ML20197F423
| ML20197F423 | |
| Person / Time | |
|---|---|
| Issue date: | 06/03/1988 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1674, NUDOCS 8806130249 | |
| Download: ML20197F423 (177) | |
Text
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UNrFED STATES NUCLEAR REGULATORY COMMISSION
.............m ADVISCR'l CO:0!ITTEE ON REACTOR SAFEGUARDS
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In the Matter of:
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3 3S th GE: ERAL tiEETING
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.il DATE:
June 3,
1988 PAGES:
142 through 29 LCC.iT I ON :
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1 PUBLIC NOTICE BY THE s'
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 accepts any responsibility for errors or g( )
14 inaccuracies of statement or data contained in this transcript.
15 16 17 18 19 i
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22 23 1
24 25 l
i Heritage Reporting Corporation (202) 628-4888 r-
142 P
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1 UNITED STATES NUCLEAR REGULATORY COMMISSION 2
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 3
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4 In the Matter of:
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5
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338th GENERAL MEETING
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6
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7
- Friday, 8
June 3, 1988 9
Room 1046 1717 H Street, N.W.
10 Washington, D.C.
20555 11 The above-entitled matter came on for hearing, 12 pursuant to notice, at 10:30 a.m.
()
-13 BEFORE:
DR. WILLIAM KERR Chairman 14 Professor of Nuclear Engineering Director of the Office of Energy Research 15 University of Michigan Ann Arbor, Michigan 16 ACRS MEMBERS PRESENT:
I 17 DR. FORREST J. REMICK 18 Vice-Chairman Associate Vice-President for Research 19 Professor of Nuclear Engineering The Pennsylvania State University 20 University Park, Pennsylvania 21 MR. DAVID A. WARD Research Manager on Special Assignment 22 E.I. du Pont de Nemours & Company Savannah River Laboratory 23 Aiken, South Carolina 24 25
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1 MR. CARLYLE MICHELSON Retired Principal Nuclear Engineer 2
Tennessee Valley Authority Knoxville, Tennessee 3
and Retired Director, Office for Analysis and Evaluation of Operational Data 4
U.S. Nuclear Regulatory Commission Washington, D.C.
5 DR. HAROLD LEWIS 6
Professor of Physics Department of Physics 7
University of California.
Santa Barbara, California 8
DR. PAUL G.
SHEWMON 9
Professor, Metallurgical Engineering Department Ohio State University 10 Columbus, Ohio 11 DR. CHESTER P.
SIESS T
Professor Emeritus of Civil Engineering 12 University of Illinois Urbana, Illinois
()
13 MR. CHARLES J. WYLIE 14 Retired Chief Engineer Electrical Division 15 Duke Power Company Charlotte, North Carolina 16 MR. JAMES CARROLL 17 Retired Manager, Nuclear Operations Support Pacific Gas and Electric Company 18 San Francisco, California i
19 DR. DADE MOELLER Professor of Engineering in Environmental Health l
20 and Associate Dean for Continuing Education I
School of Public Health 21 Harvard University Boston, Massachusetts i
i 22 ACRS COGNIZANT STAFF MEMBER:
23
~
Raymond F. Fraley 24 25 i
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NRC STAFF PRESENTERS:
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P&OCEEDINGS (f
2 CHAIRMAN KERR:
Mr. Remick?
3 DR. REMICK:
All right.
Gentlemen, back a few 4
months ago I had the pleasure of hearing a presentation 5-similar to the one we are going to hear this morning on a new 6
thread on the international scene for something called the 7
World Association of Nuclear Opera' ors, and so we have invited 8
in.today Mr. Stanley Anderson, who is the vice president of 9
the International Supply Division of INPO, to tell you about 10 this new development, so it is an informational type of item.
11 Stan indicates that he is most willing and anxious to answer 12 questions as he goes along, so do not hesitate to interrupt.
()
13 I told him he did not need to worry about that from this 14 group, we always interpret, and accompanying him today also is 15 Chet Harris, also from INPO, and I believe the same division, 16 is that right, Chet?
17 MR. ANDERSON:
That's right.
