ML20147J299
| ML20147J299 | |
| Person / Time | |
|---|---|
| Issue date: | 12/14/1978 |
| From: | Bradford P, Gilinsky V, Hendrie J NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7, RTR-WASH-1400 NUDOCS 7812280037 | |
| Download: ML20147J299 (56) | |
Text
- -
o 4
NU CLE AR REGUL ATO RY COMMISSIO N-I IN THE MATTER OF:
l PUBLIC MEETING SRIEFING ON USE OF WASH-1400 BY NRC STAFF Place - Washington, D. C.
O ct e.
Thursday, 14 December 1978 p
1.,
5 THIS L 'UMENT CONTAINS P00R QUAUTY PAGES ts.onen.:
(*.0':)*.47.*7*C s.
ACE -: wERAI. 7"CR12.e4 GC.
W - W !ntr*
m Ner-h Cr.citel Sh we Wcshi..3..n..C.C. *.CCO 1 78122800M O, - (l.
NATICNWICE COVERAct. C ALLY L
s.
1
+
.ca17'ai g.
\\
s.
DISCLAIMER This is an unofficial transcript of a meeting of the United Statas Nuclear Regulatory Ccmmission held on mursday, 14 De 6er 1978 in the Commission's offices at 1717 H Street, M. W., wasnington, O. C.
The meeting was ocen to public attendance and observatien.
This t:-anscript has not been reviewed, corrected, or edited, and it may contain inaccuracies.
The transcript is intended solely for general infor=a'tfenal purposes.
As provided by 10 C: R 9.103, it is not part of the femal or informal record of decision of the matters discussed.
Expressions of cpinien in this transcript do not necessaiily reflect final determinations or beliefs.
No pleading or other paper may be filed with the Ccmmission in any proceeding as the result of or addressed to any statement or argument contained herein, except as the Ccmmission.tay autheri::e.
a e
e I
I m
l 2
CR1786 1
UNITED STATES OF AMERICA HEER:mp I
mask 2
NUCLEAR REGULATORY COMMISSION i
3 l
l PUBLIC MEETING i
4' l
3RIEFING ON USE OF WASH-1400 SY NRC STAFF 5
1 6'
i 7l Room 1130 l
1717 H Street, N. W.
8 i Washington, D. C.
i 9
Thursday, 14 December 1978 f
10 The Commission met, pursuant to notice, at 9:45 a.m.
II BEFO RE :
1 12 DR. JOSEPH M.
HENDRIE Chairman 1
13 VICTOR GILINSKY, Commissioner f
I' Id PETER A.
E ' ADFORD, Commissione.
15 JOHN F. AHEARNE, Commissioner i
16 parsga7:
17 !
Messrs. Shapar, Haller, Centon, Gossick, Kelley, Pederson, Bunch, Rehm, Eisenhut, and Levine.
18,
I 19 !
i 20 i
21 t
22 i 23 !
I 24 l Ect FC50ral Aeoorters, Inc.
25,
l l
t i
i
-... ~.
l
.~
\\
3 CR1786 PR0CEEDINGS tape 1 CHAIRMAN HENDRIE:
If we could come to order.
3 david 1 The Commission meets this morning for further discussion 4
on the Lewis Report on WASH-1400 and the general subject 5
i of the use of WASH-1400, the results, methodology, 6
et cetera, Commission statements on the same.
7 We have a number of late running papers I
8' l
connected with the subject, enough in fact so that 9l Commissioner Kennedy thought it more efficient for him 1
10I to remain in his office and read then than to come here 11 and discuss papers he hasn't seen.
12 The fact that there are several recent distributions 13 suggests to me that although I expect this morning's discussion to be useful, that I do not expect it to lead I
15 to conclusions, j
16i But let us see.
17
We have had for a couple of days at any rate 18 ;i the current staff paper,78-637.
What we might do is I
i 191 go ahead.
And there is a briefing prepared on the basis 20 of that.
It seems to me that may provide us as good a 21 framework as any as a basis for discussion, and we can 22!
i see where it leads us.
23 Lee, why don't you go ahead.
24.!
i MR. GCSSICK:
Thank vou, Mr. Chairman.
oruca *eoornnq Corncany l 251 As you indicated, among the papers before you is
4 e
david 2 the December 12th paper that gives the Commission the j
2' revised statement that was prepared by NRR working with the NMSS and IE on research.
3 Also in that paper is the result of the 4
summary or the review of the uses of the WASH-1400 that 5
y u directed us to do.
6 There is a separate paper that addresses the 7
budget impact, also asked by the Commission to be reviewed; 8;
i 1
9l and as indicated, the effects primarily show up in the j
1 proposals by the research of fice, 10 jji And then thirdly, there are comments that have been provided on this most recent draf t statement by 12 IME and MPE and some additional comments by NMSS.
I 13 ja suspect you will get some additional comments from the staff.
It is still in the process of being circulated 15 I
gl by the office directors to their staff for those people
)7l who wish to make separate comments on it.
18' We do have a presentation this morning and unless 39i there are questions, we will j ust proceed.
CHAIRMAN HENDRIE:
Before you take of f on that, 20 is the budget thing in 637?
21 MR. GOSSICX:
No, that's a separate paper, 638 22 23 dated September 12th.
You may not have yet the paper that 24 came down yesterday that provided the comments that I en.c. accornns c w e.nv 25 indicated.
s I
david 3 CEAIRMAN HENDRIE :
Well, 637-A I've got.
2 MR. GOSSICK:
Well, mine addresses the budgets, 3
- 638, i
1 I
4 CHAIRMAN HENDRIE :
Yes, John just gave me that, b
5 and I had not seen that before, but I do have 637, 637-A.
l f
l 6
MR. GOSSICK:
637-A must be the comments.
1 i
7l COMMISSIONER GILINSKY:
Could I ask why did j
l l
i 8'
l j
this paper come down last night as opposed to, say, a 9l day or two ago?
10l' I
HR. GOSSICK:
The draft paper actually came down --
j 11' was distributed on the 12th.
637, it probably did not 12 get to you.
I don' t know when it got to you.
13 3
COMMISSIONER GILINSKY:
I got it last night.
14 I j
I see the memo to you is dated the 8th.
i 15:
l MR. GOSSICK:
Well, it came down essentiallv I
16' l
the same day, didn't it, Don?
MR. REEM:
I think it came down here the same l
18-day we got it.
i i
19 MR. GOSSICK:
I don ' t know what the -dif ference 20 l
is in distribution.
21l VOICE TWO:
I think you got it about 5:00 22 o' clock on Friday.
23!
i MR. GOSSICK:
I did look at it over the weekend.
I 24!
i I remember now.
acc.o n.weno como.ev !
j 25' Is it okay to proceed?
1
[-
_ _. _,, _ ~.,., _
6 david 4 CEAIRMAN HENDRIE:
Yes, why don't you go s'tead.
2 MR. BUNCH:
Could I have the first slide, please?
3 (Slide.)
4-Since we last met, the staff has had basically 5
l two activities :
one, to try to crystalize our thinking 6 I for you, identify a little more crisply just what were the 7
principal issues that we thought ought to be in any 8
statement regarding reactor safety study review group 9
report and to try to clarify more directly just what 10 1
{
range or views there were on that kind of argament.
11l What I'm going to do this morning is very i
12; briefly walk you through the principal arguments in the i
13 proposed NRR statement and by discussing a few siected 14' l
topics or issues indicate the range of views that surfaced i
15 during the staff's attempt to come up with a consensus 16I document.
j i
17i And finally, I will quickly summarize the l
results of the various office reviews of correspondents, 19' l
licensing actions where the reactor safety study might 20!
I have played a role.
(Slide.)
22 The next chart is a busy chart and attempted 23l l
to show only one thing, that the reactor safety study t
24 I j
covers virtually every subject in one form or another that oria 4.c n no c w e.nv 25 is addressed in reactor licensing, whether it is reactor i
l
7 I
david 5 vessel toughness or whether it's the health effects 2
associated with ionizing radiation.
3 It is a very large document.
There have been a 4
tremendous number of comments on it; all of this points 5
to the fact that there are a considerable number of I
6 papers including the number of papers you've seen now, 7
including Commission papers on the reactor safety O j study and on comments on the reactor safety study.
l 91 l
(Slide.)
10 ;j The next slide basically will describe what T
11 has transpired since our last meeting.
As I have indicated, 12 the scope of the reactor safety study basically covers I3 the area from the cradle to the grave and in each 14 technical area we have found a diversity of views regarding 15 l the technical validity, if you would, the adequacy of 16 I
coverage of the reactor safety study.
1 17'i Similarly, there has been considerable i
181 diversity of views about the review group report, what i
I 19 '! it means, what its significance is, what implications it i
20 might have to the licensing process.
21 At this point I would like to just reiterate 22l a view that the review group is not an independent
\\
23; group in the sense that they have never been associated i
24!
with the reactor safety study before.
