --
t-
k 479
,#11-4-SueW 1 the POSS has been used since about 1983, '82 or '83, but
' \' 2 the maintenance, the MAST, has only been used since October i 3 of-'84?
4 MR. MASCITTI: The POSS has been used since 5 1981.
6 MR. WYLIE: Okay. What about the maintenance?
7 MR. MASCITTI: The maintenance I believe was
> 8 available in late '83.
9 MR. KLEINKE: Late '84. Our implications are 10 on a company-by-company _ basis. So that does not mean that 11 in October of '84 we turned a switch and fifty companies 12 started using it.
I 13 MR. WYLIE: I understand. It was initiated 1
14 in '84?
16 MR. KLEINKE: That's correct.
19 MR. WYLIE: So it's a relatively short. time.
17 The other question, I believe Dr. Mascitti said 18 that Wisconsin used tests for selection of managers. Was HI that what you said?
20 MR. MASCITTI: Yes, sir.
l 21 MR. WYLIE: Or, was that for selection of 22 technical ability?
23 MR. MASCITTI: No. We used tests of natural 24 ability.
[L]J 26 MR. WYLIE: To screen managers?
I L
480
- 11-5-SueW 1 MR. MASCITTI: To screen managers.
/~
s 2 MR. WARD: It's a chair with one short leg.
3 MR. WYLIE: Okay. Thank you.
4 MR. MASCITTI: Would you like to comment on 5 that?
6 MR. CASSIDY: Only to extend what he was talking 7 about, managers. We are talking _about executives on down.
8 There is a file in the -- it's a confidential file, it's 8 on the Chief Executive Officer of the company.
10 MR. WARD: Okay. Well, thanik you very much, 11 Dr. Mascitti and Mr. Cassidy. Thank you. It has been a 12 very informative session.
18 We told them we would be a little late, but 14 we ought to get upstairs promptly.
15 We will re' convene upstairs.
16 (Whereupon, the meeting is in recess at 2:16 p.m. ,
17 to reconvene at 3:50 p.m., this same date.)
18 MR. WARD: The meeting will come to order.
18 Our next topic is the River Bond Nuclear Plant. Dr. Okrent.
E MR. OKRENT: This Subcommittee's report will II be in two parts. Carson Mark was kind enough to Chair the 22 first half of the Subcommittee meeting while I was completing 23 the GESSAR II Subcommittee meeting yesterday, and so let's start with the topic that Carson dealt,with.
" MR. MARK: It sort of would be economical of
481
- 11-6-SueWt time, since the topics that came up during the part of the 2 meeting that I was looking after seemed to call for very 3 little argurient as between the Staff and the Gulf States 4 people, that I would merely announce what we covered and 5 what it looked like, and have either the Applicant's people 6 or the Staff fill in if I seemed to have failed to bring out 7 the point.
8 Perhapa having said that I would give it, I 9 think maybe I will change right away and ask Mr. Stern to 10 give a simple statement r s to whether and what there may be 11 in the way of outstanding issues or things which are yet 12 going to be settled later.
,m, IINDEX 13 MR. STERN: Thank you, Mr. Mark. I'm Steven 14 Stern, the Project Manager from the Division of Licensing, 15 Office of Nuclear Reactor Regulation. It's a very easy 16 statement to make.
17 All of the issues for the full power license 18 have been substantially resolved. There does remain some 19 residual Staff work.
20 For example, associated with license conditions l 21 such as containment venting that remains to be done. But 22 this is normal for this stage in a full power license.
23 In essence, we expect -- we fully expect to j i
'~', 24 be ready, provided the applicant or the utility can move M on removing its license conditions, to be ready in the middle i 1
i
482 1-7-SueW 1 of next month on a full power license.
2 MR. MARK: Well, as you can see, there isn't 3 really a large package of things that have to be thought 4 through there.
5 I might bring out the point that at the Sub-6 committee meeting, it was said and made clear that there 7 has been really first-class cooperation and response on the 8 part of the apple: ant in return for requests for information 9 or clearing up points. This was evidently very, very good.
10 Another item that we discussed was the fact 11 that Gulf States is using TDI diesels, which have been the 2 '
subject of a great deal of concern and attention. They have
(, 13 the same diesel motors as the ones at Shoreham. These have 14 been inspected, worked over. The Owners Group recommenda-15 tions have been all, or essentially all, adopted by Gulf 16 States.
17 Both the Staff and the applicant believe that 18 these machines are now in a really solid shape. They should 18 be in the good class of diesels from the point of view of 20 station blackout, namely in the ninety-eight plus percent 21 class for start on demand. I believe they are not as large 22 as some of the diesel motors that are in the business.
23 They are rated at thirty-five hundred horse-24 power, are only eight cylinder dinky little affairs evidently.
25 These machines, although on the nameplate called thirty-five
483
- 11-8-SueW 1 hundred, are really -- really have a limit specification of 2 thirty-one thirty kilovolt, and the applicant is planning 3 to tailor the load so that it doesn't really have to go 4 above twenty-nine hundred kilowatts.
5 They are going to be perpetually warm and 6 perpetually lubricated. There will be no need for cold 7 starts, and only once every six months or so will they 8 be subjected to a fast start.
9 I think that's all I had that I thought you 10 would like to hear on the diesels. We feel very encouraged 11 about them.
12 There has been an investigation of people at 13 the plant, conducted I guess by the Drug Enforcement Agency, 14 or some such group. Had some publicity. The applicant has 15 spent, I think it was said, thirty-five hundred manhours 16 of going over work done by the people who had come under 17 suspicion without finding any evidence of anything that 18 hadn't been done essentially properly.
19 It is thought that there is not likely to be 20 a large new public flap on this particular thing since it 21 is essentially over.
22 Region IV reported to us that the staffing 23 looked very good, and in very good shape, with senior
~1 24 operators and qualified operators. And that they wished 25 that some of their other plants gave as good an impression as t
484
- 11-9-SueW 1 that.
x
'w '
2 I think the only other thing I wanted to 3 mention, this project from the start of construction until 4 fuel load which was half donc last Wednesday, has been 5 stretched out for a total period of seventy-two months.
6 That's really a -- we are used to hearing that it's fourteen 7 years, twelve years.
8 Now, I should ask the Staff if they feel there 9 are other things on those topics during the first third of 10 the meeting.
11 MR. STERN: No. I think that's an excellent 12 summary.
() 13 MR. MARK: Applicant?
14 MR. BOOKER: Jim Booker, Gulf States Utilities.
15 We certainly concur with the statements that Mr. Stern made 16 about being able to complete the items to go above by 17 five percent power by mid-October.
18 Mr. Cahill, Senior Vice-President, would like 19 a few words if you don't mind.
20 MR. CAHILL: Well, I don't want to crow but 21 you said it, Dr. Mark. We finished this plant construction 22 in six years.
23 And although that's a very, very expeditious 24
['] pace, we didn't sacrifice quality. We met all of the
\ /
25 regulations and rules. We don't agree with all cf them. Some L
485
- l-10-SueW1 of them are not very economical or productive. But, And 2 nevertheless we knew what we had to do and we did it.
I'm very, very proud to have headed up the effort. We 3
4 don't intend to stop here.
5 We intend to have an exemplary operating record, 6 too.
7 MR. MARK: Mr. Chairman, that concludes the 8 first third of the meeting.
9 MR. WARD: Okay.
10 MR. REMICK: I have a question on this portion.
11 It's my understanding that at the Subcommittee, you did 12 discuss this fitness for duty question.
I 13 And I'm curious what initiated this? Was this 14 an applicant-initiated endeavor? Is this a Staff-initiated 15 endeavor or what? .
16 MR. NOVAK: My understanding is that it took 17 sixteen days, thirty-five hundred manhours, about twenty-five 18 million dollars lost because of the sixteen days delay.
19 MR. CAHILL: Let me address that, sir. It 20 was an NRC-initiated endeavor which arose. I think I will 21 pass this news clipping around, because this is about the 22 clearest published statement of the problem.
23 It came to the attention of the NRC that some
~ ' 24 individuals who had worked at River Bond were implicated 25 in drug use and traffic, and the concern was to +>.n extent
486
- 11-ll-SueW 3 there was at this time still people involved in this kind 2 of thing, working at River Bend, and to the extent that
. 3 there had been people there, or still were, whether their 4 .use of drugs, suspected use of drugs, had effected the 6 quality'of the work.
6 In actuality -- so, this came up just at the 7 last minute as we were waiting for the license. We met with i
e the Office of. Investigation and NRR and the' problem was i o explained to us, required our cooperation with the investiga-10 tors and in making these checks. We did cooperate with the !
11 investigators.
12 They found that basically from the Drug Enforce-13 ment viewpoint, they personally told me there was no problem 14 on our site.
la I might say that we've had, within the limits i
16 of our capability and the capability of the law enforcement
- 17 in today's laws, had a very strong drug enforcement program .
t la on site P' rough the entire period of construction, including ;
19 searches with dogs, some undercover operations, so that they 80 found that we had had a very, strong program prevention, 21 that there were none of the -- well, it turned out one of i 28 some ten or twelve names they had was on site, but had not l 88 been involved in any sensitive work. I think he was an 1 ,
j M insulator or something like that.
' ( 26 And the others weren't working there anymore.
I i
l
487
- 11-12-Sues Some of them were quality assurance people. And, therefore, 2 we checked their work. That's what took the thirty-four 3 hundred manhours.
4 We and Region IV inspectors who came to the 5 site worked through Friday, Saturday and Sunday and we got 4 out a very thorough check of the work and found there was 7 no indication that there was-any impairment of the --
8 MR. REMICK: Am I correct that permission to 8 load fuel, however, was withheld for sixteen days?
10 MR. CAHILL: No. It wasn't nixteen days. We 11 had the -- at least we thought the license was momentarily 12 expected when this came on us.
18 And that was on a Thursday. We were ready to 14 load fuel the following Monday, physically waiting for the is license. And we got it ten days later than when we were is ready. So, we lost ten days out of it.
17 I will say this, that if it wasn't for the 18 prompt way we responded to the investigation in a cooperative 18 way and also the prompt way the Region IV inspectors followed 8
up on our work that it would have taken a lot more delay than 21 ten days.
22 MR. REMICK: I'm interested from the Staff, was 88 this a result of a late allegation?
8' I'm also interested from the Staff on the basis
! U " '
I of apparently withholding permission to load fuel on the basis
488
- 11-13-SueW 1 of a late allegation?
/ T s/ 2 MR. NOVAK: Tom Novak of the Staff. It's 3 my understanding that our office -- I don't have firsthand 4 information regarding how we obtained the names of certain 5 individuals, but I think it's fair to assume that our Office 6 of Investigation was informed of the names of certain indivi-7 duals which Mr. Cahill referred to.
8 That was turned over to the Commission. Mr.
9 Denton, as I understand it, then discussed this with the 10 Commission. We brought in senior management from the Gulf 11 States Utility, shared the names of those individuals with 12 them, and from that point on they took on a response to
/ 5
( ) 13 identify what the potential would be of work performed by 14 these individuals.
15 MR. REMICK: So it was a Commission decision 16 then to hold --
17 MR. NOVAK: Clearly, it was a Staff decision 18 with close consultation with individual Commissioners. We 19 did not have a formal meeting.
- But it's my understanding that Mr. Dirks and 21 Mr. Denton and Mr. Hayes did discuss individually with a 22 number of Commissioners the situation. They made a recom-23 mendation as to what some of the action should be.
(T/
24 And it's my understanding that individually the x_/
2 Commissioners concurred in those actions.
489
- 11-14-SueW 1 MR. REMICK: Was this a case where the licensee, O
k-)
s 2 knowing their problem, agreed to do it?
3 Or, was it en Order issued?
4 MR. NOVAK: There was no Order.
5 MR. REMICK: No Order, just withholding of the --
6 MR. CAHILL: It-was in our interest to cooperate.
7 MR. REMICK: Okay. Thank you.
8 MR. OKRENT: I will go on with the rest of the 9 report. Dr. Savio handed out this morning something with a a
10 yellow front page marked Agenda Item 12. It includes some 11 material concerning hydrogen control.
12 We had a consultant, Dr. Jefferson Sandia, who
[)
x,-
13 had supplied some typewritten remarks and then after the 14 Subcommittee some additional handwritten remarks.
15 Since the Subcommittee meeting, we have received j 16 what is the last page of this handout, certified mail, 17 letter to the NRC, from Gary and Brown. I understand that 18 a copy of this has been given to the Staff. And I suspect 19 the Staff could provide us with comments as they can on the 20 contents of this letter today.
21 And, has a copy been given to the --
22 MR. STERN: Yes, we did get a copy.
23 MR. OKRENT: IIas a copy gone to the utility?
24 MR. SAVIO: Not yet.
25 MR. OKRENT: Well, why don't we make sure they b
490
- ll-15-SueW know of this.
2 You received a proposed agenda and in back of 3 the agenda is the possible draft letter. And you will 4 see at the end are a couple of draft memoranda. And let 5 me mention something that relates to these memoranda.
6 During the Subcommittee meeting, one thing that 7 did occur was Mr. Houston, in fact, while discussing the 8 generic or general program on hydrogen indicated that it 9 might be worthwhile for an ACRS Subcommittee to review the 10 program and while you might not offer comments on it, it's 11 something that will be going on over some period.
12 And, as you will see, there is a proposed 13 memoranda supporting Mr. Houston's suggestion.
14 A second thing that came up during the meeting 15 is, there was considerable discussion concerning the status 16 of containment venting in the event of accidents beyond the 17 It seems that, in fact, the committee lacked design basis.
18 some of the information that maybe it should have had. It 19 was a Staff generic letter that we don't seem to have in our files.
21 And, in general, since we had originally asked 22 back on Grand Gulf to be kept pretty much informed as to 23 how these matters were being treated, there is -- as a result, 24
- ) you see suggested action by the committee to have some 25 subcommittee meet to look at generically what is going on
491 1-16-SueW with regard to containment venting for accidents beyond the 2 design basis.
3 You will hear about this with regard to River 4 Bend in the program today.
END #11 Jon flws 5 6
7 8
9 10 11 12 m,
7 N_,,
13 14 15 16 17 18 19 20 21 22 23
- g4 w/
M
492 12-1-JoeW21 1
I might note that the Staf f in issuing a list f}
V 2 of five Percent power license, had made it a condition that 3 the emergency procedures, with respect to containment venting 4 be in place before full power.
5 As a result of the discussions that were held 6 yesterday, it seemed to the Sta'ff, and it certainly seemed 7 to members of the subcommittee, that one should not rush 8 into establishing these procedures.
9 That there were a variety of things one has to 10 consider, and in fact we heard yesterday from the people from 11 GESSAR II that they could see a variety of dif ferent criteria 12 that one had to think on and so forth, and so you will note 13 in the draft letter -- in fact, as it now stands, it is 14 proposed that we not try to get this resolved by full power, is but by year after full power.
16 For example, to give a little bit more time when 17 the job is done, and hopefully it is done reasonably well, le but'the Committee may feel differently.
19 We did talk about a few other items that were in
- the Committee letter of Tuly 17, 1984. They are, in fact, 21 summarized briefly in the draft letter so I am.no going to 22 report on that. You can read about that. I propose we just 23 get into Item 3 of the agenda, unless members of the sub-24 committee or other people have questions or comments at 25 this time.
493 12-2-JoaWal 1 MR. MICHELSON: Is this being handed out?
e m.,
2 MR. OKRENT: Yes. Have a copy.
3 MR. MICHELSON: Do you have an extra one?
4 MR. OKRENT: Yes, I do.
5 MR. WARD: There appears to be no comments, so 6 why don't we --
7 MR. OKRENT: Why don't we go into Item 3, the 8 Staff will initiation discussion of the hydrogen control 9 issue.
! 10 It is not a vast amount of time. We are supposed 11 to conclude by 5:45, so the Staff and the Applicant were 12 each told to have about half of the allotted time, and the
/D 13 Committee has about half; not two times.
()
14 MR. STERN: I would like to introduce Dr. Wayne 15 Houston, Assistant Director for Reactor Safety, in the Office 16 of Nuclear Reactor Regulations.
17 Dr. Houston?
XX INDEX 18 MR. HOUSTON: Thank you, Steve . It seems it 18 hasn't been too long since I have been up here talking about 20 this subject.
21 I will apologize first for having the same slides 22 and viewgraphs that I had on Wednesday afternoon -- Wednesday 3
23 evening at the subcommittee meeting, so although they will 24 look the same, I am going to try to put a different emphasis i (V}
i 25 and a briefer emphasis on my verbal presentation.
494 12-3-Jo3W31 1 (Slide.)
7
( ,) 2 One of the things that distinguishes the River 3 Bend Case now from the first and the previous case of a 4 BWR 6 MARK III facility up for a full power license, is 5 that we now have. a rule in place which was not the place when 6 Grand Gulf received its license', but the~ work was done in 7 anticipation of a rule based to a large extent on what had 8 been a proposed rule.
9 The implementation provisions, or implementation to features of that rule are shown here. One of the main things 11 that I would point out is that the rule does provide that 12 these facilities install a system to control hydrogen from 13 degraded core accident prior to exceeding five percent power.
[')T
'q 14 The MARK III owners, and River Bend specifically, 15 have chosen to install ingniter systems to achieve the 16 objectifes of the rule.
17 The rule requires that there be in place a 18 suitable program of experiment and analysis, and that the-19 design of.the system be based upon an amount of hydrogen 20 that is generated that is equivalent to 75 percent metal 21 water reaction, and seventy-five percent of these are zirc 22 clad on the fuel, from a zirconium metal water reaction.
23 And that one of the major objectives of showing l
24
,-~ is that the integrity of the containment will be maintained
'~ M should such a system be used.
i 495 '
12-4-JoeWal 1
That is, as a result of the burning, the deliberate 2 controlled burning that would take place by reason of the 4
s use of igniters.
4 There -- they are also required to present to the 5 Staff at least a preliminary analysis that provides
~
6 preliminary justification for the choice of the system, and 7 to provide a preliminary demonstration of how well it may 8 meet the objectives of the rule.
l 9 Subsequently, there is to be a final analysis, which will confirm preliminary findings or add to preliminary
.10 i
11 findings to achieve compliance with all of the requirements 12 of the rule and in particular the. final demonstration of the 13 survivability of equipment which is essential to achieve and
- 4. ' 14 maintain safe shutdown, and any equipment which is essential 16 to maintain containment integrity.
i River Bend has complied with these implementation
. ~
16 -
- 17 features of the hydrogen control rule. The reason I think i
! 18 why it is an issue here today in-the full power license i
l 19 case is because there may havefbeen some concern .because -the 30 . matter is not finished, and as a matter of fact as we will l
l 21. see in a moment, it nay not be finished yet for over a-year
! 22 in terms of: closing out the open questions, and confirming I
M. .results of tests, experiments,.and' analyses,
'M With the publication of the ruleJand the gs 25 statement of considerations, it was indicated that for-the l
12-5-JoeWnl 496 1 MARK III facilities, that the Staff was working with a group
,m is- ) 2 that was formed back in 1981 by the four utilities who have 3- this type of facility, known as the hydrogen control owners 4 group.
5 In the relatively recent past -- well it is 1
6 almost a year ago now, I guess, the -- a fairly definitive 7 program plan was established and documented by the hydrogen 8 control owners group, and there were several purposes that 9 that plan serves. It is a management control tool in one 10 sense, but it is also a very convenient device whereby the i 11 owners of these facilities can interact fairly frequently 12 with the staff.
() 13 Here is a case where we have a rule on the books 14 for which there is no regulatory guide. No standard review 15 plan, and no pre-established staff position as exactly what is would be acceptable to comply with the rule.
17 And, therefore, in this case what we are doing
- j. 18-is interacting on a fairly continuous fashion with the owners i
19 of these facilities to achieve a consensus and compliance 20 with the requirements of the rule.
21 The IICOG program plan has some interesting 22 features. There are fourteen tasks identified. You see 23 eight of them on this slide, and there are six on the next 24 one. You can get some. indication of the status of them, 25 whether they are complete as_ of the present time, or r -
497
- 12-6-JosWal approximately when they are expected to be complete.
1-a 1-1 2 There are actually about two hundred and twenty 3 some sub-tasks involved here, and as I mentioned a moment 4 ago, in the absence of staff developed standard review plan, 4
5 the owners group have also attempted to adopt and discuss 6 with the -Staff proposed acceptance criteria dealing with 1
1 7 all of the fourteen tasks.
8 And there are actually about 79 of these in their 1
9; program plan. ,
, 10, We have had a number of meetings in the past,-and
. 11 we anticipate a number of meetings in the future with the '
12 group. We.have had visits to their-experimental facilities
~
5 13 and experiments are under way at this time. l I
i 14 One of the main things that.I would like to focus l 15 on right now, -- in a sense one might say stems from Task 6 _
[
+
i 16 -- and this has to do with a basic problem, and one of'the ;
I !
l 17 reasons that one can point to why- the program is not complete l l
18 at this point. ;
l !
ill And .that has to do with mechanisms - of hydrogen j i !
- combustion that may occur in this type of facility.
t 21 MR. MOELLER : Wayne, are the mechanisms of- !
i I
22 combustion quite different than say, for a PWR. I gather j i
M they must be.- :
L i es 24 ' MR. HOUSTON: .Yes. This is'about what I was
(_-) 25 i
I
- about to talk about.
i l
t i
l 12-7-JoeWol -
498 i
The principal differences, we will see in a
(
\s)s/ 2 moment, that one of the most likely expected place that 3 hydrogen would appear in the containment would be by passing 4 through the suppression pool, and therefore it comes out 5 from the surface water.
6 For some time, we have known that this has the 7 Potential for producing what are called diffusion flames;
~
8 that is, more or less continuous burning right at the surface, t i
e and that is with the flame anchored at the surface of the 10 water.
11 Such phenomenon was demonstrated in a test 12 facility which was part of the HCOG program a few years (G)
%/
13 ago called the 20th scale facility.
14 At that time, for example, one of the conclusions 15 that was drawn was that it appeared that there was a threshold 16 phenomena involved for diffusion flames. That is, that if
- 17 the hydrogen release rate when translated to a scale for the 18 MARK III facilities themselves exceeded about .4 pounds per 19 second, one could expect diffusion flame phenomena.
20 But it could be inferred that for lower hydrogen 21 release rates, one might not observe diffusion flames.
22 MR. S!EWMON : That .4 pounds per second is an 23 average over the entire surface area? What is the unit 24 area on that?
(<
s~s s) 25 MR. HOUSTON: That is the entire hydrogen generation e
(, . - -._ ._ . -- __ ...- . . -. - . ~ ~ . - . - --- .- - . -
12-8-JotWal 499 t
~1 rate, yes.
.2 It will come up through spargers, so it is the i
3 - total. . Total coming out of the core is perhaps another f 4 way to look at it.
l' 5 MR. OKRENT: But it is not necessarily coming 6' up --
s 7 MR. HOUSTON: It comes through the SRV spargers.
8 The reason for mentioning it, particularly at this point, J
9 is -that up until relatively. recently, with the expectation that there'was a threshold for diffusion flame phenomena, it
~
10 i .
- 11 seemed that they.would be the -- the owners would be faced l 12 with the problem of dealing with a degradation' type burning, 1
() 13 . as well as diffusion flame burning..,
More recent tests,.which you may hear a'little 14" 15- bit more about later if that is part of the Applicant's i .
presentation, in;a larger-facility which has been built and 4
16 17 which is now in use.as a test facility for this program, _
t a so-called quarter scale test facility, seems.to be suggesting 18 i
! - 19 results that diffusion flamelphenomena are observable at i-20 substantially lower hydrogen release rates than tJun . 4. t r
21 Down'at least to .1, and.perhaps in some instances.a steady ,
22 flame phenomena can be observed at even slightly lower rates.
1
. 23 The result of .all this is some uncertainty in how i'
M- one can' analyze the containment response because there are
.Q 25 no codes that are available that are.sufficiently; valid i
l v ^p 9 -+==v19 ,-e ee-we- y- -
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- re.---*-W-Wrc'v'-M+F
12-9-Jo:Wal 500 1 or sufficiently reliable for analyzing the effect of
.f .
U 2 diffusion flames.
3 So, this has given rise to really a strong 4 interest on the part of the Staff, encouragement on the 5 part of the Staff, and agreement on the part of the owners 6 group to construct the quarter scale facility whose primary 7 purpose has been to look at the relevant phenomena of 8 diffusion flames in a mock up of the MARK III facilities.
9 So, it is the necessity to complete those 10 -experiments, and to analyze the results, in order to 1
11 complete the program plan that creates the necessity for 12 extending a period of time before we will have this question
/<
(s x)
,/
13 fully resolved. <
14 The main conern here, the main issue I would say 4
15 fram a technical point of view, the primary one of concern i
. 16 is still the question of equipment survivability and not
~
17 so much the one of containment integrity from the point of 18 view of the pressure that would be created by the burning 19 process.
20 (slide,)
21 The balance of the program tasks are shown here.
22 Task 9 is the -- essentially the description and ' character-Z3- ization of the quarter scale test program, and as you can 24 see, the completion of that part of the program is scheduled 7~.
(^/ 2 for September '86, about a year from now. -
l -
l l
[
12-10-Jo:Wal-501 1
Another thing I might mention in here has to do
) 2 with the combustible gas control EPGs -- incidentally that 3 is a typographical error. That should be 12/85 according 4 to their present program, not 12/86.
5 And they are proposing -- that is, the hydrogen 6 control owners group as distinct from the committee under 7 the BWR. owners group, who otherwise have the responsibility a for developing emerge. procedure guidelines, who are taking 9 on the task that deals specifically with the MARK III problem 10 of the combustible gas control EPGs, vis-a-vis the 11 activation and use of the igniter system.
12 (Slide.)
In discussing these tasks with the subcommittee
(~)
v 13 14 on Wednesday evening, a number of questions that were posed 15 dealt with the question of the accident scenarios and the 16 hydrogen release rates that were involve.d, so I thought I 17 would spend a minute or two trying to focus a little bit 18 more sharply at this time on those questions, or re.ponses I
19 to those questions, than we were able to on Wednesday i
! 20 evening.
1 21 In the first place, the -- with respect to the 22 accident scenarios, the rule itself does not specify 23 accident scenarios. It does say that they should be accepted
-s 24 by the Staff, and that those to whom the rule applies must
! (_,) 2 j provide supporting justification of reactor system behavior l
502 12-ll-Jo:Wal 1
during and following a degraded core accident.
2 At the present time, the hydrogen control 3 owners group have proposed, and the Staff essentially has 4
found it to be acceptable, what are basically two categories 5 of accident scenarios.
6 Both of these involve essentially preliminary 7 total ECCS failure. That is, an inability to get water back 8 into the core. Both involve manual actuation by the The 9 opera, tors of the automatic depressurization system.
to Staff believes that this is a reliable system.
11 In one case we are dealing with a set -- actually 12 it is sort of a surrogate for transient phenomena which
[) 13 would be coupled with a stuck open relief valve, which has u) 14 the effect of admitting hydrogen into the suppression pool 15 through one more sparger than would otherwise be the case.
16 It is slightly more conservative than not having 17 it stuck open.
18 The other accident scenario is a dry line break, i
i 19 with ECCS failure, with manual actuation of the automatic l
20 depressurization system.
l 21 In both cases, eventual recovery of some injection l
22 capability occurs, otherwise of course one does not have a l
l 23 recoverable core.
l gs ) 24 The difference between the two accident scenarios i 5
%J 25 there is that in the first case, all of the hydrogen comes up
_. . . . - - - _- .= - _ ... . _ - _ - _ - _ -
l '12-12-Jo Wal i
503 1 .-
-F 1 through the suppression. pool, and in the'second case it is
( -
2 divided between entry into the suppression pool, an'd entry i 3 directly into the drywell.- That is without having first i:
l 4 ' passed through the pool.
5' The quarter scale test will simulate the 6 transient scenario, not the second one. The hydrogen release 7 characteristics which essentially have been agreed upon
-8 between the Staff and the IICOG group involves two different i
9 subsets of this scenario, i
j 10 One involves: the injection of five thousand 11 gallons per minute of water at about 3,900 seconds af ter the J
12 initiation -- after the beginning of the transient.
13 This scenario produces a fairly large spike of 14 hydrogen generation, a very high release rate for a relatively t
15 short period of time,-but does notlgoLto the full seventy-16 five percent metal water reaction target of the rule.
17 _ It is considered to be' a much more likely hydrogen i
la generating event thanzthe-next one.that I will describe.
- 18 .That next one, and the second one, is also a i
20 transient situation, in which. injection of a' much smaller l
21 3
amount- of water, and we have agreed on a figure for 22 g calculational. purposes of 150 gallons per minute, which is 23 "
l approximately the capacity of a CRDM pump, at about 3,100 i
24 seconds.
25 i And that one then is followed by what I will call r
504 12-13-JoeWnl 1 a totally -- essentially non mechanistic constant hydrogen V 2 release rate of a tenth of a pound per second.
3 Now, in the case of the first scenario where one 4 has the equivalent of recovery o'f one full ECCS injection 5 pump, like a LIPSI pump, the peak hydrogen release rate 6 would be about nine pounds per second for 'a short period of 7 time, and the total amount o.f hydrogen generated, I don't 8 have a figure, but my recollection is that it is probably 8 about a few hundred pounds of hydrogen.
10 In the second case, the peak hydrogen release rate 11 is lower, but extends for a longer period of time so that 12 the expectation is that one has sustained diffusion flame i 13 burning for a longer period of time, goes to the full 14 75 percent metal water reaction, which in the River Bend
- 15 case, then, amounts to a total of about 2,000 pounds of 16 hydrogen being released.
17 Both of these hydrogen release scenarios are 18 to be used -- have been, and are being'used - in the 19 quarter scale test facility, which will form a substantial 20 portion of the basis that will be employed in order to 21 demonstrate equipment survivability.
22 Now, that concludes the specific remarks that 23 I wanted to make on the program plan.
{
24 There are many other things that could be said, i 25 .but I wanted to focus on that to try to clarify what -- where j
I
12-14-JonWnl 505 1 the Staff stands with the owners group with respect to the n
k_), 2 hydrogen release rates and the accident scenarios.
3 MR. OKRENT : Any questions?
4 (No response.)
5 MR. HOUSTON: Let me go to Item B, which is 6 on the agenda fairly briefly, although I think in a sense 7 I partially covered it, but particularly with respect to 8 the conclusions specifically that are in SSER 4.
9 Dasically, the conclusions are that- they have 10 satisfied the requirements of the rule for this particular 11 stage of the proceeding.
12 The one thing that I would point out that is (g; 13 stated there is that the preliminary demonstration of 14 survivability of equipment is not complete. It is not 15 persuasive, one might say,_in terms of the kinds of analysis 16 that were done.
17 The particular concern here is that in using 18 the Classics III code, which was used to determine the 19 -- both the pressure and thermal environment of the containment 20 as a result of hydrogen burns, it does not give a conclusive 21 showing of the ability of equipment in the wetwell itself ,
22 to survive the temperature environments that are created.
23 The particular items that have been demonstrated l
24 l g-, to be of concern are, in fact, the igniters themselves, and i
' \J M the cable associated with it. -
l
12--15-Jo;Wal 506 1 The reason that it is a concern is because 7-km 2 the igniters themselves are not required for safe shutdown 3 but there is a concern here because credit was taken for 4 them functioning in the analysis, and so we simply don't 5 know that if one were to do a re-analysis in which those 6 igniters are assumed not to function, whether that would 7 have changed some of the conclusions further away from the 8 -- above the IICU floor in particular, because the preliminary 9 analysis did show that equipment on the HCU floor appears to 10 survive the burns based upon that evidence.
11 However, that evidence is based upon Classics III 12 analysis, which assumes degradation type burning, and here (v ) 13 again, I would point out our concern here, and their concern 14 is, that it does appear to be much more likely that diffusion 15 flame type burning will occur and this needs to be factored 16 into the final determination.
17 MR. MOELLER: So, the equipment was not specifically 18 located on the assumption of diffusion burning, diffusion 19 flame.
20 MR. IIOUSTON: No analysis has been performed 21 that would attempt to reflect an effect of diffusion. That 22 is where you have equipment actually in the flames, that is 23 correct, or directly over hanging.
(~; 24 MR. MOELLER: What key equipment would be just
(' l 25 above the suppression pool?
12--16-JoeWnl 507 1 MR. HOUSTON: The only two items that I am aware
("'s N., 2 of -- it 'is really the igniter system that is the concern.
3 Our analysis of essential equipment is not 4 complete. We also identify this fact in the SSER. As a 5 matter of fact, one item came up at the subcommittee meeting.
'6 The criteria that we employ would cover the 7 concern that Mr. Ebersole had. I might add at that particular 8 point that we are dealing with a degraded core situation.
9 It is my understanding that in this type of 10 facility, all of the neutron sensors are in core, and with 11 a degraded core, they may not be present anyway.
12 MR. EBERSOLE : I wds wondering, you know PWR is r~
(s) 13 different. However, at least you can get something outside.
14 Normally that is done. I was wondering if you might think 15 it appropriate to retain some sort of neutronic instrumentation 16 of some sort inside.
17 Unlike the PWR core, the BWR core MR. HOUSTON:
18 will go suberitical substantially without the necessity of 19 addition of boron.
20 MR. EBERSOLE : Say again?
21 MR. HOUSTON: Without the necessity of adding j 22 borated water.
23 l
MR. EBERSOLE: Yes, if you get the rods in, of 24 course.
C_s) 25
l
+- -- -
, -~
- _ . = __ -
508 12-17-Jo Wal MR. EBERSOLE: llowever, there is an interesting 1
p
\w l 2 followup to that.
3 I don' t know what it would do if you progressively 4
melt it down in the context of progressively losing the rods.
5 MR. HOUSTON: I agree there are uncertainties 6 there; that is why I believe they have B4C in the rods.
7 Rods would not necessarily expect to retain their integrity 8 under the circumstances.
9 MR. EBERSOLE : I don' t know the order of failure, 10 and for the sake of argument I will just say the rods went 11 out first and leave you with the problem.
12 MR. HOUSTON: That is conceivable. If there
() 13 are no further questions, I will move on to C, which will be 14 brief.
15 MR. OKRENT: Let's see. Was the difference in 16 containment spray versus fan cooler mentioned to the full 17 committee?
18 MR. HOUSTON: No, it has not.
19 MR. OKRENT : Well, why don't you make that point 20 so they understand.
21 MR. HOUSTONi Of the four MARK III facilities, 22 three of them have contaiment sprays, and one does not.
23 The facility.we are talking about today, River l
i j gs 24 Bend, is the one that does not have containment sprays.
