ML20151C345
| ML20151C345 | |
| Person / Time | |
|---|---|
| Issue date: | 07/14/1988 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1680, NUDOCS 8807210324 | |
| Download: ML20151C345 (80) | |
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NUCLEAR REGULATORY COMMISSION 2.....................................................,..,
In the Matter of:
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339 th ACRS GENERAL MEETING )
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MORNING SESSION O
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July 14, 1988 o........e...............................
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HERITAGE REPORTING CORPOR12ON ln on"* w v
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1 PUBLIC NOTICE BY THE
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2 UNITED STATES NUCLEAR REGULATORY COMMISSION'S 3
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
5 6
7 The contents of this stenographic transcript of the 8
proceedings of the United States Nuclear Regulatory 9
Commission's Advisory Committee on Reactor Safeguards (ACRS),
10 as reported herein, is an uncorrected record of the discussions 11 recorded at the meeting held on the above date.
12 No member of the ACRS Staff and no participant at 13 this meeting acceptc any responsibility for errors or 14 inaccuracies of statement or data contained in this transcript.
()
15 16 17 18 19 20 21 22 23 24 25 Heritage Reporting Corporation O
(202) 628-4888
4 1
1 UNITED STATES NUCLEAR REGULATORY COMMISSION 2
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 3
4 In.the' Matter of:
)
)
s 339th.ACRS MEETING
)
6 I
- Thursday, July 14, 1988 Room 1046 1717 H Street, NW Washington, D.C.
20555 11 The above-entitled matter came on for hearing, 12 pursuant to notice, at 8:30 a.m.
13 BEFORE:
DR. WILLIAM KERR:
Chairman
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14 Professor of Nuclear Engineering Director, Office of. Energy Research 15 University of' Michigan Ann Arbor, Michigan 16 ACRS MEMBERS PRESENT:
17 DR. HAROLD W.
LEWIS I
18 Professor of Physics Department of Physics 19 University of California Santa Barbara, California 20 MR. CARLYLE MICHELSON 21 Retired Principal Nuclear Engineer Tennessee Valley Authority 22 n
Knoxville, Tennessee, and, s<
Retired Director, Office for Analysis & Evaluation 23 of Operational Data U.S.
Nuclear Regulatory Commission 24 Washington, D.C.
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2-1 ACRS. MEMBERS PRESENT~(Continued:)
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2 DR. PAUL G.
SHEWMON.
Professor, Metallurgical Engineering Department:
3 Ohio State > University
. Columbus, Ohio 1 DR. CHESTER'P.'SIESS 5
. Professor Emeritus of: Civil Engineering.
University of Illinois-6 Urbana, Illinois I
7 MR. DAVID'A. WARD
.)
Research= Manager on Special Assignment-8 E.I.
du Pont de Nemours,& Company Savannah River Laboratory 9
Aiken, South Carolina
.l 10 MR. CHARLES J. WYLIE R
Retired Chief Engineer 11 Electrical Division Duke Power Company 12 Charlotte, North Carolina 13 MR. JAMES C.
CARROLL v
14 s
ACRS COGNIZANT STAFF' MEMBER:
15 Dean Houston 16 Raymond'Fraley, Executive Director H.
Stanley Schofer, Technical Secretary
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17 NRC STAFF PRESENTERS:
18 Themis P.
Speis 19 20 21 I) 23 24
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2 DR.'KERR:
The meeting will come to order.
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This is the first day of the 339th-meeting of the
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4 ACRS.
During the meeting today we plan to discuss the NRC v
5 staff's integrated plan for closure of severe accident is-i 6
sues, future ACRS activities.
The discussion that we are to l
7 have with the Commissioners in the afternoon, we'll spend 8
some time discussing that just before lunch.
And we then j
9 will meet with the Commissioners at two o' clock,'if I remem-10 ber correctly.
Af ter that we will have a closed :s -ating at f
11 the White Flint building to discuss the ECCS proposed rule 12 changes and the evaluation --
/
13 DR. SIESS:
Are we going to meet out there?
I 14 DR. KERR:
We're going to meet out there.
15 DR. SIESS:
A good reason?
16 DR. KERR:
Well, we will be there and so will the i
17 staff.
They asked that we meet.there and we agreed.
i 18 DR. SIESS:
'I think it's a poor precedent, but j
i 19 that's all right.
20 MR. WARD:
Do you hear that, Ray?
21 MR. FRALEY:
Yes, sir.
I 22 DR. SIESS:
I admit we did that once out at Ger-()
23 mantown, Ray.
We met with the Commissioners out there while 24 Schlesinger was chairman and then we stayed over for another
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25 hour2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> and listened.
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DR. KERR:
Once every twenty years is enough you 2
say?
3 DR. SIESS:
Yes.
They had a presentation on FFT 4
'if,I remember.
5 DR. LEWIS:
Let the record show that I agree with 6'
Siess.
This is an historic event.
f 7
DR. KERR:
Items for discussion tomorrow are listed 8
on the bulletin board in the back of meeting room.
The meet-
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9 ing is being conducted in accordance with the law, applicable 10 rules and regulations of precedence.-
11 Mr. Raymond Fraley is the designated federal of--
12 ficial for this part of the meeting.
i 13 We have received no written statements or requests 14 to make oral statements from members of the public.
f 15 I call your attention to the reorganizations of 16 the month which include a rather significant reorganization l
17 at the TVA, representing a rather large cut in personnel.
18 One of the things that has occurred'is the number of people 19 reporting to Mr. White, I believe it is, has been decreased 20 significantly.
And there h' ave been delays and postponements i
t 21 of some of the nuclear plants.
l 22 The details of this are available if you have not 23 yet seen a press release or a report.
I suspect most of you 24 did.
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25 There has also been a recently implemented 7
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'l reorganization of the Office of Research and-there is avail--
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.2 able details on the newly reorganized offices and. office
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3 directors.
4 The move to Bethesda11s.now scheduled for. August 5
26th, so it apparently is remai'ning-at about a' month ahead 1
6 of any particular date, _so-I don't know whether.to. predict 7
if it's August'26th.
Or September 26th cr not..
But'at'least' 8
I'm told that the ccafidence in this date is somewhat higher 9
than some of the earlier dates that-have been announced.
10 Yesterday a subcommittee met with members of'the 11 staff to discuss SECY-88-147, if I remember the number. cor-12 rectly.
Which is Integrated Plan for Closure of the Severe
-Q 13 Accident Issues.
We had I think a good bit of communication L;,m, L/
14 during the course of the meeting and a rather wide range of 15 discussion.
16 In the scheduled time today I asked Mr. Speis who 4
1 17 led the discussion yesterday and whoserespon'sibility I think 18 the organization of thig integration is, to give a brief 19 summary of what was presented yesterday and >1 eave: a good bid 20 of time available for questions.
21 A number of committee members were present at 22 yesterday's meeting.
I would ask if there are ar" further O
23 comments before we turn things over to Mr. Speis.
24 Mr. Spels, the floor is yours for whatever presen-O 25 teti = v u c " iaer ever eriete-Heritoge Reporting Corporation m **.=
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MR. SPEIS:
Good morning, Mr..Chai' man, members..
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I assume that'I will cover two areas that I didn't f-)
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get a' chance to cover-yesterday.
I'll start with that?
4 DR. KERR:
Yes, sir.
5 MR. SPEIS:
And then proceed to cover some other 6
subjects.
7 DR. KERR:
That seems appropriate.
8 MR. SPEIS:
Okay.
So I have. kind of a brief sum-9 mary of the Containment Performance Improvements Program 10 which is described mostly in SECY-88-147.
As I said yester-11 day, this is the effort that was initiated a year and a half 12 ago or so after Chernobyl.
Bornero was the Division Director 13 of the BWR Division who started this effort.
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t 14 If you recall, we told you last fall that after 15 Bornero put the initiative together and a number of so-called 16 improvement for MARK I containments, we called together all 17 the experte fron the laboratories, from the universities, 18 and they had a lot of difficulties with some of the tet.inical 19 areas and we did the same thing--we-had a meeting with indus-20 try and the views were wide ranging ~about the technical i
21 efficacy, whether there was a need and so on and so forth.
22 SO what we decided was to study it some more.
Like any good
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5 23 bureaucrat would do after getting into difficulties.
24 Back in December of
'87, we sent the Commission a
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25 SECY-87-297 where we laid out the plans for containment Heritage Reporting Corporadion nunnam
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performance ~ improvement.
At.that-time we told the.Commi'ssion 2
q that we would give them an interim report this summer and our V
3 final recommendations by the end of this year.. And that'is
'4 the schedule that we are working on right now.
5 Again, the. background.-
The initial effort was 6
focused on MARK I, but the-program includes all-containment 7
. types and again, recommendations will ba made to the Commis-8 sion on all containment types by the end of next year.
9 The essence of the program is to evaluate the.
10 generic challenges to containments, understand the failure 11 modes and also look at the potential improvements that_can 12 be made to mitigate or lessen the challenges'of the severe 13 accident to the containment.
14 The status for the MARK I program right now, I 15 have briefly summarized in this Vu-Graph.
We are pursuing an 16 approach that involves both accident prevention and mitiga-17 tion.
We are looking at a number of things.
For example, 18 under accident prevention, we are looking at accelerating the 19 implementation of the station black-out rule.
We are looking 20 at fire water to the residual heat removal system.
We are 21 looking at what can be gained by hard --
vents to depres-22 surize.
We are looking at improvements to emergency operating 23 procedures.
24 Under accident management, we are also looking for O
25 some f the same things.
Improved vents.
Improved emergency Heritage Reporting Corporation m mm.
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1 operating procedures.
And under= accident mitigation, we are.
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.also looking at additional 1 sources of water to'the sprays.
3 Also vents.
4 So some of these things that-we're looking a lot' 5
between prevention, accident management and mitigation.
6 We are undertaking a regulatory analysis to see 7
how those things stack against the backfit policy.
If you 8
recall in this SECY-88-147 that we are reviewing right now, 9
on page 18 it says.that in addition to the regulatory analy-10 sis, what we'll be doing to evaluate some of these so-called 11 improvements.
12 There's a statement there that says "However, 13 specific plant and operational improvement psy be identified
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14 which do not meet the backfit rule, but if implemented would 15 significantly alter the risk profile of the plant, improve 16 the balance of reliance in both prevention and mitigation or 17 substantially reduce uncertainties in our understanding.
Any 18 such improvement identified will be brought forward to the pp Commission with recommanded action on a case-by-case basis."
20 So it is possible that out of that assembly of. things that I 21 mentioned earlier, some of them might not quite fit the past 22 regulatory analysis muster,~but we might decide that some of O
23 these things make sense in light of what I just read, and 24 make recommendations to the' Commission.
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25 Now, this program will come to you before it goes Heritage Reporting Corporation onm
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.3 you and come and tell you what~are our conclusions as far as s.
4 what MARK I's improvements-are.
5 Again, thisois the schedule'so that's all I have-6 to say on this subject here.
7 I'm ready-to go to the next one.
8 DR. KERR:
Are there questions on this particular--
9 Please' proceed.-
10 MR. SPEIS:
Is there anything else?
Oh, I-think 11 they all know about the Baltimore meeting.
ACRS has a repre-12 sentative there, so--
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13 In the package there is a Vu-Graph that summarizes--
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y we had a workshop in Baltimore to go over'some of the-techni-15 cal information to see what are the views on the failure modeF 16 and potential improvements especially the question of the I
17 liner that has assumed quite a bit of notoriety and the next I
18 Vu-Graph kind of summarizes those things.
19 Let's go to the LWR.
20 DR. KERR:
Let me make one comment.
21 MR. SPEIS:
Yes.
22 DR. KERR:
During the discussion yesterday at the O
23 subccmmittee a point was'made, if.I understood it correctly, 1
24 that the staff might find situations in which even though a
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25 plant or class of plants seem to meet. the safety goal, they Heritage Reporting Corporation imm =
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I guess Ilhad not realized w
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Did I misunderstand? -
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I did not say that' I said regulatory
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3 DR. KERR:' It was Sheron who made the"statement 6
I thought, but correct what I said if it's incorrect.
7 MR. SPEIS:
I think this thing says Backfit Policy 8
and Regulatory--Backfit Policy.
Even though it might not 9
mean Backfit Policy, we might still have to recommend.
go Those things-are not one for one.
It's possible 11 that you recommend something which is outside the bounds of 12 Backfit Policy--
13 DR. KERR:
No.