It was comprised ionics encormg Comoanv 25 of individuals who ranged from ardent supporters to very I
i
.m..,
i t
I david 6 passionate critics of the reactor safety study.
It did 2
not include any NRC staff members.
3 To the extent that the review group contains I
4 a number of recommendations and conclusions, I think the 5
fact is that it doesn't present much new information.
It 6
presents findings an'd conclusions that are the consensus 7
of' that group, but the f act is that there are ranging 8'
views about what the review group says and what the 9
emphasis ought to be placed on the review group findings.
10 COMMISSIONER AREAPEE :
Would you care to or 11 would you please expand a little bit on what you mean by 12 the comment that it was not an independent group, number 13 one.
14l And number two, you seem to make a heavy point, i
15 '!
taat it was e mposed of people who were either critics or supporters; and number three, that there were no 17 NRC staff members on it.
J 18 What significance do you attribute to those 19 statements, and what is the message you are trying to get 20 across because I'm not sure I got it.
21 MR. BUNCH:
Well, I was going to get to the 22 conclusions or the implications of that in a mcment, but 23 basically the message I was trying to convey by an 24 independent group is as folicws:
af ter the issuance of ionica Accornnq Corneenv 2Si the reactor safety study, there continued to be a lot of 4
.._--,,.,_,,,,_,,,,...........-..,.m_...,,_._.._,......,m_,_._,..._,_._,,,,,,....,.
9 I
I' david 7
. commentary on the accuracy of various elements of that 2l study and regarding the use of that study or conclusions I
3 drawn from that study.
]
di They haven ' t abated.
Some of the critics include, 5!
for example, Dr. von Hippel, who was a member of the j
l 6 l review group; some of the people who found considerable 7
me'rit in various parts of the reactor safety study were 8I also on that group, such as Professor Rasmussen.
9l The point is not to imply --
10 COMMISSIONER AHEAT.IE:
Excuse me.
Rasmussen lit wasn't a member.
12' MR. BUNCH:
Excuse me, that was Dr. Kouts who had been assodiated with the study.
t I
14 The point is not that there was any bias in i
15' the deliberations of the review group, but rather that 16i it did fairly include a broad range of opinion on the study, 17!
j that it had developed prior to the formation of the group.
18!
And the diversity of the members of the review group was sufficiently great that one would not really have 20 expected a new finding to come out, but rather a 21 consolidation and a consensus.
22 COMMISSIONER AHEARNE:
What I'm still struggling 23 wi th, I'm not sure you're making that comment es a f actual 24 i
statement.
We also certainly know the composition of the oon.o n.mn, con,o av i 25' review group.
We know the reasons they were chosen were to d
~
10 1
david 8 provide a spectrum and to try to find at least somewhat 2
knowledgeable people.
Or are you trying to say that that 3'
is a point in favor or a point in criticism or it?
4 MR. BUNCH:
Not a point in criticism; let's 5
\\
see if I can capture this.
6 One of the problems that the staf f has 7
had in developing a statement that we could all share and 8;
j warmly endorse has been that we could not reach 9'
l agreement on what the review group said.
Different 10!
people have had within the staff different views about 11 the reactor saf ety study.
12 Those views have ranged just about as broadly 13 as the views of what the Lewis Committee said.
And to 14 some extent, people read into the report or appear to have 15 read into the report the views that they themselves have 161 j
held, and there have been shades of emphasis that have 17 resulted.
18 Well, what we tried to do in developing this 19 last version was to avoid some of tne problems that have 20 been identified before, namely an abundance of bureaucratic 21 language and a lack of specificity.
j 22 We reviewed past Commission and staff statements.
231 i
We attemnted to consider all of the documentation that we l
24' had available as a result of the staff review of the use of
- uno a. m nq come.nv the reactor safety study in the licensing process.
s
,,,,,,--..-rcc r-ny mv+.-,---
,v-
11 david 9 We tried to identify positions that should be j
taken in the statement and basically what you see in 2
SECY 637 is an 8 page document that supports the 3
findings and recommendations of the review group.
4 That concludes that there has been some misuse 5
6 of the reactor safety study, but also concludes that the 7
reactor safety study can serve as a useful and helpful tool for the staff.
It recommends continued support of 8
ql the use. of the reactor safety study, qualitative fault i
tr-e and event tree methodology;in the methodology, 10 jj but consistent with the Lewis Committee, urges that care 12 continue to be given of any use in the licensing process of the RSS.
13 34 And finally, it provides for a number of i
15,
specific measures to try to help assure against any j
16 misuse of hcw the reactor safety study -- and to try to j7l point the direction towards improvements in the developmental 18l stage of the reactor safety study.
19 (Slide.)
20 What I would like to turn to now is a preliminary 21 introduction to the main body of this presentation, which is:
what are the points where we think your attention ought 22 23 to be focused in your review of our paper and your review of 24 the comments that you'll see on the paper that was
'Onicx Ascoreng Comoany 25 developed?
l i
'+
e-'----
- w, y-------?+
w+ w gg wp ip-w-gv --yg
12 I
.' david 10 And I'will go into certain of these in a little 2
more detail.
3 One has been:
to what extent should the 4
statement deal directly with certain comments that have 5
i been of fered by the staff and by the Commission in the 6
past on the reactor safety study?
Should we go through 7
rote and list names of here's a piece of correspondence 8'
that said such-and-so, and here's our present view 9!
regarding that kind of posture.
10 The proposed statement does not do that.
We 11 thought it preferable not to dwell on the p But it was 12 to try to indicate what we have learned from the past and 13 set a course for the future.
14 Another comment that was made was that we had 15 downplayed the findings of the review group report and 16l certain of the findings, particularly some of the more 17 negative findings, deserved considerably more expansion i
18l I
in the text.
19 And I referred, for example, to such matters 20 as the review group's comments on the s tatistical treatment 21 in the reactor safety study where they had found scme 22 very poor handling of statistical methods.
'3
^
COMMISSIONER AHEARNE :
That is a little starker 24 than coor.
un,c= a.ocruno como.nv 25 MR. SUNCH:
Yes, sir.
.A---
.._,,-,-,-- -.~---
13 davidL1 What we have done is attempted to again 2
indicate agreement with the review group findings and 3
describe only generally the corrective measures that would 4
need to be taken and point out that in the conclusion what 5
measures are developed, what guidelines are developed will 6
be available for public inspection.
7 The next one, a view, for example, cited in the 84 L
Union of Concerned Scientists' recommendation on the 9'!
policy statement, would be a view that the reactor i
10i e
i safety study is a discredited document i
ll i I
I think generally a majority of the staf f 12 at least does not agree with that view and finds that there 13l is considerable merit to the reactor safety study, although 14l l
we have continued to recognize that there are some 1
15 i significant limitations to those analyses, i
16I There is no prohibition.
There is no directive i
17 ': that would constrain the use of the numerical estimates 18 in the reactor safety study.
19 Rather, as has been the case for the last 20 several years, there is reliance on more general 21 prescription for care --
22 COMMISSIONER AHEARNE :
I have not gone back in 23 the transcript, but I thought certainly frem CPE 's summary, 24' it seemed to bear out what I thought Lewis had said when ono a. m n, corno.nv 25 he was here, namely that the uncertain bands around the l
14 david 12 quantitative aspects on the numbe.rs were so great that
)
they could not be used either' absolutely or relatively.
2, And I thought what you had just summarized 3,
I I
was a statement that you could --
4 5
i 6j the end of the discussion when we talk about the use and the reactor safety study methodology.
It is a point 7
gl where there is some disagreement.
I COMMISSIONER AHEARNE:
Fine.
9 COMMISSIONER GILINSKY:
Disagreement wi thin 10 ijjj the report or disagreement about what the report said?
MR. BUNCH:
About what the report intends, yes, 12 81#*
13 I think what is happening is that different ja 15{
people are reading the language to have different meanings.
16l COMMISSIONER GILINSKY:
I understood Hal Lewis I
j7l to be saying that you could not make any scatements about it' 18 MR. BUNCH:
Some would extend that to say you j9 can make no use of any of the numerical estimates within 20 the reactor safety study unless they have been independently 21 preverified; not just statements about what is the chance of 22 l
23 ;
a core melt, but anything.
What is the probability of a large less accident to any specific number?
24 l
4en.c a.c e na c e c.ev I think it is a matter of degree rather than 25 a
_.%4,,
4c,,,...yw.,-..
..,y q.,e,,
..9_.y.
15 I
david 13 kind.
2 COMMISSIONER GILINSKY:
But you will get to that?
3 MR. BUNCH:
Yes, sir, I will.
4 The UCS has recommended through a chain of 5
logic that if you discredit the reactor safety study and 6
you agree with the premise that the reactor sa fety
)
7 study is a linch pin for the Commission's determination 8l that reactors are safe, that you must necessarily go to 9'I rule making.