5 In the preliminary analysis performed in the l
- . . ... . . _ = _ - .- . . . - _
, .-12-18-JOeWal 509
~
1 Grand Gulf case, credit was given, in effect, for the 2 spray system, which probably had a beneficial effect with
-3 respect to the thermal environment, although I can't be 4 100 percent positive that that was the case.
t
' 5 I believe that was probably the case.
- i End 12. 6
- SunW fols.
j- 7-i 8 9
i l 10 I
t .
(
- 12
! 23 j 14 i
i .
' 15 1
1 16 l
! 17
)
! 18 '
19
)
I- 3 i
l 21 4
i i n r
i g
i ;
24 25 s
r f
i
- _ . .=
510
- 13-1-SueW 1 MR. HOUSTON: With respect to the test program p
k,- 2 of the facilities,'the quarter scale facilitieg we have 3 within the relatively recent past questioned the justifica-4 tion that the Owners Group has used to, in effect, take 5 substantial credit for sprays in those facilities that have 6 the sprays.
7 Our position is that both the situations should 8 be given at least equal weight if not more weight to the 9 situation in which there are no sprays for the purpose of 10 demonstrating equipment survivability. The Group has not 11 yet responded to the Staff with respect to the Staf f position.
12 So, I don't know what the final might be. But
() 13 the Staff position haa been made rather clear.
14 If there are no further questions on that, I 15 will proceed to the next item which is 3.D, which reads:-
i 16 An NRC Staff assessment of the severe acc'ident behavior of 1 17 the River Bend containment with a discussion of differences 18 as compared to other MARK III containments.
18 MR. MOELLER: Excuse me, Wayne. I should have 3D asked.
21 In terms of the unit coolers that are going 22 to be used in place of. containment sprays, the GSU, of course, 23 replied to questions I gather from the Staff on that in 24
(~'N which you asked to what degree can a unit cooler system be
-\_ 25 expected to remove airborne radiciodines or other materials.
.+ - . , , . , , - - - . -
511
- 13-2-SueW 1 And were you-satisfied with their response?
r, k/
s 2 Was the Staff satisfied?
3 MR. HOUSTON: I can't answer that question.
4 MR. STERN: The Staff is looking at that 5 response now. We just recently received that response.
6 MR. MOELLER: Oh, okay. Well, it was given to 7 us on August the 29th. And I see then that it is new.
8 And, of course, they responded to a number of 8 questions raised by the Committee on this. So, all of this 10 then we will hear about later? I mean, in a few weeks or i
3 11 something?
)
12 MR. STERN: Yes. r 13 MR. MOELLER: Okay. Thank you.
14 MR. MICHELSON: Excuse me. Is that a chill i
l 15 water system they are going to use, Dade?
~
16 ' MR. MOELLER: They call th'em unit coolers. I t
17 guess we had better ask them.
18 MR. BOOKER: Jim Booker with Gulf States i
!~ 18 Utilities. That would either use normal cooling tower
?
L lE water or standby service water.
21 MR. MICHELSON: But not chill water?
t
! 22 MR. BOOKER: Not chill water.
l' 23 MR. MICHELSON: Thank you.
24
(~} MR. HOUSTON: Okay. The Staff quite clearly V 25 recognizes perhaps both the right and the obligation on'the l
I f i
-m-,.-1e,---.-- -- m-- - --s.,,--. ,-- ~ s --w--- - - - ~< - - . - - ---
512 2
- 1,3-3-SueW 1 part of ACRS to raise questions without being fettered by
\~) 2 the change of regulations.
3 As I had indicated that the Subcommittee 4 meeting, it was somewhat of a surprise to see on the agenda, 5 however, a statement which could be read to mean that the 6 Staff had in fact performed an assessment of severe accident 7 risk in the River Bend facility. The Staff has not performed
, 8 such an assessment.
9 This is not part of the licensing basis under 10 current regulations of a plant. So, we really have not made L
11 any kind of an assessment that one could in any sense rely 12 upon. One could perhaps only make conjectures, and we would 13 prefer not to do that.
3, 14 At the Subcommittee meeting, we did ask Jack 15 Rosenthal on the Staff, who is one of the individuals on the 16 Staff who has been very experienced in severe accident 17 assessments and has dealt, as I'm sure most of you are aware, 18 very much with the ACRS Subcommittee on the GESSAR docket 19 and appeared here before you yesterday also, who provided so I think -- though I wasn't here, I'm sure he provided a 21 pretty good assessment of what the Staff has done for a 22 facility which has a great deal of similarity to the River 28 Bend facility.
24 And I think that included perhaps even some l
25 comparisons with some of the assessment work that had been l
l c
513
- 13-4-SueW - g done also on Grand Gulf but did not include anything on
(\
')
\s , 2 River Bend, because there are certain details of the River 3 Bend design which our severe accident assessment people
. 4 simply have not gotten around to looking at yet.
5 Perhaps at some point -- probably at some point 6 in the future, that is likely to occur as a result of the 7 implementation of the severe accident policy statement ,
a recently issued by the Commission. At some point in the e future, I would imagine that River Bend, like many other 10 P l ants, will come under some kind of scrutiny by the Staff 11 in this connection.
f I 12 MR. OKRENT: I might just note.for the Committee' s
() 13 information -- I don't think.it is anything to be done with s 14 the information at this time,- but as we've heard, River Bend is uses the unit cooler. And the drywell configuration is-16 different. It turns out, I think they have a purely signifi-17 cant cavity under the pressure vessel which ends up leading i 18 to a lesser thickness of concrete.
i a
19 And this could or could not have some influence 30 on the course of an event should the fuel melt and get out 21 of the reactor vessel. And just observing that not all 22 MARK IIIs in fact are designed-identically, as another 23 example of plant specific differences that one would at 24 least have to assess if one were looking at that part of 25 it. -
l l
l
.r.
514 il3_-5-SueW .1 It was not my intent that it be on the agenda
./ \
> 2- today, but since it's on I was misunderstood in trying to 3 give an oral proposal yesterday. I just wanted the Committee
~4 to know that there were these differences.
e 5 Are there any other -- now, the Staff didn't 6 I see tell us whether or not there may be some problems 7 with regard to survivability of equipment.
8 You mentioned that there may be a problem I 9 guess with the ignitors. Do you think you can conclude 10 that's the only problem at this time?
i 11 MR. HODSTON: No.
12 MR. OKRENT: You are not that far along?
() 13 MR. HOUSTON: No. I think the conclusion is 14 a. limited one. The conclusion is that the analysis did i
N not clearly demonstrate the survivability of the ignitor 16 system.
17 That's really about all we can say.
18 MR. OKRENT: But do you think it demonstrated i
19 the survivability of everything else?. ,
f E MR. HOUSTON: There is a fair margin there. ;
t ,
21 Not with a hundred percent certainty one can say, the basic 22 underlying reason being of the uncertainty as the ability of 23 CLASIX to give the kind of results which one can rely on !
/ \ to that extent. !
But to the extent that one can and one is willing
515
- 13-6-SueW 1 to rely on the predictions of the CLASIX-3 code, it looked
\s / 2 like equipment which is at or above the HCU floor, coupled 3 with other engineering judgments that one can make about 4 the situation. It looks like there is a reasonable probability 5 that the final showing will not change on that.
6 MR. OKRENT: Well, I'm certainly not in a 7 position to offer any opinion. I will note that a consultant 8 and others have noted the possible sensitivity of environ-9 mental conditions to hydrogen generation rate and possibly 10 some problems in scaling from one quarter scale up to full 11 scale.
12 MR. HOUSTON: The Staff has the same problems.
MR. OKRENT: That may not be straightforward,
( 13 14 and so if you have a hundred and fifty degree margin to 15 the good it's probably not a problem.
16 But if you are working with ten or twenty degrees --
17 MR. HOUSTON: Absolutely.
18 MR. OKRENT: -- it's not so obvious.
19 MR. HOUSTON: That's correct. That's correct.
20 MR. EBERSOLE: I. wonder if you could comment 21 on the failure mode of the ignitors?
22 I would have thought they were steel and porcelin 23 and --
t; 24 MR. HOUSTON: It's primarily the transformers.
b-26 MR. EBERSOLE: Oh, I-sce.
I I
y -
! 516 1 MR. HOUSTON: You see, because right now the
- ,13.
- SueW s 2 transformers are located inside.
3 MR. EBERSOLE: Right. Well, that's an unfortunate 4 state of affairs.
6 MR. HOUSTON: And I should add that one of the 6 contingent. provisions, I might say, of the program plan and 7 the Staff's understanding is if survivability is not, as 8 the plants now exist, adequately demonstrated they do have 9 a provision for looking at the possible ways of rectifying 10 that situation by changing their location or providing 11 shielding or insulation or whatever may be necessary.
12 MR. EBERSOLE: I see. You mean, putting them
(~N '13 outdoors?
14 MR. HOUSTON: In the case of -- one of the 15 possible feasible ways of dealing with a transformer problem, 16 if that's it, would be to put them outside the containment.
' 17 MR. EBERSOLE: Sure.- But more often than not, 18 there is a vast study to demonstrate environmental capability 19 before that is done? !
20 Whereas, the first might be the more simple f
21 thing to do. !.
22 MR. OKRENT: Are there any other questions of :
23 the Staff on hydrogen control? [
l 24 (No response.)
- 25 Could we ask the applicant to comment on !
)
V
517 613-8-SueW 1 hydrogen control.and --
m' f 2 MR. BOOKER: Before we get to that subject, let
\_/
3 me add to my response on the question on cooling for the 4 unit coolers.
5 During an accident scenario, the coolers, the 6 unit coolers would be either the normal service water or 7 the standby service water.
8 During normal plant operations, chill water 8 is used for those coolers.
10 MR. MICHELSON: In purchasing or specifying 11 the piping for the chilled water system, have you had to 12 take into account the NDT transition of the carbon steel rx ' n 13 which I suspect you are using?
14 You can give us a reply later.
16 MR. EBERSOLE: The unit coolers there, did you 16 mean all cooling required by safety equipment?
17 MR. BOOKER: No. These are the unit coolers 18 inside the containment to cool the atmosphere in containment.
19 MR. EBERSOLE: Oh, to cool the at lohere.
20 Okay.- Thank you.
MR. SHARP: Excuse me, sir. My name is David Sharp with Gulf States Utilities. And-I can respond to your NDT question right now.
f In fact, the NDT requirements on this carbon l steel pipe are met for normal service. We do not use these d
l 518 I
- 1'l-9-SueW 1 services or this pipe for any accident cooling or accident 2 water to the unit coolers.
3 MR. MICHELSON: I understand that. But, during 4 an earthquake -- in the unlikely event of an earthquake, 5 these coolers are running on chilled water at the time so 6 the piping is chilled at the time and you don't want it to 7 be brittle --
8 MR. SHARP: Yes, sir.
9 MR. MICHELSON: -- if it's to be seismically 10 qualified.
11 MR. SHARP: The only portion of that that's 12 seismically qualified is that inside the containment. And
/ ,
( 13 the NDT effects by the seismic event have been considered
)
14 in our plant.
15 MR. MICHELSON: But you found out you didn't 16 need to consider NDT, I guess?
17 MR. SHARP: Essentially, yes, sir. That the 18 analysis showed that we were not in an NDT region.
19 MR. MICHELSON: You are operating at 40 degrees.
20 MR. SHARP: About 55 degrees on these.
21 MR. MICHELSON: 55?
22 MR. SHARP: Yes, sir.
23 MR. MICHELSON: And do you know what the 24
. transition temperature is for the metal?
25 MR. SHARP: For this metal, not right offhand,
519
- 1}-10-SueW 1 no, sir.
2 MR. WARD: Okay.
3 MR. OKRENT: Yes.
4 MR. REED: My name is Bill Reed. I'm the 5 Director of Licensing for Gulf States Utilities. And at 6 this time, then we will proceed with our presentation on 7 hydrogen control.
8 Mr. Irwin Zoch, who is the Supervisor of our 9 Nuclear Engineering Group within our Nuclear Plant Engineer-10 ing Department will provide that response.
11 MR. WARD: Mr. Zoch, before you start, I would 12 just like to make a side comment to the Committee.
- 13 After the Gulf States presentation, we will want
)
14 to have about fifteen minutes to continue our discussion of 15 the future Committee activities that we interrupted last 16 night.
l 17 Go ahead, please.
l INDEXX 18 MR. ZOCH: Thank you. And good afternoon, 19 gentlemen.
20 I want to add perhaps one clarification to what 21 Dr. Houston said concerning the ignitors in the wetwell U region or in the region where most of the diffusion burning 23 occurs. There are only twelve, a total of a hundred and four
(
24 ignitors in River Bend in that region.
M And with that I will just go on with the
520 ty)-ll-SueW1 presentation here.
C)
(,) 2 MR. OKRENT: Excuse me. Are you going to 3 analyze what happens if they don't work?
4 MR. ZOCH: Yes. I think we will do that. But 5 my assessment of that right now is if those ignitors in the 6 wetwell region fail we have a large number of ignitors above 7 that in other regions of the containment that will be 8 available.
9 MR. OKRENT: But I think one has to look at 10 the impact of burning at another level and so forth. You 11 have to follow the trail through and not --
12 MR. ZOCH: Yes.
()~
13 MR. OKRENT: -- just automatically assume --
14 MR. ZOCH: Yes, I understand.
15 MR. OKRENT: Okay.
16 MR. ZOCH: We have submitted preliminary analysis 17 to the Staff which supports the use of the distributed 18 ignitor systen in River Bend.
19 (Slide.)
20 Since the Staff had expressed some concern about 21 survivability of these wetwell ignitors we have undertaken 22 additional analysis using the thermal environment that came 23 out of the Hydrogen Control Owners Group quarter scale testing i
24 program.
%J l
25 And my presentation today will address this-l l
l
521
- Y additional analysis that we've completed in our program to G}-12-SueW1 2 demonstrate final compliance with the rule.
3 The goal of the Hydrogen Control Owners Group 4 quarter scale test program is to define the thermal environ-5 ments that result from diffusion type burning in a MARK III 6 containment. We model the facility so that the temperatures 7 and pressures recorded there are representative of full 8 scale values.
9 And we also have the capability to model all 10 of the four members' geometry differences for their contain-11 ments. We have included a sufficient amount of instrumenta-12 tion in that facility we believe to characterize the environ-7-
13 ment.
14 (Slide )
15 Some of the important results that we have 16 obtained to date from testing, and that's after about twenty 17 different tests being completed, we have noted that the 18 serial deflagrations that have been predicted in the CLASIX 19 code do not exist. Instead, we see diffusion type burning 20 down to very low hydrogen release rates.
21 More importantly, we see that the thermal 22 environments resulting from this burning are significantly 23 less severe than the CLASIX-3 predictions.
24 (y MR. MOELLER: Excuse me. When you say you know 25 what you are learning from these experiments, you have listed
522
- 13-13-SueW1 them as River Bend Hydrogen Control Program. Is this the O
\_s) 2 work of the Owners Group or the work of GPU -- GSU, excuse 3 me?
4 (Laughter.)
5 MR. ZOCH: It's the work of the Hydrogen Control 6 Owners Group.
7 MR. MOELLER: Okay. Well, do you have a person 8 full time wherever these experiments are underway, you know, 9 right on site and involved?
10 MR. ZOCH: The Owners Group has a person full 11- time on site at the facility.
12 MR. MOELLER: But your utility does not?
( 13 MR. ZOCH: No, sir.
14 MR. MOELLER: So, who feeds you the information?
15 Do you receive written reports?
16 MR. ZOCH: . Yes. We receive written reports and 17 telephone reports directly from the individual or from their - -
18 from our Program Manager.
19 .MR. MOELLER:~ And what input have you had, like so in the planning of the experiments and so forth?
21 MR. ZOCH: We have reviewed the design-of the 22 facility and the design report, the modeling report, have
- 23 had extensive meetings with the contractor and Electric Power 24 ' Research Institute in developing this program, p 25 In addition to that, we've met quite extensively
_J
523
- 13-14-SueW1 with the Staff to get their input in this program.
2 MR. MOELLER: And so you have a person that 3 personally keeps up with all of this?
4 MR. ZOCH: Yes, we do.
5 MR. MOELLER: What --
6 MR. BOOKER: Dr. Moeller --
7 MR. MOELLER: -- percent of the time does --
8 MR. BOOKER: Dr. Moeller, we have more than 9
one person that is full time -- spending full time on the 10 hydrogen facility.
11 MR. MOELLER: Okay. Thank you. That is all.
12 MR. ZOCH: My next slide addresses the equipment n
( ) 13 survivability that we've undertaken utilizing some of the 14 quarter scale test results.
15 (Slide.) .
16 We have analyzed the two components in the wet-17 well region to some of the thermal environments that have 18 been produced in the quarter scale, namely the ignitor and 18 its associated power cable.
20 Again, we have used the data from the quarter 21 scale and results of that analysis show that the ignitor and 22 cable will survive the transient with considerable margin.
23 END #13 Joe flws e s 24
( )
25
14-1-JoeWal 524
- i (. Slide . )
[
N_./ 2 My next slide shows the temperature profile as 3 measured in the facilities. This is a temperature profile 4 for the lower region of the containment, and the initial 5 peak temperature here of 622 degrees represents that from 4
6 the release history, and then the other portions of this, 7 out to 75 percent metal water reaction release history i
8 represents the lower release histories.
9 Temperatures, again, they peak for 622, and 10 there are temperatures in this region here, about a .14 11 pounds release --- pounds per second release rate, on the 12 order of 300 degrees or less. They are more like 250.
() 13 This is a case without sprays, so there is 14 no mitigating effects of temperatures due to sprays.
15 This temperature profile was then applied to 16 the analysis for an igniter assembly, and the cable. Its 17 power cable.
18 I have the results here for the igniter 19 assembly, the results for the cable, or similar to this, 20 were given at the subcomndttee meeting .
, 21 The curve here represents the response of the
) M igniter case. The outside portion, and this curve represents 23 the response of the transformer.
24 And as you can see here, the line here -- horizontal 25 line -- represents the qualification temperature for the l
- 14-2-Jo:Wal 525 1 igniter assembly, and there is a fair amount of margin
) 2 between the transforer response and the qualification !
3 temperature. t 4 MR. MICHELSON: Besides temperature, what was 5 the other condition. It must have been some humidity, or 6 excess moisture condition, or something wasn't there?
7 MR. ZOCH: Yes, there was. I don't know those -
[
8 values off the top of my head. [
t 9 MR. MICHELSON: Does somebody else know? ;
10 VOICE: We could get that information from the 11 test report. l 1
12 MR. MORRIS: Marvin Morris, Gulf State Utilities. i
[}
~
13 The thermal profilies that Irwin showed previously were >
%/
14 applied to a Heating 6 model of the igniting assembly. There ,
15 wasn't any consideration of any moisture internal. ,
16 MR. MICHELSON: Okay. There was no humidity, 17 or excess moisture, or rain, or whatever applied to the !
l l ;
l 18 system when it was -being tested? ;
19 MR. MORRIS: Oh, during the test, when it was
?
I 20 qualified.
21 MR. MICHELSON: Ugh-ugh.
22 MR. MORRIS: They are qualified for operation ,
23 with sprays, but that really doesn't apply to us. 'We don't 24 have sprays. !
s 25 MR. MICHELSON: Thank you.
/4-3-JoeWal . 526 1 MR. REMICK: Another question. Your previous l
,+
( , 2 slide, was that a temperature history with time, and if 3 so, what are the units. Are they seconds, or --
4 MR. ZOCH: Let's see. Those are in seconds.
5 MR. REMICK: Thank you.
6 MR. ZOCH: Full scale values. Those are quarter 7 scale values in terms of seconds, and in applying the analysis 8 then to the equipment, we expand that out in time.
9 MR. MOELLER: Excuse me. On the last slide you 10 had up just before this one.
11 MR. ZOCH: Yes.
12 MR. MOELLER: Where the transformer profile in
,m
( ) 13 different, now why is that?
w.
14 MR. ZOCH: It is on the inside of the igniter 15 assembly. It is protected by the case.
16 MR. MOELLER: Right. So it just doesn't receive o
17 the impact --
18 MR. ZOCH: It doesn't respond as quickly.
19 MR. MICHELSON: That transformer wouldn't be 20 affected by the high humidity you would have in conjunction 21 with an accident?
22 MR. ZOCH: It is sealed from th'e environment.
23 MR. MICHELSON: Now, the usual purpose of 24 testing is to verify that indeed it is sealed. How do you
,s
? )
M know it is sealed.
1
l
/4-4-Jo:Wal 527 i There must be some test some time or other m
I \ to verify it was sealed.
\ / 2 3 MR ZOCH: In qualification testing, I would 4 assume that that was confirmed.
5 MR. MICHELSON: dkay, and it was in the same 6 temperature-humidity range?
7 MR. ZOCll: I can't. answer that. I am not sure 8 I understand your question.
9 MR. MICIIELSON : Well, the question.' is, how do 10 these devices survive in a high humidity, high temperature 11 environment, like the transformer.
12 MR. ZOCII: They have been qualified for the LOCA environments which include the high temperatures and
[)
v 13 14 high humidity conditions.
15 MR. MICIIELSON: Presumably 340 degrees, a hundred 16 percent humidity?
17 MR. ZOCH: Yes.
18 MR. MICIIELSON: Thank you.
19 MR. ZOCH: The last slide gives our conclusions, 20 and programmed to demonstrate final compliance.
21 (Slide.)
22 The results of this analysis indicate that all 23 equipment will survive the hydrogen burns, and based upon i -s 24 the quarter scale testing, we have' additional analysis and l
25 testing underway to demonstrate final compliances of the 7
/4-5-JoeWal 528 1 quarter scale testing program for River Bend is scheduled A
( ,) 2 for completion approximately in July of next year, and 3 the final analysis expected to be complete by the end 4 of the year.
., 5 Our conclusions are based upon the analysis 6 conducted to date with quarter scale results, we feel 7 - that all equipment will survive the thermal environments 8 produced by hydrogen burning.
9 That there~is no threat to containment integrity to from a pressure standpoint, from the _ small pressure rises 11 that we see resulting from hydrogen combustion, and that 12 the River Bend hydrogen igniter system is adequate for
[bj 13 handling effectively and safely the generation of large 14 amounts of hydrogen.
15 MR. OKRENT: Have you thought about the situation 16 where one postulates complete. blackout of AC power, and 17 gets into a degraded core condition, and generates some 18 hydrogen?
19 MR. ZOCH: We have thought about that. We 20 haven't resolved that issue finally.
21 MR. OKRENT: Uhat are your thoughts?
E MR. ZOCH: My thoughts are that it is a very 23 low probability event. First of all, the generation of
- j. -, 24 hydrogen to this extent is extremely remote, and our plant 25 capabilities for a station blackout, we can recover power.
I
-/4-6-JoeWal 529 1 I simply don't believe that it is a likely 2 situation.
3 MR. OKRENT: So, your thoughts are it won't occur?
4 MR. ZOCH: Yes.
5 MR. OKRENT: I might note that in France they 6 are taking extra precautions to keep it from occurring.
7 Considerable extra precautions.
1 8 So, that is-in the backfitting mode.
l 9 MR. EBERSOLE: Just as a matter of kind of crude 10 practicality, what is the size and cost of the MG set that j 11 will run th~e igniters, just stuck in an outdoor shack?
12 MR. ZOCil: I don't know the answer to that.
~
, 13 MR. EBERSOLE : Let me guess it is less than five 14 thousand dollars at the outside. Mounted on rubberized l 15 springs, for that matter.
L 16 MR. OKRENT: Okay. Are there other comments or l
l 17 questions on the matter of hydrogen control?
1 18 (No response)
- 19 If not, let's go into BWR containment venting.
20 I guess the Staff is up first?
21 MR. STERN: Dr. Okrent, as a result of the 22 discussions we had Wednesday, the utility has revised -- has
-2 made some revisions in their approach, and this has been l
i 24 discussed briefly with the Staff yesterday.
O 25 I would like the utility to make a presentation l- . - _ - ._
' i 14-7-Jo:Wal 530 11 on that, and we will be glad to offer some comments.
2 MR. OKRENT: Sure. Why don't we let the utility a up first, then.
4 MR. BOOKER: Jim Booker, from Culf State 5 Utilities. What I would like to do this afternoon, Dr.
6 Okrent, is to discuss where we are today in our containment 7 venting procedure in relation to our discussions at the 8 subcommittee meeting Wednesday afternoon, and a meeting with 9 the Staff yesterday.
10 GSU originally developed our containment venting 11 procedure based on the NRC generic letter 8304, and the 12 BWR owners group emergency procedure guidelines. This letter is and guidelines gave directions that all means of cooling 14 were loss.
15 Containment pressure continues to increase, that 16 procedures be in place in existing equipment to fit the 17 containment before it ruptures.
18 I am sure all of you gentlemen understand that 19 means we have lost all means of cooling. We have lost the i
20 use of the main condenser. We have lost the use of the RIIR 21 -- we have lost suppression pool cooling, and River Bend 22 has a unique design' feature in containment coolers.
i 23 We have also lost the containment coolers.
24 Be that as it may, the guidelines say if you J 25 have increased pressure in the containment, you need to have
4- :
i 14-8-JoeW21 531 .
l i
1 a procedure in place. )
b s ,/ ' t The procedure we originally developed called for
.P 3 it being at two different pressure levels.
4 The first level of venting was going to occur at 5 1.3 times containment design pressure, or approximately 20 4
6 Pounds, and we will start venting to a three inch hydrogen :
i 7 purge -valve, which will go to the standby gas treatment 8 system, and then to the building vent. ;
9 And this 20 pounds will buy us additional time
)
1 to to attempt to get some means of cooling back in service.
i 11 And as I mentioned the unique design feature 12 that River Bend has, the unit' coolers -- we have three
()
13 unit coolers,.if we can get two of those unit cool'ers.back I 14 in service, to' cool the containment atmosphere,-you would 15 never have to go into_ venting.
l l 16 These unit coolers have two sources of cooling-I l 17 water, so by starting to vent at the lower pressure will buy ,
j 18 some' time to try'to get that back in service.
l 19 But still in the event the cooling cannot be
- so restored, pressure continues to increase, we had proposed i
j 21 to use 36 inch normal' containment purge valves to start i
- 22 venting at 45 pounds.
! l l
23 But as I mentioned,.because of the concerns raised L 24 by the subcommittee Wednesday afternoon and with discussions 25 with the Staff about introducing a steam environment into j i i
. - ,s -- --. e m - ., ,- g, .m.----gy ,- ,_.
9 , _mus, 47,,,.... _ _ . .- y ,
_,,_%, ,%_..., , ,, ,,,,,,,n--.,,-w,--mar-.-_., e
14-9-Jo1Wal 532 1 the auxiliary building through the potential either leakage
/ ;
x/ 2 or rupture of the duck work in the auxiliary building, we 3 have eliminated this portion of our procedure today until 4 we have done some additional analysis of environment in the 5 auxiliary building, to look at the various elevations, 6 temperatures and equipment in each one of these locations, 7 to assure that there is some equipment that will survive this 8 event that will provide for long term cooling.
9 We have done some preliminary looks at it, and 10 we we say there is enough equipment that will survive this 11 event located at other elevations that will now preclude 12 long term cooling.
r~N 13 But before we commit to vent today at 45 pounds, (vj )
14 we wish to do some other analyses.
15 MR. EBERSOLE: I recall that case where you 16 admitted the gases and vapors to the auxiliary building, and 17 you went to the trouble of building a vent in the roof. It 18 subsequently occurred to me that you would have spent a lot 19 less time and money to put about a one-eighth inch steel 20 plate or something as a damper which could be nanually 21 operated that would close off the point of entry into the M aux building.
23 gn, CAIIILL: The vents in the roof, they are there.
24
(~'hI MR. EBERSOLE: Oh, they are already there.
O Well, it still applies it would be comparatively simple, and 1
14-10-JoeWnl 533 1 not too involved to simply out a plate barrier in that 2 vent that fitted off into the aux building. Or was that 3 the only point of discharge?
4 MR. BOOKER: What we would be doing, we would
[ 5 be overpressurizing all the duck work inside the --
6 MR. EBERSOLE: There is no other relief point i
7 at this time?
8 MR. BOOKER: That is correct.
9 MR.EBERSOLE: So, what you are going to do is 10 blow the duck work into the containment.
11 MR. BOOKER:- What we are looking at is to put 12 in some plates in the duck work, so you go there ahead of 13 time, and we~ leave that underneath these roof plugs up there 14 to direct the flow out --
> 15 MR. EBERSOLE: Under the circumstances, I think
) .
j 16 you could do what you want to do with a shotgun.
i.
i 17 MR. REMICK: In.the case where you would' vent f 18 through the standby gas treatment system, what is the 19 driving force? Do you require a blower.there, or just the 20 pressure from the containment itself? Would that force it
! 21 through the filters.
22 VOICE: It would be the pressure from the 23 containment.
24 7
n 25 MR. REMICK:
kind of a passive system.
From the containment. So, it is I assume the standby gas treatment L
534 14-ll-JoeWal 1 withstands those pressures.
iO
%- 2 MR. BOOKER: You won't see fifteen pounds.
3 MR. REMICK: You won't see fifteen pounds. Won't 4 or will?
5 MR. BOOKER: It will not. We have done an 6 analysis to show that that duck work and the standby gas 7 treatment system will survive..
8 MR. REMICK: But couldn't it exceed 15 if your 9 containment' pressure is building up during the time you are 10 venting through standby gas treatment?
11 MR.. BOOKER; Yes.-
12 MR. REMICK: I assume somebody has looked at that (O,,
13 standby gas treatment. I don't know what pressures those 14 are designed for.
16 MR. EBERSOLE: Forrest, they were discharging 16 this vent directly into the aux building? Not the first 17 vent path, the second vent path.
18 MR. BURMEISTER: -Gary Burmeister, Gulf States 19 Utilities. There would be.no significant pressure buildup
- in the standby gas treatment system. It goes first into 21 our annulus, where it is diluted with the annalus mixing 22 system, and then drawn off from there into the standby 23 gas treatment system.
24 MR. REMICK: Drawn off? That sounds like it is
(-s v 25
[
blower?
14-12-JoeWal' 535 1 MR. BUR?iEISTER: Yes,.there is some vans on the 2 standby gas treatment system in the annalus mixing system
- 3 in operation.
4 MR. REMICK: So, it would require AC power then?
5 MR. BURMEISTER: Yes, sir.
6 fir. REMICK: It is not a pass-through system. ,
7 I forget where standby gas treatment vents to. Does it go 8 through your ---
9 MR '. BURMEISTER: The exhaust from the standby l i 10 gas treatment system goes'to the atmosphere. '
End 14, 11 Suet fols.
. 12 4
i 13 i
i I 14 15 !
, i j 16 ,
i 17 i
i
- 18
! 19 t i
21 :
, i I
22 !
i 23 i
!' 24 l 1
t i
l 25 I i
f I
536
- 1 SueW 1 MR. MICHELSON: Have you verified that you can 2 open a thirty-six inch valve with a forty-five pound dif ferential?
3 MR. BOOKER: Yes, sir. We have looked.
4 MR. MICHELSON: Do they have a sufficiently 5 large operator?
6 MR. BOOKER: Yes, sir.
7 MR. MICHELSON: Is this an air operated piston?
8 MR. BOOKER: Yes.
9 MR. OKRENT: Does the Staff have comments on 10 this now?
11 MR. STERN: On the valve operability, no. We 12 have not seen the analysis. But I would like to call on
( ) 13 (krald Mazetis of the Division of Human Factors Staf f.
14 MR. MAZETIS: My name is Jerry Mazetis of 15 the Procedures and Systems Review Branch. And as indicated 16 to the Subcommittee, our review is as published in Supplement 17 Number 3 in August for River Bend, is incomplete, and it's 18 identified four or five areas that we are evaluating the 19 proposal, one of which is equipment operability.
20 MR. OKRENT: Was that a confirmatory item or 21 an open item? I don't remember.
3 MR. MAZETIS: It's an open item.
23 MR. STERN: It is now a license condition.
24 Well, as I mentioned earlier to 3 MR. OKRENT:
25 the Committee, the Subcommittee developed the, I would say, l
537
- 15-2-SueW.1 fairly strong opinion that it would be worthwhile at a
,/ -
(s / 2 future Subcommittee meeting to look a little bit more deeply 3 into just what it was that the Staff was now authorizing 4 with regard to containment venting for conditions beyond 5 design basis accidents.
6 And it seems clear that with regard to River 7 Bend there was not yet worked out something that we were 8 going to recommend to the Committee as in a defined shape 9 and the Staff still has it as an open item.
10 So, I don't think we have to try to close out 11 the issue today. It is really in a sense a status report, 12 as far as I see it.
() 13 MR. EBERSOLE: I believe as a matter of a 14 permanent record, we should get the documented results of 15 an investigation that shows the tolerance of particularly 16 , electrical apparatus to the conditions that would exist 17 in the auxiliary building under the circumstances of discharg-18 ing into it, as you had proposed.
19 MR. MAZETIS: As I understood, the licensee's 80 proposal in their near-term submittal within the next week 21 or two, analyses like this should be submitted.
22 MR. EBERSOLE: I sec. They are going to show 23 the tolerance of the apparatus that will keep the core cool?
24 MR. MAZETIS: Perhaps we can ask the licensee a' 26 what details he plans to submit.
538
- 15-3-SueW 1 MR. BOOKER:- What we talked about yesterday e-- .
~\ 2 to submit here in a week is not going to be the complete 3 analysis on the auxiliary building and equipment there.
4 That will probably take a month or two.
5 MR. OKRENT: I would like to know, and you 6 may have alluded to it earlier, but our records seem to 7 . indicate that we got the letter of transmittal for generic a position 8305 but not the document itself.
9 MR. KERR: Could someone tell me, what is this 10 analysis we are asking these people to do?
11 MR. OKRENT: No. Let's see, the Staff, in fact, 12 is requiring licensee to develop an emergency procedure 13 which deals with venting for beyond the design basis accident.