I was not referring to that.
That
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But I did not-realize before l
15 yesterday that the staff felt there might be cases in which i
16 even though a plant ostensibly met the Safety Goal, they 17 would feel responsibility to recommend improvements.
18 MR. SPEIS:
Well, that's kind of a little bit ab-19 stract, because right now we haven't decided how to implement 20 the Safety Goal.
We haven't defined yet what is the large i
21 release, for example.
22 DR. KERR:
Yeah, it is--
0 23 MR. SPEIS:
So there's an abstraction'to it.
24 DR. KERR:
It is an abstraction, but it is an
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2 MR. SPEIS: 'Well, I'want to make sure'I un'derstand 3
what Brian said.
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DR. LEWIS:
I sympathize with'what Billisaid. There 5
are two issues.
One is, you know, we have written letters I j
6 believe saying that one should n'ot-use the Safety' Goal as a-7 judgement criteria.on' individual plants, I think we have l
-8 sent off such letters.
9 MR. SPEIS:
We agree with that.
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10 DR. LEWIS:
Pardon?
11 MR. SPEIS:
We agree with that.
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12 DR. LEWIS:
I see.
Then how can you say that in I
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14 DR. KERR:
No, I didn't say that.
A class of i
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I 16 DR. LEWIS:
Oh, a class of plants, 17 DR. KERR:
Yeah.
18 DR. LEWIS:
- Okay, In that case, what use is
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39 Safety Goal?
i 20 MR. SPEIS:
I want to make sure that I know what i
21 Brian said because what I said and what is written down there, 22 it says, beyond the regulatory analysis.
23 DR. KERR:
No, what you said is another question, s
24 and I don't--I mean I think you have expressed that before and
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25 I think the staff has expressed that before.
There might be J
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of cost benefit, you'd still'want to'do it.
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I had not heard the other statement before.
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'4 MR..SPEIS:
The'other. question is the Policy-State-5 ment the' Commission told us to'try to. strive for a balance 6.
-between prevention and mitigation.
7 DR. KERR:
Yeah.
8 MR. SPEIS:
How you achieve that and--
9 DR. LEWIS:
But the whole idea of the Safety Goal to was to find a basis 'for deciding when enough is enough.
When 11 safe enough is safe enough.
And we have heard many different 12 things by the staff on the interpretation of that.
In parti-()
13 cular, I remember somebody, and I think-I wrote a dissent on 14 that one.
It came to us, and said, "Gee, if we know a way 15 to improve the safety of-a plant, we are going to do it."
16 And the Safety Goal was intended precisely to get rid of that 17 criteria.
18 And that's another thing that's not quite closed 19 yet.
The implementation of the Safety Goal.
If you look on 20 page 25 of this SECY, you see a number of accidents that we 21 have to go through this summer.
One of them is the Safety 22 Goal paper that's due to the Commission at the end of August.
O 23 And we'll be scheduling some meetings with you to discuss 24 that.
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I'm not 2
sure.
3 MR.-SPEIS:
Well, we'll get a chance to spend the whole' day just on the Safety Goal so I don't'want to say any 4
5 more about it.
6 I want to say a few things about future LWRs.
If-7 you recall also the Policy Statement told us to develop 8
guidance or criteria for' how to treat severe accidents-in.
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9 future LWRs.
And also in SECY 88-147 we kind of summarize 10 of what--again, this is another action that we owe the Com-gi mission by the end of July, by the way.
12 What we would like to do is clarify to the extent 13 possible what the requirements for severe accidents should t
14 be for both the industry and for the staff itself.
15 Go to the next Vu-Graph.
16 This is just for completeness.
At the present 17 time the LRWs that are on the NRC's menu is the advanced 18 boiling water reactor.
The combustion engineering 80 plus 19 and the Westinghouse SP-90.
And then we have the passive 20 LWRs.
And this is the 600-megawatt.
And, of course, these 21 are the advanced from DOE and we would have been interacting 22 with you separately.
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what I'll say towards the advanced or future 24 LWRs--so again, the question is what type of--can we avoid O
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And-that is the area that we are attempt-
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5 Again, you know--so.let's go to the-next-Vu-Graph.
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We have some idea of how to 'o it and we met with.
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. industry also on June lith to' discuss some of those~ ideas.
8 What I have here is a number of-options of how to treat a
9 severe accidents in advanced LWRs.
And the first option 10 would utilize the general statements in proposed 10 CFR-52 11 which deals with' standardization.
This is something that'has 12-gone out for public comment.already.
13 The only thing that we will have there, we'll-have v
14 a regulatory guides.on the performance and content of a PRA.
15 We are not going to say anything specific about severe acci -
16 dents, but we would let the certification hearings come to 17 grips with that.
You know, the' staff will present its posi-18 tions at that time and the certification process itself will 19 decide what the severe accidents requirements would be.
20 MR. MICHELSON:
I have a little trouble with that 21 comment.
22 Mk. SPEIS:
With the comment or--
23 MR. MICHELSON:
It leads me to believe that you j
I 24 are not going to deal with severe-accidents until you get to
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write off on the FDA'that the certi ication is.a*public kind
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with its-input, isn't it?
4 MR. SPEIS:
Yes.
But this--
5 MR. MICHELSON:
Well, if the staff hasn.'t even 6
considered severe accident up to that point, how does th'is 7
work?
8 MR. SPEIS:
We're not going to have a separate 9
rule but this is going to be a rule here.
The outcome of 10 this will be a rule--
11 MR. MICHELSON:
Well, I understand that, but the 12 certification process was not snposed to be introducing any 13
-new technical questions.
If I. understood it correctly.
U 14 MR. SPEIS:
Yes.
But the hearings to come'to 15 certify this particular design, at that time the decision 16 will be made about what would the staff's requirement-would 17 be.
18 MR. MICHELSON:
But the staff is-going to have to 19 treat severe accident much earlier than that.
20 MR. SPEIS:
Yes.
But the certification will be 21 done at this point in time, i
22 MR. MICHELSON:
In the case of the BWRs'right now.
O-23 MR. SPEIS:
The certification will be done at this 24 time.
25 DR. KERR:
What was that word?
The what?
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1 MICHELSOh:;
Cer'tification, indeed. Will be'done E
2 MR.
O-then but the technisal is all done before the certification 3
L-4 process even starts.
DR. KERR:
I mus't admit I don't understand that-3 6
Process, Carlyle.
MR. MICHELSON:
Well, that's my understanding at 7
g least, which I see nodding of heads to verify.
Therefore, 9
the severe accident questions must all be raised as the. in-dividual modules are written off, as I see.it.
Because I' 10 don't find a module that says severe accident.
gg MR. SPEIfe:
Cecil, do you want to say something?
12 MR. THOMAS : C e c i l T h o.m a s.
You are right, Carlyle.
13 DR. KERR:
Excuse me.
Is that thing on?
g, M9. THOMAS:
Cecil Thomas,~NRR.
You are right.
15 16 The conside ation of severe accidents will occur during the review process.
The certification n=rt is really a hearing 17 r a procedure that codifies what ccmes out of it.
18 MR. MICHELSON:
So we need guidance or whatever 39 20 n w, nt four or five years frota now on this issue.
d MR. THOMAS:
You need it prior to the start of 21 I
the review.
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MR. MICFELSON:
You need it prior at least to the 23 writing off of the first modules that might be affected by 3
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MR. THOMAS:
Ideally, yes..
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Yeah.
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Brad,fdo you want to~ add some-more
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clarification?
5 MR. HART:
Bra'd-Hart,.from Research.
6 DR. KERR:
I'm sorry.
What was the.name?
7 MR. HART: Brad Hart from Research.
8 I just wanted to commant that t'ais table was pre-9 pared based on some preliminary conversations that we've had to with the staff.
And it's intended to display some. options 11 that we've seen that really haven't neen finsife.sd in any way.
12 So in looking at C'cion 1, it just happens to be one of'the 13 particular cptions that we - feel could be implemented here.
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14 MR. MICHELSON:
I'm only commenting that I' don't 15 think it's even a viable option under the present process..
10 MR. SPEIS:
We don't disagree with you.
This is 17 just an option.
We haven't made any recommendations.
I 18 should have said that.
In fact, this is at the branch chief 19 division director level at this point in time.
But this is 20 what we're thinking right now, okay.
21 The next option will have a rule, two rules, in 22 fact.
One of them will be a procedural--there is such a rule O
23 already, 10 CFR-50, but we're revising that.
That rule deals 24 with those seven cps that were anticipated to be --
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But anyhow,,we'llLhave re-(~
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It will V) 3 say that every plant in the future should'have a PRA and a 4
few other things..<And the' REG guide wil'l spell out what the z
5 details of that will be.
6 In addition, we'are-thinking ~of'another rule that 7
will deal--addreFJ general and keep in mind the word "general.'
8 General performance requirements to consider margin in the 9
design to prevent or accommodate severe. accidents.
10 Again, here--
Il MR. MICHELSON:
Let me ask you, if you are talking 12 rule, which you are in this case, you are talking about some-13 thing which takes a couple of years to get through the process v
14 doesn't it?
15 MR. SPEIS:
Right.
16 MR. MICHELSON:
And the reviews are going to be 17 done by the time this is even through the process. The review l
18 of ABWR, tha t is.
So what do we do for ABWR?
19 MR. SPEIS:
Brad, what's the answer?
20 MR. HART:
That's a good point, that we've been 21 wrestling with that.
And we have set up a schedule in which 1
22 we are attempting to have these rules and REG guides in place 23 before the design certification starts oc the three lightwater 24 reactors that are currently in house.
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25 In addition, another thought is that if we can get
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c?'en. that ~ time, it would be useful.
And so this is the' 3
' basis that we're operating.under.
4 MR. MICHELSON:
It may be that in the case of:the 4
5 ABWR we'll have'to putJsevere accident /as tihe jast' item on~
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the schedule before.-final write off.
Like I think the PRA-i 7
is near the last' item on the schedule-right'now.
I think the 8
severe accident is going to have to be purposely put at the 9
end of the.whole schedule.
Then-by then you may have this 10 dialogue completed.
That's one thing we:can' entertain.
I 11 MR. WARD:
This is a dialogue between who?
i 12 MR. HART:
Well, it's been going on in the staff 13 now for scme months and we had a public meeting also'on June-U 14 9th to start to get some dialogue among the industry and i
15 the public as well.
16 MR. SPEIS:
The only thing I want to add to this-6 17 point here is that we don't anticipate changing the design l
i j
18 basis.
We are talking about going beyond to make sure that j
19 the plan itself as margins to accommodate or be able to miti-j 20 gate some of the more likely events that emmanate from severe 21 accidents.
22 MR. MICHELSON:
It certainly affects the design O
23 from the beginning.
It can affect it from the very be-l 24 ginning.
O 2s "a
ses's:
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Heritage Reporting Corporation I
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DR. KERR:
Mr. Speis,'in the second option, it 2
is referred to under "comments" as an IPE type of approach.-
O-3 Now, it was my impression that the IPE was an effort to 1ook
~
4 aa individual plants andtit'was. felt necessary because ex-
~
5 perience has indicated that"individual plants out there now 6-differ widely one from the other.: I don't quite.see-the 7
point in an IPE approach where one has a standard' design which 8'
includes'just about everything being'identic'l..
a 9
MR. SPEIS:
I think it 's meant that--don ' t take all 10 Vu-Graphs as gospel.
But it's meant.just a. general examina-l 11 tion of the plant itself, the design to make sure that.it has l
12 margins.
I 13 DR. KERR:
Something in addition to a PRA?
{
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14 MR. SPEIS:
Yes.
Well,. the PRA will tell-you what
[
f 15 the plant vulnerabilities are, what the risks are, to what 16 extent it can or cannot accommodate severe accidents, es-i 17 pecially some of the more likely sequences and then make sure i
18 that the plant has some margin, okay, to do that.
And you 19 are right.
When you are looking at an existing plant, it's l
20 not the same thing.
So it's not appropriate.
21 DR. KERR:
Let me ask you another question.
22 Currently the design of containments--
7-V 23 MR. SPEIS:
The design of what?
24 DR. KERR:
The design of containment systems--
()
23 MR. SPEIS:
Yes.
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LDR. KERR:
Is based on a consideration of > the' s
2 design basis accidents.
Is that going to be the case for O
3 advanced reactors as well?
(
4 MR. SPEIS:.Well, that is-something that we haven't 5
worked out-the. details, okay.