18 DR. REMICK:
Stan, it's yours.
19 MR. ANDERSON:
Thank you very much, Forrest.
I put 20 the mike on just so I would project a little better.
I hope 21' that's all right.
22 Mr. Chairman, it is a pleasure for me to come up 23 here and brief you on the World Association of Nuclear 24 Operators, a new organization that INPO is, has sponsored from
.( }
2,"
the beginning, but before I do the World Association, I just t
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would like to give you a short overview of the current
()
2 international program'at INPO, and because of it's out of the
- i 3-international program at INPO that really came the World 4
Association, so I will just go through that rather quickly.
5 (Slide) 6 MR. ANDERSON:
Maybe the lights would be a good
-7 idea.
Thank you, sir.
8 There is the extent of the program--44 utilities in 9
three countries, and about 185 reactors.
I will go through 10 those countries and tell you what they are.
These are the-11 countries that are currently members of the INPO international e
i 12 procram.
You start out on the Far East, Japan, Korea, Taiwan,
' ().
13 and I have listed the representative organization to INPO.
In l
14 the case of Japan, it is Central Research Institute for the 15 Electric Power Industry.
In the others, I think they are t
16 obvious, like Taiwan Power Company.
l 17 (Slide) 18 MR. ANDERSON:
In the Americas, we have with us 1
19 Brazil, Canada, and Mexico.
j I
20 (Slide) t 21 MR. ANDERSON:
And in Europe, Belgium, England, 22 France, Germany, Italy, Spain and Sweden; as of June 1st, I
1 23 there should be a correction to this slide.
Yugoslavia has f
24 asked to affiliate with INPO, so we are just getting them on j
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l 25 our mailing list as of the last couple of days, so that will j
4 4
HERITAGE REPORTING CORPORATION -- (202)628-4888 j
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actually make 15 countries counting the U.S.
curr
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2 program.
3 DR. SHEWMON:
What is VGB in Germany?
4 MR. ANDERSON:
That is an organization in essence, 5
that I can't tell you the, I don't have the acronym.
I can't 6
tell you what the words, letters mean, but it is a utility 7
organization, certainly not only nuclear, but they have 8
members of all the German nuclear utilities, and therefore, 9
they represent Germany to us.
10 MR. WARD:
Similar question for Belgium.
11 MR. ANDERSON:
Belgium, Belgium currently is 12 Electrondaire, and it is the same type of an organization.
('s q,)
13 MR. WARD:
Both utilities?
14 MR. ANDERSON:
That's right.
15 MR. CARROLL:
It is sort of a German and Belgium 16 ZEI?
17 HR. ANDERSON:
Yes, I think that would be pretty 18 close.
I know in the case of VGB it would be fairly close.
19 HR. WYLIE:
I couldn't remember your previous slide.
20 Did you have Korea?
21 HR. ANDERSON:
Yes, we have Korea.
22 (Slide) 23 MR. ANDERSON:
Now just very quickly, we call that
~N 24 the benefits that are available to the participants.
Now if (d
25 you look at this list, and you look at the list of benefits or HERITAGE REPORTING CORPORATION -- (202)628-4888
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what we provide to the U.S. utilities, there are two major
()
2 items missing, and I think that would be good to point those 3
out.
You don't see the plant evaluations and you don't see 4
the accreditation program.
5 Other than that, the international participants 6
receive essentially what the U.S. utilities receive.
Just 7
very quickly, the data bases, nuclear NETWORK, which is an 8
electronic messaging system, international system, to pass 9
plant information back and forth, the See-In program.
That's 10 the significant event information products, and those products 11 are like significant event notifications and reports, and 12 SOERo, tho significant operating event reports, that kind of
()
13 information workshops, about a dozen a year down at INPO, 14 advisory group, and I am going to talk about that a little bit 15 later, and the technical exchange.
I will go into that a 16 little bit more as well.
Let me just talk about liaison 17 engineer.
In INPO today, we have about a dozen liaison 18 engineers.
They come from the countries that are 19 participants.
They each rate having one with us.