14 MR. KERR: I understand that. But I thought 15 Mr. Ebersole was asking for an analysis --
16 MR. OKRENT: All right.
17 MR. KERR: -- of the operability of all of the la equipment in the auxiliary building.
19 MR. OKRENT: All right. On Wednesday, we heard 8 the then current proposal from the, I guess, licensee now 21 .which would have involved the venting, transmitting the 22 containment contents into a section of ducting in the 23 . auxiliary building which ducting was not expected to withstand 24 - the pressure and which would fail; thereby, exposing the 25 auxiliary building to not only hydrogen but steam and so forth i
l-
539 l
- 15-4-SueW 1 that was in the containment. And there was a question 1
()
\N/ 2 raised about what would this do to the operability of 3 equipment --
4 MR. KERR: Okay. But, since --
5 MR. OKRENT: -- in the auxiliary building.
6 MR. KERR: -- the applicant may not use this 7 procedure, we aren't going to ask him to do this analysis 8 no matter what, I assume?
9 MR. OKRENT: I'm not at the moment requesting 10 anything. You heard Mr. Ebersole --
11 MR. EBERSOLE: Let me tell you, I guess I was 12 a little selfish about that.
( 13 I would be interested in the tolerance of that 14 equipment in there, but in the long run I'm confident the 1
15 applicant will not discharge this stuff through the aux 16 building.
17 I think it would be worthwhile, knowing what 18 the survivability would be.
19 MR. KERR: The last time I looked, analyses 80 i of this kind cost a good bit of money, 21 MR. EBERSOLE: You are right. And it would
- 22 cost a lot more money than to divert this flow to another --
23 MR. KERR: Yeah. But if they are not even 24 going to use this procedure, and we don't know that they 26 are, I would be a little reluctant --
l l
l
540
- 15-5-SueW 1 MR. EBERSOLE: It's fair to say I don't know
[' 1
\w- 2 what is going to happen now. So, we will just have to let 3 it unfold.
4 MR. KERR: Okay.
5 MR. EBERSOLE: . I think it would be worthwhile 6 to know what the tolerance of this equipment is to such-a 7 hypothetical intrusion.
8 MR. MICHELSON: Although they are not going to 4
l 9 use the originally proposed procedure, aren't they using a 10 modification of it now and that's what they are going back i
11 to look at, and that modification still involves a certain --
i 12 MR. KERR: I thought I heard the Subcommittee
() 13 Chairman say that this is still an open question --
l 14 MR. MICHELSON: Yeah.
15 MR.-KERR: -- and that the Subcommittee decided i
16 that a further look should be given at the whole question 17 of procedure.
18 Now, did I misunderstand?
19 MR. MICHELSON: Well, I misunderstood, because 80 l I thought Jesse wanted them to look at whatever part of i
21 the auxiliary building might still be involved with some 22 modified procedure, only that part.
23 l MR. BOOKER: The modified procedure venting 24 should not put steam --
G 26 MR. EBERSOLE: At all?
I
. . - - . - - - . - . ~ , . _ . - _ - - - -- -- -,-
541
- 15-6-SueW 1 MR. BOOKER: That's correct.
(O/
's / 2 MR. MICHELSON: Then, there shouldn't be a 3 question. Then, I agree with Dr. Kerr.
4 MR. OKRENT: As I said at the beginning, and as 5 I thought I indicated now, it could only be an information 3
6 presentation, that the full Committee at some future time 7 will want to look at the -- both hydrogen control and the 8 emergency venting procedure.
9 It's impossible to conclude that today.
10 MR. MAZETIS: If I may address just briefly, 11 in assisting the Committee, in responding to Dr. Okrent, 12 I could refer to an August 19th, 1983 Subcommittee Meeting.
i
() 13 I think it was the ACRS Subcommittee on Human Factors in 14 which there was a series of presentations on the generic 15 guidelines from the four Owners Group, on behalf of the four 16 Owners Group by the Staff.
17 One of the presentations was the boiler 18 emergency procedure guidelines. And there may be some in-19 formation in there with regard to discussions on containment
=
20 venting of interest to the Committee.
j 21 MR. OKRENT: I will ask our Staff to see if 22 they can dig that out.
23 Let me say,without any blurs to the people 24 looking at human factors, it probably is a question that
)
26 we look at in terms of hardware and a variety of reliability
?'
j N i .. . .- -, _ _ - . - -
542
- 15-7-SueW g questions and so forth.
' Well, let's see, I think we were supposed to 2
3 hear a very brief statement summary from- the applicant 4 concerning their development on PRA.
5- MR. REED: At this time, Mr. Mel Sankovich, a who is Director of our Nuclear Fuels Design and Safety 7 Analysis Group will provide the presentation.
INDEXX 3 MR. SANKOVICH: We are planning to do our PRA 9- development at River Bend in three stages, two of which 10 are now complete.
11 The first stage was based on WASH 1400, and 12 we used Grand Gulf as the surrogate plant. This is reported
() 13 in the Environmental Report and to the Committee a year ago 14 last July, 15 The results of that study were that Grand Gulf --
16 excuse me, River Bend was typical of other BWR plants of 17 modern design and comparable size.
18 We then decided to do a Phase 2 study which 19 is also based on Grand Gulf. And we used the event trees 90 from Grand Gulf, and we made that plant specific with fault 21 trees for River Bend.
22 The Committee asked us to look into earthquakes 23 and fires as external initiators. And we used the data 24 from the EPRI study, seismicity Owners Group study, as well
( 26 as the data from the Lawrence Livermore Laboratory which
543
- 15-8-SueW 1 showed that of the nine sites considered, River Bend was
/T t i N/ 2 the most of the nine site with the very low probability of 3 ever exceeding the design basis accident.
4 General Electric looked at the comparison 5 between River Bend and GESSAR II for fires. It was con-6 cluded that neither fires nor earthquakes contributed 7 significantly to the core melt frequency for River Bend.
8 And we conclude that the core melt frequency 9 fo r the River Bend station is lower than for other plants 10 that have aircady been licensed.
11 The third stage of our PSAR development will 12 be to develop this methodology in house, and we intend to.do
() 13 this on an incremental basis over the period of the next two 14 to three years. And we intend to use this for training, is maintaining maintenance schedules and tech spec changes 16 should they be required.
17 MR. OKRENT: Have you documented what you 18 call Phase 2?
19 MR. SANKOVICH: Phase 2 was done as an internal 80 report. And we are not required to document that.
21 No, I didn't ask you -- I didn't MR. OKRENT:
22 say you -- I just asked whether it was documented.
23 Are you reluctant to issue the report for some N
O
%/
reason?
U MR. SANKOVICH: Well, it's an internal report,
544
- 15-9-SueW. 1 and as such we are reluctant to issue it, yes.
/'
(
\ 2 MR. OKRENT: Well, it makes it hard to evaluate, 3 I must confess --
4 MR. BOOKER: Dr.'Okrent, the Phase I report is 5 documented in the Environmental Report.
- 6 MR. OKRENT
- Yeah. That I --
1 7 MR. BOOKER: Phase 2, if you would like to see 8 the report we would be more than happy to let you see the 9 report informally, but we don't see any reason to put it 10 as a public document.
11 The actual results of Phase 2 are better than 12 Phase 1.
( 13 MR. OKRENT: I'm interested a'little bit in 14 seeing what assumptions went into Phase 2 and this sort of 15 thing.
16 MR. BOOKER: Well, we will be happy to make 17 a copy of that available to you or any other committee 18 members that would like to see it.
18 MR. OKRENT: Fine.
20 MR. BOOKER: We just didn't necessarily to put 21 it on the public document.
22 MR. OKRENT: Well, I'm willing to leave the 23 point at that.
l
()
'w/
24 Are there any other comments from the Committee 4
25 that you wish to raise on PRA or on anything else in
545 ,
- 15-10-SueW 1 connection with this review?
/ T' m- / 2 MR. MICHELSON: I have a question on the reactor 3 water cleanup lines outside of containment.
4 In doing your PRA, I assume that you assume 6 the possibility of pipe breaks in the reactor water cleanup 6 system and dealt with the probability of not being able to 7 get the isolation valves closed.
8 Did you find such an event to be a potential 9 high risk contributor? Did you even look at the event?
10 MR. SANKOVICH: I would like to have Stone and 11 Webster answer that question, please.
12 MR. HAZZAN: Mike Hazzan, Stone and Webster.
(3
/
- 13 We analyzed a spectrum of pipe breaks in the PRA, not the 14 reactor water cleanup system specifically.
15 And we did assign --
16 MR. MICHELSON: Well, that's the only one I'm 17 really interested in discussing. If you didn't look at 18 it specifically, then I guess we can't discuss it.
18 Let me ask, is the reactor water cleanup 20 seismically qualified outside of containment?
21 MR. ZOCH: Irwin Zoch. And the answer is,
" yes, it is.
23 Okay. And the valves on the --
MR. MICHELSON:
24 that isolate the potential reactor water cleanup line breaks, f^x
" have you done any type of test program or -- how -- what is i
I
546
- 15-ll-SueW 1 your confidence level that-they will operate under the blow-
/3
-l 2 down conditions that they will see if the pipe were to break?
3 Was this included in your specification, for 4 instance, to the. supplier of the valve so he realized what 5 size operator it would take?
6 MR. SAVO: Tom Savo, Stone and Webster Engineer-7 ing Corporation.
8 We specified valves to open and close against 9 the differential-pressures associated with pipe breaks.
10 MR. MICHELSON: You are saying -- I guess I 11 will have to put words in your mouth in order to understand 12 your answer.
()
- You are saying that you specified the blowdown 14 rates and so forth that the valve would see and told the is valve. vendor to supply a valve that would close under those 16 conditiona?
17 MR. SAVO: No, we did not.
18 MR. MICHELSON: Then, how did you tell the 7
19 valve vendor what size -- how did he size his operator? ,
20 MR. SAVO: He sized them against the maximum 21 static differential pressure.
22 MR. MICHELSON: Okay. He just used full i 23 differential pressure, and that was it?
24 MR. SAVO: That's correct.
26 MR. MICHELSON: Do you have some basis to believe
, , _, .m, - ,- -
547 5-12-SueW 3 that that's all the operator you need to close under blow-( 2 down conditions?
) 3 MR. SAVO: Not currently, but we can evaluate 4 that.
5 MR. MICHELSON: Okay. I think it might be 6 well for you to think about it.
7 MR. MOELLER: I need a clarification, not l 8 necesssrily from the Staff or the applicant but in terms 9 of the report which the Committee will prepare.
10 For example, they said on venting that the 11 applicant had talked to the Staff in the last couple of 12 days and the Staff has not had time to analyze the results.
() 13 .And then I asked about this letter from GSU to the Staff 14 of August the 26th in which they responded to ten items 15 identified by the ACRS in its July the 12th letter. Now, a
16 the staff says they have not looked over, you know, have r
17 not had time to analyze the responses.
18 Do we exempt these things from our comments?
19 How do they fit in? ,
30 MR. OKRENT: I would say if there are any ,
21 matters on that list that you think relate to going to full 22 power, ask questions now.
23 My proposal to the Committee is that you will 24 be seeing Gulf States again in connection with hydrogen 25 control and venting, and at that time, as we all know, other l !
l
l 548
- 15-13-SueW1 topics become fair game. As far as the Committee is con-G 2 cerned, we are just trying to get educated.
l 3 But if there are some things that you want to 4 hear about now, you should ask those questions. And if 5 you want to think on that, let me ask the Staff to comment 6 on the letter that we just received.
7 MR. STEPA: On the matter of the Brown letter, 8 we are entering that in the allegations tracking system.
9 That has been turned over to Region IV.
10 MR. OKRENT: I see.
11 MR. NOVAK: Plus, Dr. Okrent, we will probably 12 want to establish contact with this individual. From a 13 preliminary review, it would be advantageous to us to try 14 to pin down the concerns more specifically and then follow 15 up as necessary. ,
16 That will be our intent, to establish contact 17 and to try to better understand the concerns.
18 MR. EBERSOLE: Mr. Chairman, the question that 19 Carl just asked --
20 MR. OKRENT: Let's make sure that we are done 21 with --
22 MR. EBERSOLE: Oh, okay. Go ahead.
23 MR. OKRENT: Are there any further points the 24 Committee wants to raise with regard to the letter from
[
25 Mr. Brown?
549
- 15-14-SueW 1 (No response.)
2 We have been told the Staff is going to deal 3 with it.
4 Okay.
5 MR. EBERSOLE: Yech. The question that Carl 6 just raised is a ritual question that we always ask the 7 applicants about, the possibility of high pressure floods 8 entering the containment and being unable to be turned off 9 if the pipe bursts.
10 It's inclusive of the steam that comes through 11 RCIC, the reactor water cleanup, and unfortunately we have 12 got rid of RCIC because it's electric.
j 13 This gets into the matter again of the resistance 14 of the equipment inside the secondary -- I mean, inside the 15 aux building to tolerate a moisture laden and warm, humid 16 atmosphere naving been previously cooler than that and now 17 will suffer condensation on electrical apparatus and'over D 18 '
heating of it.
19 One defense of this is compartmentalization such 20 that these flows of steam would go to outdoors rather than 21 go over the plant, you know, the walls, and designed to 22 control the flow of steam to exit externally without doing 23 all the damage.
24
( ,
The other, of course, is to get valves that 25 work. I am trying to recall, I thought we had gone over all
550
- 15-15-SueW 1 of this and layed it to rest. Can the applicant -- my 2 memory is worse than it should be.
3 Has the Staff layed this to rest, it being a 4 standard review question and a standard matter? You know, 5 Limerick had compartmentalization so even if the valves 6 didn't work they were in high cotten.
7 But I can't remember whether this plant does 8 or not.
9 MR. MICHELSON: GESSAR II had a pretty good 10 answer on that.
11 MR. EBERSOLE: GESSAR II has compartmentaliza-12 tion.
13 MR MICHELSON: If that's what you were think-( ,
14 ing, we went in great detail with GE --
15 MR. EBERSOLE: I don't know. These things 16 run together a little bit.
17 MR. MICHELSON: -- on GESSAR II but I wasn't 18 in River Bend meetings, so I don't know what you are cover-19 ing.
20 MR. EBERSOLE: I'm almost certain that down 21 in Louisiana we brought this matter up.
22 MR. MICHELSON: It could be. I don't know.
23 It could be.
24 MR. OKRENT: I don't recall the details of that.
1 i
I 551
- 15-16-SueW 1 MR. EBERSOLE: Perhaps it is layed to rest.
( '
2 MR. MICHELSON: I'm not convinced it's layed 3 to rest here. I was just asking to see what they had done.
4' MR. OKRENT: Well, why don't we leave it that l 6 the applicant has heard you mention this, and he knows 6 you are going to see them again.
7 MR. MOELLER: Okay. You asked about the ten 8 questions. One was on the refrigerated charcoal beds and, 9 you know, if they heated up. And I'm happy with -- I 10 appreciate the response, and I'm satisfied with that.
11 Carl had asked this one, if my memory is 12 correct, on the inflatable seals.
.()
(N 13 Is he' happy with that? It's Item Number 5.
14 MR. MICHELSON: I didn't ask it on this. I 15 haven't been on River Bend.
16 MR. MOELLER: Well, I thought it was more of 17 a generic thing. It's where the centainment personnel 18 and equipment hatches utilize inflatable seals.
! 19 And we asked the length of time accumulators E would be able to maintain air pressure to the seal in a 21 post-accident situation and recovery plans should one lose i
22 the air pressure to the seals in a post-accident situation.
23 I sort of remember that was your baby.
24 . MR. MICHELSON: I've been asking about it. I
}
25 didn't realize they had inflatable seals here.
552
- 15-17-SueW 1 MR. MOELLER: Well, I gather they do.
s_/ 2 MR. MICHELSON: They do?
3 MR. MOELLER: And they've given us a response.
4 I'm not -- it's not my --
5 MR. MICHELSON: One might also ask their means 6 of monitoring the check valves to assure that the accumula-7 tors remain filled after an accident and so forth.
8 MR. MOELLER: Right.
9 MR. MICHELSON: I didn't realize they had s
10 inflatable seals.
11 I don't know the history.
12 MR. WRIGHT: I'm Jim Wright, Gulf States 13 Utilities.
14 We do have inflatable seals in the containment 15 air locks, and they do have check' valves in there. They 16 are monitored by instrumentation in the control room that 17 gives an alarm any time you have a low pressure at the 18 supply line or the seal.
19 MR. MICHELSON: How do you know if the supply 30 line is at its normal pressure and the accumulator is at 21 its normal pressure, that the check valve isn't wide open?
E You know, nothing happens until you bust the 23 air line.
,/- 24 MR. WRIGHT: Well, it wouldn't be required
\- 25 until the air line was locked or you had a back flow i
l 553 l
- 15-18-SueW 1 situation. l 2 MR. MICHELSON: Well, now that air line is 3 probably non-seismically qualified and so forth.
4 MR. WRIGHT: The air line has the CAT-1 5 supports on it.
6 MR. MICHELSON: Well, wait a minute now. I 7 asked a little different question, although that's part 8 of the answer.
9 Is the air system supply and the accumulator 10 seismically qualified to supply, seismically qualified?
11 MR. WRIGHT: I would -- I can't answer that 12 specifically. I do know that it is seismically hung.
) 13 MR. MICHELSON: That may be. But you have got 14 to go back and load the compressors, the whole works, 15 because you've got to have, air if -- you know, you have to 16 go through a little argument.
17 MR. WRIGHT: Okay. The system in the doors 18 where it supplies the seals where the seal is dependent 18 on the supply, that is all Class 1 ASME material and system.
20 The supply line up to that is Category 1 21 seismically hung. If you --
22 MR. MICHELSON: How much leakage have you 23 accounted for in the inflatable seal?
24 Do you assume some leak rate in sizing those 2
554
- 15-19-SueW 1 MR. WRIGHT: Yes. The system was designed to 2 last for thirty-five days with a specified leakage rate l 3 of one point two eight psig per day.
4 MR. MICHELSON: Is that the seal leak? I mean, 6 the air leakage out of the seal --
6 MR. WRIGHT: That's the air leakage out of 7 the seal.
.8 MR. MICHELSON: Thank you.
8 MR. WRIGHT: And during the testing, we found 10 that it's considerably less than that, i
11 END'#15 Joe flws 12 14 15 16 17 18 19 20
, 21 22 23 2.
555 16-1-Jo;Wal 1 MR. MOELLER: The only other one I have, again,
,7 ks _) 2 it is not my area, but the ACRS recommendbd that GSU review 3 and detail the seismic capability of the AC power supplies, 4 and the DC pcwer supply, and small components such as 5 actuators, relays, and incident lines that are part of the 6 decay heat removal system.
7 f1R. OKRENT: They reported that they had looked 8 at it -- what I would call a significant sample of things 9 that they had. Very sizeable margins about the SSC.
10 Whether they have picked up all of the items 11 of that nature, I am not able'to state.
12 MR. EBERSOLE : Mr. Chairman, I think something
'T 13
~
(Y went by prett'y fast here, and maybe needs clarifying.
14 What Carl, I think, is saying is the capacity is of the air supply system can easily mask leaks which the 16 storage system can't tolerate, either by virtue of the 17 check valve leaking, or having leaks in the rubber itself.
18 Therefore, there should be some probably periodic 19 tests to see that both the check as well as the rubber itself 20 is still intact.
t 21 That means putting it on its storage system and 22 observing whether the pressure falls away or not.
U MR.-OKRENT: Can the Staff comment on Mr. Ebersole's 24 claim?
25 MR. STERN: No, sir, we can' t comment on that.
_ . .. - - .. = .--- - .-.- - , .- .. .. . - . . . -
i 16-2-JogWal ,
556 1 MR. EBERSOLE: That is a generic problem with
( 2' all'these things.
3 ME. MICHELSON: The trouble is though that -- I 4 don't know if 'we' can make it a generic problem, because i 5 rarely' do people use inflatable seals on these penetrations. !
1 6 This is one of the very. few cases in the country, because
- . 7 I have inquired around a number of plants, and there is one i other right now that I know of us that uses'inflateable s [
. 9 seals. Generally, people will'.not use them, and this is one i
10 of ~ the1 principal reasons.
i 11 MR. OBERSOLE : The same general logic applies l 12 to the SRVs.
13 MR. MICHELSON: Yes.
(}
- . 14 MR. BOOKER
- This is a very common design, as 15 I understand it.-
i 16 _
MR. MICHELSON:1Not with-the air inflatable seal.
{ 17 General Electric is the' only one -that has been using these, 18 hs I understand it, and they -- not all utilities will use-I
~19 them, if they got a general electric plant.
(~ 20' ItLis an option'that you decide. You decide, or !
yn- 1
~
, 21 .your architect-engineer decided whether he-is going to use M static seals or inflatable seals.
23' 701. WRIGHT: Mr._ Jim Wright, from Gulf States 24 Utilities.- Grand Gulf'has a similar design to this, and l.-
O . 25 -we' checked with; I think,'Waterford.
I L
-. ,, . . . - - - . - - - - = - - - . ~ -, _ ~ , , .,.-.-- . . - - - . . . , . - .
16-3-JosWal 1
The also have the inflatable seals on the contain-
-) 2 ment. air locks.
MR. MICHELSON: That I didn't know, i 3
4 MR. SIESS: We also do better in a severe accident 5 an O Rings, than the other scals.
6 MR. WRIGHT: We also have surveillance procedures 7 that require those systens be tested periodically. And 8 every eighteen months it gets a leakdown check.
9 MR. WARD: With the air compressor supply off?
10 MR. URIGHT: -Isolated from the system. ,
11 MR. WARD: Oh, every eighteen months. So, that 12 is what you want..
() 13 MR. OKRENT: Any other questions?
14 Any_other topics or questions?
15 MR . REMICK: Dave, was it covered at the 16 beginning what is the status of the plant at this moment 17 on start up?
18 MR. OKRENT: I will let the Applicant tell you 19 that.
20 MR. BOOKER: I am glad you asked that, because 21- at some time--- I.saw in Energy Daily, for example, that 22 there was a remark that we;got the plant done so quickly 23 . because we had deferred some significant amount.of r'5 24 construction until later, although we did plan originally b 26 our schedule was to load fuel in April of this year.
.t
16-4-JonWal 558 1 We are four months behind, and during that time
/^\
(~) 2 a lot of the things that we had deferred, which were 3 mostly in the turbine plant, cooling towers, some tests --
4 it is all now virtually complete.
5 Our fuel loading is about halfway thro 6gh, and 6 we expect to finish that in about a week, and start low
~
7 power testing, and be ready to go through five percent and 8 be waiting for a full power license in early October.
9 We are going very well. And it is now as 10 complete as any plant that has gone from the start of 11 construction through without interruption.
12 MR. OKRENT: Any other questions or comments.
() 13 If not, I will turn it back to you, Mr. Chairman.
14 MR. WARD: Thank you very much, gentlemen. Let's 15 take -- do we'want any comment -- you have a letter drafted, 16 David, and is there any -- there is nothing in the letter 17 to indicate that the Committee has a problem with the full 18 power license.
19 MR. OKRENT: That is correct. It says the 30 Committee though will want to review certain things in the 21 future.
22 MR. WARD: In the future, right. Okay. I just 23 wanted to --
n 24 MR. OKREUT: Severe accident matters.
25 MR. WARD: And the hydrogen control, yeah, which l
I L_
16-5-Jo: Wal 559 1 -- yeah, okay.
v
) Thank you very much.
, 2 i
1 3 Let's take a real short break while we clear the 4 room, and we have --- let's see, this won't have to be on 5 the record, the rest of it.
6 REPORTER: Than I can close the record here?
i 7 MR. MARD: Yes, you close it now.
8 (Whereupon, the recorded portion of the meeting 4
9 concluded at 5:45 p.m., this same day.)
10 11 i
12 i 13 14 15 16 I
17 19 l 2 i
21 22 23 O
l
1 CERTIFICATE OF OFFICIAL REPORTER 2
3 I
i 4 I i
5 This is to certify that the attached proceedings (
f 6 before the United States Nuclear Regulatory Commission in the 7 matter of: ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 6
8 l P
9 Name of Proceeding: 305th General Meeting i
10 I 11 Docket No. [
12 Place: Washington, D. C.
13 Date: Friday, September 13, 1985 l 14 I i
t I' 15 were held as herein appears and that this is the original !
l 16 transcript thereof for the file of the United States Nuclear f l
f 17 Regulatory Commission.
{
i
! 13 i i, (Signature > g g g g g j (Typed Name of Reporter) Myrtle H. Walsh (
20 21 (
t 22 !
23 Ann Riley & Associates, Ltd.
l 24 ;
25 !
i
/a7 D
RIVER BEND STATION o ACRS FULL COMMITTEE MEETING SEPTEMBER 13,1985
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REVISED - 9/12/85 ,
Agenda for the Friday September 13, 1985 Discussions On River Bend
- 1. Subcomittee Report 15 min 3:45 - 4:00 pm
- 2. Status of NRC Staff Review and Anticipated Schedule 5 min 4:00 - 4:05 pm
- 3. NRC Staff Discussion of Hydrogen Control Issue and Containment Performance
- a. NRC generic position on the implementation of the Hydrogen Control Rule and application to River Bend 10 min 4:05 - 4:15 pm
- b. NRC Staff sununary of the conclusions of SSER-4 and assessment of equipment survivability 15 min 4:15 - 4:30 pm
- c. NRC Staff assessment of severe accident behavior of the River Bend containment with a discussion of differences as compared to other Mark III containments. 15 min 4:30 - 4:45 pm
- 4. Applicant Comments on Hydrogen Control and Containment Performance 15 min 4:45 - 5:00 pm
- 5. NRC Staff Repo-t on BWR Containment Venting with Applicant Comments 20 min 5:00 - 5:20 pm
- 6. Applicant Comments on the River Bend PRA and the Use of Risk Assessment 10 min 5:20 - 5:30 pm
- 7. General Discussion, Conclusions, and Future ACRS Actions 15 min 5:30 - 5:45 pm
n*~ ~ -A -- A - - a- - ,a _- s- e. . -, _ _- -
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1 I
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l RBS HYDROGEN CONTROL PROGRAM OUTLINE o HCOG % SCALE TEST RESULTS 4
i j o EQUIPMENT SURVIVABILITY BASED ON k SCALE ENVIRONMENTS lO i
o PROGRAM TO DEMONSTRATE FINAL COMPLIANCE l
f O .
~
'A I.
- 8
b MARK III HYDROGEN CCN1 POL CMNERS GROUP 1/4 SCALE TEST PROGRAM o GOAL IS 'IO DEFINE 'IHERMAL DNIRONENTS PRCDUCED BY DIFEUSIVE CCNBUSTICE IN A MARK III CCNTADNENT o 1/4 SCALE FACILITY IS MCDmm SO 'IHAT TEMPERA'IURES AbD PRESSURES MEASURED ARE REPRESENTATIVE T EULIrSCALE VAIDES O
o FACILITY WILL BE USED 'IO SIMJIATE EACH MARK III CCNIADMENr'S GECNETRY .
o INSTRLNENTATICN IS INCLUDED IN FACILITY 'IO CHARACTERIZE
'INEPMAL DNIRONENT J
s L
l O l t
L i
t l
RBS HYDROGEN CCNTROL PROGRAM l
KEY RESULTS FRCH CURRENT 1/4 SCAIE TESTS l
i l o SUSTAINED DIFEUSICN FIMES EXIST D0iti 'IO VERY Im HYDROGEN RELEASE RATES o SERIAL DEFIAGRATICNS DO Nor 00 CUR O
l o 1/4 SCAIE 'IHDMAL ENVIRCMENT IS SIGNIFICANFLY IESS SEVERE
'IHAN CIASIX-3 PREDICTICNS
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DISCUSSION OF l
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l OFFICE OF NUCLEAR REACTOR REGULATION .
I REORGANIZATION :
i WITH ACRS
+
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t 9/13/85 i I
i i
_ _ _ _ _ _ _ _ . , _ _ - _ _ _ _ _ _ _ . - _ _ _ _ _ _ , . _ . _ _ - - _ - - - _ . - - _ _ . - . . ~ . _ , . --.. __
Q . - -
Q Q WORKLOAD TRENDS S TO OPERATING REACTORS OVER THE LAST FEW YEARS WORKLOAD _
PROJECTED AT HAS END SHI ACTUAL E Y 8 7_ EY 88 FY 85* FY 86 EY 82 EY 84 FY 80 6 4 26 13 49 42 1 1 56 3 1 REACTORS UNDER OL REVIEW 8 6 1 1 32 3 1
- SERS UNDER DEVELOPMENT31 8 7
- FESS UNDER DEVELOPMENT 115 117 95 108 77 85 69 REACTORS OPERATING .
TO OPERATING REACTORS WORKLOAD IMBALANCES BETWEEN TECHNICAL B
- SOME TECHNICAL SKILLS REQUIRED FOR LI OPERATING REACTORS LINES NUCLEAR INDUSTRY IS TENDING TO APPROAC
- OWNERS GROUPS ORGANIZED TO RESOLVE
- INP0 ORGANIZED ALONG VENDOR LINES
- STANDARD PLANTS DESIGNED BY VENDORS
- AS OF 8/31/85
O .-
O e
1200r- TMi CLEAN-UP 9 9, _
$ 1000 -
.' ope"#
sn '.- _
g,,9
-i L "sEfVis6iisunidVi! l
$w 800
-:-m-:.-
- M Mili O ..' __:
SEWORK g
i g 500 "i
3 OPERATING REACTORS 8 200 1 100 l 1986 1987 l 1985 1983 1984 0 1982 1980 1981 1979 FISCAL YEAR l
NRR PROGRAM AND RESOURCE TRENDS (1979 - 1987)
SCENARIO FOR FUTURE (1986 AND BEYO CTIVITIES WILL DOMINATE WORKL OPERATING REACTORS AND SAFETY TECHNOLOGY 1986, 108
- BY END OF FY FYAPPROXIMATELY 1986 RESOURCES ARE 20% FOR SAFETY TECHNOLOGY PLANNE TO REFLECT STANDARDIZATION RAGING STANDARDIZATION EW FUTURE REACTOR LICENSING E STANDARDREVIEWS PLANTAREDESIGNLI CONGRESS, COMMISSION, AND INDUST PPROVED STANDARD DESIGNS EPRI ENCOURAGING STANDARDIZAT
)
AND REGULATORY IMPROVEMENTS (SAFETY GOAL, BACKFIT REGULA CONTINUE TO SHARPEN REGULATORY TOOLS MAKE ONLY COST
$30-35M
- RESOURCES ARE NOT LIKELY TO INCREASE 650-700 FTES AND
- NRR PROGRAM WILL LIKELY BE i
i O O O OBJECTIVES OF PROPOSED ORGANIZATION CONTINUE TIMELY COMPLETION OF COMMISSION PPG AND EDO PROGRAM GUIDANCE GOALS INCLUDING EXISTING OL DECISIONS PROVIDES FOR CONTINUITY OF REACTOR REVIEWS AND SAFETY ISSUE RESOLUTION CREATE AN ORGANIZATION THAT IS CONSISTENT WITH CHANGING WORKLOAD (FROM LICENSE REVIEWS TO OPERATING REACTORS) AND THE NEW INDUSTRY /NRC APPROACH (STANDARDIZATION, OWNER GROUPS, NUCLEAR INDUSTRY GROUPS)
INCREASE OPERATIONAL EXPERTISE SEPARATE " FORWARD-LOOKING" AND " DAY-TO-DAY" LICENSING ACTIVITIES INCREASE ROLE AND RESPONSIBILITY AND AUTHORITY
- SHORTEN LINE OF COMMUNICATIONS
! - IMPROVE MANAGEMENT OF LICENSING ACTION INVENTORY REDUCE OVERHEAD l
PROVIDE SUFFICIENT FLEXIBILITY TO ADDRESS MAJOR OPERATING REACTORS PROBLEMS WITHOUT THE NEED TO CREATE SPECIAL TASK FORCES l
i
O -
--e O FUNCTIONAL RESPONSIBILITIES ISIONS
- NEW ORGANIZATION WILL HAVE ATION 2 STAFFS OF THE AND PPAS
- PROVIDES ADMINISTRATIVE ICE. MANAGEM PROGRAMS AND RESOURCES E OF THE OFF TO IDENTIFY ORAS
-- SYSTEMATICALLY ASSESSES OPERATING SIGNIFICANT EVENTS FOR DETAILED R TECHNICAL SUPPORT GROUPS.
ONE DIVISION ONE TO WILL GENERALBE DEDIC ELECTRIC 3 PROJECT OFDIVISIONS WESTINGHOUSE-DESIGNED REACTORS,ENGINEERING AND BABCOCK DESIGNED REACTORS AND ONE TO COMBUS AND WILCOX-DESIGNED ICAL GKILLS REQUIRED TO P REACTORS.
THE PROJECT MANAGEMENT AND TECHN LICENSING ACTIVITIES. MAJOR TECHNCIAL PROVIDES (1) CENTRAL TECHNICAL FOCAL PO DSR0 SUBJECTS (E.G., ASME REPRESENTATIDVANCED REACTOR DESIGN, FORWARD LOOKING SAFETY ISSUES (E.G., AE ACCID SAFETY GOAL, SOURCE TERM AND SEVER (3) OVER AND GENERIC SAFETY ISSUES); AND E IMPLEMENTATION OF RE AMONG THE PROJECT DIVISIONS IN TH REQUIREMENTS AND GUIDANCE. TORS, TECHNICAL RESPONSIBLE FOR OPERATOR LICENSING, HU DHFT 41ECIFICATIONS, MAINTENANCE AND SUR
O O O 1 Office of Nuclear Reactor Regulation Director: H. Denton Deputy Director: D. Eisenhut Planning and Program Analysts Staff Operating Reactors Assessment Staff Director: J. Funches Director: G. Holahan l I Division of Presserfred Water Division of Boiling Water Civision of Pressurized Water Reactor Licensing-A Reactor Licensing Reactor Licensing-B Director: H. Thompson Director: R. Bernero Director: F. Miragita Deputy Director: T. Novak Deputy Director: W. Houston Deputy Director: F. Schroeder Ofvision of Safety Review Division of Human Factors and Oversight Technology Director: T. Spels Director: W. Russell Deputy Director: B. $ heron Deputy Director: D. Ziemann
~
O O O BASES FOR ASSIGNING PLANTS TO PRCUECT DIVISION APO TO PROJECT DIRECTORATES SEGREGATE PLANTS BY NSSS VENDOR (W, GE, CE, B8W)
FOR EACH VEPOOR, SEGREGATE PLANTS BY NSSS DESIGN PARA NTERS (VINTAGE OF NSSS DESIGN, POWER LEVEL, RCS DESIGN - NO. OF LOOPS, CONTAINENT DESIGN, ECCS DESIGN)
- FOR EXAPPLE, PROJECT DIRECTORATE #1 HAS
- EARLIEST VINTAGE WESTINGHOUSE DESIGN 4)0-500PWE ALL EXISTING 2 LOOP DESIGNS
- LARGE DRY CONTIAPK NT
- PLANTS ASSIGNED ARE:
GINNA KEWAUNEE PulNT BEACH 1/2 PRAIRIE ISLAPO 1/2 SAN ONOFRE 1 YANKEE ROWE
--v-----w., -we-w..,.-,,-,..,-,-~.--,-w, - . - - . . - - . -w--
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Olvision of Pressurized Water Reactor (PWR) Licensing-A Director: H. Thoseson, Jr.