4
, ell, that's a pretty iniportant ques-6 IMR. KERR:
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7 tion.
It seems to re--
c 8
MR. SPElS Well, I think-the next two months
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9 we're arguing about that.
For example,eas I<said yesterday, i
l 30-you have a containment which is designed.for a design basis gi load and then you do a best estimate analysis and you find 12 out that--
l 13 DR. KERR:
Look, I understand the situation for 34 existing plants better than I understand for new plants.
)
15 MR. SPEIS:
Okay.
16 DR. KERR:
Existing plants are there.
You've got 17 to say "What can we do about these?"
But for new plants you 18 have a chance to start over.
I 19 MR. f,PEIS:
Right.
20 DR. KERR:
Say here are the things that we think 21 ought to be considered that weren't considered twenty years 22 ago when the plants were designed.
And I haven't seen any O
23 evidence that that's being thougnt about seriously.
24 MR. SPEIS:
Well, let me address--give me a minute,
()
25 okay.
My example, okay, you look at the design and you look Heritage Reporting Corporation
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1 at the best estimate capability-for some severe accident, and
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2 then you say, "My God, you know, if this best ostimate capa-l 3
bil.i'.y had forty pounds more capability, I would be able to 4
accommodate those more probable scenarios."
But then'to get s
that forty pounds more capability will cost the designer or-l 6
whoever builds the plant $100 million and he says, "No.
Maybe I
7 the best way to do that is to do something^else inside the 8
plant to eliminate that,s6quence."
And that's=the. type of 9
guidance that is needed in this type of thought tihat one has 10 to go through to decide, you know.
il MR. WARD:
Yes, but that ends up giving you a con-12 tainment which will handle an artifical accident but not the
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13 real accident that's likely to occur, and you've dealt with
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14 it by making the real acciu nt less likely.
I mean, the whole is thing is just not logical.
16 MR. SPEIS:
Well, I guess the question is how does 17 one define the so-called most probable severe accidents, okay, i
18 and some of those things are in the minds--
19 DR. KERR The question that I'm asking is do we intend to use the design criteria developed for existing con-20 21 tainments, developed back in the 1960s, on advanced water 22 reactors?
If we do, it seems to me to be sort of an unfor-O 23 tunate use of resources.
24 MR. SPEIS:
I guess we haven't decided right now.
25 MR. WARD:
Well, let me give you a real world i
Heritage Reporting Corporation' (302) 684 4888
23 1
example, of'the ABWRS.
The intention presently is to only 2
design that conta;nment for tne-design basis accident.. The 3
Japanese-are building a plant that way.
They are putting 4'
their emphasis upon prevention,-not on mitigations of severe 5
accidents.
And that's the way:that. design is going that we 1
6 are going to have reviewed and--
I 7
DR. KERR: But_thGy are nervous _that the NRC-is 8
going to do something different.-
9 MR. MICIIELSON: I'm-nervous thatEthey are going to 10 wait three or four yeads from n'ow to decide that something 11 different is needed after the design is alltdone.-
4 12 DR. KERR:
If they are building a containment, 13 they are putting some emphasis on mitigation.
They may be U
14 mitigating the wrong thing, that's what bothers me about this.
t j
is But if you build a containment you are talking about some form l
16 of initigation.
Tt ecoms to me to use the same design cri-17 teria that was develsped thirty years ago almost is somewhat 4
l 1
18 unwise.
i l
19 MR. MICHELSON:
They are using state-of-the-art 20 design criteria.
In other words, for what you design now
}
21 for the LOCA, but they are not going beyond that.
22 MR. WARD:
We've had several years now of severe O
23 accident research and it's shown that the LWR containments 24 designed by this--for this artificial accident are maybe not
()
25 so bad.
I mean that's what it shows.
But you havenc been Heritoge Re,,orting Corporation i=> u.m
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able to crystalize that research into a new more focused, more 2
directly applicable set of design criteria. 'And it's a very--
3 if it was easy it would have been done a long time ago'I 4-guess.
But I think the point that' Bill is. raising is that 5
there doesn't seem to be any interest or effort devoted to j
6 try to do that.
7' MR. SPEIS:
That's not true.
We are suffering with 8
that issue..My personal'~ view, and~I'm.not, speaking for my.
9 division or my office or my Commissioner, is that having gone 10 through the last three years with this whole severe accident 11 area, and margins and so on and so forth, my personal view 12 is that the containment'should have--some-additional criteria
(
13 should be imposed on them in addition to the present ones.
v 14 Some of these things will be done maybe silently 15 like-I don # t think anyone will come forward with just a i
16 MARK-1 containment.
The way we understand them right now.
l 17 okay.
So maybe by elimination we'll get there but I see where I
l 18 you are coming from and I share that.
But we are looking 19 into it.
3 20 At the same time we don't want to destroy, you 21 know.
We want to--the present design basis has served us 22 well and we'll have to make sure that whatever we do doesn't 23 make things worse.
1 24 Okay.
Brad, do you want to add some more?
()
25 MR. HART:
I just thougnt it would be helpful to Heritoge Reporting Corporation
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25' t
I make a comment about the words IPE approach on'that second 2
option.
It's an unfortunate choice of words I think, but 3
it's one that the staff--certain members of the staff have 4
been using that and I can see it's causing confusion, but
.5 the real important thing that we were trying to get across 6
there is that we're identifying in this particular option a 7
cost benefit-would be used to decide that a certain design 8
feature should be included and when they shouldn't be.
9 You'll see in the other options, 3 perhaps 4, that 10 we have a different criteria there for cost benefit, 11 MR. SPEIS:
Option'3 is the same as 2 except that--
12 what',s the difference between 2 and 3, Brad?
I thought I 13 knew this morning, but I guess--
s t
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14 MR. HART:
In 3, rather than using cost benefit is in terms of making of decisions on whether design features would be included, we would have specific criteria which may 16 17 be in REG guides, it may be in rules, but rather than using i
is cost benefit entirely, we would actually have some specific gg requirements spelled out, have particular options.
20 MR. SPEIS:
And Option 4 is the same except for the 21 word "general" has been replaced with "specific."
Where 22 specific sequences or specific loads will be told to be de-
)
23 signed against, okay.
It will be provided.
For example,.you j
1 24 know, take care of hydrogen or some other generic threats.
( )-
u This is in your attachment, by the way.
Heritoge Reporting Corporation
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-l IL DR. KERR:- I ask with some trepidation,'but I ask
'2 anyway.
What is a' SAP?.
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7 MR. SPEIS:
Severe Accident Policy.
- O r
-4 DR.' KERR:
Okay.
Thank you.
i
- 5 3
MR. MICHELSON:
Themis, you state that~there's no-6 practical time as a comment _to support this--
4 7
MR. SPEIS:
What did I say?
8 MR. MICHELSON:
You said in Option 4 comment.
l i
9 "No practical time to do this one," so therefore it's not 10 particularly viable I gather..But it suggests then that there is practical time in which to implement these others.
12 And I would like you to explain to me why a rul,e,will ever l
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13 be in practical time for'the ABWR, for instance. 'That's one
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14 example.
I don't know about the others'
- I think--I'm just l
15 not that familiar with the schedules.
16 MR. HART:
The difference between Options 1, 2,
4 i
17 and 3, and then 4 is that in 4 we're just identifying that l
18 there is an option to have some rather stringent requirements
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19 in the rules.
And wc recognize that there's a great deal of
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20 disagreement and uncertainty among the staff even on how that t
21 can be done.
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22 MR. MICHELSON:
Well, my real point was is there j
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23 a practical time in which to implement 1, 2 or 3?
r 24 MR. HART:
We believe if we make them general
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25 enough that that would be true, f
i Heritoge Reporting Corporation i
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MR. MICHELSON:
Within the scheduled time for 2
ABWR7 3
MR. HART:
Yes.
If we make them general enough 4
we feel that they are not that controversial, that they can 5
provide guidance and yet not be held up because of disagree-6 ments.
7 MR. MICHELSON:
Okay.
8 MR. SPEIS:
Again, these are options that the 9
Staff put together the last few days and we'll be interacting 10 with the other parts of the NRC in the next few weeks to see 11 if we can come to an agreement.
12 So that's what our thinking is at our level is 13 right now.
14 Let's see, I've completed yesterday's presentation.
15 So you tell me what you want to hear now.
Should I go through 16 the IPE to give you a summary or whatever?
17 DR. KERR:
I think that might be helpful, Mr. Speis 18 if you are willing to do that.
19 MR. SPEIS:
Okay.
Well, maybe for the benefit of 20
! the members--
21 DR. KERR:
Maybe just to go through briefly--
I 22 MR. SPEIS:
Okay.
23 DR. KERR:
--the main coints of 147.
And pick 24 out those things that you consider particularly important.
llh 25 MR. SPEIS:
Maybe for the benefit of some of the Heritage Reporting Corporation em> us~
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members who weren't here yesterday, maybe I can summarize 2
the closure process because then it brings out-the two or 3
three problems that are very crucial to it, p\\ /
4 We said that the steps which each utility expected
-5 to take to achieve closurelof severe' accident issues for its-6 plants are complete individual plant examinations,-and identif: r 7
potential improvements, evaluate and fix as appropriate'.
8 Develop and implement a framework for an accident ~ management 9
program that can accommodate the information as it is de-10 veloped.
And implement any generic requirements resulting 11 from Containment Performance Improvement Program.
12 So these are.the three key things.
13 So having said that, maybe we can give you a brief v
14 summary of the IPE package.
15 The IPE package has gone to the Commission.
We 16 are meeting with the Commission next Thursday, the 21st, and 17 we are recommending that the Commission issue the Generic la Letter recommending that they give their okay to the issue 19 the Generic Letter.
If they do that, then the Director of l
20 Regulations, Dr. Morely, will sign the letter.
21 Just a summary of the IPE program itself.
We have i
22 completed the package, as I said already.
We have done all
(:)
i 23 our interactions with industry.
We have completed a large l
24 number of interactions with the SCRS, with CRGR.
As Brian
()
25 said yesterday, we had three days of meetings with the CRGR, Heritage Reporting Corporation (308) 636-aase
29 1
and we think that the package'has been;substantially improved 2-
~ as a' result'of ACRS and'CRGR comments, especially'in areas 3
like guidance on containment. performance improvement, screen-4 ing criteria, and a few other areas.
H 5
I guess these are some of the areas that we had 6
detailed discussions, that the discussions' focused on with 7
We are proposing to subsume 8
the USIA.45 into the IPE process.
We plan to review the 9
submittals.
And we plan, of course, to periodically inform-10 you and the CRGR and the Commision of the progress.
11 The other point I want to make--during the dis-12 cussions that we had with you and especially last year when 13 you so indicated in your letter you told us that the guidance v
14 cn containment performance was.not very clear, we. attempted 15 to do better,.ut the CRGR kind of told us the same thing 16 so what we plan to do--we think>we have taken, you know, their j
17 comments and we think we have improved that guidance farther, 18 but what we have decided to do was to send,the package out 19 with the guidance of containment performance but before the 20 utilities respond to us, and tell us whatever they have to 21 respond to what questions, that would be delayed until we 22 have some workshops with them.
We'll go through the Generic 23 Letter.
We'll go through the containment performance guid-24 ance, and see if they understand it, if they have any ques-I'
()
25 tions, and if the package needs clarification, we'll try to l
l Heritage Reporting Corporation 4
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l-I clarify it.
And then we'll send it back to them.
And only i
2 then the clock will begin to tick.
Only then--
l 3
l And this package,.especially the containment O
4 guidance performance, we'll maybe improve on it.
We'll go j
back and discuss it with the CRGR.
And we'd like to brief
'you if_you are interested.
6-7
-Let's.go to the next one.
That's it?
8 So that's the summary on the IPE.
I spend some time yesterday--I_ guess we had some_Vu-Graphs that indicated to
~our response to your comments.
I don't know if you want me Il to go through it again.
They are discussed in the second-12 paper.
Also in the attachment on pages-14 and 15.
Starting O
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14 ACRS comments.
4 15 I understand from our' discussions yesterday that 16 possibly in some areas there have been some misunderstandings 17 but I'm not--
I c
18 DR. KERR Before we get to that--
19 MR. SPEIS:
Yes.
20 DR. KERR:
May I refer to page 6 of the IPE letter,
]
21 the latest draft in which there is discussed the containment 22 analysis and the language confuses me a bit.