I 10 We have tried in our proposed statement to 11 more clearly state what was the intended purpose of the l
12 reactor safety study and to clarify its intended role in j
13 the licensing process.
l 14 Again, there have been some suggestions in 15i terms of how much specificity ought to exist in this 16l particular statement in terms of the specific actions 17'
{
that are included at the end of the paper, whether or not 18' there should be specific milestones as well as just the i
19 statements of what actions would be taken.
20 (Slide.)
21 At this point I would like to turn to each of 2
the principal topics and deal with them shortly.
I 231 l
Now, you will see, unfortunately, these are 1
24' I
rather long charts, and I will just only capsulize them.
onics Aecernno Companv i 25 Our review of the correspondence, which has been provided to
.I
-m.
16 1
david 14 i
you, I believe, in Mr. Pedersen's letter on the review I
2 of Commission correspondence and staff correspondence, indicates that the range of commentary on the executive 4l sun: nary -- most notably there is one comment which is cited
$1 1
here, which is a statement to the effect that the 1
6 I executive summaries are a fair and accurate explanation 7
in' laymen's terms of the full study.
Si The review group comment which is stated below 9
has a different tone.
And the problem again is a matter 10)t of intent and a fair reading of the language.
What we I
11' have done --
12 COMMISSIONER AHEARNE:
It is not really a tone; 13 at least what Hal Lewis said was that the executive 14 surmtary is not a summary of the report.
15 l>
MR. BUNCH:
Yes, sir.
16 COMMISSICNER AHEARNE :
I mean, that is not really i
17 1 a matter of tone, is it?
18 That is a straight statement.
19 MR. SUNCH:
It is a straight statement.
20 COMMISSIONER AHEARNE:
He went on to say it 21 should not be attached to the report or described as part 22 or it.
23, j
MR. BUNCH:
What i have tried to put here is i
24l to contrast the review of at least some correscondence to en
%=nn9 0mo.ny t 25j that review group finding.
i i
v3-+
e-ap- - -
+wtew-y-av pi
-y 4wp-T-t-wp*=9-p of*p--'WTfPdt rF'e1'"M F'9""TWW f
'T-'YWYN*T-'8'W"f*WW'"'
1 17 j
I davidl3 COMMISSIONER AHEARNE:
I was just trying to --
)
2 at least I thought that I picked up an implication that 3i j
there was a difference of tone of what the review 4l group's position was with resoect to the executive 5:
i
- summary, l
6 1 HR. BUNCH:
With respect to that specific 7l statement, I think there could not be a bigger contrast.
8l There are quite a number of other references to the
\\
'\\
9; executive summary, not all of which take this form.
j 10:
I am not in my own mind sure that the j
11 body of that every says the summary reflects the full study, 12, but rather it says here is a summary which has a purpose.
13
\\
The purpose is one of public conveyance of 14' I
information to the public, which may or may net contain the 15 details of the study.
16 ll l
I think what the position statement does is i
17; basically consistent with the past one that was discussed 1
18 about a month ago; try to correct the view that the 19 executive summary does fairly present what is in the 20 main report and try to clearly indicate that the executive 21 summary has ceen misued.
I 221 l
And for example, there is a recommendation 4
23 that any report on followon RSS programs, where they have 24 an executive summary, should try to avoid the pitf alls Aon.cn Accorting Corecany 25 l diat have been pointed out in the review group.
i i
18
.davidl6 COMMISSIONER AHEARNE:
And what do you think 2
we ought to do about the current situation?
What does 3
your policy statement say we ought to be doing with that?
4 end 1 6
7 8,
I 9l 10 1
11l 12 13 14 15, I
l l
164 17 18 19 20 l
21 22 l
23 24 icnica accormnq Comoany 26
... -. - - -. -.. ~. -,.
._ ~
CR 1786 HEER:jwb 19 l
It says basically that the current report!
- 2 1
MR. BUNCH:
2 ou-ht to be accompani'ed by the Review Group findings.
3 COMMISSIONER AHEARNE:
What does it say we ought to i
4' do about the current executive summary?
5 MR. BUNCH:
It says nothing, sir.
i 6
The point being, there, is:
It does exist, and it l
7 is on the record, and positions taken would comment on it, but i
3l not try to repeal it, revoke it, or otherwise revise it.
9l COMMISSIONER AHEARNE:
What comment does your posi-l 10 tion statement make on it?
11 MR. BUNCH:
If I might turn to that, I can quote 12 i specifically what it says.
That is indicated as page 5 of the 13 statement.
The bottom of page 5, to the top of page,6.
In fact, i
la i as I see the words, they are at the top of page 6.
i i
15 You will see a statement 1
16 '
COMMISSIONER AHEARNE:
I see a statement, and it i
17 seems to me to be critical of che Ccmmission's staff's statement, 18 l not the executive summary, i
19 MR. BUNCH:
Yes, sir; that is correct.
The executive 20, summary was prepared by the Reactor Safety Study Group.
i 21 !
COMMISSIONER AHEARNE:
So your proposed position j
22 l statement generally agrees with the Review Group?
e
\\
23 i MR. BUNCH:
Yes, sir.
24 COMMISSIONER AHEARNE:
The Review Group saying it tor.was A. corms, inc. [
25 ; wasn't a summary, it doesn't indicate the consequences --
i
-l 1
2-2 jwb' 20 Lewis' statement that it shouldn't have been attached; andyourf i
i view of the general agreement is to criticize Commission and 3l' Staff statements.
3, I
MR. BUNCH:
Sir, what I think I'm trying to convey 4
1 here is the statement -- the executive summary was prepared by--
5!
i 4
was not prepared by the AEC or NRC.
It was not.
It was 6
prepared by the Reactor Safety Study Group.
j 7
1 I
COMMISSIONER AHEARNE:
And the people who wrote that gi l
9; study were not employed by the AEC or the NRC?
Are you sure of that?
10 l
11 MR. BUNCH:
Well, perhaps Mr. Levine would care to i
respond, but there were some members on detail from this agency.
12 t
i The point I think the position statement herein 13 14 l advanced is:
It represented whatever views these individuals i
r had.
If there was any misuse on the part of the agency, it was j3 16 in how we took to regard that summary, i
1 MR. GOSSICK:
I think, if you would turn to page 7, 37 item one, it does say that this statement will be distributed to 18 I
j9 { all subjects of the executive summary.
It doesn't say we're l
20 l going to revise it.
3.1 l COMMISSIONER AHEARNE:
And I can't find any statement 22 in this proposed policy that criticizes the executive summary, I
MR. BUNCH:
Well, that is the point of this discus-23 l 3 i sion, sir.
In our own mind, what we had done was say that :ne w+mwo neoon.n. inc.
25 ' misuse that needed to be corrected was our characterization of
~. _,.
2-3 jwb I
21 l
the study; and that it served whatever purpose it served.
And l
1 some have felt -- apparently as you do -- that we ought to go 2
3; farther and to actually physically comment on the document i
itself.
4 And with that, I would like to move obIto Topic 5
c Number 2.
6, i
(Slide.)
7 Topic Number 2 basically describes one of the other 3
major areas of contention, not necessarily within the staf f, but 9,
I jo ! certainly others have found this to be a very great problem.
l I
There have been a number of comments made by the 11 staff in its review of environmental -- excuse me, in its review' 12 of cccments on environmental impact statements; in responding to' 13 la public inquiries, there have been other statements over the i
1 15 l signatures of certain Commissioners where we have talked to the
\\
16 i meaning of the Reactor Safety Study results in terms of the II
- 7l acceptability of nuclear power plants, for instance.
18 l Now the most common one is an abstraction from some i
19 l of the results of the Reactor Safety Study to the ef fect that i
20 l the risks associated with LWR accidents are low compared to the risks associated with such things as meteorites, airplane 21 22 crashes, and other manmade hazards.
23 i There have been a few statements -- one of which I l
24 have included -- to the effect that the report confirms the I
eFcceral Reoorters, Inc. '
25 : Commission's convictions that the plants satisfying our i
i s
2-4 jwb i
22 l
regulations are safe.
The Review Group, as is noted in this slide, stated 2[
! that there have been instances in which the Reactor Saf ety 3
3l1 Study has been misused as a vehicle to judge -- or improperly, t
I 5l I w uld imply -- improperly used as a vehicle to judge the l acceptability of reactor risks; and that this may have been 6
premature at the time the Reactor Safety Study was initiated.
7 As the position statement would indicate, the g
9; ability to make some sort of conclusive statement about accident 10 i risk was regarded as rather a hope, rather than something that 11 clearly was going to come out of this effort.
The proposed position statement agrees with the 12 l 33, Review Group, and it cautions against use of the Reactor i
Safety Study to reach an unqualified statement about accident 34 1.c ' risks.
(Slide.)
16 l,
- i Other pecple have argued on this topic, that this 17 13 i statement does not go far enough; that specifically, the i
19 l Commission should respond to the comment made in the letter of l
20 ! october 29th, 1975; and that we should make some sort of an 21 l equivocal statement about the acceptability of accident risks.
i
'2 li I believe, in Mr Pederson's recent memo to you, he l
23 ! has posed one related question.