Deputy Director: T. Novak i
Assistant Df rector for Technical Support (PWR*A)
Assistant Director: J. Knight PWR Project Directorate #2 Engineering Branch (PWR-A) Plant 'Sy' stems Branch (FWR-A)
PWR Project Directorate #1 Branch Chief:
Project Director: -- Project Director: Branch Chief:
G. Lear L. Rubenstein R. Ballard W. Gaasnill PWR Project Directorate #4 Electrical Instrumentation and Reactor Systems Branch PWR Project Directorate #3 Project Director: Control Systems Branch (PWR-A) --
(PWR-A)
Project Dfrector: Branch Chief:
- 5. Varga 8. Youngblood Jranch Chief:
R. Rosa C. Berifnger PWR Project Directorate #5 Facility Operations Branch (PWR-A) i Branch Chief:
Project Director: V. Benaroya V. Noonan
- [ -
v Division gf Pressurfred Wate[ Reactor (PWR) Licensing-B a
Director: F. Miraglia Deputy Director: F. Schroeder i
i Assistant Director for Technical Support (PWR-B)
Assistant Director: D. Crutchfield PWR Project Directorate f6 PWR Project Directorate #7 Engineering Branch (PWR-8) Plant Electrical Instrumentation Project Director: Branch Chief: and Control Sy*? m Branch (PWR-B)
Project Director: -~
Branch Chief:
J. Stolz G. Knighton W. Johnston
- 0. Parr PWR Project Directorate #8 Special and Standardization Reactor Systems Branch (PWR-B)
Branch Chief: Facility (Operations PWR-B) Branch Project Director: Project Directorate Project Director: C. Thomas Branch Chief:
A. Thadant W. Regan H. Bertow Integrated Safety Assessment TMI-2 Cleanup Project Project Directorate Directorate Project Director: Project Director:
C. Grimes B. Snyder Deputy Director:
W. Travers
.O ,
Divtsfon of Bollfag Water Reactor (BWR) Licensing Director: R. Bernero Deputy Director: W. Houston g
i l
Assistant Director for Technical Support (8WR)
Assistant Director: G. Lafnes I BWR Pmject Directorate f2 BWR Project Directorate #1 Engineering Branch (BWR) Plant Systems Branch (8WR)
Project Director: -- Project Director: 8 ranch Chief: Branch Chief:
J. Zwol1nski D. Muller 8. Liaw L. Hulman BWR Project Directorate #3 OWR Project Directorate #4 Electrical Instrumentation and Reactor Systems Branch Project Ofrector: Project Director: Control Systems Branch (BWR) __ (BWR)
E. Adensam W. Butler Branch Chief: Branch Chief:
M. Srinivasan Vacant
, Facility Operations Branch (8WR)
Branch Chief:
D. Vassalto
( b Division of Safety Review and Overstght Director: T. Spels Deputy Director: 8. Sheren Risk and Reliability Assessment Branch Reactor Safety Issues Branch Regulatory Improvement Branch Branch Chief: W. Minners Branch Chief: Z. Rosztoczy Branch Chfef: F. Congel Engineering Issues Branch Safety Program Evaluation Branch Branch Chief: R. 80snak Branch Chief: K. Knfel i
~O O O Division of Human Factors Technology Director: W. Russell Deputy Director: D. Ziemann Operator Licensing Branch Human Factors Issues Branch Maintenance and Training Branch Technical Specifications Coordination Branch Branch Chief: B. Boger Branch Chief: F. Rowsome Branch Chief: H. Bocher Acting Branch Chief: E. Butcher e
_m -- -__ ____ _ _ _ _ . _ _ . _ _ _ . _ .
l s.
IMPLEMENTATION FEATURES OF HYDR 0 GEN CONTROL RULE 10CFR50.44(c)(3)(Iv)-(vII) l l
e EFFECTIVE DATE OF RULE - FEB. 25, 1985 o PROPOSED SCHEDULE FOR MEETING RULE - BY JUNE 25, 1985 i
e STAFF RESPONSE - FINAL SCHEDULE - BY SEPT. 23,-1985 l e COMPLIANCE WITH PARA. (C)(3)(IV)(A) - BEFORE EXCEEDING l 5% POWER HYDR 0 GEN CONTROL SYSTEM PROVIDED (IGNITERS) -
j t
SUITABLE PROGRAM OF EXPERIMENT AND ANALYSIS CONTAINMENT INTEGRITY MAINTAINED - 75% MWR l
. i e PRELIMINARY ANALYSIS TO SUPPORT INTERIM OPERATION AT FULL POWER j
f e FINAL ANALYSIS l
HYDR 0 GEN BURN SURVIVABILITY OF EQUIPMENT NECESSARY FOR (1) SAFE SHUTDOWN
- (2) CONTAINMENT INTEGRITY
[
e APPLICATION TO RIVER BEND :
09/11/85 !
HC0G PROGRAM TASKS - SCHEDULE / STATUS TASK 1 - ESTABLISH MOST PROBABLE HYDROGEN GENERATION EVENT COMPLETE 9/85 TASK 2 - SELECT MITIGATION SYSTEM
- COMPLETED TASK 3 - DESIGN HYDROGEN IGNITION SYSTEM'
' COMPLETED; TECH. SPECS. 10/85-12/85 TASK 4 - CONTAINMENT ULTIMATE CAPACITY ANALYSIS .
COMPLETED e
TASK 5 - SELECTION'0F CONTAINMENT RESPONSE ANALYSIS CODE COMPLETED 1
f TASK 6 - HYDR 0 GEN COMBUSTION TESTING i'
COMPLETE 10/85 TASK 7 - GENERATION OF HYDROGEN RELEASE HISTORIES COMPLETE 11/85 TASK 8 - CONTAINMENT RESPONSE ANALYSIS COMPLETE 6/86 09/11/85
I HCOG PROGRAM TASKS - SCHEDULE / STATUS (CONT'D.) l l
I l
, TASK 9 - DIFFUSION FLAME THERMAL ENVIRONMENT (1/4 SCALE TEST PROGRAM)
COMPLETE 9/86 TASK 10 - EVALUATION OF DRYWELL RESPONSE TO DEGRADED CORE ACCIDENTS COMPLETE 12/86 TASK 11 - EQUIPMENT SURVIVABILITY ANALYSIS PROGRAM COMPLETE 12/86 (CONDITIONAL)
\O TASK 12 - VALIDATION OF ANALYTICAL METHODS COMPLETE 6/86 j
TASK 13 - COMBUSTIBLE GAS CONTROL EPG i COMPLETE 12/86 ,
TASK 14 - NEVADA TEST SITE DATA EVALUATION COMPLETE 11/86 O
09/11/85
IMPLEMENTATION FEATURES OF HYDROGEN CONTROL RULE O 10CFa50.uu(c)(3)(iv>-(vii> .
e EFFECTIVE DATE OF RULE - FEB. 25, 1985 e PROPOSED SCHEDULE FOR MEETING RULE - BY JUNE 25, 1985 e' STAFF RESPONSE - FINAL SCHEDULE - BY SEPT. 23, 1985
- e COMPLIANCE WITH PARA. (C)(3)(Iv)(A) - BEFORE EXCEEDING 5% POWER HYDROGEN CONTROL SYSTEM PROVIDED (IGNITERS) -
SUITABLE PROGRAM 0F EXPERIMENT AND ANALYSIS
]
CONTAINMENT INTEGRITY MAINTAINED - 75% MWR e PRELIMINARY ANALYSIS TO SUPPORT INTERIM OPERATION AT FULL POWER e FINAL ANALYSIS l
HYDROGEN BURN SURVIVABILITY OF EQUIPMENT NECESSARY FOR (1) SAFE SHUTDOWN
.(2) CONTAINMENT INTEGRITY l
e APPLICATION TO RIVER BEND o 09/11/85
HC0G PROGRAM TASKS - SCHEDULE / STATUS O
TASK 1 -- ESTABLISH MOST PROBABLE HYDROGEN GENERATION EVENT COMPLETE 9/85 ,
TASK 2 - SELECT MITIGATION SYSTEM COMPLETED TASK 3 - DESIGN HYDROGEN IGNITION SYSTEM COMPLETED; TECH. SPECS. 10/85-12/85 TASK 14 - CONTAINMENT ULTIMATE CAPACITY ANALYSIS .
COMPLETED TASK 5 - SELECTION'0F CONTAINMENT RESPONSE ANALYSIS CODE COMPLETED 4
TASK 6 - HYDROGEN COMBUSTION TESTING COMPLETE 10/85 TASK 7 - GENERATION OF HYDROGEN RELEASE HISTORIES COMPLETE 11/85 TASK 8 - CONTAINMENT RESPONSE ANALYSIS l
COMPLETE 6/86 O
09/11/85 ,
I i
1 HC0G PROGRAM TASKS - SCHEDULE / STATUS (CONT'D,)
O .
TASK 9 - DIFFUSION FLAME THERMAL ENVIRONMENT (1/4 SCALE TEST PROGRAM)
COMPLETE 9/86 TASK 10 - EVALUATION OF DRYWELL RESPONSE TO DEGRADED CORE ACCIDENTS COMPLETE 12/86 TASK 11 - EQUIPMENT SURVIVABILITY ANALYSIS PROGRAM COMPLETE 12/86 (CONDITIONAL) .
.O TASK 12 - VALIDATION OF ANALYTICAL METHODS COMPLETE 6/86 TASK 13 - COMBUSTIBLE GAS CONTROL EPG COMPLETE 12/86 .
l
~
TASK 14 - NEVADA TEST SITE DATA EVALUATION l
COMPLETE 11/86 O !
09/11/85 >
i
t I e
i 1
1
. ABILITY TESTING AND PERSONNEL SELECI' ION i
i -
Joseph Zeidner .
l The George Washington University .
1 i
I for i
The United States Nuclear Regulatory Ccamission Mvisory Ocamittee on Reactor Safeguard September 13, 1985 l
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t INTRCDUCTION
.O 2his paper will highlight four points: current concerns surrounding
. personnel selection testing; the validity or effectiveness of selection tests; valiMty generalizations; and the cost-effectiveness or utility of tests.
One of the nore enduring effects of the Weld War I military personnel f
selection program must be the inpetus it gave to mental testing in the
~
- - civilian sector. The Army Alpha tests were the first written tests of mental ,
ability to gain respect and they still serve as the model of scientific testing today. Because tests were administered to groups, they represented ,
a convenient means of ranking everyone for nearly every purpose. Biplqrers ,
j were quick to utilize tests as one means of increasing productivity, especially j
! since the tests were perceived as being objective and predictive of later ,
! perfozmance. Over the decades numerous validations studies attested to their j effectiveness as predictors of training and job success. ;
1 However, in recent decades there has been much social and scientific I controversy surrounding testing. Critics have focused on tests' fairness and their adverse impact, the limited predictive powers of tests for long-tenn ;
job performance, and the often narrow range of skills covered by tests. In ;
1 short, tests are criticized as inadequate for the purposes they were designed j b
I to serve. At the same tine, scientific cr'. tics began to question the :
1 theoretical bases of measuring individual differences in cognitive skills, j i the inability of researchers to break the asynytomatic barrier of job l validities (the ".3 problen"), and the limited advancement in theory and {
f practice.
CURRDfr CONCERNS j
- i i
I would like to elaborate on a half dozen current issues of major concern l
}
- in the anploynent testing comunity today. .
r l
Testing and the Iaw ..
a There has been a continuing concern that selection tests deny qualified {.
i applicants access to jobs. Title VII of the Civil Rights Act of 1964 has been !
the primary legal basis for protecting individuals against enployment discrimination I
h i
e
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i .
4 to the Act, however, expressly permits the use of I
. The 'Ibwer .----u professionally develq=d ability tests in selecting enployees. The Supreme court laid down a series of rulings on test usage that together with the aqual sployment Opportunity Ccanission Uniform Guidelines define acceptable I practices, particularly for denenstrating jot >-relatedness and equal effectiveness in prediction for minorities and non-minorities. l Differential Prediction
. The legal challenge to testing stimulated an interest in evaluating
- differential prediction in and -ia, industry and the military through conparison of regressive systems for different groups. If individuals fra two different subgroups (e.g. race or sex) have the same , scores on an enplo p t test, but then predicted performance scores based on subgroup regression bases are different, differential prediction has occurred.
In general, results show that there are no differences in predictions based on minority or majority group data.
4 Validity Generalization Case law also awakened a long-dormant interest in valdity generalization i or transportability of tests. The prevailing view through the years was that enployment test validations were situation-specific and that empirical data were needed for each new situation. Recent work, correcting for various sources of artifactual, between-study variance, sburgly supported the utility
! of validity generalization and thus makes it possible to develop general
- principles for linking ability tests to classes of job.
However, a long-standing aspiration of researchers was to use smething nore emprehensive and relevant than training indicators or supervisory ratings
! of job performance as criteria'for evaluating selection tests. Again, because of the legal enphasis on enpirical measures of test validity against job performance, researchers turned their attention to the difficult, tine i consuning, and expensive task of measuring job performance through a canbination of objective hands-on measures of performance, job knowledge I
- naasures, and behaviorally-anchored rating scales.
- Cmouterized Adaptive Testing Although research on "ta N red testing" started several decades ago, the everyday application of amputerized adaptive testing (CAT) only ha<w possible with advances in micro-cmputer technology and refinement in Item Response Theory. CAT pemits autmated testing using a display screen and a light pen (or other device) for responding. Test questions are tailored by the response to the previous question, and emputer-soored
! after each response. The terminal used by the examinee is designed expressly for testing purposes. The sequencing of items in tailored testing has as its principal goal equal precision of estimating ab.ility
~
for the total distribution of examinees, not just at the middle or at a given cut-score. Other CAT advantages are test security, simplicity of test .
revision, scoring accuracy, and efficient use of t2me. The Departrant of Defense has an ongoing large-scale implementation program designed to replace traditional paper and pencil tests with CAT.
cognitive 'msting l
~ Until recent times, the theory of cognitive abilities in differential
- psychology depended on factor analytic techniques. Thurstone's primary mental ability structure (or variations of it), with its seven relatively independent factors, served as the theoretical basis for selection and classification batteries for a half century. Many cog'itive n psychologists, however, were looking for a deeper understanding of individual differences in information processing based on an experimental rather than on a correlational approach.
In the cognitive approach, stinulus variation is examined more closely than the variation of individuals, which is the focus of the differential approach.
Research is now underway to see to what extent the two approaches can form a carmen basis for testing abilities for selection and training. 'Ihe hope is that psychmetric testing can be supplemented by infomation processing
, sucedures. While conputer technology new makes this possible, the i critical question that remains to be demonstrated is if there is inproved l validity. :
O !
l l
VALIDATING THE ARMED SERVICES VOCATIOt&L APTITUDE BATIERY
'Ihe current issues just described are being actively addressed progrannatically by r*= archers in the military setting through an analysis of a ocanon selection and classification battery, 'Ihe Amed Services vocational Aptitude Battery (ASVAB), which is administered to one million military applicants each year in all four services. A version of the ASVAB also is given to about the same number of high school students for vocational counseling and recruiting purposes. Although the ASVAB is a direct lineal descendent of the Amy Alpha of 1917, the services are now more active than ever before in seeking improvements in the ASVAB. This can be attributed to a nunber of factors including significant develognants in cognitive theories and caputer technologies, Congressional directives that the ASVAB be shown to be valid against job performance (rdther than ,
training performance), and social concerns surrounding testing.
- The Army Research Institute is undertaking a remarkably ambitious, large-scale, longitudinal research effort designed to address many of the current key scientific issues in the selection and classification area. At this point, a comprehensive set of predictor and performance measures have been already developed for 15 of 19 representative Army occupations, most with civilian job counterparts. A concurrent validation study is well underway. One feature of the research, especially worthy of cmment, concerns the develognent of criterion measures. A central aim of the research was to validate tests against job perfomance measures and to ensure that these measures were the best that the state-of-the-art pemitted. Consequently, a significant anount of effort was spent on the develognant of such measures.
Because of the m11ti-dimensionality of job performance, many different per-femance measures are not only possible, but considered desirable. After careful selection of a cross section of occupations, behavioral job analyses were done on each occupation. The strategy adopted in measuring job performance was to use a conbination of measures based on hands-on performance tests, job knowledge tests, and behaviorally-anchM ratings.
Hands-on performance tests were considered to be the best in terms of job relevance, fairness, and for jobs having a significant psych.ar omponent.
Knowledge tests, linked to knowledge-based task elements, were ' considered to have wide applicability and feasibility. Performance ratings permitted f
I measurement of dimensions not tapped effectively by other means.
a f
_ _ _ _ . _ . ___. _ _ _ _ _ _ _ ..___._ ___ ~ __- - = . = -
A related effort of the Army Research Institute deals with the develegnant of a person-job matching (PJM) system to inventory available abilities for jobs and to develop a strategy for allocating these abilities (
to meet organizational goals. 'Ihe development of a PJM system is an f ir.tardisciplinary process using performance criteria and predictor information,
- personnel supply and demand data, models for planning, executing and. ,
l evaluating person-job decisions, and decision support system such as da+ahaaa=,
carmunication interfaces, and control nodules. The utility of a PJM system
! '- in terms of productivity gains measured in dollars should be considerable.
i _
i VALIDITY OF SELECTICN TESTS i
This section presents data obtained within the military setting. Such l
i data are generally based upon nuch larger sample sizes than ocuparable job ,
data obtained in the civilian sector. Table 1 gives examples of validities -
l obtained with the the Amy General Classification Test '(AGCr) administered l
to 10 million soldiers during World War II. The AGCr consists of four i subtests: reading and vrahn1=vy, arithnetic ccmputations, arithnetic reasoning, and pattern analysis. The AGCr was initially used as a broad f
clarification instrunent, a measure of general learning ability. It gradually was transformed in post World War II years into a differential aptitude battery. In place of a single test score, a cambination of tests were used for assigning people to various groupings of jobs.
j Although the data in Table 1 are more than four decades old, there are still inportant generalizations that can be made. A scan of the validities in Table 1 shows that the AGCr was quite successful, in general, in selecting
(
- individuals for Army specialist training. Since most of the sanples for these validity studies were preselected on the AGCr itself (or on sans other highly correlated factor), correlations, although generally substantial, are underestimates of validity because of range restriction. The standard l
deviation (SD) for the AGCr is 20 in the Army population; nest of the SDs l
! in'the table censiderably smaller. When the SD is around 20, validities j
are higher (e.g. M-+=Mer trainers, validity .62) .
l Note, too, t validities are highest when grades are used as the criterion measure; validities are much lower when either supervisory ratings i
I or hands-on performance measures are used. These differential validity results for the three different types of criteria is a general finding i
confirmed in later studies through the years.
e various Exa.mpics of ialidity Coef ficianto for t.h3 AGCT i (Zeidner and Drucker,1983) Tablo 1 1 1
Popuisttes Criteries 5 haan ED y Me.1Mttee Clerical Trainees. AAT Credes 2947 121.7 11.1 .40
.t' Masa: Trstsees. AAF l;1tal Trassees, ArsoreC Cred e s (vst sht ed)
Crede s 123 119 123.9 125.3 9.9 8.3
. A4,
.33 (NJ rtsa2 Tratsees,tsAAC Crad es 197 116.1 12.0 . 6,2 E rplant hechc ie Trainees Crade s 99 1C4.8 10.6 .32 Air 1ame mecharit tratmens Crad e s 3:11 418.1 10.7 .35 kstar >s cha=1s Trainees Crases 318 51.3 24.4 .69 T e k hechasic Traineena Cre d e.a 137 116.6 11.3 .33 Aircraf t Arier trainees Cradas atti 117.3 10.9 .&D Aareraft Areer 7tatsees lations 449 112.1 12.1 .27 E rtraft Valttag trattees Cra d e s 313 114 . 4 10.3 .26
&emaatsht h attataste Trainees trad e s 115 121.1 12.5 .31
. Sheet Antal Trainees, AAF Crades ?$4 115.6 10.3 .27
. 121 stype M.itte a.ste tratseet. AAT Credes 457 1 3.5 12.1 .20 14:1e Operater & Machanit Trainees, 4AF Crades ICSS 121.4 11.1 . 12 h cts c'peratsr a hatha = e Traine.ea, AAJ Ceee Re t s pee d , Vm 111 111.4 1.1.7 .24 -
t.atta berater tratsees, u.A: Credes 152 116.2 11.7 .34 .
Latte ha sta=tt Itainees, u? Crases 419 ,
101.0 12.0 49 C; r.e-y tratnees. Aru.aret Crades 66 lit.C 1*.1 .1C f aalt A. tClary tra!oees. Instr.ne:t et 5sewey Crates 61 1:2.1 6.5 .23 h:ter Tr anepert .;tainees. VaA* Crades 269 112.4 13.6 .31 fam.k I'rteer tratmees La tin g s 330 t;.7 19.5 .36
!;wek 2-teer trasmees la.a t ins t h t ta gs 421 11.1 2C. .13 n shartier Trainee s. A.AT Crade s Acases.1: AC 111.3 11.6 . 62 f.>ircraf t Var-tag Trassees Flotter-Taller trades Theory 119 1C7.1 15.6 . 73
'reraf t Va rr.tng tratme as. Flerter-Taller Crase s , Perf ersasta ill 1C*.1 11.6 .26
[ is11tgence tratsees. A.47 t ra s e s . Aza sesa r Ice 111.9 1C.6 . .31 s
k.Ertegrapy trainees A.aJ C ases 43' 111.C 11.9 .24 Cryi s e rr a Py !?stse e s , AAT Cretes, F' mama 1 417 121.9 9.7 .31 heatur Osse-war tratmeea, AAT Cras e s 1:42 130.2 , 12.3 43 Cf ficer ca.ndtastes, inf antry Cr eda s . Aaa eematt 133 121.0 1C.8 .30 cificer Cassidstes. Orts'asse Credes . As.adez.it 190 111.2 9.6 41 cfficer Canctestes, sissal Corps Crases Azaaesit 113 128.6 10.1 .36 cf tster Candteates, tant teatreyers Crades Acasesis 12 115.5 10.7 64 Cf ficer Canettates, 7temeyertatten Carps Crades, Assessat 314 126.6 9.8 .38 Cfficer Candidates. EAAC Credes Acadesie 787 128.4 11.3 66 E!! ster Cantti.stes, Inf astry b e d e r s t.it La t t.m s 2C1 122.6 1C.t .2 Cf f seer Canistates, cresaste basarsity Iatists 190 121.2 9.6 .07 Cf ficer Cattitates,13 Arms and Eervices 5e:ce ss vs. Fa.L1:Te 1166 121.7 1C.0 .28 4.s: traAmeen, basis engtseertag Cras e s. 1me r g er.at 112 126.6 1.6 .21 Chemistry AI; frainees, basic engineering Crases, hath. Cirig.) 112 126.6 7.8 .36 As; Trathees, persennst peyshalogy tela 1.s Stattsttes 132 134.2 2C.4 .3 As; testsees, pereennal per:Aelery tank.a *.a tests 4 13C 13A .0 10.3 .2%
haa s ureurste Wet Pstet Cadets, 4th Class Crsdes, taglie b f32 131.3 10.9 .&D W st 7 stat Cade ts, 4 th Gees Crades, m.sthamattee. 712 1.11.3 1C.9 43 1 6est Fstat Cadeta, 4th Caos Cra de s , p.:. lit a ry To
- Petrathy 9 12 1 11.3 10.9 40 test psiet Cadets, 4th came Credes, factics 932 131.3' 1C.9 .29 wet PeLat Cadets, ath Cass Credes , f rescN* 161 13 .2 11.0 .22 best FsLas Cesets, 4th Claes trade s , Cermae+ 164 112.4 10.9 .20 het Feist Cadets, 4th caos Credes, speatet 9 12 121.3 3C.9 .19 6 st Petes cadets, 4th Cass Credes, fortugwsre 130.0 10.3 166 .12 911aera1Carrelattee e fare 1ers
-5A-
_ = - =
In 1949, the AGCr was replaced by the Amy Classification Battery, a l 1
. Q1 differential aptitude battery, that made possible differential assigment.
V Since that time, the Amy Classification Battery was validated in numerous studies encloying grades in the training situation and' supervision ratings in the job situation as criteria. An estimate of the mean range of validities f obtained in the training situation, corrected for range restriction,is .4 to i
.6. 'Ihe mean range of validities obtained in the job situation, corrected for range restriction,is estimated to be .35 to .40.
To sumarize the historical data of World War II and the following two decades, ability tests show a very powerful and practically useful effectiveness in predicting training and job success. But the degree of validity depends on the specific type of test used as a selection, the type of training or job performance being evaluated, and the type of performance measures used. (e.g. grade, objective hands-on, job knowledge or spisory ratings) .
It'is generally acknowledged that these measures represent different aspects of job performance, and substituting one for the other will result in the loss of sme unique information. Ccrnplete perfornance measurement would include sme cabination of all three types of measures. Hands-on performance taps both skill and knowledge ccrnponents of the job; written job-knowledge tests measure knowledge only; and supervisory ratings measure job performance and notivation over time. Obviously hands-on tests are nest costly and ratings are least costly. Thus the selection of a job performance measure l
is a trade-off anong the relevance of the measure, its psychmetric quality and the cost of obtaining the measure.
!bving rapidly on to current validity information, Hanser and Gafton (1983) evaluated the current ASVAB ccrrposites against five Army military occupational specialities (.06), with sanple sizes of 200 to 11,000. ~ 'Ihe ASVAB contains 5
ten subtests: four are general ability cognitive tests, four are vocational /
technical, and two are _=paadad. The criterion used was the Skill Qualification Test (SQr) . The sgr is typically a paper-and-pencil job knowledge test.
However, at the time of this study, small emponents of hands-on performance and supervisory rating were incorporated into the overall score. Validities, corrected for range restriction, were .50 to .73.
McLaughlin, et al ( 1984) validated the ASVAB for 81 MOS using a sample 1
.-_. __ _ _.~ - - . - -
of sizes fr a 1,500 to 16,000. Table 2 shows the validities obtained for a general ocznposite (consisting of two verbal and two written tests) and O' for a "best ccznposite" (consisting of the best ocabination of tests from among the ten subtests of the ASVAB) . Fr m the table, it can be seen that the general ccanoosite, a measure of general learning ability, had a range of corrected validities against the training criteria of .31 to .52, l with a mean validity of .39. For the job-knowledge criterion SQTs I
(obtained after about one year on the job), the range of corrected validities l . was .41 to .58, with a mean validity of .44. 'the best possible cmposite i .
added just a few correlational points--for training, .41 and for job knowledge, .48.
l l It is .unportant to point out that the rather high validities between l test ecznposites and jobs is most likely due to the use of a paper-and-pencil '
l criterion measure for both the training and the job situation. Note the .
3
~
similar ragnitude of validities for both reaining and job, scmething not generally found in the validation literature. Such measures, of course, are not representative of job derrands on errployees. I hally, additional criteria (e.g. supervisory ratings, hands-on performance) need to be added.
A large amount of information on the General Aptitude Test Battery (GATB) of the United States Employment Service (USES) is reported in the GATS manual.
! Data are given for 450 studies involving 25,000 individuals (employees, f applicants, trainees, etc.). The large majority of studies used only concurrent validation prr - b es. Most of the canposite validities for the GATB cluster around .40, although cross-validation had not been systematically carried out and rather crude statistical procedures were used. Hunter (1980)
! analyzed a large nunber of USES jobs employing synthetic validity and f validity generalization procedures and reported a validity of .53 across all i jobs. Hunter and Schnidt (1983) found, based on a review of the literature and application of meta-analysis techniques, that oognitive tests effectively
- predict performance in all jobs.
- Frcan this brief review of empirical research in the military and in the
! civilian sector over seven d= ahs, it is clear that selection tests have worked well in the school setting and in the world of work. 'Ihe true estimate
! of effectiveness awaits the developnent of more emprehensive and reliable job performance measures such as the ARI study underway, as discussed earlier.
__--------.-----,----re-n,,.--a - a -- - ---,.,-- , - ,,_e- - - - --,--v... , , . . - , . - , . , - ,.-,..n-,,_. .
l TABLE 2 -
1 Valid 1 ties of General Ability Composite and Dent Composite for Nine Clusters of Army Enlisted Occupations l (Eaton, llanser, and Shields,1985)
I Job Knowledge
, Training Performance y General Best y General Dest Composite Clusters of Occupation Composite Composite Composite 8000 .58 .56 j' .47 .47 5300 j Clerienl/ Administrative .45 16000 .43 1
' 33 35 l 2900 Combat .46 W .41 6000 .43 s
2600 .40
! Elcetronic repair f 7000 .44 .48 f 1800 31 36 Field Artillery i 39 .42
.48 52 11300 1900 l General Maintenance .46
.44 4300 .41
? 5400 39 I Hechanical Haintenance .53 l 7700 . 49' 4600 34 3'6' Operators / Food .
f .
3600 .50 .53 1500 37 37
- Surveillance / Communications .56
.54 6900 .56 3200 .52 Skilled Technical
- 1 ,
VALIDITY GE2ERALIZATION Historically, ability tests that were validated in school or job settings considered to be quite similar yielded validity coefficients that varied widely. Such findings were the basis of the almost universal belief in the " situational specificity" of psychological requirements in training or on the job. The discouraging fact then was that test validities did not generalize to different situations. Olniously, this placed a severe practical constraint on the proper utilization of tests since each new test application required a new empirical validation.
In the industrial setting, there are a number of severe limitations in establishing the relationship between a predictor and criterion such as the avaHability of only quite small sanples, lack of adequate performance .
measures, length of time required to ccznplete a predictive validation study and cost factors. For the nest part then, except in the military, it is
. difficult to provide evidence of test validity.
In recent years, Schmidt and Hunter (1982) along with their associates, applied newly developed meta-analytic techniques to data obtained frcrn a wide variety of jobs. Their findings indicate that general ability tests d (verbal, numerical and reasoning aptitude) generalized across many different jobs, even jobs that were quite different. Such findings would mean that the underlying abilities required in many jobs depended on a ocmnon set of cognitive skills. The differences in validity coefficients traditionally found in other studies were found by these researchers to be artifactual.
'Iheir ata-analytic techniques were designed to deal with the distorting effects of artifacts such as sampling error, measurement unreliability and
{ range restriction while integrating findings across studies. Schmidt and Hunter showed that correcting for these sources of artifactual variance l
I accounted for an average of 62% of variance in validity coefficients, with a range frcan 43% to 87%. 'Ihu: there is little variance left for situation specific factors. Such analyses provide strong evidence that observed variations in validities frcm study to study, for similar test-job ccznbinations, I is artifactual in nature. Rejection of the situational specificity doctrine obviously opens the way to validity generalizations. Only a job analysis is necessary to ensure that the job at hand is a member of the class of jobs l
from which the validity distribution was derived. Schnidt and Hunter point 1
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out that only a very few published studies are corrected for range restrictions, criterion unreliability,and the use cf a dichc h .,us criterien which result j in systematic underestimates of validity and masks the extent of test
! generalization and utility.
l Tenopyr (1982) states that the fate of the cucayi. of broad generalization j of ability tests will dog 1-4, in part on the acceptance of a general factor
! like that cw.uly called intelligence. Another factor in acceptance concerns
'. the nature of criteria enployed in the studies showing validity to generalize
! so widely. Supervisory ratings are the main criterion used in unny of those studies. Such ratings reflect only broad abiliites that are essentially all that supervisors recognize in enployee behavior. 'Ibe only answer is care l fully designed research involving performance measurenent of general, group or,spe-cific factors to be able to manifest. To acccmplish this requires the use of' grades, t~
hands-on knowledge-based tests and ratings criteria as detailed earlier in the ARI research. Another question concerns techniques of placing jobs into i specific groupings.
ascent research clearly has denonstrated that validities generalize to l
t a far greater extent than has been believed previously. The central question e
now revolves around the limits of generalization and how to best determine I the similarities or differences of jobs.
l Although validity generalization is .very app ==Hng, as Tenopyr (1982) .
i I indicates,lit will most likely take scne time to inpact actual practice.
Validity specificity has been the predczninant view for more than five decades.
Additionally, the Uniform Guidelines on Employee Selection procedures and I
case law. call for specific validitions. 'Ihe next practical step, short of l
l definitive data, appears to be scne middle ground that calls for validation l of m p tional clusters or job groupings. ,
i UrILITY OF SE2CTICE TESTS Until reA.ly, the most widely-used indicator of test utility was.the t l
l Taylor-Russell tables published in 1939. The model takes into account the selection ratio (the gepod. ion of applicants hired) and the base rate (the percentage of applicants who would be successful without the use of the test) . 'Ihe Taylor-Russell tables readily show that even a test with a modest validity can greatly increase the percentage who are successful among l
. . _ . . _ _ _ . . - - _ . _ _ _ . , , _ _ . _ , _ _ .. .~... _.- _ ____. _ _._ , _ _ _ _ . _ _ . , _ . _ . , _ . _ . . _ _ _ _ _ _ . . . , _ _ . , _ ~
. . . .- - . . . . _ . . . - -..- __ _. ~_ . -
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those selected when either the selection ratio, the base rate, or both, are low.
] For example, given that the current percentage of successful enployees is 60 percent (base rate .60) and only one of ten applicants is accepted cm the basis of tests (selection ratio .10), a test with a validity of .25 will
~
i increase the percentage of successful enployees to 76%, a gain of 16%.-
he Taylor Russell model has two shortcanings: firstly, the nodal l employs a dich.-us criterion (all enployees categorized as being satis-factory have only a single utility value, and all unsatisfactory enployees another single utility value); secondly, the separaticm between the satisfactory I
and unsatisfactory groups-is set quite judgmentally.
Major advances in utility measurement were made by Brogden (1949) and l l '
Cronbach and Gleser (1965) . A brief description of their model follows ,
Eaton, et al (1985) .
i Brogden, and Cronbach and Gleser provided the first' systematic
!. descriptions of the utility of testing programs indexed in dollars.