It says, it's 23 beginning about the middle of the paragraph, "Licensees are 24 expected to correct vulnerabilities that might be identified."
O-Then it te1xe eboet uncerteinties end the eerformence Heritoge Reporting Corporation
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improvements-programs, and "Finally-industry.Will not be P aced in the position of having implemented improvements l
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before all containment performance decisions have been made."
Does that mean no changes in containment systems will be made 4
5 until this is completed?
Or'that some will be or--
6 MR. SPEIS:
No major.
I think, you know, one'of 7
the purposes of the-integration plan is to make sure that-a these things are coordinated,. integrated--
9 DR. KERR:
Just one.- I'm not trying to be criti-3 go cal of the paragraph.
11 MR. SPEIS:
We're saying no major--as a result of f
12 the IPE, you don't have to undertake major containment changes j
13 until you see where we're coming on the generic containment 14 requirements.
{
)
15 DR. KERR What is a major. change?
And what is 16 a minor change?
l i
17 MR. SPEIS:
Well', a major change can be a filter gg for a PWR, for example.
For a PWR, a filter vented system.
39 DR. KERR:
My question is'will there at some point
- o be given guidance to the licensee so that they will know what 21 you consider to be minor changes because it certainly isn't j
22 here.
O 23 MR. SPEIS:
This will be clarified further with 24 these workshops that I mentioned earlier.
The wo: kshop this O
2>
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1 32-i DR. KERR:
Well,~does that mean that you don't know
-2 what you are going to designate as major and minor at-this 3
point and you have to wait until the workshop?
4 MR.-SPEIS:
No, we know, we know.
I guess--
5 DR. KERR But you can't write it down?
6 MR. SPEIS:
Major involves, you know, substantial-7 amounts of money I guess.
Not a few million dollars but tens 8
of millions of dollars.
9 DR. KERR:
So anything that costs under $10 million 10 is a minor change probably'and--that's going to'be--I'm not
~i i
11 trying to be critical, I'm just trying to understand how a 12 licensee makes a decision.
/]
13 MR. SPEIS:
For example, this issue on MARK-I con-34 tainments, whether the liner fails given a severe accident.
I With a 90 percent probability or a 10 percent probability, is t
4 i
16 That's an issue that has been argued back and forth and by l
37 this statement, we are telling them, you know, you don't have 18 to go and beef up the liner.
There are some other things i,
that can be done, okay, to alleviate this issue.' Maybe there l
l 3
are things that can be done to reduce the source term.
But d
23 on MARK-I, we'll tell you by the_end of the year.
4 22 I think there is some--we are saying this to make
. ()
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23 sure that if somebody undertakes the IPE very fast in an 1
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l 24 accelerated pace, and he comes to this problem dealing with the 4 ()
25 liner or the direct containment heating of PWRs, he might as Heritoge Reporting Corporation
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wel1.waitJfor whenever we come up with pronouncements on
~
's 2
those two issues by'the end of next year.
At the end of this 3
year on MARK-I's, by the-end of next year on the rest of the 4
containments, okay.
5 DR. KERR:
It's fairly possible1that somebody 6
might decide if by making' a minor change 11. could solve both 7
those issues.
Would you then want the licensee to go ahead 8
with--
~
9 MR. SPEIS:
Well, yeah.
What we're telling them t
to right now is to do your IPE.
See what improvements you'can 11 make..You can go ahead and make'them on your own, okay.
12 And there is a vehicle in the regulations that you can under-l O'
13 take those changes on yourself.
And we are warning him at l
f 14 the same time that this so-called big issues that have been i
15 around for the last few years, you know--you'll hear from us 16 some more.
Right now, make sure that you understand what 17 they are and understand the ranges of the possibilities that 18 could arise if something like that takes place.
And keep 19 thinking about it, okay, together with'us.
i 20 DR. KERR:
So it's possible that a-licer.aee.might 21 conclude that any change in his containment system will be
-)
a major change and therefore no changes:should be made until 22 V
23 after the containment improvements program?
24 MR. SPEIS:
Yes.
()
25 DR. KERR:
Okay.
Go ahead.with what you were going Heritage Reporting Corporation
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1 to talk about.
~s 2-MR. SPEIS:
I don't know wherefto go.from'here.
_k-3 DR. KERR:-LWell, I have one suggestion.
4 MR. SPEIS:. Yeah.
5 DR. KERR:' And that is how is 1150, which-is-6 pointed to in the SECY as being sort of a building block,.a~
7 cornerstone, whatever, of this effort, how is it going to be 8
used?
Would you talk a little about that?
9 MR. SPEIS:
Okay.
10 MR. MICHELSON:
Perhaps before you get to that, if 11 I may ask a general question on severe accidents.-
I'm having 12 a little difficulty. deciding what I think a severe accident 13 might be, so let me give /ou an example and see if you can
(]
(/
y help me out.
15 In the case of. fire, we have' designed certain areas to have a fire which burns for'less than~one hour and 17 We Put in one-hour protection for certcin equipment required 18 for safe shutdown for that fire.
There is a finite and per-g9 haps not trivial probability that a fire that ignites in that 20 area might burn beyond one hour.
And therefore begin to 21 jeopardize the equipment needed for safe shutdown.
22 Is that a severe accident and would the rules for 23 designing for that eventuality come under the Severe Accident 1
24 Rule or how do you treat it?
()
25 MR. SPEIS:
You are talking about for future LWRs?
Heritage Reporting Corporation
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.MR. MICHELSON:
Well, let's start with future and 2
then we'll go back to the present.
3 MR. SPEIS:
I think, Brad, if I correctly read
('~/
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4 your paper, and again, it's just a very early draft thatToe're 5
talking about preventing.and mitigating and in the. prevention
(
6 we're.saying that there are some events that you have to:go 7
beyond the sinale failure.
8 M F.. MICHELSON:
I wasn't even considering that.
t 9
People recently at Sandia have made some estimates of what-10 the. probability of putting fire out in one hour might.be.
11 And it turns out that it's a fairly high probability that if 12 you get such a fire you r y not get it out in one hour and 13 therefore, does that now come under the' severe accident-de-N 14 sign rules?
What do I do about it?
If anything.
15 MR. SPEIS:
If there are areas that would threaten i
16 the core or the containment, you know, this whole game is j
17 prevention and that is--
18 MR. MICHELSON:
Right now it's my understanding 19 that the ABWR is going to use the'same rules we're presenting 20 using under Appendix R and the' rest of the fire protection, 21 in which case they will be allowed to route. conduit with one-22 hour protection through such areas.
And lacking any other 23 guidance or requirements from the NRC,-that perhaps is the 24 way it will be designed.
But yet, there is a fairly high-p) g 25 probability that a fire that burns for forty-five minutes Heritage Reporting. Corporation m o..
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might not lx3 put out.in one hour.
b Have you discussed that with the NRR'
<^s 2
MR.~ SPEIS:
3 staff who are addressing-the-- you are reviewing the ABRs.
Ok-[
4' MR. MICHELSON:
Well, that's right.
We~ asked the' 5
fire protection question on what' rule are you going to use 6
and the answer from GE was they are going to use Appendix R 7
requirements.
But I'm just wondering, do you classify a fire 8
that burns beyond one-hour then a severe-accident?
You must 9
give that some thought even though you aren't worrying about 10 ABWRs?
11 MR. SPEIS:
When I'm'up here and talking about 12 severe accidents, I'm talking about a severe accident is on
/"'
13 its way.
I'm talking about loss of coolant--
\\-;)
14 MR. MICHELSON:
This is the consequence of the 15 fire burning down one hour 1 now a severe accident.
You are 16 talking about the initiators of severe accidents in this case.
17 MR. COMPTON:
My name is Tom Compton and I'm from 18 NRR.
Let me try to shed a little' light on this.
The Severe j
19 Accident Policy Statement says that a severe accident is going i
i 20 to be one that leads to substantial core d' mage.
I would say a
21 if this fire, this postulated fire, lasting one hour could be 22 thought of in a sequence leading to substantial core damage, O
23 then we certainly have to cons 5 der it as a severe accident 24 sequence.
l l( )
25 MR. MICHELSON:
And then we would consider what to do Heritage Reporting Corporation j
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37-I about it under'the severe accidence guidance?
I 2
MR. COMPTON:-
Severe accident guidance and cri-O-
3 teria.
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_4 Mu MICHELSON:
That's the way I would' kind-of 5
think that you'd almost have to answer it.
6 MR. COMPTON:
That fire or.any other event.
7 MR. MICHELSON:
So give that some thought when i
i 8
you are dreaming all of the rules up that fires beyond one 9
hour are not low probability events.
10 MR. SPEIS:
Well, back to the NUREG-ll50.
The way-11 we say it in SECY-88-147, that's'the only thing I can quote 12 that has been signed by our EDO.
It says that the.obje'ctive j
()
13 it provides is not short of the state-of-the-art PRA techno-N-
14 logy incorporating improvements-in methods and i
15 accumulated in WASH-1400.
In close examination of severe 16 accident frequencies and risks a.td their associated uncer-I 17 tainties for five months.
The coles in regulatory process.
18 It's an independent staff assessment of risk, provides tech-l t
19 nical data base as input to some of the activities that we I
20 have underway.
Also it will provide us quite a bit of infor-21 mation in prioritizing and focusing of resources.
22 DR. KERR:
Mr. Speis, I read both of those things
()
23 and that's the reason I asked the question.
I don't under-24 stand from what's written how it's going to be used by the
(])
25 staff in the review of IPE's, and I think it's important to Heritc.ge Reporting Corporation nana==
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1 recognize--to know this, because if it is going to have an f-)
important. role and it certainly-seems to me the final draft 2
N_/ -
3
.needs to be improved significantly over the'first draft.
p)
(_
4 If it's not going to have an important role, then maybe it' 5
doesn't matter.
And it is not clear to me what role it will 6
play.
7 MR. S*/EIS :
You can --:
~1150 PRA types for five 8
plants.
PRAs.cn: five plants.
So when we review the draft 9
especially in the front end, you know, what are the sequences, 10 what are the common most failures that were identified in 11 1150 that can challenge the core, we took those things into 12 account in going through our review of the IPM.
Maybe Frankie
[~}
13 can say some more about it.
'm t_/
14 Also we have put together a document which is s
15 NUREG-49 to Andy which tries to simulate all the knowledge 16 that has been gained up to now from PRAs, from resource, 17 from operational experience, and those insights that were 18 harvested from 1150 are there, especially in the front end.
19 The back end analysis--
20 DR. KERR:
What document is that?
21 MR. SPEIS:
4920, which is going to be provided 22 to industry the next month or so.-
23 DR. KERR:
It's in' process?
24 MR. SPEIS:
It's in the process, yes.
And I
()
43 think that's an important document because it's five Heritage Reporting Corporation o n mm
~39 1
documents.
It deals with each' containment type.
And we ig have discussed that document,-you know, extensivelyfduring 2
G'.
3 our int 3ractions on the IPE last year'.
4 DR. KERR:
Do the five documents'tell how 1150 is 5
going to be used?
2 6
MR. SPEIS:
Fell, no.
It provides-insights from 7
1150.
Here is a sequence that wasn't thought or'before, so 8
when you do your IPM, you know--but I don't think ll50 will 9
be used as a guidance document itself to tell us how to re-10 view the IPM or anything else, okay.
It's the insights that 11 are there and we are using them as such.
12 DR. KERR:
Okay.
Now, whatever insights are there 13 have come from the draft version of 1150 and not the new 14 version, right?
15 MR. SPEIS:
Well, maybe, Frank, why don't you talk 16 about the front end and then I'll say about-the back end.
17 DR. KERR:
Well, only the draft versicn of 1150 18 exists.
The final version doesn't.
So you can't have pre-19 pared documents that are already in existence--
20 MR. SPEIS:
Well, I don't think those insights 21 will change.
I don't think it's' going to change.
22 DR. KERR:
I don't know whether the insights will 23 change or not.
I'm simply trying to find out what version of l
24 1150 was used in preparation of_these documents and must
()
25 surely be the draft version.
Heritage Reporting Corporation l
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MR. SPEIS:
Let me give you an example on the liner, 2-the MARK-I liner failure that.we've been talking about for the pO 3
last two years.
1150 says that the condition of failure of the containment because of challenging'the liner is somew'here
~
4 5
between 10 percent and 90 percent, and that was.it.