To wit:
Has the Review Group 24 altered the Commission's view about the acceptability of the s
e.cere n. con.n, inc.
25 safety of current lightwater reactors?
,1, m.,
..m
..-_.-,,___...._.m
2-5 jwb I
23 Now this position statement basically would have a j
discussion of the Reactor Safety Study and its role in the 2
3
- 3) licensing process, but would not in fact deal with the safety i
I of current lightwater reactors.
That would be some other sub-4 5l ject, if that subject need be faced.
I 6lI What we have tried to do is separate the role between!
I 7l the licensing process and the Reactor Safety Study, and 1
g; characterized the Reactor Safety Study as an activity of an overall longer term development of probabilistic methods.
9 i
As I said, there are some corrective measures which 10 11 are proposed that would avoid further such problems, but there 12 i are some who would like to see a little stronger statement made that we thought appropriate.
33 i
H ja !
If I might turn to the third viewgraph --
4 (Slide.)
15 16 '
-- on the matter of peer review, there have been quite a number of comments over the last four or five years 37 about the inadequate peer review, or at least the inadequate 18 :
j9 treatment of peer review comments on the Reactor Safety Study I
20 l in going from the draf t to the final statement.
21 !
The Review Group concensus supported those concerns l and made a number of statements about the inadequate treatment 22 !
23 ; of legitimate concerns and technical problems in the final d
document.
24 i<m Fecero Reoorters. Inc, 2c The proposed statement again endorses the Review Group
2-6 jwb 24 l
l findings.
It delineates some specific actions to improve the j
peer review group process, one of which I would note would be 2
the call for a second round of review when there has been con-3 i
i siderable controversy on the major documents such as the 4
Reactor Safety Study.
5!
l i
6l There has been no attempt to retract the Anders to Nader memo, which does describe the extent to which the peer 7
comments were considered -- although many would read the Review g
i Group as suggesting that that was necessary.
And it does not 9
explicitly deal with the treatment, or adequacy of treatment, 10 l
11 ! of staff-peer comments.
l l
As I indicated at the outset, there have been and 12 t
continue to be a diversity of comments within the staf f, and j
13 views within the staf f, about how good the Reactor Safety Study y
15 l is.
I think the s:3ff generally believes it has equal technical t
i capabilities to the community outside, and it should be accorded y
4 j7: the same peer status.
ig '
And there are many who have quite a bit of problem
\\
19 l with the Reactor Safety Study analyses.
There are many who l
20 i find that the benefits to be gained from this study substantially i outweigh the deficiencies of the study.
21 so we have this diversity of views.
22,
m, ;
Mr. Pederson did point out the Eisenhut report, as
, j 24 he called it, which was a very brief report that followed the
- %;.eers a.conm. inc.
25 ; finalization of the final draf t report.
And I think Mr. Centon i
2-7 jwb 4
2S I
j would like to add a comment on that.
l j
1 2;
MR. DENTCN:
Maybe it would be well to describe what I
3; the role of the staf f members were in the preparation, and by 1 staff members -- I mean the Licensing Staff members were, in 3
the preparation and comment on the Reactor Saf ety Study.
5 I have been able to identify four phases of comments.!
6!
I i
i 1
7j The first phase was that some individuals from te staf f did look at draf t versions of the draf t statement and g
commented as individuals -- act of the Reactor Safety Study --
9 individual members with expertise in various areas were asked
)
10 ij !
to look at draf t versions of the original draf t of WASH-1400.
i So that is not what I would call a " staff effort."
It wasn't 12,
I run through the staff in a coordinated f ashion, but individuals j3 l were selected.
ja I'
COMMISSIONER AHEARNE:
There, you're talking about j3 the 1974 version?
16 i
1 MR. DENSON:
I'm talking about the draft.
So they j7 commented on a draft of the draf t.
18 t
1 19 And then af ter the draf t was issued, the staff did I
20 l do what I would characterize as a "staf f review" of the draf t.
This resulted in approximately five statements or comments on 21
! the draft statement.
22 I
COMMISSIONER AHEARNE:
Is that a coordinated set of 23 I
24 comments?
scree m asoonen. inc.
MR. DENTON:
That is what I would call -- as I remember 25 i
i
., -...,.,.. - 1
2-8 jwb I
26 it, it did go through each of the individual licensing disci-plines in the staff, and was coordinated.
And I think it would 2
I be fair to characterize that as a staf f review of the draf t.
3 4{
MR. BUNCH:
I have a copy of that here, if you would I
like to see it.
5 i
i 6 !
MR. DENTON:
The next phase --
i COMMISSIONER BRADFORD :
When was that?
7 MR. DENTON:
That was while the draf t was out for 8
- comment.
9 I
COMMISSIONER AHEARNE:
That would have been, I guess,
~10 3
i sometime in '74?
11 i MR. BUNCH:
In the f all of
'74.
12 MR. DENTON:
They were voluminous comments, and the 13 Licensing organization did participate fully across-the-board.
ja And then the next interf ace was right at the final 15 i' stages of the preparation of the final report, while various 16 ii1 sections were being pulled off the press.
37 The Commission did pull together several individuals 18 I
j9 l from the s taf f, and several outsiders, to comment on this i
section.
And this is what is ref erred to as the "Ei's e nhu t 20 i
Rep rt."
21 !
I 22 !
Now I have present in the audience Darrel Eisenhut.
I g; Why don't I let him explain the actions tha t took place during that time.
24 '
\\ceaeceras Poornes. Inc.
MR. EISENHUT:
In October, or a little before October,
- u.,
I i
i
..n.
2-9.jwb 27 1
la '75, as Mr. Denton just mentioned, several members of the i
2 staff got together and we were forming what was called a little 3
bit of a " task group."
And we had been asked, after discussion 1
4! with the Commission at tha t time, to take a quick look at the i
i Si final report while it was already being essentially in the galley i
6, proof stage, ready to go to press.
l 7
That is, we all didn' t want to be caught with, all ofj a
a sudden, the report going on the street without kncwing 1
l 9'
basically what's in it.
It was an independent icok at the V
10 report, in the sense that there was no feedback from what we i
11 were doing back into the report as it was being developed by 12 ;
Saul Levine's people, i
13 The report that we put together, our study group, l
i i
14 j or task force, or whatever you want to call it, basically looked!
i 15 '
at four different areas.
I 16.
It was commenting on the overall responsiveness of 17 the final draf t to the ccmments that were received.
1a l It was to look and see whether we could not say i
10 l something about the methodology; I
20 j To look and see whether we couldn' t make some ecmments
~,
I 21 ) about the consequence model; I
I 22 l And to look at the overall report for the general 23 l substance of the report and the tone in had.
24 ;
And actually, there was a fifth area:
which was the ice Fecerse Aeoorvers, Inc.
25, development of a position statement for use of WASH-1400's final I
2-10Ejwb
.t 28 report Lin dun licensing process.
j 2i Since we were' doing this exercise actually before l
t 3: 'the final WASH-1400 report was complete, we did not have the l
i
! benefit of all of the actual completed pieces of the final 4
i rep rt that went out as WASH-1400.
l 5
6}
We did not have the summary, for example.
We did j
Thereforel
' not have any of the details on the consequence model.
7 by definition, we couldn't really " comment" on the consequence g;
model too much.
9 Secondly, we also defined our report as being a two-10 4
week review effort.
The five people, or the several people i j 2'
that were mentioned, performed basically a two-week review on i
i those pieces of the document.
13 11 I
We put together sort of a draf t of our report, and j3, j3, we came down and discussed it with the Commission, I believe, in late October of
'75.
16 g?
MR. DENTON:
That is what I referred to as " Phase III*"
18 ;
j9 l MR. EISENHUT:
Yes.
That was sort of the Phase III in die ' comment process.
20 21 lI COMMISSIONER AREARNE:
That then led to the October 22 28th report?
i i
23j MR. EISENHUT:
Yes, sir.
That report had contained l
24 in it a draf t statement of policy as one of the sections in the sesecuni Recomn. iae. ',
25-report.
i i
.--~-r r
e c
r
-1.+-4-,,+,
w.
tr-~~-.,.-.
,-*-m-e.---w,--~.-w~
, -, - - - +
2-ll.jwb 29 l
i i
Af ter discussion and a meeting with the Commission, 1
i i
i we went back and finalized the report, and issued the report 2
I r
! which is later dated --
3 3l COMMISSIONER AHEARNE:
November 15th?
MR. EISENHUT:
November 15th.
5 You will notice also it does not contain a general 6
l i statement of p]licy.
That had been removed.
It was basically 7
removed because we just had not gotten te that point in the g
~
felt we could ccament on an i
process where people, as I recall, 9
overall policy statement based upon a two-week, limited review 10 I
i l
11 j of a draf t of the final report, where we did not even see
! various sections of the report.