{
hey linked normally distributed performance levels to the dollar values estimated for those perfornance levels. Their fornula for the
< Sollar value of the gain in productivity, or utility (US), obtained ,
j by using valid selection procedures includes: (a) Ns, the number i of ixiividuals selected; (b)- SDS), the standard deviation of per-formance, scaled in a utility metric such as dollars; and (c) the .
! average perfonnance WM on the criterion by the selected group 1
i as estimated fran a valid predictor, given by g 3: ;
! E = N.!.s. SDS M g i
While the values of nost of the variables in this in=uation can readily be determined (and c.vmctions made for test adnini-
! stration costs), the estimation of SDS is less certain.
\
Until recent years, few investigators, however, applied this ,s cs .ch in
- f. their own evaluations of test value because of concerns about meeting l
statistical assurptions, the belief'in situational specificity, and the difficulty in obtaining estimates of the standard deviation in dollars. '
In the 1980s, these concerns were shown to be too cautious and applications ,
j of utility enployee dollar netrics began to appear.
l Eaton and his co-workers state:
1
,, ,_...-- _ _ , , , , . _m. ,-- . , ..,. . , _ _.,,_..___.._.,,_,,,-_....mo_rr_.,_,_, .
_ , , . ,__m,-,,_ , , _ , - -
I two rts have a using cost accounting methods. One oczmon alternative to the cost accoun- \
ting methods is to estimate the dollar values to the organization of -l i
performance at the 50th percentile level and the 85th percentile level (one standard deviation above the mean) . 'Ihe dollar difference ,
! between the 50% and 85% provides an estimate of SDS.
]
'Ihis "SDS estimation technique" was used by Cascio and Silbey p
- (1979) with second level managers in food and beverage sales (Mean = S30,000, SDS = $9,000); by Schmidt, Hunter, McKenzie, and ' ;
Muldrow (1979) with caputer progranners (SDS = S10,413); by Hunter and Schmidt (1982) with budget analysts (SDS = $11,327); .
I by Bobko, Karren, and Parkington (1983) with insurance counselors 1 i (Me.an = $16,000, SDS = S5,550) ; and by Burke and Fredrick (1984) 1 ' with district sales managers (Mean = $75,000, SDS = $32,284) .
'Ibe SDS estimations reported above were derived in contexts where dollar values were relatively easy to assess. Managers were
- f instructed to " consider tha cost of having an outside fim
) provide these products and services" (Schmidt et al.,1979, for computer progranmers), or to " consider what the cost would be of having anoutside consulting firm produce these products and services" (Hunter & Schtnidt,1982, for budget analysts) .
- The Schmidt,et. al study (1979) is elaborated, cm here to indicate more l
fully the utility of-selection tests. 1
'Ibey used the job of caputer prograners in the Federal goverment as an exanple of savings that could be achieved by the use of a ocmputer aptitude test with a validity of .76 in selecting new hires for one year.
! Their estimates were based on the use of meta-analysis to data on hand in l the U.S. Office of Personnel Management. 'Ihe pu-Mare used in the caputer progranmer study used estimates obtained frczn experienced supervisors through' a carefully constructed questionnaire. Each supervisor estimated the yearly dollar value to the organization of the services of an average progranner ;
j and a superior performer at the 85th percentile. Estimates of 185 supervisors j
were averaged. 'Ihe average difference in dollars between these two estimates was the SD used in the subsequent calculations. l l \
Results indicate that the use of the test with a selection ratio of d .05, ccinpared to randczn selection, resulted in a gain of 97.2 million dollars.
Estimates of savings using cnesus data of all ccmputer progranmers enployed in the thited States were also made. Hunter and Scirridt (1981) in a subsequent study estimated the savings to the entire national work force in all occupations. These preliminarr and crude estimates clearly indicated the great productivity increases of allocating people to jobs en the basis of tests.
CCNCLCSIONS Emplognent testing in recent times has been the subject of intense public controversy, especially because of perceived adverse impact on minorities. At the sa,e time there have been expanded research efforts, at least as a partial response to criticism. .
Results indicate that cognitive tests effectively predict the future outo:ne of training and job performance, and predict equally well for various sub-groups. The validity of tests of general ability appear to generalize across a broad array of occupations.
The use of individual difference neasurement in matching people to jobs contributes greatly to productivity and is a significant factor in national productivity.
Research is still W fcr estimating tra validities of tests against better criteria, inproved methods of conducting validity generalizations across precisely defined job clusters, and developing more accurate techniques for reasuring cost-effectiveness.
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i REEERENCES Bobko, P., Karren, R., & Parkington, J. J. (1983) . The estimation of '
i standard deviations in utility analyses: An enpirical test. Journal of Acolied Psychology, 68, 170-176. 3 I
Brogden, H. E. (1949) . When testing pays off. Personnel Psychology, 2_,
i 171-183.
1 l Burke, M. J., & Frederick, J. T. (1984) . 'No nodified procedures for i
estimating standard deviaticns in utility analyses. Journal of Applied i Psycholoav, 6_9,, 482-489.
+
Cascio, W. F., & Silbey, V. (1979) . Utility of the assessment center as a selection device. Journal of Applied Psychologv, 64, 107-118.
I -
Cro. bach, L. J., & Gleser, G. C. (1965) . Psychological Tests and Personnel
- Decisions (Second Edition) . Urbana: University of Illinois Press. ,
Eaton, N. K., Hanser L. M..& Shields, Joyce L. (in press) , Validating selection tests against job performance. In J. Zeidner (Ed.) Human j Productivity Enhancement: Volune 2, Organizational Effectiveness, Personnel
! and Decision Making. New York: Praeger.
' Hanser, L. M. , & Grafton, F. C. (1983) . Predicting job proficiency in the Army: Race, sex, and education. (Personnel Utilization Working Paper 82-1) . Alexandria, VA: U.S. Amy Research Institute for the Behavioral and l
Social Sciences.
f Hunter, J. E. , & Schridt, F. L. (1982) . Fitting people to jobs: The impact i l
of personnel selection on national productivity. In E. A. Fleishnan &
i M. D. Dunnette (Eds.), Human performance and productivitv: Volune 1. Human
- canability assessment. Hilladale, N.J.: Iawrence Earlbaun and Associates.
l l
Hunter J. E. (1980). Validity generalization for 12,000 jobs: An application I of synthetic validity and validity generalization to the General Aptitude 4 7bst Battery (GATB), Washington: U.S. Employment Service.
I
! McIaughlin, F. H. , Rossmeissl, P. G. , Wise, L. L. , Brant, D. A. ,. & -Wang, =ites,
! M. M. - (1984) . Va1 Mation *of current and alternate ASVAB area 0 haea9 on training and SQr infornation of FY 81 and FY 82 enlisted accessions. ,
' U.S. Army Research Institute '1%chnical Report 651. Alexandria, VA: U.S. ,
Army Research Institute. .
(
l Schnidt, F. L. , Hunter, J. E. , McKenzie, R. , & Muldrcw, T. (1979) . The inpact l 1
of valid selection yrcmdures on workforce productivity. Journal of Applied .
i Psychology, 6_4, 609-626. i i
l Zeidner, J. & Drucker A. J. (in press) Behavioral Science in the Army: A j Corcorate History of the Amv Research Institute _. Washington, D.C.: U.S.
Goverment Printing Office.
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' Analysis and Recommendations
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Regulatory Washington, D.C. 20555 Commission
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4 i PANEL ON ACRS EFFECTIVENESS ANALYSIS AND RECOMENDATIONS CONCERNING THE SCOPE, METHODS, f
i MANAGEMENT, AND EFFECTIVENESS OF
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i THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS i
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September 1985 Washington, D.C. i 1
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d TABLE OF CONTENTS Page
(
I. Introduction ........................................ 1 II. Scope of ACRS Activities Through the Year 2000....... 4 A. . Background...................................... 4 A.1 Nuclear Capacity................................ 4 A.2 Reactor Safety.................................. 4
. A.3 Waste Management................................ 5 A.4 Dec onsni s s i o n i n g . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 A.5 New Design Initiatives.......................... 5 f A.6 New Management Concepts......................... 6 A.7 NRC Licensing Activities........................ 6 .
B. Impl i ca ti on s for ACRS. . . . . . . . . . . . . . . . . . . . . . . . . . . 6 {
III. ACRS Approach to Substantive Technical and [
Related Issues..................................... 9 t A. The General Approach............................ 9 ;
B. Implications of the Approach....................ll ;
C. Regulatory Research............................ 12 !
IV. Relationships of the ACRS Within and Outside the Nucl ear Regulatory Comi s s ion . . . . . . . . . . . . . . . . 14 l A. Relationship with the Comission and [
Com i s s i o n e rs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 j i
- B. Relationship wi th the NRC Staff. . . . . . . . . . . . . . . . 15 ;
, t C. Rel a tionship wi th Congres s . . . . . . . . . . . . . . . . . . . . . 16 {
D. Relationship with Licensing Boards............. 16
{
E. Relationship with Industry and Intervenors..... 17 i F. Relationship with International Groups......... 17 !
G. Relationship with the General Public...........17 ,
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i f
O TABLE OF CONTENTS (continued)
Page ,
V. Membership on the ACRS and the Selection Process....18 ,
1 A. Purpose........................................ 18 B. S i ze o f the ACRS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 C. Composition.................................... 18 D. Length of Service of Members . . . . . . . . . . . . . . . . . . . 19 E. Appointment and Reappointment of Members....... 20 F. Conflict of Interest........................... 22 VI. Organizational Effectiveness of the ACRS............ 23 A.. The Chairmanship and a Proposed Management Committee......................... 23 B. Sub-committees................................. 25 C. Consultants.................................... 26 D. Ef fort Requi red of Members . . . . . . . . . . . . . . . . . . . . . 27 E. The ACRS Staff................................. 28 4
VII. ACRS Opera tional Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 A. The Consensus Objective and Means for Achieving Consensus........................... 31 A.1 In ACRS' Current Role, Clarification of Issues is More Important than Achieving Consensus.................................... 31 A.2 Better Use of Consensus-building Techniques is Attainable..................... 33 B. Letter Writing: Documenting the Consensus Process............................ 33 11 1
l O
V TABLEOFCONTENTS(continued) 4 4
C. Achieving Better Communication with the Audience Requires More Oral Presenta-tions and Discussion......................... 34 C.1 Important Written Opinions of the ACRS About
' Which at least One or Two Members Feel Strongly Should be Backed up by Oral Dis-cussion...................................... 34 J C.2 ACRS Should Deal with the Regulatory Staff on a Technical and Professional Basis........ 35 i
D. FACA........................................... 36 E. Committee Budget............................... 37 4
VIII. Enhancing ACRS Contributions to the Regulatory Process................................ 39 A. Perceptions of ACRS Contributions. . . . . . . . . . . . . . 39 B. Advi si ng the Consnissioners. . . . . . . . . . . . . . . . . . . . . 40 C. Licensing Reviews.............................. 41 D. Regulatory Policy.............................. 42
. E. Timelines s of Recomendations. . . . . . . . . . . . . . . . . . 42 r F. Evaluating Difficul t Issues. . . . . . . . . . . . . . . . . . . . 43 l
G. Contributions of Members as Individuals........ 44 I .
I IX. Conclus ions and Recomendations. . . . . . . . . . . . . . . . . . . . . 45 A. ACRS Mission................................... 46 B. Relations with the Commission and the NRC Staff................................ 47 i
C. Internal Operational Questions................. 48 O
l 1 111
4 t
TABLE OF CONTENTS (continued)
P_agg APPENDICES
! I. Proposed Task Description for an 1 ACRS Effectiveness Study...........................Al II. Interview Questions..................................A4 ,
! III. Conflict of Interest Restrictions...................A18 ,
I l IV. Consensus-building Techniques.......................A21 1 V. Letter Writing......................................A22 7 1 (1 i
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s PANEL ON ACRS EFFECTIVENESS i
{ I. INTRODUCTION i
l The Advisory Committee on Reactor Safeguards (ACRS) of the U.S.
j Nuclear Regulatory Commission (NRC) was established by law in 1957. l l
Previously, a Reactor Safety Committee had been established by the Atomic r Energy Commission, but the Congress in its report amending the Atomic- !
Energy Act to establish the Committee stated that the main reason for making the Committee statutory was "...to ensure that any features of new reactors would be as safe as possible. This subject was thought to be so j - important as to require a committee established by statute." (Report of Joint Committee on Atomic Energy, Public Law 85-256, September 2,1957.)
l The current law pertaining to the ACRS, including amendments, provides as follows:
1 There is hereby established an Advisory Committee on Reactor
, Safeguards consisting of a maximum of fifteen members appointed by I the Commission for tems of four years each. The Committee shall, ,
I review safety studies and facility license applications referred [
i to it and shall make reports thereon, shall advise the Consission ;
i with regard to the hazards of proposed or existing reactor i
facilities and the adequacy of proposed reactor safety standards, ;
i and shall perfom such other duties as the Consission may request. l One member shall be designated by the Committee as its Chairman. [
The members of the Committee shall receive a per diem compensation j for each day spent in meetings or conferences, or other work of &
the Committee, and all members shall receive their necessary :
i traveling or other expenses while engaged in the work of the .
- Committee. The provisions of section 163 shall be applicable to i the Coumittee (exempting the Committee from conflict of interest j
{
statutes except for compensation from a source other than a non- !
I profit educational the Commission institution or in which theofCommission any matterisdirectly directly involving interested ). :
{
In addition to its other duties under this section, the Committee, !
making use of all available sources, shall undertake a study of (
j reactor safety research and prepare and submit annually to the j j Congress a report containing the results of such study. (Section !
29, Atomic Energy Act of 1954, as amended.)
l The Advisory Committee on Reactor Safeguards shall review each {
application under section 103 or section 104b. for a construction pemit or an operating license for a facility, any application under section 104a. or c. specifically referred to it by the :
Commission, and any application for an amendment to a construction i pemit or an amendment to an operating license under section 103 O ;
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or 104a., b., or c. specifically referred to it by the Commission, O( and shall submit a report thereon which shall be made part of the record of the application and available to the public except to the extent that security classification prevents dis-
- closure. (Subsection 182b., Atomic Energy Act of 1954, as '
amended.)
To assist the Advisory Connittee on Reactor Safeguards in carrying out its function, the Committee shall establish a fellowship program under which persons having appropriate engineering or scientific expertise are assigned particular tasks relating to the functions of the Comittee. Such fellowship shall be for 2-year 4
periods and the recipients of such fellowships shall be selected pursuant to such criteria as may be established by the Comittee.
(Section 6, Public Law 95-209. December 7, 1977.)
> In recognition of changing requirements in the regulation of
, peaceful nuclear uses, the ACRS in December,1984, decided to appoint a j panel to assist the Committee in its efforts to define better the
- Comittee's role, goals, and procedures so as to improve its effective-ness as an advisory board. The Task Force Description, which is .
i enclosed as Appendix I, states that "The purpose of the Panel's review should be to provide advice and guidance that will permit the ACRS to i
improve its' effectiveness as an advisory body to the Nuclear Regulatory Comission and in furnishing more general leadership in matters of l
reactor safety. There are indications that some of the Committee's practices and policies, while effective in the past, may not be as i
! appropriate for the maturing and changing industry and regulatory l
! climate of today." As a result, the panel on ACRS Effectiveness was i
established in early 1985, with the following membership:
i Mr. L. Manning Muntzing, Chairman i Doub and Muntzing, Chartered l Washington, D.C.
- Dr. John F. Ahearne l 4
Resources for the Future !
j ,
Washington, D.C. (
Mr. Myer Bender l Querytech,Inc. [
Knoxville, Tennessee ;
f Mr. Edson G. Case (Retired, fomerly U.S. Nuclear Regulatory Comission Washington,D.C.)
Dr. Home: J. h gedorn l Arthur 9. L4;tle, Inc. !
Cambridt pA4assachusetts [
l Mr. Richard Hubbard
- MHB Technical Associates t San Jose, Ca11(ornia :
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Dr. Herbert J. C. Kouts
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Brookhaven National Laboratory Upton, New York Mr. Steven Sholly Union of Concerned Scientists Washington, D.C.
i Mr. John M. West (Retired, fonnerly Combustion Engineerin 1 Windsor, Connecticut)g,Inc.
i Members of the panel conducted interviews with a idde range of persons who have either dealt with the Committee or are interested in its activities. The panel interviewed approximately sixty-five per-sons. These included all current NRC Conunissioners as well as prior i Commissioners, all members of the current ACRS and some prior members, a number of members of the NRC Staff as well as prior staff members,
' NRC lawyers and members of the Hearing Boards and Appeals Board of the NRC, Congressional staff personnel, members of industry, representa-tives of public interest organizations, and state attorneys general.
(A copy of the questionnaire developed for use and guidance during the interviews is enclosed as Appendix II.) The interviews served as an
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important input for the panel's deliberations, and the time and effort
- given by the many people interviewed to share and discuss their views j
with the panel are greatly appreciated.
The panel recognized that the ACRS had an operational history dating back to the 1950's and thus focused its attention on how the Cossnittee could be most effective in the coming years and on ways in which improvements could be made in the Consnittee's work. To do this, the panel considered the expected future scope of ACRS activities and approaches to its mission. Relationships to other organizations were evaluated so as to focus on the prime audience for the Committee's deliberations. Various managerial questions were addressed, such as membership on the ACRS and the selection process, organizational i
issues, and methods of operation. Finally, the panel considered the past effectiveness of the ACRS and developed illustrative criteria for i
measuring future Consnittee effectiveness, i
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l II. SCOPE OF ACRS ACTIVITIES THROUGH THE YEAR 2000 j O A. Background Discussion of the scope of ACRS activities throughout the rest of
, this century requires decisions on two fundamental issues: first.
l what will be the likely conditions of the nuclear industry and events
! affecting it throughout the next fifteen years, and, second, what
! ought to be the role of the ACRS with respect to the NRC and other i
audiences. This chapter will primarily focus on the first issue and j then draw conclusions regarding the scope of ACRS activities. Chap-ters III and IV will address the second issue.
)
The Panel developed major assumptions for the nuclear field for i the next fifteen years, focusing on those that might have an impact on i the ACRS. These assumptions are not unanimously agreed to by the Panel. Where there were several strong views represented, the de-
< scription indicates this split. Although the Panel addressed a i broader list of issues, those that seemed to be most important in :
{ determining the appropriate scope for the ACRS are the following:
I A.1 Nuclear Capacity ,
i i There has not been a sustained booking of a nuclear power plant in the U.S. since 1978, in sharp contrast to the average of 24 units
- per year between 1965 and 1974. Furthermore, cancellations have 3
O reduced the number of nuclear plants currently on the books to approx-imately 125 units.
1 i
Demand for electrical power continues to grow. The nuclear
- plants under co'rstruction or in operation, which now represent about
! 15 percent of the U.S. capacity, will be critical to maintaining the
) existing national capacity. As further supply expansion occurs, it j will be mostly in fossil fuel plants or in nuclear plants. In any
- case, it will be desirable for the existing base of nuclear power i plants to reach its anticipated, useful lifetime and perhaps to extend its lifetime because of its economic value. ;
A.2 Reactor Safety i
} The Panel believes it is not possible to confidently predict either the severity or the frequency of future accidents. However, it l 3 also is not possible to preclude accidents in the future. The Panel *
! assumes that the average number of events per operating reactor year ,
will be the same as today, with one relatively large event (e.g., -
l similar to the Brown's Ferry fire or the Salem ATW5 event) approxi-i mately every five years. The Panel could not agree on whether there i would be another accident as severe as TMI-2 during the next fifteen -
j years or, in the event of a major accident, whether significant off-
! site exposures should be expected. Nevertheless, the Panel does note
' that reactor years are accumulating at an accelerated rate: twenty years up to now were needed to experience the same number of operating years as will be accumulated through the remainder of the 1980's.
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A.3 Waste Management q
Spent civilian fuel is expected to be delivered to the Department of Energy at a monitored retrievable storage facility which is ex-pected to be operational in the 1990-1995 time frame. The Panel expects a high-level waste repository site to be chosen, the licensing review process completed, and construction begun, before the year 2000, but operation is not expected by then. The Panel expects state rompacts for low-level waste disposal to have been approved by Con-gress, and 4-10 low-level waste sites to be operating.
There probably will be increased interest in the use of dry vaults for at-plant storage, such as those with which TVA is experi-
. menting, to decrease the number of spent fuel shipments and stretch them out past the useful life of a plant. Although issues will continue to be raised, it is expected that there will be increased shipments of nuclear materials whose risk will need to be considered.
However, the transportation requirements that have been developed are thought to be adequate to prevent any significant releases.
A.4 Deconnissioning The Panel' assumes there will be a strong incentive to keep nuclear plants running as long as possible because once the capital costs have been paid off the electricity they generate will be rela-tively inexpensive. The Panel expects no decommissioning of large plants, but estimates that some small reactors will have ended their O. useful life by the year 2000.
Although nuclear plants will be operated as long as safety and economics justify their use, the deconnissioning actions needed for these plants will have to be considergd well in advance of plent shutdown. Experience with TMI-2, Dresden 1, and Shippingport will provide the underlying basis for future regulatory requirements concerning deconnissioning. Service life extension of "near-end-of-life" plants will require attention to disposition of parts of
, these plants that are no longer useful.
A.5 New Design Initiatives Most utility executives believe that the light water reactor (LWR) type should be improved rather than abandoned in favor of a radically different type for which there is little or no experience.
i There is some interest in parallel development of potentially attrac- ,
tive types such as a small, passively safe reactor.
i Most utility people believe that the existing LWR designs should be improved in an evolutionary way in certain areas and then standard-ized. The Electric Power Research Institute (EPRI) has launched an Advanced LWR Development Program whose goal is to develop criteria that i NSSS vendors and architect-engineers will follow to produce standard-ized designs. The Panel expects the NRC will be asked to endorse 5
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l this program in order to relieve uncertainties and increase predicta-
- bility.
A.6 New Management Concepts There may be a shift in the way reactors are owned and operated.
Generating companies may come into operation that would own generation facilities and then sell electricity to transmission and distribution companies. These generating companies may not be regulated utilities; they would be under safety regulation but not necessarily under economic regulation. They would tend to be regional entities.
A.7 NRC Licensing Activities 4
The Panel expects reactor regulation through the year 2000 to place more emphasis on quantitative safety goals and on operating facilities. While it is not expected that Congress will impose new regulatory requirements, some licensing refonn legislation may be
- l. passed that will affect licensing procedures.
J j B. _
Imolications for ACRS As noted~in Chapter I, the basic requirements for the ACRS as listed in the Atomic Energy Act, Section 29, were put into statute in 1957, with some modification in 1962. The world has changed drastic-ally in the subsequent years, as can immediately be seen by trying to O construct an estimate of what the next fifteen years would have looked like using 1960 as the basis. Given the above scenario for nuclear power in the United States over the next fifteen years, what are the implications for the ACRS?
- In the early years of its existence, the ACRS was strong, the Regulatory Staff was relatively weak, the Atomic Energy Connission i left most of the initiative on safety to the ACRS, and the Joint Committee on Atomic Energy through its oversight role reinforced an ACRS dynamism. There were few licensing cases to consider. The only public hearings provided were those held by the ACRS. It was during this period that most of the broad enduring contributions of the ACRS were made.
In more recent years, the Joint Committee was disbanded, and the
- new Nuclear Regulatory Connission assumed the single role of regulat-ing the nuclear industry. The regulatory staff grew greatly in size and competence as the general policy decisions of the earlier period were developed into a mass of detailed implementation requirements, and as the rate of licensing cases greatly increased. De facto, the role of ACRS changed to the position of evaluating the adequacy of the j staff's licensing review.
At the same time, the two layers of Hearing Boards that provide public hearings were assuming a greater importance, in response to I increased activism by intervenor groups. The Atomic Safety and Licensing Boards and the Atomic Safety and Licensing Appeal Boards l
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l also became backstops to the regulatory staff. In the 1980's the NRC s staff is much stronger. The NRC differs from the AEC, which had to devote much of its time to other programmatic problems, especially the nuclear weapons program. Comissioners now have increased interest and roles relative to regulation of nuclear power.
The unique importance of ACRS languished, subjugated to the secondary job of " keeping the Staff honest " and facing competition even in this. Some came to regard the ACRS as an anachronism no longer required except to issue letters on docket cases and to issue an annual review of safety research as required by statute.
The Panel has concluded that the need for continued detailed ACRS review of license applications no longer exists. This may even raise in some minds the question as to whether the ACRS itself is still necessary. However, in the flood of licensing reviews in recent years and in the midst of turmoil of readjustment following the TMI
< accident, memory of the other contributions of ACRS in the past has been submerged. The Panel believes that it is the activity of the ACRS in advising on broad technical policy that has been most valu-able. ACRS is still needed, but not for licensing reviews. It is very much r.eeded in the more important activity of providing wise, broad, technical policy advice.
The Committee's title includes two words whose current validity
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i is questionable: reactor and safeguards. The term safeguards has been used to refer to issues concerning protection against sabotage and diversion of nuclear material. The Committee's role is far
" broader than that (and some would recomend excluding those two subjects from the ACRS secpe). With regard to " reactor", the funda-mental issue is: should the Committee restrict itself to reactor issues. In light of the changing range of interest of the ACRS and the meaning of the word " safeguards", a more accurate name would be appropriate, such as the Advisory Comittee on Nuclear Safety, Ad-visory Comittee on Nuclear Regulation, or the General Technical Advisory Comittee, to fit the revised role that the Panel suggests in this report.
The issues that are going to be most important for the NRC and therefore for the ACRS in the next fifteen years, as outlined in the
, previous description of our estimate of the future, include much greater stress on generic issues, operational plants, waste management issues, and future reactor designs. Even though fewer plants will come up for review, the Panel believes that the ACRS should spend much less time on each individual plant. The ACRS is not a second regula-tory staff. It is recomended that the ACRS not review a plant of a type previously reviewed unless a unique feature is involved. In that case, the ACRS review should be directed toward this unique feature and its implications. Thus, the ACRS should do selective review, and then only if there is an important issue (e.g., a new containment concept). The Panel recognizes this will take a legislative change.
O However, the Panel believes such a change important: the objective is l
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to permit the ACRS to focus on the new, important, or troublesome Os issues, rather than the routine.
The Panel believes the ACRS should be involved in covering issues of waste management because those will be of great importance to the NRC. However, we agree the technical issues are neither as complex i
- nor as directly related to the skills of the current members as safety of nuclear power plants (obviously, the latter point can be resolved by selection of new members). The Panel does not believe the ACRS should be involved in the design of new reactors but it ought to be involved to an extent in the review of such design proposals, partic-ularly in the review of criteria that are suggested either by the industry or by the NRC staff. ,
Issues that the Panel has identified as appropriate for the ACRS scope do not specifically include detailed review of research budgets.
This topic is discussed in more detail in Section III of the Panel's report.
If, as the Panel is recommending, the ACRS is to be available to cover the wide range of NRC technical regulatory policy issues, it is i
obvious that it cannot do so with the type of detailed technical depth that it has been inclined to use in the past. This does imply a shift to more of a generalist approach. It also raises the question of additional advisory groups. Currently the NRC has an advisory group on medical isotopes. Some of the interviewees recomended foming O' advisory comittees on radiation effects and waste management. It has in the past been suggested that a specific advisory comittee on research be formed. Forming these specific groups would fit with the conclusion of a current member of the ACRS who said "the NRC needs a General Advisory Comittee to help them on management, administration, and regulatory problems." In fact, a general advisory comittee is the type of comittee that the Panel is recommending. Whether spe-cialized advisory comittees would then be appropriatt we leave up to the NRC to decide, since any such would be advisory to elements of the staff rather than to the Commission as a whole.
In sumary, the Panel recommends the ACRS be a true advisory comittee to the Commission, with a charter much broader than merely reactors, particularly when reactor issues are defined narrowly as being those issues appropriate to the design, construction, and operation of nuclear power reactors.
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III. ACRS APPROACH TO SUBSTANTIVE TECHNICAL AND RELATED ISSUES
! A. The General Approach i
l In addressing the Comunittee's scope one must decide what type of I approach should best be taken in the future. In our interviews we 2
have identified two lines of belief: the " nuts and bolts" and the j
" cosmic" camps. We come down on the side of the latter, believing that the Committee should be composed of " wise, best judgment ex-l perts." This implies that the Committee should take on aspects of the i long-tem view that the NRC does not (or cannot) find the time to l
consider. The Cosunittee's most important role would then be to advise e the Comunissioners on the needs the Commissioners may not even rec-i ognize, which is one of the more valuable functions an advisory group
! can perfom. l i
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We were consistently told by interviewees that the Conunittee
- should be more decisive, should lead not follow, and should try to ,
j provide incisive advice rather than cautious platitudes. .It should
- accordingly be a voice of critical, constructive reason even if in l
this process the ACRS' record of being seldom wrong may be lost.
i However, the value of an advisory group is not simply in how often it, I
! is right but in addition, how often it provides timely useful'comunents
- on important issues. In this sense, the ACRS would be providing advice on issues of high importance to the NRC, and, consequently, its
! scope should be broad enough to cover all matters of safety importance I to the NRC. This must be true if the ACRS is going to be a true l j advisory body. We recognize there has been considerable concern about !
j the ACRS getting into what have been described as administrative or i i management questions. However, where these questions have important safety aspects, the Panel believes that they should be within the t purview of the Casunittee.
1 i Almost all interviewees believe that the ACRS ought not to be
} involved in firefightin accident (or incident)investigation. g and, in particular, We concur notwith bethisinvolved in -
view. This National Transportation Safety Board (NTSB)-type activity is currently :
i being discussed both in the Congress and the NRC. However, we do not i believe that the ACRS ought to be involved in that type of activity.
The ACRS does not have the time, the expert detailed knowledge of ,
- specific plants, nor the staff to be accident investigators. In l
addition, even if the bulk of the ACRS resources were to be allocated t to this effort, so that the above objections could be met, we do not l believe that would be a wise use of ACRS members' time. !
As was said earlier, the issues that are going to be most import-l ant for the NRC, and therefore for the ACRS in the next fifteen years, t
will include generic issues, operating plants, waste management, and ,
i future reactor designs. With regard to operating plants, the Panel l believes the ACRS should focus on technical issues of high importance i
-- issues that are mostly generic and seldom narrowed to plant-specific ;
i areas. Experience from operating plants should be considered not only l
i from the ' standpoint of whether any changes should be made in existing l l- i i
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t I- plants, but also whether changes should be made in safety criteria for future plants,
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i The. Panel believes that the ACRS should become more proactive i concerning technical safety issues of disposal of radioactive waste.
4 The ACRS should contribute best by providing advice regarding techni-I cal criteria to be used by the NRC.
The ACRS should also cooperate with the NRC Staff to establish i safety criteria for advanced nuclear plants that industry may sponsor l
in the future. Significant industry efforts are underway to develop j specifications for future LWR plants which will be safer, more con-i structable, more maintainable, simpler to operate and that should have
! - a higher plant capacity factor. The ACRS should review future designs as they are developed by industry for the purpose of providing early guidance-on the safety criteria for future plants. This could reduce ambiguity and enhance licensing stability over the long run. A fresh i
look at safety objectives could result in both additions to and i deletions from current criteria, as well as modifications to adapt
! them to non-LWR plants.
l The Panel does not believe the ACRS should in any way prescribe i i
reactor designs. This is the responsibility of the nuclear industry. .
j However, the ACRS can provide guidance and leadership regarding what designs developed by others must accomplish with regard to protecting -
i the health and safety of the public. Such guidance may in some instances need to be quite specific as, for example, the nature of i
containment provisions needed. A guiding principle should be that
- uncertainty in licensing requirements should be minimized and that a clear new requirement or deletion of an existing practice could, in
! some cases, be less onerous than continuing to carry an unresolved j safety issue. .
The list of activities that the Panel believes appropriate for ;
the ACRS in the future does not specifically include research budgets as an area that might receive greater stress. In fact, the ACRS ,
currently spends what most of its members seem to believe is an i inordinate amount of time reviewing the NRC research program. This .
review leads to reports to the Congress and to the Comission. Most ACRS members recomend substantial reduction in the amount of effort '
devoted to reviewing the research program. As one member said, the-ACRS spends too much time on the research program " holding endless i meetings on the subject." Undoubtedly, some of the conclusions that t this effort is wasted are based on perceived lack of effect.' The individual quoted above also noted that even when the ACRS reconnends '
more research the budgets continue to fall. However, one other ACRS l
member pointed out that if the size of the budget is a measure of .
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, importance, the ACRS should spend even more time on the research ,
program.
The Panel believes the ACRS should provide an overview of the O research program which avoids the detail of the current reviews and which is instead focused on overall progress and on whether the 10
3 critical issues are being addressed. This activity could be in-
$ creased, but the detailed, budget-level examination should be dropped.
The detailed report to Congress appeared to be a good idea at the time, but it now seems to have lost all value. If a report to Con-gress is still needed, a short letter report should suffice.
The preceding is consistent with the Panel's belief that the effectiveness of the ACRS can be best achieved by altering its mission to concentrate on major safety issues with a corresponding decrease in other activities that are better conducted by the NRC Staff or by owner / operator processes.
B. Implications of the Approach The NRC Staff has extensive capability. It includes many highly skilled personnel, and it can draw on supplementary resources from National Laboratories and contractors to handle day-to-day licensing problems and investigate unusual events. However, the press of day-to-day concerns forces it to concentrate on current problems leaving little opportunity for its senior personnel to seek long-term solutions and to forestall future problems. This creates the void that an AC.RS is well suited to filling. It is the Panel's view that theACRScanandshouldprovideamorecosmicpersgettivedirectedto a rational regulatory system, rather than solving nuts and bolts" problems of day-to-day regulation.
This does not mean that the ACRS would entirely ignore the more practical aspects of nuclear power plant safety or that it would totally divert its attention from current events at individual nuclear power plants. But its interest in such matters would be directed to ensuring that problems are understood and treated, and would not extend to direct participation in finding corrective solutions, or to oversight of subsequent actions. The Panel's discussions with outside observers suggest that the most effective contributions of ACRS in these areas come from anticipating problems and drawing attention to need for action on them early enough for problem resolution before a regulatory crisis.
A body of 15 people cannot be expert in everything and cannot have time to follow all areas of NRC Staff activity. In fact, it would make no sense for the ACRS to duplicate review by the NRC Staff.