I under-6 stand the final report will say the mean is 50 percent, and 7'
these panels have gotten together--there were five or six of 8
them that thought it was close to zero and there were five or 9
six that thought it was close to 100.and then they split the 10 difference and they came to--
11 DR. KERR:
Did you ever hear the story of the lit-12 tle boy who asked his father where he came from?
His father
({}
13 went through the birds and the bees story and when he finished 14 he said, well, the little boy up the street came from Boston 15 and I just wondered where I came from.
16 I'm not trying to get al.1 this detail.. I just 17 want to know whether these documents were prepared using the 18 draft version of 1150.
The answer is probably yes.
Isn't 19 it?
20 MR. SPEIS:
No.
Some of the insights from 1150, 21 yes.
But they were prepared using insights from the PRAs 22 that have been performed, okay?
23 DR. KERR:
I give up.
24 MR. SPEIS:
1150 is not the bible.
And I don't
()
25 know if anybody told you it's the bible.
It isn't the bible, Heritage Reporting Corporation (2et} us-4ees,
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okay?
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'DR. KERR:
I don't have any preconceptions.-
.I'm 3-trying to' find out.how 'it's going to be used.
You'tell me
'f%s) 4.
that it's going to be used to prepare.these five documents--
5 MR. SPEIS:
No.
Some of'the insights'from 1150 6
as well as insights from twenty other documents were' utilized.
7 DR. KERR:
I didn't mean nothing.but 1150 went:
8 into that.
But apparently whatever from'll50 went into it 9
came from a draft version.- Because that's all that exists.
10 MR. SPEIS:
- Right, 11 DR. KERR:.Okay?
12 MR. SPEIS:
We understand that some of the things O'
13 that were found dealing with the so-called front end, no 14 changing that much.
As far as the back end, I understand 15 that the only thing that has changed, they have put more peo-
~
16 ple on these panels that deal with these phenomenological 17 issues that were already placed in the draft and they came 18 up with mean numbers that they split the difference and it's 19 not going to change anything that we're doing.
20 DR. KERR:
So that the criticisms made by the 21 Peer Review groups are probably still valid?
22 MR. SPEIS:
I am not--I'll have to have Denny Ross 23 to address that.
24 DR. KERR:
There's been no significant--
(
25 MR. SPEIS:
I haven't bem.. involved too much with Heritage Reporting Corporation en su
.._.,__,o
42
... +
1 1150-.
2 DR. KERR:
If Mhere'h' ave be'en no>significant 3
changes,-then it:certainly must be that those comments.are
~ t'v 4
still valid?
?
~
5 MR. SPEIS:
Well, I know about the' MARK-I liner.
I 6
That's what I was told, that-they. split the difference, okay?
7 But I think 1150 identified those issues are L
8 really, as far as I'm concerned, those two or three issues 9
that affect a number of containments as needing work, okay.
10 We have to do the work.
We can't play with numbers, okay.
11 I mean, the numbers--you know, you are the experts here.
I 12 only come from the knowledge of the phenomena of the physics i
/]}O 13 of the engineering, you know, and then you' translate that into 14 numbers, you know.
Trying to play with numbers without having 15 that understanding is, you know--
16 So why are you putting me on-the spot on this, 17 you know?
We have talked about it continuously--
18 DR. KERR:
I did not mean to try to put anybody on 19 the spot.
I was just trying to find out how 1150 was going l
20 to be used in this process.
i 21 MR. SPEIS:
Whatever is worthwhile, we'll use it.
l 22 And there are a lot of good things there.
If you are--
()
I 23 DR. LEWIS:
That's not very helpful, to say that l
24 we're only going to use the parts that are right and we're i
'(f 25 not going to take seriously the parts that are wrong.
Heritage Reporting Corporation amn.
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. _. ~. -
43
?
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DR. SHEWMON:- Trust us. lWe can't tell you what-t i
2-we'll do, but we'll do the right t'hing?
That was:your last
^
~
3 answer.
/3
'\\d 4
MR. SPEIS:
No, no, no, no._
I said there are some 5
areas there that, you.know, 1150, and pointed-them as being-
~6 uncertain'.
That's why the experts'cannot decide _what;it is'.
7 And I'm saying that these are the areas that need additional 8
work.
And as I told you yesterday, there is a program.
We'll 9
be focusing the next two years to make sure'that we'll have a 10 better understanding of those areas, okay?
11 And.that..is the reason. '.You-know, there's'im-i 12 perfection in this containment guidelinesthat everybody brings
{~T 13 up and' points out. 'You know, hey--you are confusing the in-I f'r
(
14 dustry.
I don't.think.it's. fair to tell them;to design the' i
15 containments for direct containment heating right now.
Be '
j 16 cause we don't know if it's real and so on and so forth.
17 MR. WARD:
Themis, let me ask you a more specific 18 question about how 1150-might be used.
When.these IPEs or 19 PRAs, whatever is done for the IPE to start' rolling in over 20 the next few years, the~ staff is going to have a big job in 21 doing those.
22 MR. SPEIS:
Right.
i 23 MR. WARD:
And is it going to use 1150 and the.
24 insights from 1150 as a primary tool,_ primary standard, what-()
25 ever, for judging those IPE submittals?
Heritage Reporting Corporation
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MR, SPEIS:
I think as I'said 1150,will be utilized 2
very extensively,!but I don't knc.v if I can.say it's going' to 7-)
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'3 be the primary' standard.to put here and then-put the IPE
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Ps) 4 against it.
I don't'thinkiso'.
5 MR. WARD:
Well,- what will the staff use as a--
6 MR. SPEIS:
Well, you know, there are guides for 7
reviewing PRAs and this is an evolving technology, so there 8
isn't a perfect standard review plan where you can put here and then you can put next to it your PRA and go page~by page o
to.
and review it.
You know, you have to have people who under-11 stand those things,.who have been involved in it, but that 12 standard review plan, you know, there isn't such-a thing.
13 There are some review documents, you know, that tell you 14 these are the things to look on,-these are the important 15 sequences.
Make sure that your PRA has considered this and 16 that and that.
But there isn't, you know, a very well codi-17 fied document that says, you know--go step by step, paragraph 18 by paragraph and page by page.
19 MR. WARD:
But that could mean that the absence of 20 such a thing could mean that staff members will rely very 21 heavily on 1150.
22 MR. SPEIS:
Go ahead, talk about that, Frank.
23 MR. KAUFFMAN:
Frank Kauffman, from Office of 24 Research.
At the risk of being a little redundant-of what
()
25 Dr. Speis has already said, maybe I can put it in the Heritage Reporting Corporation cmnu -
45 I-perspective of how 1150_was'used to date'and I~would expect, 2
I won't-predict, but I would expect that in the future we a
3 would use 1150 in.the same way..
1150.was.used for the pur-y s
3 4
. poses of developing these insights.. What do'we~mean by in-5 sights?
We raan looking'at'therdeductive: logic that you;have 6
in the PRA analyses and the display.
Introducing also what-7 we understand about the plant, we gain these insights into
.+
8 the mechanics of what goes wrong, what pieces of the plant l
9 can go wrong.
At what level of detail you have to look at s
10 those components.
At what numerical values you beg'in to take 11 interest.
Those types of things are-the insights that were i
12 summarized and put into NUREG CR-4920, these five-volume re-(u~)
13 ports.
For the purpose of indicating--of sharing this infor-
\\--
14 uation with the industry and also for the purpose of setting 15 the thresholds for what is.of interest when you are looking 16 at severe accidents.
l 17 So one of the major uses of 1150 along with the 18 industry PRAs and for the in core IPEMs was for the purpose 19 of setting the screening criteria of what should be looked 20 at.
21 So that's in a general way how it was used, and I g-would expect that this same type of information--we would 22 V
23 Probably would it with similar use.
24 If I could also address the question of the cur-()
25 rency of the information.
The information that is cited in Heritage Reporting Corporation von m
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46 I
the IPE--I'm sorry.
The citations that are in the-IPE-letier
-/ y 2
and in these 4920 reports are the referencable or citable LJ 3
versions of 1150.
However,lweiare'not sitting around in one 4
office' waiting for '-down the hall, for them to give usuth'e l
0 5-final version of 1150., We-are currenti,There~were several 6
pre-drafts of even the draft 1150,,and we;were staying on top 7
of each pre-draft.- We're not waiting for th1s information.
8 We're just trying to keep up to date with current information.
9 MR. WARD:
Because with all its warts, it's the 10 best intormation there is available.
That's your argument 11 I guess?
12 MR. KAUFFMAN:
I'm not going to say best.
I'm f'
13 going to say it's information that we can't' ignore, and-it 14 has to be part of our consideration.
And it is reference 15 information.
And if part of the staff that's managing 1150 16 says it's the best available, then--
17 MR. SPEIS:
Frank, I should have said one thing 18 earlier to a question Mr. Ward. asked.
We are putting together 19 guidance for the staff how to review the IPEs, and that 20 guidance will go out to the industry whenever it's ready.
21 That also will come out as a result of these workshops, and e
22 that's the guidance that we'd like to discuss with you.
O 23 In addition to sharpening up the guidance for 24 containment performance, we're putting together--attempting
()
25 to put together some type of general guidance or maybe in j
Heritage Reporting Corporation
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47 I
~
l' some areas more specific than. general, how these IPEs should 2
be reviewed. 'What should_be;the standards, to the extent 3
that we can.
But we are putting that down"and it's ene of-4 the conditions that was from the 'CRGR-before they gave: their-I
.5 okay, they want to make sure that w'e havelsuch a; thing.
So 6
I sh'ould have said t at edrlier.
7 MR. WARD:
Well,-I guess you feel like we're sort
~
8 of picking at this point, and I guess.we are.
But we are 9
in kind of a--
10 -
MR. SPEIS:
Just don't ask me about 1150.. Anything i
11 about--
12 MR. WARD:
Okay.
But we're in sort of.a dilemma.
13 From what Frank described and what you just said, I might l
34 conclude that 1150 is going to be a very important standard 15 for the review.
I might conclude that.
I don't know whe-16 ther--
17 MR. SPEIS:
It's an important document, but.there 18 are other--you know, there are some other PRAs that we're not 19 ignoring.
The Limerick PRA.
The designer Indian PRA which 20 the staff and the contractors reviewed extensively.
So 21 I think 1150 has added more, you know, to the process.
There 22 are many other good analyses that have been done in addition
-l O
23 to 1150.
But I think 1150 has, you know, its real contri-24 bution has put those big bars there.
~ Attempted to go beyond O
25 the means r the--to understand uncertainties.
Heritage Reporting Corporation wn su
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DR'.. KERR:
Mr. Michelson.
1
. ill all the 1150 PRAs, include 2-MR. MICHELSON:
W 3
external events?
A-r. -
4 MR. SPEIS:- Two of them.
5 MR. MICHELSON:
Just,two.of,them?-
6 MR. SPEIS:
Yes.
7 MR. KAUFFMAN:
LaSall' eland' Grand Gul'f I think.
~
8 MR. MICHELSON:
I know LaSalle was going.to con-9 sider fire.
Is it considering.the full spectrum of external 10 events on LaSalle and on which other one?
11 MR. SPEIS:
I forgot the other one.
12 MR. MICHELSON:
You are not sure, okay.
- LaSalle,
(~)
13 for sure, is kind of an all-external events included.
14 MR. SPEIS:
You have the answer.there..
Houston 15 should have the answer. It was given by--no, the man next to 16 you.-
Houston.
Denny Houston.
Denny made that presentation 17 yesterday.
It should be one of his Vu-Graphs.
18 MR. MICHELSON:
Which one?
19 MR. HOUSTON:
Surrey.
Peach Bottom.
20 MR. MICHELSON:
LaSalle is one cf them, I know.
21 MR. HOUSTON:
LaSalle was an advanced PRA which 22 will come along later.
O 23 MR. MICHELSON:
It comes under a different hat..
I 24 MR. HOUSTON:
Yeah, right.
(h 25 MR. MICHELSON:
Which one is under 1150?
Heritage Reporting Corporation uen sn.a
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MR. HOUSTON:
Surrey and. Peach Bottom.
j
.2
'MR. MICHELSON: 'And are both.of.those completed
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now?
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4 MR. HOUSTON:
No.. It says they are progressing 5
well.
This slide does.
I ell me ' roughly when the j
6
'MR. MICHELSONi Okay.
T
~
7 results will be available that will include external events.
,I! don't know..We'll'get you that in-
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9 9
formation.
{
10 MR. MICHELSON:
- Okay.