12 l l
We put together that report and issued it November j3 15 th, and I. understand that report has been made public.
y 1.c !
That is basically a very short summary of what we did at that time.
y 1
COMMISSIONER AREARNE:
Darrel, since it was a two-37 week effort, and the Draf t October 28th talks about this as a 18 19 result of the two-week effort, would it be fair to conclude 1
20 ! that there were very minimal changes between the October 28th and November 15th --
73 i
MR. EISENHUT:
As I recall, essentially none.
I have
'2
- 23. not gone back and made a point-by-point comparison.
The only 24 major change would be the deletion of the section on the policy i
% ;.e r.i mew errs,inc.,
25 statament.
I h
s
~., _.,,
.. ~.
2.-12 jwb, 30 COMMISSIONER AHEARNE:
And Martin Walsh's name?
MR. EISENHUT:
And Martin 17alsh's name, who was a 2
I 3l contributor on the policy statement.
That was the area he was 4j working on, therefore the final report -- Marty's name has been eliminated.
3 CHAIRMAN HENDRIE:
The section got ditched.
6' MR. EISENHUT:
In other words, we sort of scratched 7
\\
gj it.
I 9;
MR. LEVINE:
Mr. Chairman, just to clarify the i
record, I think Harold Denton misspoke slightly.
The original 10 review that involved staff members was on a preliminary draft 11 12 l of the entire WASH-1400.
I don't recall whether it had an executive summary, but there was an entire report, and it was 13 14 l reviewed by about a dozen people -- mostly NRC staffers, and I i
j ~c ! can recall one outside, Harold Etherington, and maybe one or t
I two o thers.
But I don't recall who was involved in it.
16 1
This was prior to the publication of the draft j7 i
j3 report.
I j9 l COMMISSIONER GILINSKY:
So this was in '74?
f l
MR. LEVINE:
The swnmer of
'74.
i 40 !
MR. DENTON:
My comment was that we had seen sec-21 l tions of it referred to my participation in reviewing the final 22 i one.
And there, as I recall, we did not have the entire report 73,
before us at that time.
24,
\\co FecCral Recorters, Inc..
i 25 ;
CCMMISSICNER GILINSKY:
The consequence model was
\\
2'13 jwb 31 waived?
j MR. DENTON:
We did not have the executive summary.
2 i
3l We had very few of the comments themselves, because they had not-1 been published in the report.
3 CEAIRMAN HENDRIE:
Dell?
5!
I 6l MR. BUNCH:
Okay.
I think the point there was :
I There was a concern expressed about the extent to which this 7
g.
review might have colored the Commissien Staff's statements on I
the Reactor Safety Study, and how valid they were, and what 9
j o 'I kind of spectrum of comments, and what kind of endorsement it i
11 ;
had now received by the staf f.
i I think, if you will read the November 15th thing, 12 13 l you will find in it considerable cautionary remarks. Since the i
yl Reactor Safety Study has been issued, the staff has continued I to interact -- the Licensing Staf f has continued to interact 15 i with Research on the RSS follow-on orograms.
16
- l L
We have provided ccmments to the Lewis Committee.
17 jg ' We have provided comments to Research regarding various parts of the Reactor Safety Study models and analyses, in our mutual 19 !
l 20 i attempts to improve that effort.
21 )ll And we have, again, a spectrum of views.
Many have L been quite -- and continue to be quite -- critical about some
'2 1
i 23, of the models in the Reactor Safety Study.
a COMMISSIONER AHEARNE:
For some of the people who sop.emi neoenm; inc.
25 may not have had an opportunity to review that Eisenhut Report,
2-14 jwb l
33 which you have just characterized as being " properly cautionary,"
j let me just read the findings '" ne thodology.
2 "We have concluded that the overall methodology is 3
appropriate and was correctly applied.
The data base used, 4
although sometimes sparse, was used in an effective manner in 3
order to properly determine risk assessments.
j 6
"Although the Safety Study attempted to calculate a 7
realistic estimate of the probability of core melt, it neces-g
! sarily made conservative assumptions that may have resulted in 9,
i somewhat high predictions of this probability.
10 i
I 11 !
"We are convinced, however, tha t the S tudy ' s ob j ec-l tive -- that is, making a realistic assessment of risk -- has 12 33 been fulfilled as reasonably as possible within the framework I
j a l! of the Study."
Close quote.
i MR. SUNCH:
Yes, sir.
13 16 I think what I was referring to --
37 ;
COMMISSIONER AHEARNE:
Let me just talk about the 33 responsiveneas of comments.
I 19 j CCMMISSIONER BRADFORD:
You were reading from the?
l 20 l COMMISSIONER AHEARNE:
Findings.
I COMMISSIONER BRADFORD:
Yes, but that is the October 21 i
Findings?
22 i
23 i COMMISSIONER AHEARNE:
Yes.
These were the ones i
24 ; that --
hCS ka
- f 81 A 9Cof tef t, (fic.,
- 3,
COMMISSIONER 3RADFORD:
But by November --
i l
2-15 jwb 33 i
a 1
1 COMMISSIONER AHEARNE:
We've been told there was 2j!verylittlechange.
j 3
COMMISSIONER BRADFORD:
By November, that "as a
reasonably as possible" had been deleted.
I i
Si COMMISSIONER AHEARNE:
It was a little difficult for i
6 me to view this as really very cautionary.
I thought it tracked' i
7 very well with the policy statement that the Commission put out a
after receiving this.
I 9
MR. BUNCH:
It may well have, sir.
10 What I was trying to indicate is that, first, I'm 11 not sure that if the entirety of the staff, in any event, 12 would have supported all of the findings here.
13 Second, there were several ccmments in here to the i
14 i effect that it would be a very short, brief study.
only a few 15 months before, there had been this document, specific comments, 16 !, and I ' m e it was not simply possible to review the acccm-1 17 'modation of each of those.
18 '
There was a statement I would also like to read i
19 i with regard to the responsiveness of comments, which wasn't i
20 l included with Mr. Pederson's comments, to the ef f ect that --
21 ;
in terms of how well the RSS acccmmodated comments :
"Some 22 ; negative reaction is to be expected, and in part will be war-23 ranted" -- I emphasize -
"because of weaknesses and deficiencies 24 in the responses provided by the Study."
aamu i n mmn. inc.1 25 Again, there is a diversity of ccaments in this end #2-thing here.
4
)
786.03.1 34 gsh 1
COMMISSIONER AHEARNE:
Since you talk about 2
responsive comments. I will read entirely the findings that 3
"the safety study had a monumental task in examining about SCO 4
pages of comments received on the draf t report.
5 "In general, it appears that this study has been 6
responsive in addressing the prinef pal technical concerns 7
expressed and received comments.
S "We urther believe that the approach used by the e
9 study in responding to the comments was accropriate for 10 dealing with such voluminous comments.
Me belie ve there may Il be criticisms, however, concerning the manner in which the 12 commants were utill:ed by the study..Only the essence of 13 significant comments is clearly. identified and answered in 14 Appendix.11 of the study.
15
" As such, many contributors may conclude that their 16 comments were not adequately addr essed."
17 MR. BUNCH Yes, sir.
And as the review group 13 report indic a t ed, to some extent, those concerns that were 19 subsecuently expressed we re legitimate and legitimately 20 based.
And we have attempted in our proposed statement to 21 indicate that clearly and try to avoid that happening in the 22 future.
23 I would like to turn now to Topic No. 4 on a 24 related matter.
25 (Slide.)
ACE-FEDERAL REPORTERS, INC. (202)347-3700
786.03.2 35 gsh 1
I understand that there was some impetus toward 2
publication of the reactor safety study in late 1975, in 3
part, due to the imminence of action by the Congress on 4
Pri ce-Ander son. e xtens ion.
5 There have been -- we though it appropriate to 6
indicate something that wasn't treated in any of the position 7
statements you have seen to date, but which has been a 3
subject of considereble in t e r e s t.
And I would just note in 9
the NRC statements that there have been a lot of correspondence 10 about the relationship of the study to Price-Anderson, and 11 it is not all the same.
12 If you Look at the record, some say that there is 13 a relationshipi some say the re is not.
The review group does la not mention it.
It does comment on the consecuence model, 15 as I indicated here, the proposed position statement.
16 COMMISSIONER GILINSKY: When you say there is a 17 relationship, what do you mean?
13 MR. SUNCH: We.ll, if you will turn to 637, we have 19 included a very short, terse chronology o f the last 3 or so 20 years of the development of the reactor safety study.
And 21 my understanding of the history of this thing stems from 22 the aborted a ttempt to update WASH-740, a subseouent 23 agreement between Senator Gravel and the AEC to undertake a 24 new study that would provide more realistic consecuence 25 estimates than WASH-740 had, and which subsecuently grew into ACE-FEDERAL REPORTERSv INC. (202)347-3700
736.03.3 36 gsh I
the reactor safety study.