In thorough study of current safety issues that are of high importance or that are perceived to become so in the future, the ACRS ensures its continued role as a leader in forming the regulatory basis for public
- safety. The implementation of regulation is best left to the NRC Staff, which has the numerical and technical strength and the legal capability of enforcement.
The ACRS could still keep its finger on the pulse of regulation by occasional reviews and selective participation in licensing actions. In this way, the ACRS could be sure that objectives of i regulations are being attained without distorted interpretation of I
J safety requirements.
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To illustrate these points, the Panel lists some important broad technical activities that can be taken on by ACRS. These are offered
! only for purposes of illustration of the Panel's concept, and are not
- meant to imply that they are the most important matters that can be '
! dealt with by the ACRS.
1 1 1 1. Selection and consolidation of the most important safety l issues from the NRC Staff's Generic Items list, the Unre- ,
' solved Safety Issues, the TMI-2 Lessons Learned Action Plan, ,
j and other listings to establish a prioritized set of those !
most urgently requiring action. (It is realized that the !
- ACRS is already involved in this activity. This topic is included in the list to indicate the kind of current ACRS ,
!. activity that the Panel recommends be continued in the ;
i future.) ACRS might also set up a system for monitoring NRC t a Staff action taken in accordance with this list.
l 2. Review of.the degree to which engineered safety features in 1
nuclear plants (especially containment buildings) provide an l l
adequate defense in depth, and consideration of the viabil- :'
,ity of alternate or. additional measures that might ef .
fectively remove any weaknesses.
~3. Development of a safety philosophy for controversial safety issues associated with such broad questions as large earth- i i
{
quakes, floods and tornados, and sabotage and terrorist
! threats. ;
- 4. Consideration of the need for a rational balance between
! provisions for preventing serious accidents to nuclear ,
i plants and for mitigating consequences if these accidents i occur. (Probabilistic Risk Assessment could become a tool i for this purpose if used with cautious concern for the j relevance and completeness of its data base and depend- !
j ability of its logical structure.)
1
- 5. Review of current nuclear plant design concepts to see how <
{ they address multiple failures, automatic versus manual i
l control, plant aging, in-service monitoring, and similar ,
questions. This should naturally lead to a clearer under- l l
standing of Standardized Light Water Reactor design require- ;
ments for future plants.
1 l 6. Development of a rational regulatory basis for the dispo- -
- sition of high- and low-leve' radioactive waste from hand-
- ling of spent fuel, from plant maintenance, from refurbish-ment of operating plants, and from unexpected accidents.
1 C. Regulatory Research l
The NRC Staff in the course of its day-to-day regulatory activity i develops " user needs" for research, and these are passed on to the research am of the Staff for development of programs to satisfy the i
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i requirements. In the course of consideration of technical policy
. issues, such as those above, ACRS will also uncover requirements for research that might have broader implication and that might be i
directed more to satisfying future requirements. The need for some research may be indicated by an ACRS list of high priority generic j issues; other research may be called for through other analysis. A j
channel should be developed for ACRS to transmit " user needs" for research to the NRC Staff in accordance with this process.
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IV. RELATIONSHIPS OF THE ACRS WITHIN AND OUTSIDE THE NUCLEAR REGULATORY COP 9tISSION It is important to determine whom the ACRS should be advising.
Should it be the Congress, or the Commissioners, or the NRC Staff, or the nuclear industry, or the public, or the press, or intervenors against licensing actions? All have been suggested at one time or another as suitable recipients of ACRS advice.
As noted in Chapter I, the ACRS was established in 1957 through
' Section 29 of the Atomic Energy Act which states that the Committee "shall advise the Commission with regard to the hazards of proposed or i existing reactor facilities and the adequacy of proposed reactor safety standards...." Sub-Section (b) of Section 182 requires that the ACRS shall review license applications under Section 103 and 104 and "shall submit a report thereon which shall be made a part of the record of the application and available to the public...." In 1977, a requirement was added to Section 29 that the Committee " undertake a study of reactor safety research and prepare and submit annually to the Congress a report...."
The requirement to review all license applications is not only an activity decreasing in intensity as fewer new plants come up for operation and no new construction is proposed, but also one that most recomendations for licensing refonn over the past ten years would eliminate. That is, the recomendations have identified the require-O ment that the ACRS review every license application as an unnecessary activity providing little benefit. It is important to stress that this ACRS function is simply to review applications mostly after the NRC Staff has already done so, and to provide reports for the record.
j Thus, here the ACRS serves as a backup to the staff in the licensing
- process rather than providing advice.
! Similarly, the report to Congress on the research program is not !
1 a true advisory opinion, as there is no mutual interchange of views based upon the advice being provided. This function has become a l formality that was presumably intended at one time as part of the annual Congressional budget process, but which seems to serve little useful purpose at the present time. Consequently, if these arguments
- are accepted, then as far as the relatively old statutory language is ',
concerned, the ACRS should only advise the Comission. But does it?
! And should it? t f
A. Relationship with the Commission and Comissioners !
These last questions focus the issue as to whom the ACRS should address its work. The answer depends on the type of issues and !
approaches to those issues that the ACRS takes on in the future. If, f i as discussed in Chapter II, the ACRS is to provide technical regula- ,
tory policy advice, its agenda will focus on issues of primary in- ;
terest to the Commissioners themselves, and the advice would naturally i O be directed to them. The ACRS role would be to help mold the phil-osophy and conscience of the Agency. Therefore the Panel concludes j
14 f I
j-that the ACRS should be advisory to the Commissioners, providing them 3
3- with independent advice as a body of wise experts. This presumes that ;
the Commissioners are willing to turn either to consultants hired by l themselves or to the NRC Staff (including their Office of Policy ;
l Evaluation and its consultants) for any assistance they seek on l'
matters of technical detail. i l This advisory attitude will be most useful when the ACRS is ,
i willing to be frank and willing to take risks of being wrong on ;
i occasion. By taking the initiative on controversial subjects, the i
ACRS has been invaluable in the past and can continue to be so in the j future. For example, someone must take the initiative in pointing out ,
1 when the benefit of a costly research project is over, e.g., LOFT. It !
j is on such major issues that the ACRS can provide the type of advisory review that will be valuable to the Comissioners. However, the Panel i
believes the ACRS should recognize that it is advice that is being offered, not decisions that are being made. The distinction between i 7
j the Commissioners' positions, which are decisions, and the ACRS' positions, which are advice, must be maintained. In the past, under-standing of this distinction has sometimes been lost. ,
4 l In the role of providing advice to the Comissioners, the ACRS is
!- acting as~a group. The views of the ACRS as a whole are being sought and not those of the ACRS staff or its consultants or even individual members. If a Comissioner wishes to receive advice from an indi- 1 vidual ACRS member, procedures in the ACRS Bylaws concerning the l O
procedure and the protocol should be followed. However, it is the ACRS majority view that will usually be most useful-to the Connission.-
l though independent views can serve to sharpen the view of the major-ity.
l s
l The Panel does not believe that individual members should be
! precluded from meeting with and discussing issues with individual . l l Commissioners. In principle, this is a role that is determined by the Comissioners since the ACRS is advisory to them. In practice, ACRS i members have a responsibility to ensure that when they meet with individual Comissioners they characterize opinions as their own and not those of the ACRS (the Panel does not mean to imply that such has i occurred in the past but rather to warn against what could be a ;
j corrosive practice).
B. Relationship with the NRC Staff ;
Several members of the ACRS said that even when its letters were !
sent to the Comission, they were sometimes really written for the
! staff, who by either participation in the meeting or familiarity with
{
the details would understand what was being said. The Panel believes i
that the ACRS should address its advice to the group that the ACRS ,
I believes will find it useful. The staff usually needs detailed advice
- on specific detailed issues, and generally the Commission does not.
Conversely, if the ACRS is providing advice that is most useful to the Comission it is in the nature of broad policy that the Comission must first adopt or modify or reject. It is only after Comission 15-i
--~_ _ _ ___ __
I p action on such matters that staff action can be instituted. The Panel s believes that although the principal role of the ACRS should be to advise the Comission, all letters should be addressed to those to whom the advice is being offered. Thus, when advice is being offered to the staff, the letter should be addressed to the Executive Director for Operations.
The Panel considered the relationship the ACRS might have with respect to the Comittee to Review Generic Requirements (CRGR). The Panel recognizes that the CRGR serves a significant management func-tion for the EDO and the Comission. The Panel believes that since the CRGR's functioning can have a significant impact on. regulatory policy, it is important for the ACRS to understand how the CRGR
. functions, and the criteria that the CRGR actually uses. The Panel therefore recommends the ACRS review the process the CRGR uses to review items brought to it, in particular the methods of technical analysis used by the CRGR, including the use w,ade of PRA and the types of data required for a CRGR decision. However, the Panel opposes the ACRS assuming the responsibility of reviewer of each CRGR decision.
C. Relationship with Congress In generil, interviewees believed that Congress does not pay much attention to the ACRS research report. For example, the Congressional staff members who were interviewed either did not know such a report was submitted or believed the review was not used. This view also can Os be seen as contributing to the lack of Congressional interest in asking ACRS to testify this year. The requirement for the ACRS report on research could just as well be either removed entirely or at least reduced in detail and effort.
The ACRS would not be very effective serving in an advisory role to the Congress. Greater effort by the ACRS might establish closer ties to some Congressional staff, but this involvement with Congress could quickly lead to a substantial investment of time by both ACRS members and staff. This would not be an effective use of ACRS re-sources either, and could substantially interfere with the ACRS role
! of providing sound, timely advice to the Comission. Furthermore, the Congress has available to it the resources of the General Accounting Office (GAO), the Office of Technology Assessment (OTA), the Con-gressional Research Service (CRS), and the Congressional Budget Office (CBO). Consequently, any review needed by the Congress can be done outside of that done by the ACRS.
D. Relationship with Licensing Boards There was unifonn objection to the ACRS having any fonnal in- .
volvement in the actions of Licensing Boards. This does not seem to be a useful function for the ACRS to perfonn and it would require an extraordinary amount of time. In addition, difficulties would be raised with advising the Comission because of the interaction at one
( level of a quasi-judicial process while still trying to advise at a higher level of the same quasi-judicial system.
16 l
l 1
E. Relationship with Industry and Intervenors i
The ACRS needs to have sufficient contact with industry to stay !
l abreast of new developments and major issues in this arena. The Panel !
believes that the ACRS should have more involvement with both industry :
- and intervenors in its meetings in order to determine the views of
- strong believers on controversial and important issues the NRC is '
4 facing. The ACRS' value as an advisory comittee to the Commission is increased if its insulation from the principal proponents and oppon-
. ents on a particular safety issue is decreased. However, the ACRS ,
i should not function as an advisor to either of these two groups.
F. Relationship with International Groups l
The ACRS is in a unique position concerning evaluation of inter- i i national nuclear safety issues. The Committee because of its repu- ;
tation is invited to send one or more members to many international 4
j meetings where important safety subject matter is discussed. The ACRS
- is able in these ways to interchange views with other review bcdies in i other countries that serve a function similar to its own. This
- practice can help to develop a broad understanding of safety ap-proaches appli.ed in different countries. While some of this oppor- .
l tunity is available to NRC staff members, the establishment of peer j relationships by ACRS can have its own unique value. The ACRS should i j expand such contacts to assure maximum advantage.
j G. Relationship with the General Public k Although members of the general public do sometimes read ACRS
! reports, the Panel believes that the ACRS should not focus its at-tention on the public. To the extent that the press and other media l
are interested in what the ACRS is doing, their representatives are .
i always free to attend ACRS meetings and to receive copies of ACRS !
reports. However, if the ACRS were to fix its eye on how its reports will appear to the public, it will lose its focus on usefulness to the .
Commission. The ACRS' principal function is to provide sound advice to i 1
the Comission and in so doing it will best serve the public. l r
i -
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l t
I I
t i
O !
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9
.,-,----_---_.._...-_.,--.-m__--_,- -
i ,
V. MEMdERSHIP ON THE ACRS AND THE SELECTION PROCESS :
A. Purpose t,
As a result of the Panel's interviews and prior experience with ,
l the ACRS by some Panel members, the following questions were identi-i fied as major potential issues concerning ACRS membership:
) 1. Is the size of the ACRS optimum?
f 2. Are the skills and experience of ACRS members consistent with
- the involvement the Committee should have with operating
- reactors, fuel cycle facilities and related generic safety l l issues?
I 3. Does the ACRS need new members?
! 4
- 4. Is the method of nominating and selecting ACRS members
- appropriate?
- 5. Has the member selection process been effective?
Do " conflict of interest" requirements adversely affect the
~
6.
i availability of potential members?
1
! The Panel's conclus' ions as to these questions are set forth in the following paragraphs.
j I
- B. Size of the ACRS ACRS membership is established by the Section 29 of the Atomic Energy Act of 1954 as amended as consisting of a maximum of fifteen j
members appointed by the NRC Connissioners for terms of four years i each. The current composition of the ACRS, including a brief des-l cription of the longevity and technical qualifications of the Com-mittee members, is set forth in Table V.I. .
I l
The Panel found that the present ACRS size appears to provide an l appropriate balance between the need for a diversity of skills on one ,
j hand and the potential inefficiencies in the group process of too large a number of members on the other hand. Further, in the inter-l views conducted by the Panel, the present size of the Committee was ,
not identified as an issue by those within and outside the Committee. ;
The Panel concluded that the present size of the Committee appears to l be reasonable for its objectives. ;
i .
j C. Composition At present, as set forth in Table V.1, nine members of the i Committee are associated with academic institutions in teaching and/or management positions while two members' experience is primarily with i
O national laboratories. One has been involved with operation or operations support of a government-owned production reactor for most 18 r . i
! . _ . . _ . ~ _ . . . . . _ - _ . - _ _ , _ _ _ - _ _ _ _ . . . . . _ . - . - - - , _ _ , _ . _ _ , . . _ - _ - . _ _ _ _ , _ - - . . . . - _ , - _
_ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ . _ _ .___ _ _ _ . _ _ ._. _ _ . _ . _ _ _ . _ _ _ _ . . _ . _. . _ _ _ . _ _ . _ . ~ . _ _ _ _ _
O .
s I
TABLE V.1 COMPOSITION OF ACRS FIRST .
APPOINTED REAPP0lNTED CURRENT /LAST POSITION TECHNICAL DEGtfE5 NAME Professor of Chemical Engineering, Princeton University Physical Chemistry
- 1. Robert C. Amtman 1981 --
1979/83 Professor and Chairman of helear Engineering Department. Mechanical Engineering / Heat
- 3. Jesse C. Ebersole 1976 1980/84 TVA, Head of Nuclear Engineering. Division of Engineering Design Electrical Engineering (retired) !
Professor of helear Engineering and Director of the Office of Electrical Engineering
- 4. William terr 1972 1976/80/84 Enery Research, University of Michigan 1983 Physics
- 5. Harold W. Lewis 1979 Pr,ogegorgfggigpt. of Physics, University of Call-
'1976 1980/84 Division Leader of Theoretical Division,l.os Alamos Scientific Physics /hthematics
- 6. J. Carson Mark Lab (retired)
Director of letC Of fice of Analysis and Evaluation of Operational Electrical Engineering /
- 7. Carlyle Michelson 1983 --
Industrial Management Data.(retired) and Principal Nuclear Engineer. TVA (retired) 1977/81/85 Professor of Engineering in Environmental Health Harvard Ikiv. Nuclear Engineering / Sanitary
- 8. Dade W. Moeller 1973 and Associate Dean for Continuing Education for the School of Engineering / Civil Engineering Pubitc Health 1967/71/75/19/83 Professor of Engineering & Applied Science, Dept. of Mechant- Mechanical Engineering / Physics f- 9. David Okrent 1%3 cal, Aerospace and Nuclear Engr., Univ. of California, LA Plant Manager-Point 8each hcicar Plant (retired) - Wisconsin Mechanical Engineering
- 10. Glenn A. Reed 1984 --
Electric Power Company Professor of Nuclear Engineering, and Associate Vice-President Mechanical Engineering
- 11. Forrest"J. Remick 1982 --
for Research The Penn State University i* r.ml G. Shewson 1977 1981/85 Professor, Metallurgical Engineering Dept., Chlo State University Metallurgical Engineering 1%8 1972/76/80/84 Professor Emeritus of Civil Engineering, University of 11tinois Civil Engineering
- 13. Chester P. Stess 14.. David A. Ward 1980 1984 Research Manager of the Reactor Safety Research Division, DuPont Mechanical Engineering Chief Engineer of Electrical Division Duke Power Company Electrical Engineering
- 15. Charles--J.' Wylie '1984 --
(retired) f
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. . _ - . _ _ - . - -- _- .-= -
of his professional career. Four members have some comercial nuclear plant experience, but only one has extensive experience with operation of nuclear plants. As a result, some interviewees questioned whether i the Committee's talent mix is weighted too heavily toward academic or laboratory experience (10 members) as contrasted to actual plant design and operation experience. !
The Panel concluded that while the Comittee's present compo-sition is not best suited to the role that is recommended for the i future, no rigid prescription of the mix of expertise of Comittee members is necessary or desirable. In general, the Panel believes the #
composition of the Comittee can evolve as new technical issues in reactor and fuel cycle facilities become dominant. Regarding the need ,
for additional members with operational experience, the Panel observed that the recent additions of two fomer utility executives promises to i provide increased utility perspective, including that of operations 1
personnel. The Panel's review reveals, however, that the reactor
- system and pressure boundary expertise developed by NSSS vendors is
! not suitably represented, that the current members' experience in radioactive waste issues is minimal, and that addition of more members
- with reactor operating experience would be appropriate. Consequently,
' the Panel believes that the Committee's composition should evolve generally"in confomance with the following objectives: members inith
- management experience in operation and maintenance of nuclear power plants, members with NSS system design experience (one with PWR experience and one with BWR experience would be appropriate), and a O member with chemical engineering expertise applicable to issues involving nuclear waste. _ Finally, the Panel concluded that regardless of particular areas of expertise, the ACRS primarily requires " wise"
- r. embers who can react to problems as generalists' and not individuals whose principal qualifications are those of narrow specialists. ,
4 D. Length of Service of Members" The duration of service of individual Comittee members is set i forth in Table V.I. A single tem of a Comittee member is four 4
years. Five of the fifteen Comittee members are serving in their ;
- third and fourth tems and two others are in their fifth and sixth
- terms. The average current member has served on the Committee for l over eight years. A number of interviewees, both within and outside -
the Committee, voiced the concern that the long length of service of l some of the current members has unduly affected the Committee's _
ability to add "new blood".
t The question of the length of ACRS service and the need for newer j members was addressed by the Comissioners in September 1983. A policy was established limiting newly appointed members to a maximum of three tems. The Commissioners approved the following plan with ;
- regard to current members: ;
- 1. Current ACRS members who are in their first term shall be !
limited to a maximum of three consecutive tems. ;
- i t
i l- 19 f
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4
. 2. Current ACRS members who are in their second or third terns shall be limited to a maximum of four consecutive terns.
2 l 3. Current ACRS members who have already served more than three
, consecutive terms shall be limited to a maximum of one more
- consecutive term upon expiration of their current term.
In establishing these limits, the Comission did not intend to create ,
a presumption that reappointment within these limits would be auto- i matic. Rather, the Comunission would continue, as it has in the past, to treat nding vacancies on the ACRS on a case-by-case, basis (see Section E .
The Panel concluded that a general policy of limiting a member of
) the ACRS to eight to twelve years of service is reasonable. Such a 1 limitation is important in assuring that new perspectives are advanced and considered. However, the Panel recognizes that increased turnover of Comittee personnel during the transition period could result in the loss of critical experience. Thus, the Panel recommends that appropriate measures to make available to the NRC and the Committee the knowledge and experience of retiring members be developed and implemented. Moreover, the Panel observed that despite the prior lack '
.I of specific guidelines in this area, one-third of the current Com- '
- mittee members are in their first term.
Finally, the Panel?s review disclosed that before 1988 the Comittee and the NRC Comissioners will be faced with eight member- .
- ship decisions
- seven potential reappointments and one new appoint- ,
- ment. Therefore, if the capabilities of the Committee are to be
! restructured over time as suggested in Section C, then the Panel '
l concludes it is critical that all reappointment decisions be carefully i evaluated in terms of the required technical composition of the Comittee. Indeed, decisions regarding needed membership capabilities
- should occur well in advance of the time of the potential reappoint-l ments. ,
E. Appointment and Reappointment of Members ;
The normal procedure currently followed for the appointment of a new member to the ACRS is as follows:
- 1. Members-discuss the needs of the Committee with respect to the discipline needed to fill an opening.
i
- 2. ACRS infor1ns the Comission of its desires regarding the discipline of the new member.
- 3. The Comission authorizes publication of a press release calling for nominations in the appropriate technical field. .
Copies of the press release are sent to appropriate technical societies (e.g., ASME) and minority organizations, as well-as the general public.
r 20 _
r e t
- r.-., -
- 4. Nominations are gathered and screened by the ACRS Staff and a l
O Nominating Panel composed of ACRS members. Nominations from representatives of NRC, including individual Connissioners, and from ACRS members are also considered. !
- 5. The ACRS Nominating Panel selects a panel of persons to be considered by the full Committee, taking into account their discipline, affiliation, and availability.
- 6. The ACRS selects a group of approximately three candidates
- and forwards their names to the Commission for a final selection. The ACRS may or may not order the candidates by preference.
- 7. The Connission makes the final selection and appoints the new member.
For replacement of an on-board member, the Committee is polled to determine if.it recommends reappointment. If the answer is yes, the member is queried regarding his interest in reappointment. If the answer is yes, his reappointment is reconnended to the Connission.
The Commission normally reappoints members so nominated, but it is not i obliged tii do so.
! The Panel concluded that the current nominating process is generally reasonable. However, the Panel concluded that because of l
O the need for new blood, incumbents should not, in practice, be auto-matically reappointed. Rather, the Panel reconnends that well in advance of considering a reappointment the Nominating Panel should
- thoroughly _ review the contribution of the incumbent as well as the area of his expertise, as if it were reviewing the qualifications of a proposed new member. The majority of the Panel believes that re-appointments should then follow the same process as new appointments, <
i which result in the names of multiple candidates being submitted to the Connission.
~
Finally, the Panel concluded that while the Committee's current selection procedures seem adequate, the present composition of the Connittee suggests some modification of the results of the actual process. For example, the Panel observed that the nominating of new
- members has been dominated by the immediately previous makeup; i.e., '
new members are often clones of the departing members. Also, the Panel observed that no woman or member of a minority group has served on the ACRS, despite past efforts to recruit such persons. The Panel believes that technically qualified female and minority candidates ;
with a diversity of skills are available. Therefore, the Panel reconnends that increased attention be focused on the selection !
process with the objective of achieving a more diverse composition of background and technical skills among the Committee members (see ;
comments on Composition). ,
i l
21
F. Conflict of Interest ;
One explanation that has been given for the small number of ACRS members with commercial reactor design or operating experience is that the Committee's conflict of interest, requirements unduly hamper the ability of the ACRS to recruit such people. The personnel policy of the ACRS pertaining to conflict of interest restrictions is contained in Part 0 of Title 10 of the Code of Federal Regulations. These regulations are based on Executive Order 11222, the Ethics in Govern-ment Act,18 U.S.C. 201-209, and Office of Personnel Management
- regulations.
Appendix III sets forth a summary of the conflict of interest restrictions which apply to ACRS members who are special Government employees of the NRC. Each provision is annotated to indicate its source in 10 CFR and any other legal basis. In limited circumstances, exemptions from these regulatory restrictions can be granted by the Chaiman of the NRC.
The Panel understands that the major problem with the current conflict of interest requirements is that the limits effectively preclude the selection of Comittee members who are active in the.
nuclear business except for employees of the national laboratories.
Another lesser problem is the fact that the limitations that are placed on the members regarding their outside activities tend to cut N them off from consulting or other activities that could continue to keep them up-to-date as to events and trends in their field of exper-tise.
The Panel concluded that while the Committee's conflict of interest requirements are pervasive and burdensome, qualified indi-viduals who would not have a conflict of interest are available for ACRS assignments. For example, individuals currently active in other high technology industries can be selected. In addition, the ACRS currently does have several members who have retired from the nuclear I
industry. Further, when necessary, any conflict of interest issue can be handled by temporary removal of the member from a potential con-flict on a project-specific basis. Hence, the Panel concluded that the current NRC conflict of interest requirements applied to the ACRS are appropriate and are not unduly restrictive.
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i VI. ORGANIZATIONAL EFFECTIVENESS OF THE ACRS O The Panel believes that several key factors contribute to the organizational effectiveness of the ACRS. In each of these key areas, either short-run or longer-range improvements would seem beneficial.
This chapter singles out for discussion comittee management (the role of the ACRS Chairman and a potential role for an ACRS Management Comittee), sub-comittee activities and their management, utilization of ACRS consultants, noms for required comittee effort, and the possible impact of change on the ACRS staff. ACRS activity consumes an annual resource of more than 7 person years in member time, plus approximately 50 person years in consultant and staff time, in addition to the time required of applicants and the NRC Staff. These are quantities that in themselves justify management and leadership
~
more active than anyone is presently in a position to provide.
A. The Chairmanship and a Proposed Management Committee This section of the chapter describes the present role of the ACRS Chairman, and suggests an augmented role which the Panel believes can be best carried out if there is simultaneously created a Management Comittee composed of the Chaiman, the imediate past Chairman,-~the Vice Chaiman and the Executive Director of the ACR$
staff (ex-officio).
The present role of the ACRS Chaiman is to be the instrument of the Committee. The Chairman presides over monthly meetings, is first among equals in planning for those meetings, and calls special meet-ings. He serves as the focal point for changes in ACRS structure, initiates the nominations process, is in the best position to call for deviations from agreed routine or changes in priorities, and provides direction to the ACRS Staff Executive Director. Hence, a chaiman takes on an administrative role more than a leadership role. Of late, the Chairman has been chosen by seniority. He is the most senior ACRS member who has not previously served as Chaiman. The Chairman serves for one year. The job is described as burdensome and anxiety-provoking by most of the fomer ACRS chairmen interviewed--an oppor-tunity to learn, no doubt, but more of an imposition than an office to be sought.
The attitudes and practices outlined above seem to have served the ACRS and its members well enough in the past. The Panel ques-tions, however, whether the place now accorded the Chaiman is helpful enough to the emerging role of the ACRS. It has been suggested earlier that the principal task in the ACRS mission should now be to advise the NRC Comissioners on important broad technical issues in the national agenda for assuring the safety of nuclear power and the nuclear fuel cycle. To do this will require more initiative by the ACRS than if its task were primarily to react to a stream of ap-plications, to react to proposed rule-makings, and to review annually l
the NRC research program.
O 23
i It would go against ACRS custom, however, to invite a Chaiman to take over the reins, and drive the Conunittee wherever he chooses. The Panel believes that any ACRS Chaiman who tried to do this would simply isolate himself from his colleagues, and would ultimately fail.
Therefore, the role urged is leadership, but not dictatorship.
Furthemore, it is a role that could be carried out effectively if done with and through a well-infomed, well-connected Management Consnittee. Such a Management Consnittee would constitute a leadership group that should be both acceptable and effective. The role of the ;
i Chairman would then be to initiate, to suggest, to stimulate, and to formulate decisions as to the direction, priorities and hard choices facing the ACRS, acting through the Management Conunittee. The i Management Consnittee would further develop planning and guidance for the Chairman and the ACRS as a whole, to test and help mature the plans the Chairman wants to implement, and to see to it that the ACRS understands and responds constructively to leadership initiatives.
To help the Chaiman carry out his role, the Panel suggests that
- the ACRS make the following changes
- 1. Elect Chaimen for a two-year tem, re-electable once if ;
desired, so that those members with outstanding capability to carry out the job have more of an opportunity to do so.
Moreover, such a change would signify to all members that the leadership capabilities of a potential Chairman are im-portant to the Committee's functioning. ,
l 2. Request that the legislation be changed to permit the Chair-
! man to be paid an additional amount as recognition for taking on an even heavier responsibility than other members.
l
. 3. Amend the ACRS bylaws to femalize and require an enhanced l role for the Chairman. l'he bylaw would say that the role of Chaiman is the primary obligation for any ACRS member who :
accepts it. A Chairman who wishes to retain Sub-conunittee l
Chairmanships, for example, would have to convince his j Management Committee, and if they are dissatisfied with his argument and he still persists, he would have to persuade
~
the entire ACRS. The Chairman should be permitted and directed in the bylaw to lead, that is, to set near-term and longer-term goals, to launch new initiatives, to close down superfluous activities, to fann sub-conunittees and propose their redirection or their termination, to call for
! improvements in ACRS operations / priorities / structure, to maintain close one-on-one contact with such important con-l stituents as the NRC Consnission Chairman and the NRC EDO, and i N demonstrate by his actions how to make the ACRS reach its stated goals. Traditional rights and duties should also be confirmed and in some cases extended: To supervise the Executive Director of the ACRS staff, and through him, the !
ACRS staff, to chair the ACRS meetings with accountability to assure their effectiveness (with consnittee-accepted criteria and standards for evaluating their effectiveness), to assure ,
24 u_ __ _. _ . _ _ _ . - _ _ _ - _ _ _ _ . _ _ _ . _ . _ _ _ - - _
1 j
! the appropriateness and balance of agendas for ACRS meetings, meetings of the Management Committee and other management meetings, to initiate the nominations process, and to call special meetings.
- 4. The bylaws of the ACRS might be amended to rename and l i upgrade the Procedures Comittee to become in fact the ACRS l 1 Management Committee. At a minimum, the Chaiman needs a :
mechanism for helping to -lift the ACRS and its sub-comittees l out of more routine activity. ACRS Chaiman, immediate past Chaiman, Vice Chaiman, and the ACRS Executive Director
]
i sitting in as an ex-officio member would comprise an effective Management Comittee. Its role could include a regular ,
schedule for review and updating of ACRS plans, priorities, 1 and activities. Revisions it makes in the plan would con-stitute guidance for the chairman. ;
l The Management Comittee could also be given certain oversight as to internal management procedure. It could be 1
l ment to the ACRS Chairman with respect toorhis any(given other) the right to com -
proposals to create,_ recharter, or disband sub-committees. It could actively i review major input or actions by consultants and sub-comittees. It ,
could be consulted by the ACRS Chaiman with respect to steps in the t j nominating _ process which are traditionally the prerogative of the ACRS Chaiman, or the responsibility of the ACRS Staff's Executive Di-rector. The Management Comittee could have a general responsibility i to monitor, through day by day contact with ACRS members and staff, j the progress and problems. faced by leadership initiatives . Beyond personal monitoring, individual members of the Management Committee could also have the responsibility to advocate, persuade, and motivate i other ACRS members to undertake and carry out appropriate activities !
, towards realizing ACRS objectives. t i
' The Management Committee could assess ACRS performance and relation-ships quite broadly. For example, it could review any extensive requests for information that ACRS sub-constittees make to the regu-l latory staff, to consider their relative priority, and their overall i
impact on the NRC, and could act as an intermediary between the managers of _ the regulatory staff and the sub-constittee chaimen when l
appropriate.
B. - Sub-connittees I The ACRS now has over 100 sub-committees. Of these, around 30 l l held meetings in 1984, and they carried out an average of three meetings each. Sub-comittees have been essential to ACRS operation, ,
i and it is expected that they will continue to be important. Sub-
! countittees are set up to accomplish at least two purposes: To carry [
out specific responsibilities of the ACRS, and to solve problems.
Most sub-committees have been formed in response to licensing appli-cations, and a separate sub-comittee exists for each of most operating plants as well as for those still under review.
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In reflecting on the way the ACRS has functioned and on its s accomplishments, the Panel has developed the working hypothesis that one sub-connittee role is most important: to deepen and enhance ACRS understanding of chosen subjects. Sub-committees by clarifying issues
' and educating the entire membership thereby support the ACRS. A valuable by-product of sub-conmittee activity is to review with the NRC Staff its basis for particular conclusions, and the basis ap-
- plicants have for particular proposals of major significance.
I The Panel questions the current practice of fairly routinely ,
, approving creation of new sub-connittees desired by individual mem-bers. As noted earlier, if the ACRS Chairman is given a somewhat i stronger role, and more of an opportunity to work with a Management t .
Connittee, one task the Chairman should assume and share with the Management Connittee is a more systematic review of requests to set up new sub-connittees. At a minimum, all sub-connittees, including those in process of formation, should be held accountable for both developing and carrying out plans with identifiable milestones. This will become even more important if the fraction of the ACRS' work that is self- '
initiated becomes larger.
- 1 C. Consultants i The ACRS takes on as consultants a number of specialists to increase the available depth of knowledge in relevant specialties.
Consultants in certain specialties are required when the ACRS does not '
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include these specialties among its own members.
Sub-connittee uses of consultants taries a great deal. Subjects ;
new to the ACRS require more consulting time and more different con-i sultants than other subjects. This seems appropriate.
! Instances have been alleged in which consultants have been allowed to " speak for the ACRS," either in face-to-face dealings with appli-cants and/or NRC Staff, or in drafting letters which then had more or i less perfunctory review by the ACRS. If such instances have occurred, -
i the Panel believes they should not have. As a general principle, the :
Panel believes the review process should develop enough understanding ;
of subjects and issues that ACRS members can speak and write for themselves. .
The Panel suggests that the ACRS should follow the following ,
!' policies and practices with respect to consultants: l i
- 1. Consultants should be briefed on their roles. (This goes i l
beyond the existing practice of briefing new consultants on the ACRS, the implications of the Federal Advisory Committee Act, etc.) In
- sub-connittee meetings with regulatory staff or with applicants.
l consultants should be careful to confine questions and remarks to .
l their own areas of expertise. They should be sure not to give any i
( implication that they speak for the ACRS, and should be careful to i l
avoid the appearance of doing so. They should assume responsibility !
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m for understanding the context of any meeting or discussion into which they are invited.
- 2. Sub-committee chaimen should prepare their consultants ahead of time for meetings and, when necessary, other sub-committee members as well. The consultants deserve orientation to the objectives, past :
work, and problems currently facing the sub-comittee. This could be ;
especially important for newly appointed consultants, or those used infrequently.
- 3. Sub-comittee chaimen should require written reports from their consultants. This requirement should be stated to consultants in advance, and in many cases, the sub-consnittee chairman will need to tell the consultant the nature of the material he wants in the re-port: the issues to be addressed, how he expects to use the report,
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and suitable scope and scale for the report.
- 4. The Management Committee, as described earlier in this chapter, should annually review the quality of the consultants of-ficially accepted by the ACRS, and the effectiveness of the work the active consultants do. This review should be based on evaluations by the ACRS members who use the consultants, on the reports submitted by, consultants, and on such other evidence as the Management Committee can obtain.