Could*you guess even--
{
11 MR.'SPEIS:
It's about one month.
l l
12 MR. MIChSLSON:
Okay.
It's immenent as opposed to
(]_
13 a year from now?
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I4 MR. SPEIS:
Yes.
That's right.
.f i
15 MR. MICHELSON:
Thank you.
16 DR. KERR:
Mr. Lewis.
I 17 DR. LEWIS:
I'just wanted to declare:that'I'm i
18 extremely confused by the whole conversation.
Because on the 19 one hand I've heard that one is using the insights from 1150, 20 not alone, with other things, because there are not going to i
21 be that~many changes.
On the other hand I hear emphasized
]
1 22 that there are changes all the time and that we're absolutely 23 abreast at all times of the current version of it and that-24 there were drafts and drafts.
I'm having trouble reconciling O
25 thoee.
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The other thing I'm havin'g trouble reconciling or
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understanding is what is meant by an insight..Because the-A,]
u-3 way in which it is used in.the 1150 context has nothing toldo
~
4
-with'the dictionary definition of insight.
It's aomething-5 else.
An insight is in the.end in regulating nuclear power 6
you have to be very precise cn1 things.
And insight is usually 7
a sort of flash of wisdom which then:has.to be turned into a-8 policy.
And misusing it here as kind ~of the policy and not 3
9 as what I would call,the! insight.
10 I'm not really asking.a question.
I'm just'saying
.I 11 it's very confusing to me.
And I hope that in the new draft 12 of 1150, which there will be, and it had better differ sub-(')
13 stantially from the current version, because otherwise you'll 1
\\/
14 have to explain why you were wrong.
It was1 fairly critical 15 of the current version.
16 I hope there will be a definition of the word 17 "insight."
I hate to ask for definitions as a freshman, but 18 since you are using the word in such_a different way frem the
[9 way it's usually used, I hope you define it.
And in the 20 process of trying to define it, I think you may come to under-21 stand what you are talking about a little bit better.
Cer-22 tainly I will.
O
%_/
23 MR. SPEIS:
Good point.
As far as we are con-24 cerned, this NUREG 4920 that addressed the five different
()
25 containments maybe you can say what insights mean in that Heritage Reporting Corporation
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51 1
report, Frank.
I think it's different from Professor Wilson's r"%
.2 MR. KAUFFMAN:
Yes,.I appreciate the suggestion i
V i
3 to define "insight."
I guess we attempt to use it almost as
~ o jargon.
j 5
DR. KERR:
Is that mike'on,. Frank?
I 6
MR. KAUFFMAN:
I could be.
I might be lazy and-
,l l
7 not speaking up.
l
~
l 8
Before I address what Dr. Speis aske'd.me to ad-i 9
dress, let me just' clarify the frequency with which the drafts 10 of NUREG-ll50 were revised, and I.didn't mean to leave the 11 impression that it was a day -to-day. type of. thing,.but I guess 12 when you are looking at five plants and you've got all the Q
13 other PRAs going on and you are the receiver of these drafts, 14 I guess we had maybe I guess a revision--we had a draft and 15 then a revision and then we got the' published draft and this 16 took place over a period of about--I think it was-like a year.
~
17 So it was at that--I didn't mean--
18 DR. LEWIS:
I never suggested that it was daily.
19 But you did emphasize the fact-that new versions were coming 20 along all the time.
And you weren't sitting down the hall 21 waiting for them.
You were really into that.
22 MR. KAUFFMAN:
Yes.
We get them--when they come 23 in to the staff, it's less than a week when we get them.
As 24 far as what we mean by "insights," in the 4920 reports, they O
2s cen be greter exteme1ve, gretty dete11ed.
1'm ervine ee rece1:
Heritage Reporting Corporation o.n su I
52' t-an example.
I guess in the Atlas situation there were-some--
2 I'm sorry.
Take a station blackout.- A station blackout, we
,,- l 3
were aware in parallel there-was.a rule going on and: station
(
4 blackout as a rule and'as a generic issue wari addressing the 5
plants generical'ly with what'was pervu 1ve'across severalj 6
plants.
7 In addition,.there were some actions that were 8
ideas on what actions utilities might take at'their specific 9
plant during station' blackout;tha,t?weren',t.important enough 10 from a value impact standpoint to merit getting into the rules 11 or proposed rule,7but they"were,'in' fact, they could be help-
~
12 ful to specific plants who, in fact, if they found themselves:
13 in that situation, and it was like a. repertoire of potential g4 reactions that could be taken.
15 They came out of the brains of the PRA analysts 16 as they were performing the examinations, the PRAs.
17 I'm sorry I can't think of any specific--I'm try-18 ing to characterize it but I can't think of a specific--
19 MR. SPEIS:
Well, I don't think the. follow--Pro-fessor Wilson's definition--for example, we're saying that 20 21 if your containment is being challenged by a slow quasi-22 static pressure, people have used filter vented systems to O
23 depressurize the system and at the same time clean up the 24 containment environment.
And this type of thing, you know.
()
25 They are accumulated, so I think when we talk about insights Heritage Reporting Corporation
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it's more.than insights.
The accumulated knowledge that it's-2 not this flash that_you described earlier..
3 G
3-DR. LEWIS:
I'm just talking-about the meaning of 1
4.
the word.
5 MR. SPEIS:
Okay.
6 DR. LEWIS:
But they are important.
7 MR. SPEIS:
Yeah.
8 DR. LEWIS:
And if, for example, one takes the-9 point that I think Frank has made that things that come 10 througn for several of the plants'that seem to be fairly-11 generic, unless my memory has failed me completely,.I snem toremembersomebody,probably.itwasbenny!,sst$nkingupin 12 (s-13 that same place and saying this is much too small o sample-14 to draw any generic conclusions'from. 'Now, maybe the staff 15 has backed off from that view.
That was.not a correct view 16 in my view.
Because this is a sampling procedure and you 17 learn something from sampling._ You don't learn everything 18 but you learn something.
39 But certainly at the time we got that briefing, 20 the staff position was then you couldn't draw'any general 21 conclusions.
That just increases my confusion about what is j
I 22 an insight.
And I'm going to let it go at that.
This isn't i
O
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We'll have 24 chances over the decades.
1
()
25 DR. KEPR:
Go ahead, Mr. Michelson'.
Heritage Reporting Corporoffen
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MR. MICHELSON:
'Well, I have a little bit of a 2
follow-up question on this subject,'and that-is only two of 3
the plants wil1 include the external events analysis.
-I as-
~
{'T
~
sume because it is quite plant specific,'the external events, 4
5 to be considered and what effects.they'll have is very much 6
dependent on the plant configuration.
Cut-you will have 7
results from two plants.
Are you planning on. drawing generic 8
conclusions from those two plants in any respect'regarding-9 external events?
10 MR. SPEIS:
I would send Chou and his seismic ex-11 perts to address that.
12 MR. MICHELSON:
Well, this isn't a seismic question P
13
'of course.
It's a' lot of oth'er questions.
14 MR. SPEIS:
Well--
15 MR. MICHELSON:
External flooding, internal flood-16 ing, wind storms, fires, et cetera.
So it isn't--
17 MR. SPEIS:
Well, you saw yesterday'he has four or 18 five subcommittees which are addressing specific external 19 events--
20 MR. MICHELSON:
How do we treat external events 21 in the future and my next question is, what are you going to 22 do from the sample you get on ll50--what do you think you are 23 going to do at the present time?
24 MR. SPEIS:
We are not ready yet.
()
25 MR. MICHELSON:- You are not ready yet?
Okay.
Heritage Reporting Corporation -
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MR. KAUFFMAN:
The IPE at this' point'is.just in-2 tternal.
l g~)
L/
3 MR. SPEIS:
Yeah, they know that.
/\\
- (~
'4 MR MICHELSON:
Wait a minute.
I. thought-Surrey
-5 and Peach Bottom were going to include external--
6-MR. KAUFFMAN:
IPE you are referring-to.
7 MR. MICHELSON:
Okay. _IPE I thought was including-8 internal flooding.
So it's more.
That is an external event l
9 by most PRA analysts, nomenclature.
Even though we had a 10 misunderstanding _ yesterday.. The general consensus I.believe.
11 is that internal flooding is an external event.. And I assume 12 internal flooding is included in Surrey-and-. Peach Bottom.
O 13 But I am, concerned if you. start drawing generic I
14 conclusions about the ef fect ofifire', for instance, by less 15 looking at the plants.
r 16 MR. SPEIS:
I think'the' preliminary conclusion on i
17 that is that on fires you have to do a specific--plant speci-18 fic, yeah.
~
19 MR. MICHELSON:
You have to do a very plant'speci-20 fic PRA, a fire PRA, on the plant to determine the true vul-21 nerability or the true risk from fire.
i 22 DR. LEWIS:
You know the inside of your stomach is I
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(./
i I
23 outside your body by any topological definition.
So it's
-l 24 easy to understand of flooding being an external event.
1
()
25 MR MICHELSON:
I don't have any trouble with it.
i Heritage Reporting Corporation nunm==
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56 l-DR. KERR:
Any further questions on this, the 1150 f-2 issue?
3 One last question.
Is the plan.to have a peer S
(s /
4 review of the final version of 1150?
5 MR. SPEIS:
Mark told you yesterday that they 6
are considering a number of options and it varies' from no 7
peer review to some type of peer review and I understand the 8
EDO and the Commision will decide.
Or the EDO.
I don't'know 9
if the Commision is involved.
10 DR. LEWIS:
Didn't we write a letter to the Com-11 mission on this subject?
12 MR. SPEIS:
I think my boss is leaning in the
{
13 direction of having some peer review.
14 DR. KERR:
We wrote a letter to the EDO saying we
~
15 understand that you said you didn't plan'a peer review, and 16 we got back a response saying how did you.ever get that im-17 pression?
That would shorten things a little bit, but--
18 MR. SPEIS:
I understand that he will come here 39 personally to discuss this with you.
20 MR. MICHELSON:
That's good.
I would be. concerned 21 if your external event treatment does not get some kind of 22 peer review.
O 23 MR. SPEIS:
If he comes here personally, I'd better 24 not say nothing about it.
()
25 DR. KERR:
I guess that means that we need to say Heritage Reporting Corporation m.m
-.- -._._,_,, _.,. ~,. _...,,,
~
57-I something.about it at every opportunity because it certainly
'2 seems to me it would be a mistake not to have a peer review 3
for-something.that is going, I gather, is going to be used -
4 and is going to be important, although at this point I'm not:
5 quite sure how.
6 Okay.
Any further questions on 1150?'.Anything 7
else that you feel needs emphasis, Mr. Speis?
8' -
Are there questions'about 147 that anyone would
~
9-like to raise at this point?
10-(No response.)
11-DR. KERR:
Then we thank you for your presentation 12 and for its brevity and succinctness.
i 13 MR. SPEIS:
Thank you.
It's always a pleasure
~
~
l 14 to come here and talk to you.
I'mean'it.
I mean it.
15 DR. KERR:
I-accept the statement at face value.
16 MR. SPEIS:,Okay.
17 (GO TO NEXT PAGE) 18 19 20 21 0
23 24 O
2.
Heritage Reporting Corporation
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CHAIRMAN KERR: I think.the discussion of yesterday 2-a'nd today illustrate that for the'first-time in a long. time,-
3 3'
we havelbeen able to ask, questions of; people, but only in-
~
(~.
%s 4-frequently have we boh a response other than that's somebody-5
' elses responsibility, or-I, don!t'know anything-about it.
s 6
This'has occurred a few-times, but here we have 7
had a number.of things. brought'together and ih some cases, 8
we have seen what apoears to be, maybe conflicts of view-9 points or difficulty and I think more of an effort to inte-10 grate things is likely to turn up this sort of thing.
11 I think the effort being made is extremely impor-l l
12 tant and I hope we can encourage it and assist in it.
(()~)
13 I would suggest that we take about a 15 minute w'
14 break at this time after which we will go to the next item 15 on the agenda labeled Future ACRS Activities.
16 MR. WARD:
Do you want to cover the letter before 17 the break?
18 CHAIRMAN KERR:
All right, go ahead Dave.
19 MR. WARD:
If you look at our letter'of May 10th, 20 where we talk about the generic IPE' letter, we made three 21 points that: (1) - was it would like to see--we suggested 12 that they consider using the IPE to subsume all appropria'te 23 USIs and GIs in addition to A-45s.