2 That is a connection since NASH-740 clearly wa s 3
used to help support the Price-Anderson legislation in the a
'50s.
And in view of the connection between the extension 5
ac tivities on Price-Anderson, I tnink, personally, it was a 6
legitimate inquiry to whether or not the reactor saf e ty study 7
results indicated a change in our thinking about the S
imo11 cation of a large accident, and what relationship it 9
might have to the levels of indemnity that would be provided 10 by Price-Anderson.
11 MR. KELLEY: Sut at a minimum, the decision was 12 transmitted to the joint committee.
13 COMMISSIONER GILINSKY:
As I rememoer, they neeced 14 to have a rule.
The last day for a rule was something like 15 November 3rd, or something, and this was sent on October 15 30th, or something like that.
17 CHAIRMAN HENDRIE: I think I remember some testimony, 13 MR. KELLEY:
Rasmussen himself testified.
19 COMMISSIONER GILIN5KY:
The re's no cuest ion tha:
20 there was some kind of legislative deadline at the time and 21 the schedule for the report was tied to that.
22 COMMISSIONER AHE ARNE :
I gue ss that could be viewed 23 as one of the definite opinions.
24 MR. SUNCH:
I think the ocint I would be in te r e s t e d 25 in making here is that it is not clear to what extent that ACE-FEDERAL REPORTERS, INC. (202)347-3700
136.03.4 37 gsh pre ssure for timeline ss af f ected our ability to respond to 2
all the comments and take corrective action on the conments.
dell, that is a separate 4
question.
But I think even Singham re fers to it as a f actor.
5 MR. SUNCH: Yes, sir. That is correct.
6 COMMISSIONER AHEARNE: And of course, the early 7
letter that you quote in '72 to Pastore makes it clear that 3
that is the reason for doing the study.
9 MR. BUNCH: That's correct.
But I tnought it was 10 worthwhile to try to bring this point out, 11 CHAIRMAN HENDRIE:
I have been puzzled at times 12 myself abeut whether it was incidental to or caused by.
And 13 I must say I'm not sure wnen I get all through, as ide from 14 noting the several items of correspondence from various 15 chairmen, which don't give an identical view over time.
16 That is interesting, and I guess I would finally say, 17 so what?
13 VR. SUNCH: It did not s eem to me to oe a oig 1.ss ue.
19 CHAIRMAN HENDRIE It is simply a point o ne notes.
20 MR. DERTON: This is probaoly a good place to 21 m e n t io n --
I would jump ahead just a bit -- in reviewing the 22 use of 1400, we did find tha t, and memoers of the staf f 23 testified regarding the constitutionality of the 24 Price-Henderson Act in 1976, and the lower court ove.rruled tne 25 staff and the Supreme Court upheld the s ta ff pos ition.
ACE-FEDERAL REPORTERS, INC. (202)347-3700
36 786.03.5 gsh i
In checking on the role of 1400 on that. I have been 2
informed that the Supreme Court decis ion did not de cend only 3
on the verbal estimates of 1400.
This use is discussed on 4
page 331 in the enclosed a.ttachment.
5 MR. KELLEY:
You will recall that we sent a short 6
statement and concluded that it was not fair to say that the 7
government relied on Price-Anderson in its support of 3
WASH-14CO.
9 CHAIRMAN HE.lDRIE: Why den't we dash ahead to Topic 10 No. 57 11 (Slide.)
12 MR. 3UNCH: Topic No. 5 has to do with perhaps the 13 greatest area of difficulty in our achieving a resolution.
14 What I have done in the NRC statements column is basically 15 track through a f ew pieces of correspondence indicating the 16 last information, at least that I'm aware of, regarding 17 commentary f rom the commission in the use of the reac tor 13 safety study in terms of guidance to the staff.
I ha ve 19 quoted it therein, the body of it at any rate.
20 The review group comment basically endorsea tne 21 use of quantitative fault tree of entry methodology and 22 as you know, they had quite a number of very critical 23 comments in certain parts of the application of the study.
24 And they refer to avoiding uncritical use of the reactor 25 safety study in the litensing proce ss.
ACE-FEDERAL REPORTERS, INC, (202)347-3700
'S6.03.6 39 gsh i
The proposed statement basically describes the commi.ssion 2
policy as one of cautious endorsement of the Reactor Safety 3
Study and a sort of deliberative extension of its use as 4
our ability to handle the technology, develops, and as we 5
learn more about It and improve the methodology, that is the 6
no undue reliance aspect of it.
7
.It also refers to the review of the staff evaluation of 3
pas t licensing applications of the Reactor Safety Study and 9
notes that the staff concluded tnat tnere has been no undue 10 reliance in the Reactor Safety Study.- The re is not a long, il lengthy dissertation on just the various kinds of use of 12 the Reactor Safety Study, other than to note its role, 13 principally, as one that is suoplementary rather than being 14 a linch pin, or a major element in licens ing decisions. '
15 So it is suoplementary use.
16 COMMISSIONER AHEARNS: Can you comment on how you 17 f eel the stand the policy statement takes?
Can you comment IS on that and the dif f ering views as raised by some memoers 19 of MPA?
20 MR. SUNCH: I will try to characterize the kind of 21 discussions that have taken place over time. Let me s ee if 22 I can go to a back-uc viewgrapn here.
23 If I could have back-up viewgraph 14, p l e a.s e.
24 (Slide.)
25 One of the things that has haocened is, as I mentioned a ACE-FEDERAL REPORTERS, INC. (202)347-3700
40 756.03.7 gsh I
little while ago, the staff, some of the staff have said 2
the statistical problems identified by the review group and 3
others are so profound that it calls into question the 4
validity of the final results.
5 If you use poor data, if you use a poor analytical method 6
in develop.ing a risk estimate, what kind of confidence can 7
yop have in the final produc t? And that is. a very legitimate 3
concern.
I don't think there's any doubt about it.
9 And the review group s eems to support that general cremise.
10 Dur review of the application of the Reactor Safety Study l
11 in the licensing process, our review of the various staf f 12 arguments, what I ref er to as speeches, staf f sucmittals to 13 the commission in terms of what we intended to do, have 14 continually exhorted the need for caution and care in l
15 deliberations.
16 It is my own view that we just simply have not seen much 17 on cost issues of the Reacter Safety 5tudy, and that wnere 13 the study has been invoked, tnere has been more than a 19 casual awareness of the limitaticns of any of tne numerical l
20 estimates.
l 21 Now we can't say that there haven't been some isolatd 22 examples where somebody has imoroperly used them. But viewing l
l 23 the record as a whole, we don't see any indication at all 24 that people haven't been aware of the lim itat ions that have 25 been talked a'out.
c ACE-FEDERAL REPORTERS, INC, (202)347-3700
756.03.3 41 gsh i
Now with regard to tne final i s s u e -- t ha t is, can you 2
use any of the estimates at all -- the statement basically 3
argues that you :an.
It is the best estimate in town if 4
you would, as I have heard it expressed, it does represent 5
the ir best estimate. It is clear that the uncertainty 6
bounds --
7 COMMISSIONER GILINSKY:
Whose statement?
3 MR. BUNCH:
The Reactor Saf ety Study estimates 9
were the best estimates they were able to do at t he t im e.
10 It is clear that the range of uncertainty that is identified
.11 in the Reactor Safety Study has been understated. The 12 review group has said that, and I think the staff agrees 13 with that, clearly agrees with that.
14 Whe re these seems to be a divergence of view is that in 15 the face of the statistical f aults can you regard the 15 reactor safe ty study as basically a usef ul tool in the face 17 of its deficiencies, or do you simoly have to say it can't 13 be used at a ll ?
19 And I gue ss I would characterite MP A's commentary to say 20 you ought not to use it until you have revalidated all o f 21 the principal ingredients of the reactor safety study. And 22 our view, as I would characterize it, is exercising due 23 caution, it is not only able to be ured, but it should be 24 used cecause of the additional persoective it provides.
25 I had indicated an this viewgraoh, one thing I would point ACE-FEDERAL REPORTERS, INC. (202)347-3700
42 766.03.9 gsh I
to you in the findings, and I will read it to you, one o f 2
the findings of the risk assessment r eview group is as 3
follows:
"The achie vements of N ASH-1400 in identifying the 4
relative importance of various accident classes has been 5
inadequately reflected in NRC's colicies.
6 "For example. WASH-1400 concluded that transients, sm a.11 7
LOCA, and human e rrors are important contributors to overall a
r is k.
Yet, their study is not adequately reflected in the 9
oriorities of either the re search or regulatory groups."
10 Now you can't make that conclusion if you don't be lie ve 11 that the numerical estimates o f a small LOCA probability, a 12 small transient probability and hunan errors have some small 13 validity.
If you don't celleve any of the numbers, you can't 14 ma'ke the kind of distinctions that the group made.
15 COMMISSI0 DER GILINSKY: I underst. cod Hal Lewis to 16 be saying that you could say sonsthing about the relati/e 1 */
importance of the effects, and also that parts of it were 13 succorted oy data and were, in eff ect, useful and could ce 1>
used.