D. Effort Required of Members This section discusses the norms underlying ACRS membership: How t much of what kind of work a member must do in order to satisfy his responsibilities. The Panel believes that the ACRS should face this subject more squarely than it appears to have done in the past.
- 1. Individual ACRS members worked on ACRS business from 69 to 223 days in 1984. The average was 126 days. The Panel believes that the ACRS should be attempting to recruit new members on the basis of their potential contribution, re-gardless of their willingness to serve the average number of ACRS days per year. As it is, a member who puts in many fewer i days than 100 in a year is likely to be perceived as not doing his share.
- 2. Individual members might try to estimate at the beginning of each year the scope of their ACRS work, including an estimate of the amount of time they can devote to ACRS and any breakdown of this time they can forecast. The estimates can then become one of the inputs for planning the work of the ACRS and its sub-committees.
- 3. ACRS members, on joining the Committee, should receive informal as well as formal orientation. They already are O given extensive reading material. They are supposed to meet with the Chairman early in their first term, and a few months 27
4 later, with some other member, to be interviewed. But with O ii er **is it is stiii et ci r ** t necessarily told how the ACRS really works, what the ACRS has to do to be effective, what the various members are good at, 6 r is i or what the real requirements are for satisfactory Comittee membership. The Panel suggests that the Chaiman should ask at least two different members to discuss informally with each new member the workings of the ACRS from their own '
viewpoints. This kind of stimulated interchange would furnish new members with some hypotheses (sometimes con-flicting) about what they observe, and the questions that i arise for them. Having such hypotheses should greatly accelerate new members' coming up to speed and focusing on the basic objectives of the ACRS. I'
- 4. The Panel has been told that the staff of the ACRS now
' receives at its own request on the order of 20,000 sets of documents each year. Most documents come from the NRC Staff.
Considerable effort goes into screening and directing these ,
documents, so the right ACRS members see the right docu-ments. The Panel believes that screening procedures could i be improved (e.g., through computerized search in the Docu-ment Control System) to reduce the number of documents examined. It should be borne in mind that the ACRS has asked !
to be included in many distribution lists. The Panel sug-l gests reexamination and pruning, consistent with revised scope and scale of effort that would grow out of ACRS imple-mentation of the Panel's recomendations as to redirection of the Comittee. If the ACRS no longer has to report on every application for construction and operating licenses, the work load will naturally be reduced.
r E. The ACRS Staff i
The ACRS staff includes over 40 professional and support level i personnel. Many of the professional level personnel function as staff project engineers, assigned to work with ACRS sub-comitteas. In i
addition, a class of employee called "ACRS Fellows" was created
! several years ago. Fellows tend to be relatively young professionals, some still in graduate school or recent graduates.
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- 1. The Panel believes that ACRS staff perfomance and staff requirements should be evaluated in depth when it is clearer what the ACRS is going to be doing over the next several l years. If all the recomendations of the Panel come to be ';
j accepted, requirements for both staff size and competence O
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could become very different, and considerable job redesign O and reorganization would appear appropriate.
Even if few changes were made in ACRS activity or its mode of ,
I operation, the staff should probably be evaluated to help clear up l t whether the size is justified or not, and whether.the technical
- competence needs more emphasis. The Panel suggests evaluation in this case not because it has any preliminary findings, but because some persons have levied criticisms and others have raised the. question.
I Some staff issues relate directly to the operating mode of the
- fully using the capabilities of_ the people now on the staff, some of i 1 whom are technically trained and prepared to do technical rather than administrative work?
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- 2. In the opinion of the Panel, the ACRS leadership evaluates the staff too rarely and in not enough depth. The proposed .
Management Committee might quite naturally take responsi- l 1 bility for such on-going evaluation. Certainly, if the F l Management Committee is to do the on-going evaluation, they I l shoul_d be involved in an initial evaluation as well. ,
q j 3. The Management Committee (or other ACRS leadership) could. l also evaluate the Fellows and the fellowship program. This l program was meant to supply the ACRS with an ability to l address special technical problems. The original idea was to .
! have individual Fellows work closely with particular ACRS I members. Fellows are given training assignments to famil-l iarize them with methodologies (such as probabilistic risk ;
assessment) with which the ACRS has been heavily preoccupied. i Even though the program concept has changed somewhat, and l
the present number of seven fellows is far below the theo-
! retical authorization of fifteen, no other evaluation than by the ACRS members themselves would make complete sense.
This section is concluded with a series of observations on the .
relationship between the ACRS and the ACRS staff. The staff is highly I i
motivated to comply with the requests it receives from ACRS members. ,!
This is a positive quality if all the requests of the members are '
- pertinent to the work to be done. One criticism leveled against the I ACRS staff and its management by the ACRS is that the experience and t knowledge of the senior members of the ACRS staff are not always brought to bear in helping to evaluate the importance of work required :
of individual ACRS staff members, as well as to figure out how that !
work is to be done. Collecting the views of staff could be a bit more '
strongly emphasized as a part of what the ACRS Chairman and the Executive Director of the staff are supposed to do.
t ACRS staff project engineers, when assigned to sub-connittees. [
are supervised by those sub-connittees, and must (naturally) satisfy i the sub-connittees. The structure itself thus sets up a tendency for O
over-compliance and under-utilization of the skills and experience of I
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i the staff. If the sub-committees become more directly and specifi- I O cally accountable to the ACRS, through its Chairman and a Management Committee, this situation can be adjusted by internal policy, so that ACRS project engineers feel a bit more entitled to speak up when they have good reason to believe a specific assignment given them should be modified, and can give good reasons why.
Committee staffs, no matter how subservient, are always subject to the accusation, and Committee members to the suspicion, that the staff members are participating in Committee decisions. The more the staff speaks up, the higher the risk. The only sure way to keep a high quality staff and minimize these rumors at the same time is for the Committee itself to be obviously vigorous and capable enough to make all its own decisions.
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VII. ACRS OPERATIONAL METHODS 1
This chapter sets forth a number'of Panel observations as to the
- process.of ACRS business and the effect process has or can have on the actual product. The topics discussed therefore include interpersonal .
relations, interactions, and other aspects of the process whereby the i Committee arrives at its technical product. These are reviewed in the context of changes in the process that can improve the product. The l
Panel identified the following questions as the major issues regarding i
the ACRS' operational methods:
- 1. Is the " consensus" method for reporting ACRS' views to the NRC comissioners working well? e
- 2. Does the Committee's letter-writing process result in clear i communications?
4 l 3. Can ACRS comunications to its various audiences be effective
! without an oral component?
- 4. Has conformance to the Federal Advisory Committee Act (FACA) adversely affected the Comittee's work? l I S. Is the Comittee's budget subject to appropriate controls?
j A. The Consensus Objective and Means for Achieving Consensus i There is strong implied pressure on ACRS members to reach con-l sensus on matters brought before the Comittee. Since consensus _can
- be hard to achieve, one of the common consequences of the pressure for ,
i consensus is to " water down" the ACRS letters, and/or to make ACRS i letters hard to understand because they do not reflect the real i variety of views which underlie them.
Although consensus remains one of the bedrock values in the ACRS j culture, dissenting views appended to ACRS letters are more frequent and more tolerable to the members than was the case a few years ago. '
I ACRS members nevertheless clearly believe that they should strive for
! consensus.
4 The Panel favors the consensus principle where consensus exists.
There are some reservations about the methods used to reac'n consensus, and the actions taken when consensus proves elusive. First, however, ,
a suggestion is made that the consensus-seeking process should be
! viewed in a revised context.
i l A.1 In ACRS' Current Role. Clarification of Issues is More
- Important than Achieving Consensus The Panel concluded that the freedom the ACRS has to lay out l
difficulties, dilemas, uncertainties, contrasting opinions, i
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priorities, and trade-offs in stark and accessible terms is now more ,
O important for ACRS to achieve than is consensus. Indeed, the attempt to achieve consensus can legitimately be regarded as a device used i
primarily.to speed up clarification of issues. This shift in the role ,
l of consensus seems to be the result of a change in the context in j which ACRS operates. No longer is the ACRS the major voice pointing out the safe or most acceptable way to go for benefit of the Joint Committee and a single AEC Comissioner with a fledgling staff, who were the government officials for whom at one time nuclear power regulation had most importance. The role of the ACRS is now that of a t major definer of the nation's nuclear power safety agenda instead of 4
being the nation's primary technical resource on nuclear power reactor safety matters. In these circumstances cogency and integrity of ACRS statements are more important than consensus among members. Decisions ;
.i are made elsewhere, by a Commission whose responsibility is safety.
Therefore the purposes of consensus-building are somewhat dif-ferent now from those in the past. Fonnerly, the principal purpose in ACRS consensus was to provide a unified direction to those being advised, to suggest to them the one best way to go, with some ad-3 i ditional validity and protection provided if the overwhelming majority 1 of members endorsed that position. In that situation, consensus needed to reside only in the particular recomended action, since'the
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- requirement was to lend credibility to moving in the recomended direction.
- The role the Panel foresees for the ACRS in the future is to throw light on the fundamental questions involved in safety-related i decisions in nuclear power policy and practice. The decisions pre-j ferred by the varying constituencies are usually stated both force-fully and early, and they provide clear options as to the possible
! direction (s) in which to proceed. What is missing or in short supply I is well-infonned technical guidance on what is true, what is probably J true, what is uncertain, what precisely should be held to be in dispute, and what is actually unknown. If in its letters the ACRS provides consensus statements that powerfully describe each important l
l 1ssue in terms of the true, the probable, the uncertain, the disputed and the uaknown, it will have done a great deal for the NRC Com-missioners and for other constituencies as well.
Although the need for consensus may no longer be as great, l
striving for consensus continues to be a valid goal, and its achieve-
- ment is laudable as long as the consensus is genuine.- Instances in j which members, on announcing their intention to dissent, then opt out
- of the discussion rob committee deliberations of their role in i sharpening the product (the letter).
A real consensus would be group solidarity in sentiment and i
belief. In complex matters consensus may be hard-won, or even un-attainable. Consensus is most valuable when it reflects comon understandings in depth, which in unfamiliar territory can occur only O after the more knowledgeable contributors have successfully trans-ferred the essentials of their specialized knowledge to the other 32
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! participants. Thus, ACRS consensus also depends on the willingness of ,
! members to give and accept education, to become more like one another I over time in their attitudes.and understanding, and to become gen- :
eralists. Recognition of the desirability of mutual education and '
gradual translation of new members into "ACRS generalists" is shared
- among at least some of the current membership of the ACRS. Attaining ,
consensus on crucial underlying assumptions will aid the process of !
i achieving consensus on matters of substance, j i The Panel also suggests from its experience that the process of
{
achieving descriptive consensus (consensus on what is true, etc.) i i
frequently results in long strides towards policy and decisioti con- *
! sensus as well. This happens because descriptive consensus is more nearly policy-neutral, and allows participants more latitude to l' j surface the assumptions they are making without, necessarily, de-j veloping direct risk to their policy preferences. In the course of 1 surfacing of major assumptions, people tend to move closer to the same :
3 views, and once they reach the same description of the issues, they i I
also tend to move closer together on what to do in the face of those i
1 issues. .
[
i The Panel believes that consensus that is reached by settling for !
the least conmion denominator is not useful, because it often results l in vague and unusable generalization. Concealing conflict from readers of ACRS letters also tends to confuse them as to the intended
) ACRS message, f j
O A.2 Better Use of Consensus-building Techniques is Attainable f
Certain discussion techniques are in themselves great aids to !
- reachir.g consensus. They are widely used in other forums where it is )
important for a group of individuals of diverse backgrounds and beliefs to work toward connon understanding and agreement. We believe I that the ACRS could more conscientiously practice these techniques l than they do.
j We have written up two of these techniques that we believe could
- be used with the most benefit, and have set them in the context of ,
l possible use by the ACRS. This writeup is attached as Appendix IV. l B. Letter Writing: Documenting the Consensus Process ;
ACRS letters are the Committee's main product. Construction permits and operating licenses for commercial nuclear power reactors !
i cannot be issued until the ACRS' opinion, in the form of a letter to :
l the Commission, is duly included in the appropriate docket. Thus !
letter-writing purposes and practices date to the origins of the ACRS. l ACRS letters have great potential value for shaping the thinking of j people who are either less technically sophisticated than the members,
- or have less time to devote to the issues considered by the ACRS. The #
l Panel has observed that some ACRS letters are cryptic, abrupt, and not i self-explanatory if judged in terms of their potential to make a j I 33 l l
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r persuasive educational case. In fact, minority views, usually written O by one person with persuasion and justification in mind, are often more illuminating than the letters themselves (in those cases where dissent is expressed with respect to a key issue). The Panel believes "scrutability" of the ACRS letters to be essential if the letters are to achieve their purpose. Some more detailed comments on ACRS letters and their preparation are given in Appendix V.
I C. Achieving Better Comunication with the Audience Requires More Oral Presentations and Discussion
" Collegiality" means to ACRS members that individual members will decline to speak for the comittee. The committee speaks through its
- letters, or as a group, face-to-face with its audience. There are negative consequences from " collegiality" and from the assumption that ACRS letters are self-contained and speak for themselves. These assumptions have the effect of abdicating a great deal of the respon-sibility for effective communications. The Panel has concluded that significant opportunity for enhancing effectiveness exists in the comunications area.
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C.1 Important Written Opinions of the ACRS About Which at least One or Two Members Feel Strongly Should be Backed up by Oral Discussion The Panel notes that ACRS meetings are currently held with the Comission at about bimonthly intervals. We believe that sustained contact between the two bodies is desirable, and we endorse the i
current effort to make these meetings more useful. In many cases, ACRS written opinions should be supplemented and reinforced by oral discussion, so that the Comissioners will have a good chance to assess the meaning and significance of the ACRS work, to test its foundations if desired, and to ask questions. As for the ACRS mem-bers, discussions with the Comissioners should provide valuable clues on the context in which the NRC is making particular decisions and on
- the Commission's priorities.
f When members of the ACRS develop strong opinions about issues discussed in an ACRS letter, and/or the ACRS wants to be sure that the Comission pays careful attention to ACRS advice offered in a letter, we suggest that there is excellent reason for ACRS to ask for a special meeting with the Comission. Not all members of the ACRS need attend--just those directly involved, most knowledgeable, most inter-ested (perhaps, for example, a dissenter) or those who for some other '
i reason are specially requested by the ACRS to participate. A meeting between 15 ACRS members and 5 Comissioners is by definition unwieldy l and wasteful if it includes people who will be unlikely to make a j special contribution. If a member doesn't have a real role in one l
discussion, he probably will have in another, so there need be no ,
I special status signified by members' participating in these smaller !
l meetings. It's worth the effort to make sure the right ACRS members i attend, in order to. increase the focus and relevance of the l I
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discussion, and it is advisable also to prepare those scheduled to s
attend in advance of the meetings.
C.2 ACRS Should Deal with the Regulatory Staff on a Technical and Professional Basis With respect to comunications with the Regulatory Staff, a very different problem exists, a problem that reflects a somewhat compli-cated relationship. The ACRS is sometimes now in the position of second-guessing the Regulatory Staff, or at least looking over their shoulders. The staff is sometimes in a position to withhold or greatly delay conducting studies or analyses that the ACRS asks for.
Neither party is unaware of these circumstances. Both ACRS members and Regulatory Staff members are from time to time made uncomfortable by them.
This kind of discomfort develops an impediment to comunication when it is expressed by ACRS members in behavior which the NRC Staff can interpret as harassment, patronizing behavior, or just plain rudeness. We have been told about a number of such incidents. We have observed a few instances in which it must have been humiliating for the NRC staff members involved, especially since it was not .
obvicus what the Regulatory Staff members involved had done to deserve the way they were treated. On the other hand, the Regulatory Staff seems to go out of its way to be careful not to treat ACRS members other than deferentially. We suggest that ACRS would have better 3' service from the Regulatory Staff and would enjoy better communi-cations with the Regulatory Staff if ACRS members were a little more considerate in the way they treat the Regulatory Staff. We suggest that it would be in everybody's interest for the ACRS to ask its Chaiman and its Management Committee to ponder this problem, and to begin working with individual members, if any, who are persistently inconsiderate, with a view toward changing the nonns in this regard.
The Panel is, of course, aware that the Regulatory Staff could be capable of recalcitrance and obduracy now and then. The question is whether harsh behavior by ACRS members has the effect of overcoming these barriers or making them worse.
In addition, certain attitudes exist, which contribute further to the same difficulties. The NRC Staff to some extent believes itself to be just as knowledgeable as the ACRS in general, and more so in detail, and that Regulatory Staff members will therefore get little profit out of their participation in ACRS meetings. Some members of the ACRS seem to assume an informal oversight role by the tone and nature of their dialogue with the Regulatory Staff. This includes the obligation of a member to administer corrective guidance when he believes correction is needed.
These two attitudes, both of which the Panel believes to be p inappropriate, exacerbate each other. It would be good if the ACRS were to break the " vicious circle." ACRS might consider arguing out Q within itself some ground rules for providing guidance to the 35 1
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Regulatory Staff. What kind of arrangements need to be in place i
between the ACRS and the Comission to cover those instances in which it is or should be legitimate for the ACRS to provide guidance, or to
" task" the Regulatory Staff? Should it ever do so at all?
Regardless of the outcome of such discussions, the ACRS should also guide itself by the following prohibitions and requirements:
- 1. Regulatory Staff members should not be attacked when it turns out that they are the wrong ones to have appeared before a sub-comittee or the ACRS itself. If the ACRS believes NRC staff witnesses are not knowledgeable, they should be i courteously excused and the issue taken up with the EDO or the Comission.
- 2. To the extent possible, ACRS questions to the Regulatory Staff should follow the lines and subject matter that the Staff has been notified of. If it is necessary to depart from the subject matter the ACRS had told the Staff would be covered, there should be no surprise, vexation, or recrim-ination when questions in the new areas of subject matter 1
cannot be answered on the spot by the Staff members present. l 3 '
- 3. Keep meetings on schedule, so visitors for subsequent ses-sions need not be kept waiting needlessly while the ACRS i falls behind. If the ACRS does fall behind schedule by more -
than a few minutes during a particular session, replan, and ,
j infor1n affected prospective attendees by telephone so they
- don't have to leave their offices or hotels until a reason-able time before their participation will be required.
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- 4. Above all, plan meetings and sub-committee meetings l; carefully. Identify the people whose attendance is desired or identify precisely the questions and subject matter to be pursued, so that the NRC Staff can chose the right people to provide the information desired. To summarize: give
- prospective attendees as much notice as possible, as to the l
infor1 nation required, the form it should most desirably take, and the time and place it is to be delivered. This will be
! easier as the ACRS begins to assume the initiative in i planning its agenda, rather than reacting to NRC Staff ,
initiatives.
D. FACA The Federal Advisory Committee Act (PL 92-463, 92nd Congress,
' Oct. 6, 1972) (FACA) is intended to assure that:
i
. advisory comittee purposes are restricted to the giving of advice;
. advisory committee meetings are truly open to the public; 36
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i q . a designated federal employee is present at all advisory Q comittee meetings to assure that FACA provisions are enforced; and
. minutes, reports prepared for or by advisory comittee, and other documentation are preserved and made available to the public.
There is one ACRS staff employee whose time is dedicated pri-marily to maintaining the required files. All new project engineers on the ACRS staff must, as one of their initial training procedures, qualify as a designated federal employee under the act.
When the FACA was passed, there were many predictions of dis-aster. The Panel did not see that FACA has had any significant adverse impact on the activities of the ACRS, with one exception. The NRC Staff may be more inhibited in its discussions with ACRS than it once was, and the requirement that ACRS deliberations and records be open to the public may have something to do with this reticence. If
> FACA has done damage to,ACRS it would seem not to be major. ACRS 1
subject matter, vocabulary, and operational mode all contribute to a situation in which the meetings are a good deal less "open" to the public in practice than they are in theory. What has been accom-plished by enforcing FACA, therefore, is indirect but useful. Those groups that are technically competent to understand what the ACRS is 3 doing now can monitor the meetings. The result is a net reduction in suspicion, and a net increase in the opportunities such groups have to influence what the ACRS does. The Panel believes that FACA does more good than harm, so far as its effects on ACRS are concerned. The purposes of the Act would be better served, however, if transcripts, handouts and other documents used or produced by the ACRS in its open meetings were to become available more promptly. ACRS meeting papers are not usually accessible at the NRC Public Document Room sooner than a month after the meetings they document. The Panel recomends
! cutting this delay to a week in the ordinary case, and no more than two weeks in extraordinary cases.
- E. Comittee Budget I
The Panel has not addressed directly the size of the budget. We were asked to evaluate ACRS effectiveness, not its cost vs. the costs
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of other advisory comittees. We are aware of the fact that ACRS is I both active and relatively large (among advisory bodies) and that it is supported by a relatively large staff. The result is a requirement for a relatively large budget. The right time to review the ACRS budget will come when the Panel's major recomendations have been implemented. With adjustments in the Comittee's role, its methods of managing itself, some of its constituency relationships, and its internal operations, there should be improvements in effectiveness and adjustments in requirements for resources.
The Panel, accordingly, recomends that the ACRS comit itself to a review of its budget and budget requirements after it has agreed to 37 l
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changes in its charter and mode of operation, and these changes have
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- begun to be reflected in the tasks it takes up and the demands that j will then be placed on the ACRS staff.
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VIII. ENHANCING ACRS CONTRIBUTIONS TO THE REGULATORY PROCESS The ACRS has been visibly involved in nuclear safety regulation over the entire history of nuclear power. A partial listing of its contributions begins with concerns about criticality control and extends through containment, emergency core cooling, pressure vessel integrity, anticipated-transients-without-scram, the "ALARA" approach to radiation exposure of workers, electrical reliability, emergency planning, human factors, and waste management. The discussion presented here is intended to provide some suggestions as to how the ACRS as a Comittee can further enhance the value of its contributions to the regulatory process.
. A. Perceptions of ACRS Contributions The Panel members' interviews with those familiar with ACRS functions over the years uncovered a wide variation in perspectives concerning what has been most valuable. The Panel observes that most of the issues to which ACRS contributions have been most important were active concerns of the ACRS several years ago. In recent years, their initiatives in major safety resolutions have not been as obvi-ous. It remains to be seen whether this difficulty in identifying contributions by ACRS in recent years as a result of initiatives it took is a product of the long gestation time of important steps, or if in fact it does represent a decline in important ACRS output.
The NRC Staff, as might have been expected, offered the longest list of matters in which the ACRS contribution was of great value.
The time span of those contributions extended over a number of years, but many have come to fruition only in the last few years. Notably, the Safety Goal Policy and the Severe Accident Policy are just now being established by the Comissioners. Others including electrical reliability, piping integrity evaluation, and fire protection are matters wherein the ACRS through its persistent probing has helped to establish a regulatory position on complex technical issues. Some regulatory controversies such as the recent problems of Diablo Canyon
- seismic design and Midland soil settlement have been clarified by ACRS assistance. Other matters in which the ACRS involvement has been useful in the near past include the CRBR licensing review, PRA method-ology, diesel generator reliability, standardized design concepts, and the research progran. During operating license reviews the ACRS has
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been a catalyst for improvements in design, operations, and defense-in-depth. Many of these matters continue to occupy ACRS attention. Infrequently, when requested, the ACRS has helped to resolve staff internal differences. ,
1 The NRC Comissioners, the main clients for ACRS advice, have identified a less extensive list and, while they would, no doubt, acknowledge the above staff listing, have cited ACRS accomplishments i
that reflect their different type of need. Current and previous i r Comissioners made reference to the following matters as helpful in l
( developing Comissioner judgements: the recomendation to tenninate the LOFT project, the involvement with the Appendix R fire protection 39 l
- rulemaking, the views on regionalization, the reports on " cosmic l
issues" such as safety goals, seismic adequacy, and on NTSB-type l accident investigations, and the various discussions that members i
appended to consensus reports.
- The Congressional Staff members mentioned only a few instances
! where ACRS contributions were deemed helpful, e.g. the safety goal
! policy, but there is not as much current interest by Congress in ACRS I activities as was the case in the days of the Joint Committee on Atomic Energy. The independent views of the ACRS on nuclear safety are not directly sought, although one individual expressed a desire i
for the ACRS to act promptly in taking a position on plant safety questions of hi.gh public visibility. ,
j Industry observers seem to emphasize instances where the ACRS,
! during licensing reviews, narrowed the issues needing to be addressed
' prior to licensing action. These individuals tended to encourage ACRS i to concentrate on generic matters of major significance and avoid becoming involved in day-to-day licensing details.
1 Members of the public value the ACRS as providing them with an i opportunity to air concerns they may have in a less formal atmosphere, i
than is available to them in hearings.
The Panel believes all of the above participants in the regu-i latory process expect the ACRS to continue to make contributions to j the nuclear regulatory process in the interest of public safety, but most believe the Connittee should focus ore its advisory function i
rather than becoming involved directly in regulation or design,
! construction, and operational details.
B. Advising the Connissioners
! The primary responsibility of the ACRS is to advise the NRC l Connissioners. The Panel believes that the Connittee should make certain that in discharging this responsibility it always keeps in mind the type of advice needed by the Connissioners and the form in which it should be presented.
In most cases the Connittee will be expected to discuss with the Connission issues which it intends to take up, whether they have arisen as a result of Connission query or are raised at the Com-mittee's initiative, and to review with the Consissioners how each issue might be addressed. As was the case of the Safety Goal Policy, the ACRS may be asked to develop its ideas on how to deal with a problem within the regulatory framework. The Panel believes that such requests are best handled by identifying the strategies for resolving a problem including sources of help, steps toward resolution, and the methods for attacking the problem through discussions with the Regu-latory Staff, the regulated industry, and contractor organizations.
Generally, this is the manner in which ACRS has supported NRC and its O predecessors in the past. The ACRS' more recent style of operation is to leave much of the initiative to the NRC Staff in detemining what 40
- . - - - _ . . ,__ - _ , - __ - = . . _ - - ..
1
! relevant information is brought in. The Panel believes that if NRC Staff resources are involved, the ACRS should develop a cooperative approach with the NRC Staff in assessing hs problems of concern to the Comissioners should be resobed, but it should feel free to directly explore such matters with all who are knowledgeable about the i subject matter.
In a few instances, the Comissioners will be interested in a straightforward statement of the problem, an explanation of the issues to be resolved, and the ACRS views on the best approach to resolving the issues. A judgement about the problem can be useful even if it is given with little or no explanation, but it will be of more value if supporting evidence is provided for the Comissioners to use in evalu-
. ating the basis for judgnent.
If, as a result of such responses, the ACRS is seen by the
. Commissioners as a positive aid to them in bringing about the regu-j latory results intended by the Atomic Energy Act, it will be serving its best purpose. To this end, the Committee should be building a strong connunications link with the Connissioners through well founded 4 j
reconnendations accompanied by well referenced evidence and
- explanatory discussion. The Panel believes that the Commissioners' I display of uniferstanding of Comittee " advice" is an excellent measure
- cf ACRS contribution to the regulatory process and should result in J
responsible consideration of its recenmendations by the Comissioners.
- C. Licensing Reviews Since review of construction permit applications (cps) is essen-j tially inactive and is expected to remain so for a number of years, i and Operating License (OL) reviews will be limited to those currently on the regulatory agenda, the ACRS will have only occasional demands for its assistance in these areas. Furthennore, the regulatory system
! has a well established set of review procedures for such licensing ,
actions, reducing the need for the ACRS to augment the staff reviews, i
l The Panel believes that, when such reviews are undertaken, the l
ACRS will be most effective if it selectively examines matters that i
~
are new or peculiar to a specific licensing action, or have become important because of new information arising from operating experience or from other sources of technology insight, for example: PRAs and
- severe accident research. The reviews can also be effective in exposing the manner in which INPO and other industry institutions are ,
! influencing industry response to regulatory requirements. The Panel does not believe that the ACRS can add a great deal to the regulatory j process by detailed examination of design, but an occasional examin-ation of a design feature to illuminate safety principles can be of value, as, for example, review of periodic testing methodology of
- diesel generators for positive and negative effects on emergency power j reliability.
!O 41
^ The Panel believes that the continuing emphasis by the ACRS on reducing the number of issues to be resolved before licensing and on encouraging a reasoned basis for interpretation of regulatory re-quirements is of special value to the regulatory process and should be continued. In this regard, ACRS review of proposed rules and im-portsnt safety guides and other regulatory tools used in licensing as a separate but interrelated matter is seen by the Panel as an im-portant adjunct to the licensing review.
The Panel believes that this focusing of Committee attention on the manner in which important regulatory issues are treated by the NRC Staff during its licensing reviews would be the best way of contributing to the regulatory process. In making this recommenda-tion, the Panel is not advocating an item by item examination of how the NRC Staff handles regulatory matters, but only an evaluation of its interpretative practices in enforcing the regulations. The results of the licensing review will then be of use in evaluating how the regulatory system is working and whether critical safety issues are being properly handled, and would thus provide guidance to the Comis-sioners about future management of the regulatory system.
D. Regulatory Policy The Panel encourages the Comittee to assist the Comissioners through advising on regulatory policy, but to limit the breadth of its s contribution to the degree that the experience and knowledge repre-sented by the ACRS can enhance policy judgments. The Panel believes that the Regulatory Staff Management must have freedom to make decisions about how to deploy the Regulatory Staff resources, if it is to be held responsible for its perfonnance. The ACRS should, there-fore, be concentrating its attention on policy matters that pertain more directly to safety issues. Safety goals, severe accident manage ment, and use of PRA would clearly fit within this area of interest.
Involvement in relations between the licensees and the Regulatory Staff should be handled cautiously. The ACRS will serve the NRC best
- if it provides explanations as to why policies would improve or j degrade regulatory results. It should not try to become an independent policy-making unit.
1 E. Timeliness of Recomendations Recomendations for actions that will require much preparatory effort before implementation should be presented in a manner that draws attention to the time required for implementation. This was the j case in consideration of pressure vessel integrity issues. Months or i perhaps years may be needed to obtain the desired results. The ACRS will also need to anticipate the types of resources that may be required to respond to ACRS advice, and how they might be used. >
4 Even the Comittee's own capabilities must be taken into account
! in developing its recomendations. Some of the suggestions given the l
Panel during interviews referred to the need to develop a better 42
_ _ _ _ . - - _ _ _ . . _ - - _ _ ~ _ - , - - _ _ - ------
1 I
i . understanding of " standardization" and of the significance of " severe accident" behavior. At the same time, others see the need for a more ;
intensive effort concerning waste management and plant operations. I While many of these are included as illustrative suggestions elsewhere i
in this report, the ACRS must consider which of such matters should be ,
- given priority on its work agenda. In deciding what matters to
! include, it must consider how current matters competing for ACRS members' time and for the resources of the NRC, industry, and others may be affected by ACRS initiatives. It may need to suggest changes .
in regulatory emphasis to the Commissioners that can alter resource j
. usage or affect the time when actions can be implemented. The ACRS to !
be effective must. display an understanding of how such priorities t
should be assigned. A measure of its contributions will be its ;
- i. .
ability to. identify and report on issues of critical significance in p time for them to be handled as a part of normal regulatory operation and not as a regulatory crisis. However, it is unrealistic to expect that every matter of critical significance must be fully examined by I the ACRS. It.will be necessary to allow many important safety matters
, to be handled by the Regulatory Staff or agents of the regulated industry, and in such cases the ACRS will have to limit itself to
' advising the Consissioners as to whether those in charge are handling matters re,sponsibly.
i r L F. Evaluating Difficult Issues i The selection of issues to be examined should not, of course, be j
O 6 see en the ievei ef 6iic tiention oiven to n 4 e- The acRs will need to consider the potential seriousness of a problem, whether
- the ACRS contribution will help to resolve the issue, and what matters
] must be set aside in deciding to attack a new issue. The ACRS
, recommendations will be of greatest value if they help to establish a .
I path to resolution. In most cases., this does not mean providing a complete answer to a problem. The advice will be of most value if the i Committee can state criteria for resolution of issues, suggest steps '
I for studying the issue, or even indicate a preferred course of action ,
l when a path to full resolution is now known. Although cautionary i
{ suggestions are sometimes necessary in making recommendations about l
< difficult problems, it is important that the ACRS " advice" be so j presented that the precautionary consents do not cause the advice to ;
- appear to be " fence straddling," thus providing no clear guidance. {
(
! One measure of the value of advice about critical issues is to j observe how the Commissioners and Staff respond to it, as shown by the ;
- following illustrations. - Tennination of the LOFT program was par- i
! tially attributable to the ACRS evaluation of its worth to the !
- regulatory program at the stage at which the safety research program l
' was reviewed. In the case of the pressurized thennal shock issue, the i regulatory actions tracked the ACRS recommendations.
l The attention which industry has given to the ALARA concept for i
- controlling worker radiation exposure and to the safety significance !
l of matters reported in LERs came from ACRS emphasis on these matters {
! during the mid-1970s. More recently, the attention to problems with l
. t i 43 j i
l
- I {
u . _ ._ _ _ . . _ _ _ -, _ __ _ ____ _ _ _ _____ _ _ -. _ __-. _ _ .
bolting in nuclear plants has intensified as the result of ACRS probes. The current attention to control room " habitability" and previous actions to assure independent operability of the emergency control room are evidence that the regulatory system is responsive to ACRS recomendations.
Neither the ACRS nor the NRC should expect that the ACRS should take the initiative concerning public safety as a result of short term emergencies; the Regulatory Staff must handle such matters. The ACRS is not expected to be a discoverer of new safety problems, but rather, an evaluator of the safety significance of those that might appear from any source. The Panel believes that the ACRS has a responsi-bility to identify, evaluate, and advise on trends in the nuclear safety arena that justify shifts in emphasis or further improvement in safety provisions, as was seen in cases referred to above.
G. Contributions of Members as Individuals Although the ACRS functions as a collegial body of experts, its members are selected in part for their individual skills, in part for-their independent judgement, and in part for ability to apply their knowledge _and judgment to the wide range of matters under the ACRS purview. As the Panel has indicated throughout this report, the last characteristic is expected to be of the greatest value in the future.
All members should expect to participate in consensus-fonning discussions, and should make certain that when they are especially expert in the subject matter under consideration, those of their colleagues who may not be as expert receive adequate infonnation as a basis for judgement. Only in this way can consensus or its absence have meaning.