We suggested that there-24 be something more nearly approaching a requirement for the
()
25 licensees to do a full scope PRA snstead of just the, you Heritage Reporting Corporation (308) 64ae00
}
59 l
1 know, the minature, the smaller examination and we said that 2
the licensees should be permitted to use something like the 3
ISAP process to integrate their response to the many new 4
requirements coming out of both the IPE examination and all 5
the other USIs and so forth.
6 As I look at the generic--the last draft of 7
the generic-letter, the staff has really--although they 8
say that they can't really accept the ACRS recommendation, 9
this is too much, they have really got, as kind of after 10 thoughts, you know, they're allowing the potential for 11 adopting each one of these positions.
12 I mean, although they permit the, you know, an IPEM
(';
13 or whatever it's called, to be used, they really suggest that
~ ~.
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the PRA is the best way to go.
14 15 The latest draft of the generic letter, Page 8 16 now says, In addition, a utility in doing an IPE, if it g;
discovers that they can figure out some way to resolve a USI 18 or a generic issue in the process of their IPE examination, 39 that the staff will go along with the arguments along this 20 line.
21 You know, that's really, essentially, what we sug-22 gested.
Then on Page 9, they say that if the staff believes 23 that if the licensee has a PRA that they should be permitted to use the ISAP approach.
l 24 25 I guess I'm a little confused as to why the staff Heritogo Reporting Corporation (mi n. on
^)
60 t
was sort of objecting to the recommendations in our letter t
2 when the IPE generic letter, in fact, incorporates all of
(
~
those things, although it doesn't incorporate them as sort 3
4 of the main thrust of the program, but only as kind of af ter 5
thoughts.
I don't know, I'm just throwing that out for 6
discussion.
I guess I'm not sure what we ought to do or 7
where we should go.
8 CHAIBRAN KERR:
There is a parallel to this in one 9
of the New Testament Parables.
10 MR. WARD: Okay, 11 DR. LEWIS:
In what?
12 CHAIRMAN KERR:
One of the New Testament Parables
(~}
13 in which a story is told of two sons, both of whom are told t7,
(_)
34 to go out and do something by their father.
One said, sure 15 dad, and he went out and didn't do a damn thing.
The other 16 one said, I'm not going to do it, I got something else to do, 17 l but on the second thought, he went out and did it.
And the jg question asked by the teacher was, which one obeyed his father?
39 20 DR. LEWIS:
What was the answer?
i 21 i CHAIRMAN KERR:
The answer is still to be deter-22 mined.
i 23 l MR. WARD: I'm not sure where that leads us.
I i
24 still think their integration program, their IPE, is kind of ll 25 ragged and I think our letter was attempting to---well, it was Heritage Reporting Corporation (mi.a..
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suggesting that they could provide a little more coherence 2
to it along the lines we were suggesting, a little more 3
integration.
4 Maybe it's coherent enough, I don't kncw.
g CHAIluiAN KERR:
A number of things that we suggested 6
they have not considered practical. One is a consideration 7
of external evento in their initial process and the other 8 i things they are making--they are pointing out the possibilities, 1
9 but they are not suggesting that this is'the only way to do Y
10 it.
And, I had not thought about it very much until yes-11 terday, but the point was made by the staff and I think it's 12 correct, that they were instructed by the Commission to develope, 13 with the industry, a method that was not quite as elaborate as f
a PRA and the IDCOR Program did that and having been told by g4 li 15 j the Commission to draw up this program and use it, the staff 4
h feels that it is not nroper to discard it once this process 16 i
l has been put in place.
I think there is something there, to 17 l
i that argument, 18 DR. SIESS:
i am not as concerned as I was about the g9 20 way they are handling external events, particular seismic and 21 I think there is some merit to the argument that we can solve 22 l the seismic problem by a.ifferent approach than the PRA type 23 thing, that doesn't bother me as much as did and maybe not as much as some other people, 24 l I still think they are mislabeling this thing as 25 Heritage Reporting Corporation inn u..
I r'2 62 I
as integrators.
2 CIIAIRMAN KERR:
You mean what we have?
3 DR. SIESS:
Even for the IPE part, not to mention 4 i all the other things in there, integration things.
To me l this is their accident policy statement and it did involve S
6 an integration, it mentioned the regulations, it mentioned the h
7 [ GSIs and it mentioned possible outlines and I don't think that O
g this is as integrated as this policy statement was.
It's mov-9 ing that way.
i 10 I don't think we'11 know what it is until somebody does it.
I don't think the staff knows how they're going to 11 12 l handle it itil somebody brings them something and it will be ll
(~i 33 l
like a lot of other resolutions, after they have done 3 or 4 1
i 34 j pr 5, they'll begin to see where they're going and the indus-h 15 [ try will begin to see where they're going.
16 If I were industry, I don't think I would want to h
17 ] be the first one in, but that's debatable.
You might get by i' with more of them.
The first one may be the back up to the 18 j 10th one. I don't think they have given us enough credit for 39 20 what they have changed in this, t
l CIIAIRMAN KERR:
We don't neid credit.
21 22 MR. WYLIE:
I think their answer, Dave, Page 16, 23 i n 2.7 of--what is this thing?
It's the plan itself, They make the statement, in summary, that they believe that the 24 25 l generic letter meets the intent of the Commission's Severe Heritage Reporting Corporation o,n one..
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_g Accident Policy and also' addresses most of;the concerns expressed by_ tlie ACRS, ' however,: to expand ' the scope and _ meet-2
.O the--we ' sent out, not'a letter, because of_ substantial delay 3
A in the total programh, so1they don' ti propose - to -do anything.
y 4
5 In summary, I guess it.was_ reasonable.
6 I guess'I thoughtthat[twasveryforceful.
- I t' 7
says use the PRA Level II and include external events-now, 8
is basically what-it said and they said if they do,-it will 9
take them a year delay.
MR. WARD: Well, it-would take a year delay in some-10 i
thing, but we heard, for example, that containment changes gg 12 that might be made in the containment systems aren't going to 13 be required on the basis of the initial IPE anyway, but we'll Q-()
wait until there is some sort of--I don't know what the timing g4 15 f these things is, if there is some sort'_of-a'more generic 16 response required on these issues.
DR. MICHELSON:
Question.
Is there a separate ITE 37 18 for external events coming later if you leave them out now?
19 DR. SIESS: It depends on what external events 20 you're talking about.
21 DR. MICHELSON: Well, there's a full set.
22 DR. SIESS:
Well, seismic, they think they can 23 develope an approsch, like margins approach.
24 DR. MICHELSON: Then there's the other members of O
25 evea-Heritage Reporting Corporation
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64 DR. SIESS: Floods, tornados--
2 DR. MICHELSON:
Internal, external 3
DR. SIESS: That I haven't heard them say.
4 DR. LEWIS:
Is that going to be an IPE later?
5 CHARIMAN KERR:
If I understand the meaning of 6
these various acronyms and I'm not sure I do, the IPE is 7
to describe the process, which is an individual plant examina-8 tion and will ultimately be both internal and external events.
9 The IPE then is to describe the technique developed 10 by IDCOR and is an alternative to a PRA and the part of it 11 that exists now refers only, so called internal events.
12 Another segment, that will be developed by the f'
13 staff will deal with external events.
Together, I think, ij those two will constitute the IPE.
34 15 DR. MICHEISON:
- lut having developed the guidance, ldo the utilities than have to go back and do another IPE?
16 CHAIRMAN V"Rr:
They will not have completed the 17 b
18 lIPE until they do the external events, I think.
l DR. MEICHELSON: Okay.
So it's just an on going g9 20 thing and as the guidance is developed, then they will incorpor-23 ate it into their PPA?
22 CHAIRMAN KERR That's my understanding.
DR. MICHELSON: Okay.
Thank you.
23 DR. CARROLL:
They're making the point that you 24 25 should do your internal events first and in that way you can Heritage Reporting Corporation m m....
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easily go back to the external events.
(
2 CHAIRMAN KERR: It's the IDCOR position and IDCOR l
i 3
!still exists as an entity, at least it's the position of some of 4
the people who have followed with IDCOR, that it may be--well, S
I've seen a letter, I think I can dare to say we really don't l
6
'think external events are very important, but I don't believe the
! staff--
7 l
l s j DR. MICHELSON:
I have seen such claims, but I 1
Nhaven'tseenthe, you know, a good basis for reaching such con-9 I
go ! conclusions, a good analytetical basis.
Since I have reen, for 11 instance, a single good fire PRA.
The only one we have seen i
12 in some examination, was the work that Sandia did and they drew 1
ladifferentconclusion,
/~')
13 t
's CHAIRMAN KERR:
Well, in particular to me then, (j
34 ;
15 we ought to say the thing ought to be studied further because U
l 16 it Could be a signficant contributor, h
17 h DR. MICHELSON: I think the other aspect is that it 4
18 lde s appear that the PRAs--they said it does appeur that the j
PRAs that were done, were not done adequately enough to draw g9 djaconclusionandit'sanonproblem, 20 h
21 MR. WYLIE:
Page 15 of this document, they discuss s
22 that in some detail, i
DR. MICHELSON:
I wasn't at t e subcommittee l1 23 1
J l meeting, I didn't get there.
I have rece ived the material, but 24 h
25 I haven't had a chance to read i. yet.
Heritage Roporting Corporation
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3 66 MR. WYLIE: It says--
g 2
DR. MICHELSON:
I'11 read it when I can, 3
CHAIIUiAN KERR:
1 would propose, in fact I have 4
already started a draft of a letter commenting on the 1.7.
I 5
just comment on the IPE.
Unless you think it's not a good 6
idea to comment, I would suggest that we try to put together lla letter and--
7 i
g MR. WARD: I think it's a good idea.
9 CHAIRMAN KERR:
And I would propose that somewhere 10 we suggest, encourage, recommend that if 1150 is completed jg that it be peer reviewed.
MR. CARROLL:
Unless they have sorae reason to 12 l
(~^ ;
g3 think that they can do it right this time.
L'~
DR. LEWIS:
The best way to avoid criticism is not g4
{ have a peer review.
15 I
DR. SIESS:
Because it's going to have appendix 16 17 responding the first peer review.
That may be an Appendix B.
I gg l DR. LEUIS:
Back in my school, we would find all our students excellent by abolishing the exams which test the.
g9 I
DR. SIESS:
They have got to give i t a new number,
20 and then they can start over.
21 DR. LEWIS:
What did Themis say about a peer 22 i
review?
23 CHA.'..KMAN KERR : He said that they were discussing y
various options and I don't remember what the other end of the 25 Heritogo Reoorting Corporation m m :-
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discussion was.
And this was, in effect, what Mark Cunning-2 ham said yesterday.
3 DR. LEWIS: The only thing that disturbed me about 4
his comment was his use of the term, "some kind of peer reviev.,"
5 because that's worse than none.
6 MR. CARROLL:
Certainly if you read the previous 7
peer review, they believed they were going to get another shot 8
at the document.
h CHAIRMAN KERR:
Somebody did make a statement 9
to chat that was not good to be done.
4 MR. CARROLL: I gather they have decided not to use 12 this group again.
~
MR. WARD:
They need to get some different peers.
13,
l 14 DR. SIESS:
That has advantages and disadvantages.
1 15 j
The next time they'll have two peer review groups doing it 0
16 l
simultu.Mously so they can pick one of them for the second
[l round.
17 1
I 18 l DR. LEWIS: That's known as comparison shopping.
MR. WARD: In the letter, it seems to me that we g9 l
i 20 might also might want to say something about the definitions 21 that are involved here.
There is a lack of definitions. I 22 mean, it's not at all clear what severe--what various speakers 1
l 23 l
or writers, what they mean by severe accident, for example.
)
i 1
24 g I guess we should go back, you know, it can r..ean 25 anything you want it to, but there should be some agreed on 1
Herito5o Reporting Corporation j
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b 68 definition and everybody doesn' t seem to be observing the g
one that was given in the Severe Accident Policy Statement, 2
which we heard Mr. Cox, I guess.
I didn't remember it being 3
defined as he defined it thougn.
4 MR. WYLIE:
Are you sreaking of the line that 5
says, where a substantial amount of the core is melted, is 6
that what you're referring to?
7 MR. WARD: Well, you see, the way he defined it, g
I 9
the way Carlyle would define it is that it's a set of l
10 l
challenges Seyond design basis challenges.
The way some l
peuple define it, is it's a accident that actually involves 33 substantial core damage or melting and the way other people 12 define it is it's an accident even beyond that, that involves J';
33 q) damage to the core that challenges the containment.