But that taken as a whole, you could not a.ttach 20 s ignif ic ance to the summary numoers or the final numers.
21 MR. SUNCH:
Too mucn precis ion, yes, sir.
22 COMMISSIONER GILINSKY: I thought he was saying that 23 you could not say anything about thos e numbers.
24 MR. SUNCH: dell, a s I said, I'm no t s ure that 25 everybody that has read this recort comes away with the same ACE-FEDERAL REPORTERS, INC. (202)347-3700
43 136.03.10 gsh I
p e rc e p t io n.
What we have tried to convey in the statement 2
is our best judgment of wnat the posture ought to be.
If your 3
v ie w is, as you have just descrioed it, that if a fair 4
reading of the Lewis committee says, don't place any 5
reliance on the numoers, personally, I would not agree with 6
that.
7
.I think they are clearly increcise, but some use could be 3
made of them.
And as I say, we've nad some difficulty 9
understanding just exactly what the review grouc as a body has 10 tried to say.
11 MR. PEDERSON: On this point, you have to go to kind 12 of a little bit of the legislative nistory.
And in the 13 transcript of the meeting briefing which you have from Dr.
14 Lewis, Commissioner Gilinsky asked him prec'sely this i
15 question.
Well, I can read it to you.
16 Gilinksy said:
"Are you saying, in effect, that one can't 17 really make use of the integrated results that the only thing 13 you can really use are the relative crocaoilit ie s ?"
19 And Lewis says: "I ha ve to be careful about tnis because 20 I have lost the view which I once held.
As you may rememoer, 21 there is a sentence in the APS study to which I subscribed 22 at the time.
So we did not have confidence in the absolute 23 prcoabilities in WA5H-14CC, but we believed it had merit in 24 assessing the relative prooabilities of different a cc ide n t 25 change.
I am personally moving away from that position ACE-FEDERAL REPORTERS, INC. (202)347-3700
44
'36.C3.11 gsh I
because if one finds diff erent a ccident enains and one f eels 2
that -- let me just invent a t e rm -- t ha t the error band is 3
a factor of 100 on one of them, I don't see how one can 4
assess its relative importance compared to the other.
5 "But on the specific issue of whether I can learn anything 6
f rom W ASH-1400 that will enab)e me to say wnether a reactor 7
is. safe or not, I can't. I don't learn it from WASH-1400, 3
speaking for myself."
9 Now Lewis was very caref ul to say he was only speaking 10 for himself, but this is as close as we could find to the 11 legislative history, so to speak, in terms of what the 12 review group was get ting at.
13 Dr. Kouts did come in and indicate, ne was not sure he 14 would agree with that view in toto.
Jo one else at the 15 table indicated a contrary view.
l$
MR. SUNCH: And that is exactly the point tnat I 17 was trying to describe, because when we read the fifth 13 f inding, as I have indic at ed, we read the view that Dr. Lewis 19 seems to ce going away from, not the view tnat he expressec 20 in the meeting.
21 And the question is what view should the commission 22 adopt?
23 COMMISSIONER AHEARNE: dait a m inute. I did not 2A understand that. Say that again.
25 MR. DENT 0J: We nave difficulty reconciling that ACE-FEDERAL REPORTERS, INC. (202)347-3700
45 136.03.12 gsh I
part of the transcrir' which says that if you think the 2
error is so large tnat you can't really make meaningful 3
relat.ive judgments with the statement in the report that 4
implies that there are, o r tne re is an ability to distinguisn 5
between high and low contricutors to risk ar.d we refocused 6
our program on such things as human f actors.
7 CHAIRMAN HENDRIE I think if we form a group like B
this and put it to work to review a difficult subject, and 9
we form the grouo with some deliberation, it seems to me 10 the conmissicn did so form it to represent various points of 11 view.
And the commission proooses, then, to take very l
12 seriously the colle gial output of the grouo.
13 You stick to what the collegial view is.
And Hal comes 14 in and presents a particular point of view one day, that 15 is his personal opinion. I find it very difficult to say, 16 well, that rides down the work of a year of the group.
17 Carefully enunciated here in this document is in fact the 13 collegial view.
19 Each word, I susoect, was naro fought over.
And the 2D extemocraneous remarks of one of the members of the group, 21 I am afraid, simply can't stand against this.
22 COMMISSIONER 3RADFORD: The whole rest of the group 23 was sitting right here at the taole with him, and with the 24 exception of Herb Xouts, they did not say anything.
25 CHAIRMAN HENDRIE: Have you read the transcript of ACE-FEDERAL REPORTERS, INC. (202)347-3700
4 i
796.03.13 46 gsh I
Hal at the ACRS meeting?
I reconnend it to you.
It doesn't 2
have the same tone at all.
it is a good deal more positiva 3
discussion of the re suits.
4 COMMISSIONER BRADFodD:
Does It back away f rom 5
that view?
6 CHAIRMAN HENDRIE: I would say, on balance, yes.
7 I recommend it to you.
3 What I simply point out is that I simply am not co ing to
?
give we ight to individual comments of memoers of the group 13 aga in st the collegial views carefully fought out and 11 agreed to and writtan down in tnis recort.
12 Now to the extent that one has dif ficulty in parsing, as 13 there are, indeed, difficulties crecisely what the collegial la view means, okay.
That is f air game for argument, and l
15 indeed, the commission ultimately will have to make up its 16 own mind over a set of words which, egain, will recresent 17 certain compromises.
IS I think I suspect that if we deal here at the table, for 19 instance, with a piece of testimony and we agree on wna the 20 collegial language of the commission is, and then I go off 21 somewhere and make remarks of my cwn which represent exactly 22 what I think ought to be done, you would all take consideraole 23 umbrage at having somebody quoting to you the chairman's 22 remarks snd ne ver mind that collegial statement.
25 And I recommend the same view here.
ACE-FEDERAL REPORTERS, INC. (202)347-3700 4
..n.,
47 786.03.14 gsh I
COVMISSIONER AHEARNE: I'm sure you are winning or 2
losing your position, Joe.
3 COMMISSIONER BRADFORD: If you did that before the Congress and we were all si.tting there, we would speak.
4 5
COMMISSIONER GILINSKY Well, wnat does the report 6
say about absolute numbers. I mean, how close does it come 7
to dealing with absolutes?
3 COMMISSIONER AHEARNE: It really doesn' t.
I mean 9
the ouote Del gave is really from the findings on the 10 relative imoortance.
1 11 COMMISSIONER GILINSKY: Why shouldn't we direct 12 this cuestion to the group, then?
13 CHAIRMAN HENDRIE I'm not sure you can get it to reconvened.
I'm not sure you can get it re co nve n'ed.
15 COMMI SSI0 DER AHE ARNE : You could get a poll of the 16 individual members.
I do n't think you could get the group 17 to come together for any length of time, since it is such a 13 significant Lssue.
And it is, rea lly. I thLnk, and Del 19 is ouite correct.
I've gone tnrougn this thing many times 20 and I can't find that.
It might be useful to cose a question 21 to the members.
22 COMMISSIONER GILINSKY I believe that the report 23 says that the error balance is understated by an amount whicn 24 they can't estimate.
25 MR. SUNCH: That is correct.
ACE-FEDERAL REPORTERS, INC. (202)347-3700
48
.736.03.15 gsh I
COMMISSIONER GILINSKY:
Which leaves the question 2
pre tty much open.
3 MR. LEVINE: Mr. Chairman, I'm sorry to interrupt.
4 There was a question asked about what the Lewis report says 3
about absolute versus relative probabilities.
And while the 6
statement doesn't address it quite that directly, I think one-7 can draw considerable ins ight to the meaning.
3 COMMISSIONER AHEARNE: Saul, can you use the mike?
9 MR. LEVINE: One can drew cc siderable insight into 10 the collegial meaning of the grouc from one of the il recommendations.
It says, in general, avoid the use of 12 probabilistic risk analysis methodology for the determination 13 of absolute risk probabilities for a subsystem, unless an 14 adequate data base e. cists and it is possible.to cuantify 15 the uncertainties.
1$
It goes on to say, however, the methodolo y can also be 17 used where cases in which the data base would only su pport 13 a bounding analysis and for other cases in the aosenc e of I?
any be tter.information if the results are procertly 20 qualified.
21 I think that is a direct answer, almost a direct answer 22 to the question.
23 COMMISSIONER AHE ARNE:
I don't think so, Saul. I 24 think it leaves the interpretation I would place en that --
25 is that it is addressing the metnodology and it doesn't speak ACE-FEDERAL REPORTERS, INC. (202)347-3700
49
'86.03.I6 gsh I
at all to the quantitative value.
2 MR. LEVI:122 It is addressing tne acclication of 3
the methodology but not for overall risk asse ssments.
4 COMMI SSIONER AHE ARiiE :
That's right.