Recognizing, too, that individuals can develop biases and that even experts can sometimes be wrong, members should make an effort to further develop their understanding of important issues through professional contacts inside or outside the regulatory system. At times the members may see the need for supplemental consultant support to help develop a position on difficult questions, but it is the
~
Committee members' judgements that are wanted. The individual members will be making their best contributions when they display the expected understanding of issues being reviewed and do not default their i
judgement responsibilities to a consultant or even a fellow member because of unwillingness to learn about the issue being judged.
l l
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1 4
IX. CONCLUSIONS AND RECOPMENDATIONS l
The ACRS has developed an influential and distinguished record over the years of its existence. It has been a leader in helping to establish the direction and the characteristics of the regulation of nuclear power, to select the general objectives of the national
! program of nuclear plant safety, and to define the major features of the methods to achieve the desired level of safety. At the same time it has followed the Congressional mandate to review the safety of each ,
new plant to detemine whether it meets the requirements for public l health and safety.
The contributions of ACRS have been most important and enduring j
when they involved broad policy questions on technical matters. Some of the more vital subjects the ACRS has contributed to over the years have been: establishment of the requirement for strong containment ;
buildings; development of the fail-safe concept; requirements that nuclear plants be designed to withstand severe earthquakes, stonns,
' and floods; the requirement for engineered safety features to prevent i accidents and to mitigate their consequences (for instance, ECC i
systems); the requirement to protect against loss of electric power (station blackout); the requirement to protect against consequences of radiation embrittlement of pressure vessels (the issue of pressurized
~
i j '
i thermal shock); and the requirement for remote siting of nuclear plants. The Panel observes, however, that most of these issues were active concerns of the ACRS several years ago. In recent years their initiatives in major safety resolutions have not been as obvious.
t ACRS review of individual license cases is no longer as essential l as it once was, when the NRC Regulatory Staff review was in its i fomative phase. In the next few years there will be few, if any, new construction permit applications and the remaining operating license j
applications will follow previously approved plant design. If new orders for nuclear plants resume at some point in the future, it is
- most unlikely that NRC will be confronted with much diversity of l design. The Panel therefore believes that the need for the ACRS to review and comment on each license application is no longer necessary or desirable. A more generic approach can be taken by the ACRS in its licensing actions, and the Atomic Energy Act should be amended to i permit this, i
Moreover, there is an urgent requirement for the ACRS to return to emphasizing the jobs and accomplishments it has done best. There ,
are numerous questions on which the Commission could profit from broad, highly competent advice on technical issues. For this, the
< characteristics needed in ACRS members are technical competence, wisdom, and freedom from day-to-day pressure of regulation. The questions on which advice as to technical policy would be profitable range across the field of responsibility of the Commission, such as 4 nuclear plant operational safety, safety goals, decomissioning r
! philosophy, decontamination of plants, extension of plant life, i safeguards and physical protection, international issues, low-level and high-level waste dispostl< and spent fuel storage.
45 l
. _ = - - _ - - _
} m This is background for our conclusions
- and reconnendations, which we have divided into three areas: ACRS mission, relations with the V
Connission and the NRC staff, and internal ACRS operational questions.
We state the conclusions or reconnendations in each area, with a brief
' discussion of the overall implications.
A. ACRS Mission
- 1. We believe that an advisory group such as the ACRS will still I be strongly needed in the future. However, ACRS should turn '
its attention to concentrate on the broad technical policy questions on which the Commission needs wise counsel. A few examples of the kinds of issues that should be tak'en up by the Connittee are given in Chapter III of our report.
- 2. The ACRS should be relieved of the requirement to conduct reviews and issue reports on all nuclear plant applications.
The Connittee should only have to review a license appli-cation when a safety-related feature is proposed that is new and significant. In such cases review should be necessary .
only for that feature.
4
- 3. ACRS reviews of the safety research program should focus on the question of whether the right research programs are '
4 planned or underway, in light of priorities. The detailed budgetary-level review seems to serve no strong purpose, and
! should be dropped..'
! 4. The scope of the Connittee's technical' interest and attention should be essentially as broad as that of the Connission. ,
The Connission should feel free to seek the Committee's views on any technical regulatory problem confronting it.
- 5. The ACRS will be most valuable in its revised role if it
!' confines its recommendations to the directions to be taken, and avoids developing detailed solutions to problems. Its advice should be~at the level of the forest, not the trees.
- 6. There are other roles the ACRS should not try to fill:
i
- a. It should not try to respond to day-to-day questions.
l l
That is..it should not do firefighting.
t i b. It should not try to be a kind of National Transportation Safety Board . If it reviews findings of investigative '
groups, it should do so for their t'echnical policy implications. S -
- c. It is not a second Regulatory Staff, and should not try tofunctionjasone.
1 l
- d. It should r.ot try to manage or oversee the NRC staff.
46 l i
4.
- e. The special relationship it once had to Congress has 1
ended, and no effort should be made to reestablish it.
- Discussion: We are recommending that the mission of the ACRS be changed to emphasize the role in which the Conunittee has historically had the most influence; namely, providing advice to the Commission on i
- technical policy questions. It would be appropriate, but not essen-1 tial, to change the name of the Conunittee to fit the new breadth and i character of its revised mission.
i 8. Relations with the Comunission and the NRC Staff
! 1. The ACRS should be advisory primarily to the Comunission, providing advice on technical policy as requested, and also- ;
i on the initiative of the Comunittee. ;
l 2. The ACRS could also provide advice to the NRC Staff, but when this is done it should be through a comununication addressed i
specifically to the staff. Such advice may have the greatest value if it is provided early in the process of consider-l ation of an issue. -
i
- 3. The Conunission should consider, now and on a continuing basis, how it can better take advantage of the existence of an ACRS which is redirected to providing broad advice on technical policy questions.
l 4. Oral comununications between the ACRS and the Conunission ,
j should be improved by better management of the agenda. Not
' all members of the ACRS need to attend every meeting with the Comunission. A smaller group of those principally concerned i with the subject to be discussed would enable better exchange i and discussion.
- 5. Individual Conunissioners should be able to discuss ACRS matters with individual ACRS members, not to undercut the collegial nature of either the Comunittee or the Commission, but to open a channel that would permit the Conunission to r appreciate ranges of opinion of ACRS members in rendering collegial advice to the Commission. We see the pitfalls in this arrangement but we believe they can be avoided. In the next section on internal operational questions, we recommend development of procedures for this one-on-one interaction. .
- 6. Relations between the ACRS and the NRC staff should be im-proved. Presumably a trend toward improved interpersonal relations can develop if the ACRS is redirected so as no longer to seem to be in competition with the staff on li-censing issues, or in the position of second-guessing the staff.
Discussion: The relations that the ACRS has with the Commission and the NRC 5taff are not ideal. The Conunission is not at present l 47
e l
accustomed to calling on the ACRS for broad advice on technical policy i v questions, and this practice will have to be built up. The relations with the NRC staff are sometimes rancorous, largely for reasons that our recommendations should help to ease.
C. Internal Operational Questions
- 1. The Panel recommends that the role of the ACRS Chaiman should be strengthened, and that the Chaiman should exercise a stronger leadership role. As part of this strengthening process, the Chaiman's term of office should be lengthened 4 to two years, renewable once, and he should receive a higher remuneration for his service.
- 2. The ACRS operates at present in a somewhat reactive mode.
The sub-comittees on generic questions provide some long-tem coherence to Committee action, but a Management Com-mittee is needed to plan out future directions of the Com-mittee, develop priorities for issues to be considered, and set the course of action and schedule for these. A suitablo Comittee might be the Chairman, the Vice-Chairman, and the p.ast Chaiman, with the Executive Director of the ACRS staff as an ex-officio member.
- 3. The consensus method of operation is appropriate. However, dissent should not be discouraged. Papering over dis-( agreement with words meaning different things to different i
Comittee members does not help the Comission and does not 4
strengthen the image of the Comittee. Letters might well reflect the breadth of opinion of the Comittee. They should especially point up the opinions of any Comittee members who are particularly expert 1.n matters on which the Comittee is comenting.
- 4. Comittee letters should be clear and unambiguous. Letters should be self-contained, so that readers need not refer back to previous letters for interpretation or understanding. If the Comittee moves away from responding to licensing needs, as we suggest, letter-writing can then be more thoughtful
' and the product more meaningful. Subcomittee chaimen should be in a position to explain the entire contents of a letter and not just a limited part.
- 5. We see no reason to change the size of ACRS. A membership of fifteen still seems reasonable as does the method of se-lection of members.
- 6. The present policy that limits ACRS service to three terms is reasonable. The practice of long tem tenure for Committee members prevents taking on new members with fresh ideas or special competence in new areas of Comission interest.
- 7. Reappointment of members should not be automatic. When a 48
l-member's tem ends, his reappointment should be considered in the same way and on the same plane as appointment of another person to replace him. f
- 8. The redirection of ACRS away from " nuts and bolts" questions should reduce the need for the Comittee to have members
! representing a complete range of disciplines. Some range of i specialist backgrounds may still be useful, but it will also be important that Committee members be generalists who can consider questions as broad issues. Thus, the ACRS should
- move away from requiring new members to be clones of the <
- departing ones.
t
- 9. Though the amount of time devoted to ACRS business by in-dividual Comittee members is in many cases very high, it
! should be made clear to prospective members that substan- -
tially less time could be adequate. The time commitment should not be a serious obstacle to recruiting competent i
members to the Committee. The appointment of each member should include an understanding of the limits each would set on his time availability.
j
- 10. l'he specific composition of the Committee as measured by'the i
skills represented may be reasonable for the present, but we
! believe that the composition should be changed as the di-rection taken by the Committee changes. For instance, the growing importance of waste management implies that a member
- should have a background in chemical process engineering.
Additional former senior utility management with experience 1 in nuclear plant operational management would also be de-strable, as well as members with NSSS systems design ex-l perience..
! 11. The list of ACRS consultants is very long, but most are not l used very much. We do not find the use of consultants to be i excessive. The Committee should be careful to ensure that
- consultants do not appear to be speaking for the Comittee.
Consultants should only advise the ACRS.
i
- 12. The size and composition of the ACRS staff should be reexamined once the ACRS mission is changed as we have recommended, and assuming this change takes place. '
l 13. A channel should be established for ACRS to submit users' requests for research to the Office of Nuclear Regulatory
- Research, just as is done by the Regulatory Staff.
4 lO 49
- 14. ACRS should establish rules to cover the circumstances in which discussions between individual ACRS members and
' individual Comissioners can take place, and the protocol for :
these discussions.
- 15. The current conflict of interest and FACA requirements are not unduly restrictive.
f
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APPENDIX I
- Proposed Task Description '
for an ACRS Effectiveness Study Background l In a meeting of its Subcommittee on Comittee Activities at Harpers Ferry in November 1984 and in the full Comittee meeting of December ~
1984, the Advisory Committee on Reactor Safeguards reviewed its own -
. perfomance and effectiveness and began consideration of several efforts
! to better define its role, goals, and procedures as part of a program to improve its effectiveness as an advisory body, including any statutory changes that may be required. The Comunittee has been active for over 25 years and during that time has witnessed great change in the nuclear i
- power industry and in the AEC/NRC regulatory role. While the ACRS has i also evolved in its safety advisory role through the years, further '
i change may be in order. Although a number of improvements in ACRS
- procedures and priorities have been agreed upon by the members, it also became apparent that it would be useful to engage an outside panel of j experts to make an ad hoc appraisal of the present and anticipated 1
future effectiveness of the ACRS and to develop recommendations for
- improving the Committee's performance.
' Organizational Appr'oach l The ACRS will appoint a panel of three to five persons who have back-ground and interest suitable for assessing the role of ACRS in today's
! environment. The Panel will be reimbursed, making use of NRC contrac-tural arrangements as appropriate. The Panel will have one of its members designated as Chaiman, and he or she, in conjunction with the 1 ACRS Chairman and the ACRS Executive Director, will fomulate a general I charter for the review. The panel will arrange for its own administra-tive and secretarial support.
Schedule The Panel shoufd complete its review on a schedule that will pemit it to make a report to the Comittee no later than July 1985.
Panel Membership: ;
Panel Chaiman - L. Manning Muntzing, Doub & Muntzing Law Fim l John F. Ahearne, Resources for the Future Herbert J. C. Kouts. Brookhaven National Laboratory Myer Bender Querytech, Inc.
Homer J. Hagedorn - A. D. Little ,
EdsonG. Case,NRC(retired) s l
John M. West, Combustion Engineering (retired)
Steven Sholly - Union of Concerned Scientists
, Richard Hubbard - MHB Technical Associates l l l l
l l
A1 ,j l i
. l
. i l . l
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Task
Description:
The purpose of the Panel's review should be to provide advice and guidance that will pennit the ACRS to improve its effectiveness as an advisory body to the Nuclear Regulatory Comission and in furnishing i more general leadership, in matters of reactor safety. There.are indications that some of the Committee's practices and policies, while i effective in the past, may not be as appropriate for the maturing and
- changing industry and regulatory climate of today. -
A base for the review should be the Committee's charter as described in the Atomic Energy Act of 1954, as amended. If the Panel believes this
- fundamental charter should be changed, recommendations for that should i
be clearly separated from advice as to how the Committee can more *
- effectively fulfill its present' charter.
l Given this starting point, the Panel should consider itself unrestricted i in its review. We have provided below a list of questions that the Panel might explore. We have no preconception about the completeness or the essential nature of these questions; they are examples only. We expect that the Panel may want to r.eview recent and past ACRS reports, f., .
interview members of the Comittee, past and present, interview Commis- -
stoners and Comission staff, members of Congress and staff, and rep-
!c resentatives of the nuclear power industry and the broader reactor safety comunity.
Is the Committee's approach to generating advice on issues (i.e.,
1.
through review of related documents supplemented by testimony to
. Subcommittees and the full' Comittee, and then devel'oping a sum-i mary, consensus report to the Comissioners) appropriate and effective?
l 2. Is the Comittee's present composition and the method of member
' selection appropriate and effective?
- 3. Is' the method of selecting the Comittee chairman and subcommittee j chairmen and members the best approach?
I
- 4. Are follow-up activities, vigorous enough?
j 5. :Should the ACRS work on generic vs. case-by-case deteminations?
- 6. How should/should the ACRS interface 0with the NRC Staff, i 'Comissioners, and boards be changed, if at all?
r.
- 7. How should the ACRS establish its work priorities?
! 8. Is the scope of Comittee involvement too broad or too narrow?
l l ..
A2
, . ~ . . - __,..m,, .,-v_--
.-.._--,_.--__ , -.m _.m _-.-.-,_.,_._._..,_....--,.__...__,.,,,,,_-_,,-._.,--,.-.,.-....m..,
- 9. Does the ACRS make effective use of its consultants? Should the use of consultants be expanded / reduced? ,
- 10. Are the Comittees conflict of interest restrictions too tight?
See guidelines being prepared by OGC and ACRS regarding fin ancial and apparent conflict of interests (per telephone conversation with D. Ward on February 11,1985).
- 11. Should the ACRS devote an increased amount of its effort to .'
following the activities of operating reactors and more -
direct / active involvement in the investigation, evaluation of reactor incidents and accidents?
- 12. Should operating experience gained from operating facilities be used as the basis for comment regarding the specific facility
, and/or more generic considerations of the program in general.' .
~
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6 l
A3 l
. APPENDIX II PANEL ON ACRS EFTEC ;*.'ENESS l Interview Ouestions Information and opinions concerning the following issues are desired in connection with interviews that will be conducted by members of the panel. The questions fall into three major cate .
l gories.
- 1 Cateoory I: What should be the role of the ACRS through the year '
20007 .
To what degree should the ACRS be addressing fundamental l.
T regulatory policy questions, including the philosophy of - '
l . regulation, or should it be addressing nuts and bolts issues?
Should the ACRS devote its attention ,
- Or a combination of both?
to establishing major safety requirements and depend on the NRC l
to see that these requirements are met?
I ~
- (:) . :
s
- 2. How much independence should the ACRS have and why? Should it l
be principally responsive to Commissioner questions and provide advice 'on those issues that the Commission requests, or should it be a semi-independent body that provides advisory opinions to the NRC independent of whether the NRC has asked for them?
p
- 3. Should the ACRS focus entirely on issues of nuclear reactor l
safety, or should its scope be broader and even equivalent to i that ,of the responsibilities of the NRC7 Should the ACRS pro- '
vide advice on fuel cycle f acilities and fuel cycle policy and technica1. issues to the same extent that it provides advice on l reacter facilities and reactor policy and technical issues?
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l 4. Sh:.:ld the ACRS have the freedom to choose which licence
- applications to review, unless specifically requested by the
- NRC to conduct a review?
l 5. To what extent could activities of the ACRS be eliminated, !
j reduced, or otherwise redirected?
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- 6. Under present circumstances, where there is a strong regulatory l
staf f and the hearing boards and appeals boards are more active than they used to be, what is the special contribution of the ACRS in licensing? In review of operating plants? -In revi ew I
- of research? In broad generic areas? l
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! 7. Should there be a restoration of the old relationship with
! Congress, where ACRS was in part responsible directly to l Congress? If so, how could this be managed under present circumstances? . .
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S. What should be thG ACRS rolo with respect to incidonts or accidents on operating reactors? Should the Committee routinely review all such events or only those events above some threshold? Should the ACRS review be contemporaneous with or follow the staff review? Should there be joint ACRS/ staff reviews?
i
! 9. In view of the fact that hardly any new plants will be licensed in the next decade, the regulatory interests will be devoted ,
l mainly to operating plants. But does such interest mean '
devoting review attention mos.tly to operational practices or, alternatively, to technological safety issues arising from operational incidents, equipment degradation, and design and construction flaws exposed by operating experiences? C.an the ACRS have an impact on plant management, training, maintenance, i
and surveillance of operating plants? Can it advise ef fectively about such matters as they af fect public risk?
If there is-to be ACRS involvement with individual reactor l
facility actions, is the Committee able to act as promptly as -
may be necessary in urgent cases?
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- 10. What involvement, if any, should the ACRS have with reactor construction and quality assurance. problems associated with individual facilities under construction?
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11 What should b3 t,ho ACRS rolationship to tho CRGR or.othor i
technical NRC staff people? .
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- 12. ' Assuming legislative changes that would permit one-step licensing of reactor f acilities, what should be the ACRS involvement in such cases at the time construction is complete and the plant is ready for operation? , ;
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What should be the ACRS involvement in reviewing the match-up '
' O 13. between a standard reactor plant
- proposed to be located at a pre-approved site (assuming prior ACRS review of the* standard ,
plant and site)? Should the ACRS be involved in reviewing the i technical competence, quality assurance program, etc.*,'of the
! utility applicant for a standard plant to be located at a i pre-approved site?
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! 14. Should the ACRS serve as a board for arbitrating technical i disagreements between staff? Between staff and industry?
Between staff, industry, and critics?
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- 15. Should the ACRS servo as tho institutional memory of tho technical regulatory process for the NRC7 l ,
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- 16. .Who should the ACRS be advising? Why? In what manner?
I (Congress,' staff, Commissioners, industry, critics, public?)
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Catacory II: How can the ACRS bost fulfill its definod rolo?
Is the size and composition of the ACRS optimum?
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o Is the method of nominating and selecting ACRS members ,
appropriate? How effective has it been? -
, o Is the average time required per ACRS member per year too .
large for people who have other jobs?
o Do the members spend so much . time on the ACRS job that they O .
lose objectivity and' expertise?
- o Does the ACRS need more "new blood"? .
Snould the ACRS, like the NRC, have some members with bread o
' systems" expertise?
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o Is it inofficiont to hovo o now chairman ovary yGor?
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o Should some ACRS members work full time?
o Art any changes needed in the ACRS staff? .
o What improvements do you suggest?
O 2.
Would it make sense to have more ACRS members and less consultants? Vice versa? Does the extensive use of consultants to ACRS dilute or augment the value of ACRS opinions?
- 3. Is the " consensus" method for reporting ACRS views to NRC commissioners working well?
t o Do minority opinions assist the regulatory process?
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o 'Aro cubecmmittoo viows givon too much weight?
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o Does the NRC staf f tell everything the way it is in making presentations to the ACRS?
o Is the procedure for arriving 'at consensus letters too cumbersome? Is there a better method that could be developed? ,
o Does the consensus approach result in a convincing communication? .
O o Is the Committee's approach to generating advice on issues (i.e., through review of related documents supplemented by testimony to subcommittees and the full Committee, and then developing a summary consensus report to the Commissioners) appropriate and effective?
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! 4. Does the ACRS have sufficient influence on safety matters?
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o Dooo tho NRC frequently foil to "closo tho loop" by not informing the ACRS of the disposition of the ACRS '
! recommendations? .
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- matters on an individual basis with NRC commissioners or NRC i staff? -
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o Should members of the ACRS participate in adjudicatory hearings? ,
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i o Do schediile conflicts adversely affect the value of ACRS reviews? -
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! 5. How can ACRS contribute to resolution of generic issues?
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o Now should the ACRS participate in establishing the l .
priorities concerning generic issues?
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i o Are all of the generic issues major concerns?
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0 How should the ACRS participate more ef f ectively in the I resolution of generic issues?
l c Is more R&D necessary? Should the ACRS have more influence i on this R&D7 o Have opportunities for international cooperation been adequately exploited? ,
i o Can the ACRS work on generic issues without doing some case reviews? . .
i 6. What is the ACRS doing toward defining safety requirements for future nuclear power plants?
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o Should the ACRS be more of a leader rather than reacting to i what others propose to do?
3 7. Would the ACRS be more effective if it concentrated on i addressing major issues rather than diluting its efforts over a broad spectrum of issues? ..
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11-o Should the ACRS depend more on the NFC to bring mattors to the attention of the ACRS rather than do its own monitoring?
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o Is there a large amount of overlap between NRC and ACRS ,
activities?
.o Does excessive paperwork detract from ACRS effectiveness?
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- 8. How will the end of operating permit application's affecti the ,
work of the Committee? Its composition?
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t i 9. How has conformance to the FACA affected the value of the l
Committee's work? Is there too much formality and " legalism" in ACRS activities?
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- 10. Tho'voguo natere of nucloor sofoty rosoarch objoctivoo ankon a judgment of the research accomplishments difficult, but what substitute can be offered for the present ACRS research review process as a means of following the progress of the safety
< O research effort? Would other types of review be more effective, and do they exist?
i
- 11. Considering the limited ability of 15 people, ev,en with an .
average work tine of 120 days per year, to cover the range and
, complexity of the subject matter introduced by the nuclear ,
regulatory process, is there any substitute for subcommittee -
evaluations so that members can focus suf ficient attention on I
issues about which it is asked to advise? Is the real value of such reviews to force the NRC Staff to show that it has a good basis for its regulatory approaches? Is too much emphasis placed on the Committee's Reports and to'o little on the review j process itself? .
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- 12. Are the skills and experience of ACRS members consistent with the involvement the Committee should have with fuel cycle facilities and other issues?
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- 13. Dsos the current ACRS lovol of involvement with roactor facilities and issues have to be reduced in order for the committee to assume a role concerning fuel cycle' facilities and other issues? ,
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- 14. Are the skills and experience of ACRS members consistent .with the involvement the Committee should have with b'oth gene'ric ,
- safety issues involving operating reactors and with plant spe-cific safety issues involved with individual operating reactor
., facilities? How do conflict of interest requirements affect the availability of people?
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Catecorv III: G2neral questions. . ._.
- 1. Where do you believe the ACRS has been particularly valuable?
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- 2. Is any new legislation desirable to improve the effectiveness i of the ACRS? .
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APPENDIX III
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APPENDIX III CONFLICT OF INTEREST RESTRICTIONS Source: ACRS Bylaws, Appendix K Aug. 20, 1985 a) As a special government employee, an ACRS member may not advise the NRC on matters affecting an entity if the current value of the stockholdings in that entity held by the member, the member's spouse, or the member's minor children exceed $1,000 in value or if the holdings constitute more than one percent of the dollar value of the outstanding shares issued by the entity. (10 CFR 0.735-21) (18 USC 208).
b) Stock ownership restrictions are imposed on ACRS members that bar the member, the member's spouse, the member's minor children, and other members of the ACRS member's hcusehold from owning any stock, bond or other security interest issued by certain companies engaged ,
t in activities in the commercial nuclear field. Each ,
4 April the Commission publishes a list of those 1 prohibited security interests. Those subject to the i
restrictions must fill out a form each year certifying l
that they are in compliance with the stock membership i regulations. (10 CFR 0.735-29).
c) As a special government employee, an ACRS member may not provide advice to th*e NRC on a matter affecting the i financial interests of the member's employer or the employer of the member's spouse or minor children. The member also may not provide advice on a matter affecting an organization in which the member or the 4 member's spouse, minor child or partner is serving as officer, director, trustee, partner or employee. This limitation does not apply if the special government employee renders advice of a general nature from which no preference or advantage over others might be gained by any particular person or organization. (10 CFR 0.735-21). [18 USC 208) d) As a special government employee, an ACRS member cannot provide advice to the NRC on a matter affecting an entity with which the member is negotiating for employment or has any arrangement concerning prospective employment. As a special government f
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O employee, an ACRS member also cannot advise the NRC on a matter affecting an entity (other than the federal government) in which the member has a vested pension.
(10 CFR 0.735-21 and 22). (18 USC 208]
e) While serving as a special government employee, an ACRS member cannot act as agent or attorney for anyone other than the federal government before the federal ,
government with respect to any particular matter involving a specific party in which the member +
' f personally and substantially participated as a special government employee. This means that if the member, as a special government employee, reviews any part of a '
construction permit or operating license application for a certain facility for the NRC staff, he or she subsequently cannot represent a private party before the NRC with respect to any aspect of that same license ;
application. Acting as an agent for a private party ,
l woul'd include signing letters to the NRC on behalf of a [
private party or meeting with the NRC staff on the ,
matter. No violation of the law would occur if the .
()
member drafts a letter to the NRC for someone else to !
! sign or if the member tells the private party what to i 4
say in an oral presenttion to the NRC but does not attend the presentation in a representational capacity. This does not preclude the member from r attending a public meeting as a public observer or ;
participating as a private citizen. (10 CFR t 0.735-23). [18 USC 203 & 205] ,
f) If, as a special government employee, an ACRS member has worked for the NRC for more than 60 days in the past 365-day period, the member may not represent a ;
private party before the NRC (see paragraph e above) on '
any particular matter involving a party or parties .
(even a matter on which the individual previously did t not advise the NRC). (10 CFR 0.735-23). (18 USC 205) g) After an ACRS member resigns as an NRC special government employee, the restrictions set forth in paragraph e above continue for life. Therefore, one l can never represent a private party before the federal l government with respect to a particular matter that the i individual worked on personally and substantially for the NRC. (10 CFR 0.735-26) (18 USC 207)
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h) An ACRS member may not use information obtained as a government employee and not made available to the public for a private gain for himself or another person. (10 CFR 0.735-51) (Executive Order 11222]
I i) On days that an ACRS member serves as special government employee, he or she may not engage in political activities barred by the Hatch Act. '
Therefore, if a member performs work for the NRC on a
- given day, during that evening the member may not engage in certain political activities, such as giving speeches on behalf of a candidate for a particular political office or raising funds for that candidate.
i (10 CFR 0.735-30) (Merit System Protection Board ,
Decision]
j) If an ACRS member is expected to work for the NRC in
- excess of 130 days in a 365-day period, the member.is subject to the same conflict of interest restrictions applicable to full-time government employees. (18 USC 202]
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O APPENDIX IV
- Consensus-building Techniques The following are discussion techniques that should be helpful to the l
ACRS and its subcomunittee chairmen in developing meetings in the
- . direction of building consensus. They are offered with some realization '
that too much dwelling on the process of leading a discussion may turn a i dynamic process of value into an overcontrolled pattern of less value.
- 1. The discussion should be focused on fundamental issues at the outset. In recent meetings of the ACRS, sub-conunittee Chainnen
. introducing a new topic or a new draft letter were often incon-sistent in how they conducted their discussions. Not all put the matter in clear perspective. Not all called attention to points in
! dispute or uncertainties. Not all recalled the history of the
- problem. The Panel believes that ACRS should develop some conunon
! expectations for its discussions and how these discussions are initiated. Casual and momentary exchanges that happen in the hall often can facilitate this process. What is really being suggested is that the sub-comunittee Chainnan should plan the general course i
of discussions and should try to keep the discussions on track.
! s
- 2. Another valuable technique in consensus building is the practice of sununarizing the discussion from time to time during the course of the discussion. It is good to sununarize when the discussion bogs down, or at a time appropriate to test for consensus. Such l
l sununaries give participants something to rally around, something
- specific to agree or disagree with, a structure to test, and a way l'
to compare their interpretations of the preceding discussion. Good suunnaries also help in consensus building by illustrating how divergent views and differences that have been explored have an influence on shaping conclusions.
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APPENDIX Y
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s Letter Writing Underlying Assumptions that Should Govern the letter-Writing Process The Panel suggests that the ACRS consider whether the following l three assumptions currently underlie the comittee letter writing ;
process, almost regardless of whether a particular letter is undertaken l
at comittee initiative, is a license-related letter, or is a comentary j on a generic issue. The Panel believes that these assumptions are, in !
- fact, broadly shared among ACRS members.
1 i 1. Consensus: The letter should sound as though it reflects ACRS consensus on a recomended course of action (see preceding section of
}l thischapter).
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! 2. Collegiality: The members believe that the ACRS letters do i
speak for the ACR5 as a body, and that few members feel a need, as
- individuals, to interpret the Committee's position.
- 3. Self-sufficient: A letter should need no interpretation. What it says is what the ACR5 means. No more, no less. The letters speak i for themselves.
l The Panel suggests that these assumptions require reexamination if l they do indeed govern the letter-writing process, particularly for
- letters of advice addressed to the Commission. The ACRS needs to ,
l recognize that the audience needs more explanation than most ACRS L
- letters provide. ;
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With respect to consensus, the implications of the analysis in the j first section of this chapter are clear. Some letters may turn out to j
be majority-minority letters, or may need in some other way to reflect i unresolvable differences within the ACRS. When either of these i situations is the case, the letter should reflect the reality, and !
should not imply a consensus when there is no consensus. The assumption j
about consensus should be adjusted accordingly, r Collegiality, the assumption that an ACRS member should let the !
ACRS letters speak for the Comittee, and not try to offer his own
, interpretation of the Committee, seems to have at least one unfortunate i
! effect. It provides the opportunity to an ACR$ member, when questioned
! about the meaning of an ACRS letter, to answer by talking about i collegiality. Being " conditioned" by collegiality can and apparently does distract members of the ACRS from noticing or having to deal with !
the obscurity of some ACRS letters. The revision suggested here is O- simply to admit that the two subjects, collegiality and comprehen-l sibility, are separate. The Panel would suggest adding to ACRS A22
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' assumptions the statement, " Comprehensibility of ACRS letters is an independent and important subject in its own right."
With respect to self-sufficiency of the ACRS letters, the fact is that times have changed. When high-ranking members of the regulatory staff attended all ACRS meetings, they constituted a well-infomed, parallel channel for transmitting ACRS intentions, whether these in- 2 tentions were well spelled out in the ACRS letters, or not. The ACRS can no longer assume that anyone outside the ACRS and its own staff
- knows enough, and has participated in enough of the development of the i ACRS position, to be able to put an ACRS letter into context. Those l
regulatory staff members who attend specific ACRS sessions are unlikely
> to have an overview good enough to pemit consistently valid inter-pretation of ACRS letters. It is unlikely that they will have enough access to the senior NRC staff to have significant opportunities for interpreting the letters to NRC management.
The Panel believes there is opportunity for improvement. We l suggest that the ACRS should assume that ACRS letters are as subject to
{ misunderstanding as are all other human connunications, and that it is j'
therefore important that letters be made clear and self-contained.
li Further, we suggest that it should be borne in mind that nobody can, speak for th~e ACRS except itself.
l As a footnote, the Panel notes that ACRS letters do and should
! contain references to other documents. But these references should be j
there to facilitate tracing the integrity of the regulatory record, rather than serve as required reading. As the limitation on number of i
terins for ACRS members becomes effective and long-service members disappear, the requirement to document the chain of precedents and evolutionary developments will become gradually more important. Sys-tematic means should be agreed on for enabling relatively easy retracing of steps taken over the years. The~ objective can be accomplished i through ACRS meeting minutes, sub-connittee minutes, references appended i to letters, a free-standing system, or otherwise. The Panel suggests
- that ACRS decide on a relatively painless and natural method for estab-
- lishing such a written " trace," and set about implementing it.
! Directions Should be Made Clear and the l
Assignments Made in Advance of Letter Writing I The Panel suggests that the ACRS should avail itself of the fol-l lowing management techniques: ,
l 1. The purpose of the letter should be decided at the time the drafting assignment is made. In addition to testing the assumptions and 1 revising them as appropriate, we suggest that ACRS made it clear to itself when making a letter-drafting-assignment what action is expected I from the recipient or what purpose the letter is supposed to serve. The extent and type of discussion in a letter will be different, depending on whether the letter is to be used to help prioritize among different O proposed ways of allocating available resources, to help develop a framework for making a decision, to provide clarification of a partic-ular issue, or to offer a specific opinion on a proposed course of A23 '
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. action. Moreover, agreement on what the letter is intended to do and what it is to be used for will suggest something about the format and
~ topical outline for the letter.
- 2. When possible, the criteria should be detennined for evaluating letter drafts well before discussing the drafts. Noting the agreements reached prior to the letter's drafting will also provide criteria for evaluating the draft when the ACRS receives it. The criteria might be for instance how well certain key points are made clear. Evaluation criteria should be made explicit at the time the assignment is made or before the draft is discussed by the ACRS. The drafter should begin discussion of the draft before the ACRS by reviewing the instructions implicit in the assignment, and should also take a frw minutes before discussing the draft to gain agreement on the criteria to be used in evaluation. If a sub-committee has volunteered a letter draft with little or no prior discussion in the ACRS leading up to it, the drafter
, might propose evaluation criteria before he actually presents the letter for discussion.
- 3. Drafts should be distributed well in advance of the dis-cussions. Members other than the drafter will be better prepared to take part in such discussions of both the evaluation criteria and the drafts if th' ye receive the drafts well in advance of discussing them.
We notice that participants in current ACRS meetings receive a great many handouts--including draft letters--just at the time these handouts are to be discussed. We believe that this practice is justified only when schedules are tight and inflexible. It seems possible that the
(>s) ACRS has allowed itself to relapse into a faulty operational mode which should be corrected.
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