34 LR. MICHELSON: There's another school that says 15 it's really the dose to the public that you look at to decide 16 whether you got a severe accident or not.
17 MR. WYLIE:
Now you have the large release and 18 i
[
they use--
39 l
20 l DR. MICHELSON:
No, no, just beyond part 100.
If it's within the 100, is it a severe accident?
TMI was within
- g 100.
Was it a severe accident?
It all depends on which 22 definition that you use.
23 If y u use the beyond 2200 degree definition, then 24 it was severe.
If you use dose to the public, it wasn't 25 Heritage Reporting Corporation non u.4.
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severe.
h MR. WYLIE:
A definition is needed of what does 2
3 substantial core damage mean.
Is it exceeding 2200 degrees, is that substantial core damage.
4 CHAIRMAN KERR.
Do you think it would be well to 5
6 have a commission approved definition of severe accident?
7 OR. LEWIS: It would be helpful if we defined it 8
because I got into a pickle long ago in which we defined a 9
core melt as something which need not melt any part of the core.
I thought that was dumb at the time we did it.
10 i
gg Now, if we talk about challenges to various systems, 12 we'll end up defining a severe accident as something which 13 isn't any accident as all.
I think that's the road to lunacy.
G MR. WARD: I think one role this committee can take g4 15 is to not--for example, in this case, is not insist on a l
particular definition, but just point out--maybe the alter-16 17 !
native definition that people should agree on or be careful l
I gg about which one they're being used to set policy or--
DR. SIESS:
Well, it must be some--explicit or g9 20 implicit definition of a severe accident in the PRA and the 21 IDCOR method.
I 22 The PRA only goes--it doesn' t get that fine.
It assumes loss of assured core cooling and then you start wonder 23 ing what happens to it in containment.
The other one must 24 have something like that.
Maybe it ought to just be gotten 25 Heritage Reporting Corporation j
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in the open where we know what it is.
2 DR. SIESS:
Am I correct that they have now defined 3
a large release as one that goes to 10
?
Does the BWR-3 4
or the PWR-4?
5 MR. WARD: No.
I 6
i DR. SIESS:
Well that'.c in--
7 MR. WYLIE:
Well you say they have defined it.
8 I don't know.
Supposedly that was going to be defined in 9
the Severe Accident Implementation--I mean a Safety Goal 10 Implementation.
11 DR. SIESS: The thing is that if we tear up the 12 selecting importance of the severe accident sequence, they 13 got 5 criteria.
One is 10 -
and more for reactor year to i
14 core damage which, again, core damage not being defined 15 right here.
Five percent or more to the total core damage i
j frequency and then one of them, functional sequence that has 16 17 a core damage frequency greater than or equal to 10 ~
per 18 reactor year.
Core damage frequency greater than or equal 19 to.'. 0 ~
and that leads to containment containment failure 20 which can result in a radio active release magnitude greater 21 than or equal to the BWR or PWR-4.
22 DR. LEWIS: Whatever that means.
23 JR. SIESS:
Yeah, I don't know what that means.
24 DR. LEWIS:
You know, it's fundamentally illogical, 25 l to define severe accident in anyway that involves a l
l Heritage Reporting Corporation vw.
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probability because you're going to end up asking what the 2
probability of this thing is and really they are two separate 3
i steps.
One is to define what it is you're talking about or 4
what sequence it is that you're talking about, what damage and 5
the next step is to talk about the probability of it.
You 6
shouldn't mix them up.
7 MR. WARD:
It's the level of consciousness.
8 DR. SIESS: But the sub point of an event tree, 9
you know, when you get right down to doing this
- thing, 10 there is some point on an event tree that they can label 11 as this is severe accident.
You reach this point on the 12 event tree--
l
)
13 l MR. WARD:
But that's in terms of a consequence urs i
i hl Cl 14 not in terms of--
l l
15 DR. SIESS:
In terms of core cooling or core damage.
h 16 ]
There's another point out there, further out in the event f
tree--
17 d
h 18 ii MR. WARD: Coro damage can be a consequence.
tl 0l DR. SIESS: I'm sure in a Pila, you can pick some 19 20 point that--is the event tree the one that goes this way?
21 DR. LEWIS:
Yes.
22 DR. SIESS:
The default tree goes this way?
DR. LEWIS:
That's correct.
23 24 DR. SIESS:
At some point on the event tree, you can say this is core damage.
There's some point out here that.
25 l
l Heritage Reporting Corporation (202) 628 4646
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you say is a release and maybe one of those columns is a large h
2 release.
3 MR. WARD:
Sure.
4 DR. LEWIS:
But that statement is true regardless 5
of whether you have assigned probabilities to the--
6 DR. SIESS:
Right.
MR. WARD:
Right.
7 :
}
8 DR. SIESS:
In the process though, there are 9
probabilities assigned to those events.
10 DR. LEWIS:
- Later, gg DR. SIESS:
But somebody has got a definition because 12 whether everybody is using the same one or not.
I
[^;
13 DR. LEWIS:
I have some sympathy for Dave's sugges-x
(_ /
tion that maybe it would useful for this Committee to supply g4 15 a menu of possible definitions of some of these ambiguous i
16 terms, just to sort of lay out the universal discourse, either 17 l with or without a recommendation for any particular one, y!
DR. SIESS:
We have written several times, talking gg 39 about the difference between core damage and core on the floor 20 DR. LEWIS:
Yeah, that's one thing.
21 DR. SIESS: And I don't know yet what the staff means 22 by core--they use the term core melt in here.
MR. WARD:
Yes.
23 i
l DR. LEWIS:
They differ, but we also have the con-34 25 flict with people using the same meaning between assured i
Heritage Reporting Corporation (292) 628 4444
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loss of core cooling and loss of assured core cooling, which 2
are two entirely different things, but they have both been 3
used by this committee.
4 MR. WARD:
Can I bring up one other point that 5
maybe the letter ought to touch on, another definition.
6 We talked about it at length yesterday, but no 7
really satisfactory conclusion was reached and that's the 8
definition of a--what do they mean by severe accident issue, 9
you know.
10 I don't know if you plan to touch on that in a lj letter, but it seems to me that that's 12 DR. SHEWMON:
You started out by what is the so E'
13 called Class 9.
You know what the first 8 are and so, does 14 the Class 9 bother you, do you still have the same problem wit h 15 that?
16 l
MR. WARD:
I don't understand.
I saw a list of f
17 things up there that they were calling severe accident issues.
18 DR. SHEWMON: The history, as I understand it and 19 there are certainly people in the room that know it better 20 than I, was that there were these 8 stages which were the 21 design basis accidents and then the Wash Fourteen llundred 22 concluded the maybe most of the risk was actually from what l
23 came beyond the design basis accidents and that got called 24 Class 9.
25 DR. SIESS:
I'm not sure that helps a lot because--
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74 l
1 DR. SHEWMON:
I don't understand where he's coming 2
from because he says everything can lead to a severe accident 3
and he sort of sweeps overything into one--
4 DR. SIESS:
Let me give you an example of what 5
bothers me with Class 9.
A 5 percent containment leak rate 6
following a LOCA would be Class 9 because the design basis 7
was a one-tenth percent a day leak rate.
l 8
l Class 9 was everything beyond the design basis, 9
some of which would be a lot less important than others.
l i
10 DR. SHEWMON: But when we talk about severe accidente 11 with risk to the public, it is a sub set of problems that, 12 I think, are reasonably well defined or better than Dave l
was feeling yesterday, I think.
('s 13
\\ c's.
l i
14 hr DR. MICHELSON:
It's possible that you can have a severe accident that has no risk to the public such as TMI
]
15 i!
!q which might, by some definitions be a severe accident, but 16 17 there wasn't a risk to the public, il
'l 18 I
DR. SHEWMON:
The Governor of Pennsylvania might l
l differ on what the risk to the public was.
19
(
20 MR. MICHELSON:
As measured by actual release, of i
21 l!
course, as perceived.
1 22 DR. KERR:
The need for a definition of severe 23 accident.
The severe accident issue, if there is anything 24 that appears in the paper labeled severe accident issue paper h
25 that one is easy.
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DR. LEWIS:
You know, I"m not as offended by the
' _L 2
failure to define severe accident as I am about other things because the definiti.on of severe accident has a consequence, jj 3
ll 4
l you know, however you do it, it only has a consequence on 5
the regulatory structure and that is what you put into a 6
particular part of regulatory activity and it has been said 7
before, sort of like besuty.
I 8
I know a severe accident when I see a severe acci-9 dent and, in fact, in my view, the fact that TMI was l
locked before it did any damage to the public, although 10 11 there was a lot of damage inside makes it not a severe acci-12 dent, in my view, but I recognize that people who had to pay
/,
13 for it may feel quite differently about it, so that there s
()
34 I would be a difference of opinion, but still like beauty, I
d 15 l generally speaking, from experience, you know what you're h
talking about and that doesn't offend me.
16 I
17 j Again, only because it only has regulatory impli-0 18 l
cations.
These other things which may have implications for how you're going to actually deal with the mitigation g9 20 and prevention, I think, are more important.
21 DR. SIESS:
Another term that never got defined was vulnerabilities, sometimes referred to as "out lies,"
22 and the policy refers to plant specific vulnerabilities.
i 23 That either assumes that there are no generic 24 l
vulnerabilities of that we already know what they are, some h
25 Heritage Reporting Corporation
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Some times we call them "out lies,"
2 and sometimes we call them vulnerabilitics and I think 3
somewhere they're going to develope a definition, whether 4
they can start off with one, I don't know.
5 DR. MICHELSON:
Just to get a little more informa-6 tion on definitions.
What do we think the definition of 7
the design basis accident is?
8 DR. SIESS:
Read Chapter 15 of the--
9 DR. MICHELSON: I understand where I might find j
to some of it, but is there more than one accident described 11 in Chapter 15?
12 DR. SIESS:
Yes.
l3 DR. MICHELSON:
Which one of those accidents 3
=
d 14 described is the design basis or are they all design basis?
15 DR. SIESS:
All design basis, i
16 DR. LEWIS:
All of them.
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17 ll DR. MICHELSON: And they have different levels of I!
j!
release and so forth, so when you talk about a design basis 18 I
19 accident, you really have to tell which one you're talking 20 about.
21 l DR. KERR: Any other suggescions for things that can l
22 go in the letter?
23 DR. SIESS:
I'm looking here and seeing words like 24 core melt in some places, core damage in other places.
DR. KERR:
Any further discussion?
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DR. MICHELSON:
Is that draft letter in the 2
hand out?
7S U
3 DR. KERR:
No, it is not, ok-)
4 DR. MICHELSON:
Do we have a copy of it?
5 MR. WARD:
Dean passed it out a little while ago.
6 DR. MKCIIELSON : 0:ay.
7 DR. SIESS:
Are you talhing about the draft letter i
8 that we would send or the draft IPE?
9 DR. MICllELSON:
Tne one that we will send.
YOu 10 don't have that?
11 MR. WARD: We do not have that.
12 DR. MICHELSON:
Okay.
I)
13 DR. SIDSS: Did we point out that the definitions are Cy)
I
'u' 14 uncertainties?
15 DR. KERR: I'm sorry, 16 DR. SIESS:
Add them to the list of the uncer-17
.ainties.
18 DR. KERR:
Anything else we want to discuss about 19 147?
20 (No response) 21 DR. KERR:
We will take a break and reconvene 22 at a quarter to 11:00.
~
v 23 (1:horcupon at 10:30 a.m.,
the subcommittee 24 took at brief recess.)
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1 CERTIFICATE 2
()
3 This is to certify that the attached proceedings before the 4
United States Nuclear Regulatory Commission in the matter oft i
5 Name: ACRS - 339th Meeting 6
7 Docket Number:
8 Place Washington, D.
C.
9 Date:
July 14, 1988 10 were held as herein appears, and that this is the original 11 transcript thereof for the file of the United States Nuclear 12 Regulatory Commission taken stenographically by me and, 13 thereafter reduced to typewriting by me or under the direction 14 of the court reporting company, and that the transcript is a 15 true and accurate reccrd of the foregoing proceedings.
16
/S/
A
/* -
l 17 (Signature typed):
IRWIN(
fCOFhENB,pdRY l
18 Official Reporter 19 Heritage Reporting Corporation 20 1
21 22 23 l
l 24 l
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Heritage Reporting Corporation (202) 628-4888