Sut it is 5
saying the machodology, application of the methodology.
I 6
see that as a future 'looking.
When you apply this method.
7 not the data or the numbe rs, out o f W ASH-1400, but rather,
,3 3
the method.
9 10 11 12 13 14 15 16 17 13 19 20 21 22 23 24 25 ACE-FEDERAL REPORTERS, INC. (202)347-3700
004E-4&E(COC) 'ONI oS83180d38 7V83G33-30V l,
syn pue
- UsJs;Jip yont si ;si no4 ;ey; uoi;ebedcJd Jolds Jo 92 Jos sig; Eseo Je ;ei su; vi asy; ano quiod et ;e7 rg Aex ;ey; ao Lex sty; ;uswdinos gg n
su; on $uiuiI woJ; s%sia sy; saedwoo TITx ex pue
- A$ot opoy;st 22 swes sy; pue eseq egep eLes ey; esn Itix en *xou *TTsMn
!?
'fuTAes pue ;ey; usex;ec soveJ8;;ip e e; Tnt s,saeyl C?
'uosiaeouco e 6i CJc; o; Aex Ou6as;;ip ;euxsCos e ui suop sousnbss Jsy;oue woJ; El Jeoenu asTJ Jaynoue o; ney; ;o ci;e4 sy; tao; pue Aex vie:aso L1 s ui suop sousnoss Ouepicoe sty; woJ; s; sci;ss %s;J e;nTos4E 91 ve buiae; usex;sq *etsyos sioux sy; s%TT ;<uop ao awayos 91 sToyx sy; s%T T noA asu;eyx *eousas;;ip swos si sJsqq ;ey; 71 e;ou c2 s%TI PTnox I *sei;TITqeqcad SAT;elsa Jo uoissnosip Cl au; ca a;ougoo; e se
- Aex sy; AE
- 318CN5H NYWEIYHD 21
- AI;usas;;Tp ;i pesJ l1 pue s6uiq: sy; s%en ueo noA ney; *;uiod s,Itag AT;oexe s;e 01
] pue noX usex;eq saustse25erTp sy; zuTy; I pus 'AboIopoyask 6
sy ssn ueo noA s^es ;I 3 3MBYEHY E3HOISSIh% 00 E
- eseq L
egep e;enbspe ue'saey non JT suoT;oTPeJd A;TTTqeqoad %sia 9
s;nTosos ao; weqq esn ueo noA sAes ;I
- 5 PIA 37 *SH g
n saequnun y
sAes ;T easyx ses 2,uop I 23N8VEHY BENDISSIWWOD E
- sasqwnu GAT;e;T;uenb 2
Jo esn ey; o; BuilJs;sa si ;I
- SPIAE7 *BW l
^d
!
- 99<
Og
v 51
'736.04.2 pv i
f irs t order, probably there are uncertainties in the data 2
case, and sort of the f irst order dis a ppears.
3 COMMISSIONER AHEARNE:
It is certainly much le ss o f 4
a problem.
5 CHAIRMAN HE NDRIE:
But that is really sort of a 6
footnote.
7 The hour wends toward J i:CO.
It seems to me that 3
topic 5 has been sxercised some.
It seems to me that enougn of these do uments have arrived recently enough so tnat the 9
c 10 discussion, while useful in exercising various points of view, 11 is not going to come to completion this morning.
In fact, i 12 have a Commissioner who says he pref ers to read the documents 13 than come and discuss them -- vnich is f a ir enough.
14 So, I propose to adjourn tnis discussion at this 15 point, and the secretary will reschedule and get it back on 16 the docket.
17 COMMI5SIONE' AHEARNE:
Could I ask a cuestion?
13 CHAIRMAN HENDRIE:
Sure.
is COMMI SSIONER AHEARNE:
de nave a memo from one of 20 the members of the staf f, calling to mind a le.tter to 21 Senator Gle'nn in December of '76 as being one of the 22 statements or items that might fall into the que st ion.
I 23 found that it was not listed in our list from our 24 congre ssional of fice and did not have time to go through your 25 backup material.
Is it in that?
ACE-FEDERAL REPORTERSr INC. (202)347-3700 4
t 52 i.
'36.04.3 pv-1 MR. DENTON:
I think I re f e rre.d to that le.tter in a 2
transm ittal meno, but I am not sure that we have list ed memos 3
to the Comm i ssion.
J COMMISSIONER AHEAR?lE:
This is a letter to 5
Senator Glenn.
6 MR. CEtrTON:
In our list of uses of 1400 in this.
7 we.did not include any of the Commiss ion's correscondence 1 is S
that correct. Dell?
9 MR. BUNCH:
That i s co rrect.
10 COMMISSIniiER AMEARNE:
No.
Ma it.
The 1ist of Il things that you have in here incluces things to Congre ss.
12 MR. SUNCH:
IF I might, let me clarify what is in 13 that list.
What we have done is cite the corresocndence that 14 acpears in the package by Vr. Kammerer, and we have cited tne 15 correscondence that accears in the oackage by Mr. Rederson.
15 What we have not done is included those soecific letters in 17 our rack-uo.
If the sta f f ident ified cert ain letters, like 13 the Glenn le tter, on their cwn, we nave included those.
19 COMMISSIONER AHEARNE:
So, are you saying tne Glenn 20 letter is included?
That was really my cuestion.
21 MR. BUNCH:
I celieve it is.
I have got a copy o f 22 it here.
And I think it should oe in the list.
But we will 23 have to check anc make sure.
What was the cate again?
24 COMMISSIONER AMEARNE:
December 9 1976.
25-MR. DENTON:
Just to ce clear, this taole that ACE-FEDERAL REPORTERS, INC. (202)347-3700
..-.--9.-
e
s.
53 756,04.4 pv i
categorizes the actions --
2 COMMISSIONER AHEARNE:
I was not l oo k ing a t the 3
chronology; I was really looking at the long list of category 4
1, category 2, category 3 issues.
5 MR. DENTON:
In that table we only included those 6
that we received from, I would say, the EDO-tyce o f fices, and 7
the other two of fices -- Ken and Carl's -- we just identified 3
as a package.
9 COMMISSIONER AHE ARNE:
Mell, this particular letter 10 accarently was a le tter f rom the EDO o ff ice.
11 MR. DENTON:
Let me eneck.
12 COMMISSIONER AHEARNE:
Could I get a copy of tha:?
13 MR. SUNCH:
Yes. sir.
14 COMMISSIONER AHEARNE:
That was more factual.
15 MR. DENTON:
Let me also mention that we nave given 4
16 the PDR a copy of the voluminous in f o rma t io n that is referred i
17 to here. so that should be available downstairs.
13 COMMISSIONER 5R ADFORD:
in the category of sort of I?
an exoeriment showing now long 1 takes me ssages to get from 20 our head to our shoulders, le: me just read scmething from the 21 Office of Administration Report for the week ending Decemoer 1
22 1.
This is an FOI A request, resconse to a recuest for the 23 Atomic Energy Commission reports on tne safety of nuclear 24 generators, to make availaole to the recuester a copy of the 25 execut ive summary of WASH-14C0 and inform them of other ACE-FEDERAL REPORTERS, INC. (202)347-3700
~--
n 54 "57.04.5 pv i
documents in the PDR.
2 MR. GOSSICK:
I just neard about it this morning.
3 Comm i.ss ione r.
4 COMMISSIONER BRADFORD:
And yo u a re c u.i te r igh t.
5 I am not sure what haocened.
6 MR. REHM:
Just -- this is subjec t to othe r 7
interpretations.
I would like to check it out.
3 COMMISSIONER BRADFORD:
For e xample, it is possiole 9
that it can be interpreted as being a request for AEC 10 documents.
11 MR. REHM No, sir.
It's possible the otner 12 documents were documents other than the Lewis report.
13 CO MMI SSIONER BR ADFORD:
Well, the problem is that 14 all the Commissioner got was a copy of the executive summary 15 of WASH-ldCO.
16 MR. REHM*
That, I would like to verify, 17 Co mm i ss io n e r.
IS MR. 00SSICK:
We will chec k it out.
It clearly 19 should have been so stated.
20 COMMISSIONER AHEARNE:
I would po int out. Tem, if 21 he got more, all we are reacting to is the paper that came up 22 to us.
23 MR. GOSSICK:
It should have stated that.
24 CHAIRMAN HENDRIE:
Well, you know, if a cerson 25 submits an FOI A request for tne executive summary, and we ACE-FEDERAL REPORTERSr INC. (202)347-3700
+5 55 786.04.6 pv i
aren't quick to deny it to him.
2 01h e r e upo n, at 11:00 a.m.,
the meeting was 3
recessed, to be reconvened at 11:01 a.m.,
this same cay.)
4
=
5 6
7 8
9 10 Il 12 13 14 15 16 l
17 IS 19 20 21
-t 22 23 24 25 ACE-FEDERAL REPORTERS, INC. (200)347-3700 e -,