20 And in some case they have two.
Japanese, Japan has i
21 three, but they do part of the LER work for INPO, and part of 22 their work for their company, but it is about a 50/50 l
23 proposition.
Their companies pay them.
We pay them a per 24 diem, but they are valuable input to INPO.
()
i 25 Let me talk about the advisory group down just a HERITAGE REPORTING CORPORATION -- (202)628-4888
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minute.
I just put down the names just in case you might be
()
2 acquainted with some of these gentlemen.
They meet at INPO, 3
usually at INPO, twice a year.
In the past couple of years 4
because of Chernobyl, we have been meeting three times a year, 5
but they comment on our international program and then we show 6
them other aspects of INPO which they comment on, make 7
ruggestions, and we get some very good inputs from them.
8 (Slide) 9 MR. ANDERSON:
The technical exchanges that I talked 10 about, we call it an exchange because we expect to get 11 something out of it when we go to their plants, to different 12 countries.
I just put down a few examples.
These are trips O()
13 we have made probably in the last eight, nine months.
- Japan, 14 as you see, we talked design engineering, outage management.
15 As we were getting our team together, Duke Power 16 heard a' out someone that said they would like to send down 17 like a trainer that adds credibility to our team, so we gladly 18 accept that.
And we were there for about five days.
In 19 Koiea, this was at the end of
'87, was a 1.'
ensing--on this 20 trip, we spent, as you see, a week there.
We had ten people, 21 and this is getting close te an INPO evaluation.
It depends 22 on the country as to whether or not they want us to come and 23 evaluate.
If we asked the Koreans may we conduct an
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24 evaluation for two weeks, they would say fine.
May we send 25 15, 20 people?
That's all right with them.
If you ask other l_
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countries about coming in and doing evaluations, you wouldn't
.()
2 always get that type of response, but I just use that as an 3
example.
i 4
Here is a couple of other ones that we have been on 5
perhaps in the last six months.
We have talked about training 6
in France, England and Spain, and this is the human 7
performance evaluation system, and we have also made a trip to 8
those countries and talked about that.
The most recent trip 9
that we have made is to Taiwan.
Perhaps you have noticed in 10 some of the literature that Taiwan is having a bit of a 11 prcblem with their press.
They have been accusing the company
.2 of workers getting overexposed, that radiation levels were
()
13 high in their plant, Cheng San in particular, so about a month 14 ago or about two months ago we got a call from them, and at 15 Tai Power they said we would like to have you send an 16 assistance team, so we did.
They stayed there for two weeks 17 in that case.
They said we would like to have you look not 18 only at the plant but at corporate as well with respect to 19 these problems.
We did that, and we just sent them their 20 report, and so that I just give you that as an illustration of l
21 how some countries use us.
They want to have these 22 evaluations.
In this case, they want a visit, and so we 23 cooperated with them.
24 CHAIRMAN KERR:
Did they make their report available
()
25 to the newspapers?
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MR. ANDERSON:
We think they will, sir.
We have (n,,)
2 told them we prefer not to be a media event.
We have 3
discouraged that, but we are not sure.
4 These are some of the other international activi'.ies 5
that we are involved in.
We loaned engineers at Electricity 6
de France.
That's our--we have had him there about a year and 7
a half.
We have relieved him an sent another person out 8
there.
We have had our second person now at IAEA.
The 9
engineer we sent there is assigned to the ORST teams.
He is 10 usually the team manager of ORST.
Then this month we will 11 send somebody into Spain.
Then you can see some of the other 12 activities we are involved in, n
(_)
13 MR. CARROLL:
What is the field of activity of the 14 INPO EDF?
15 HR. ANDERSON:
They are using him in their 16 inspection department.
He has been bringing in some of the 17 INPO procedures to their, to their primarily inspection 18 department, and we think the next engineer will do about the 19 same thing.
20 HR. CARROLL:
Inspection in the sense of NDE?
21 MR. ANDERSON:
Bill Wrigley, who is the engineer we 22 sent, was to look at about a dozen, the firefighting 23 capabilities of about a dozen plants.
That was his l
()
24 assignment.
They don't do the types of evaluations--sort of a 25 broad type of evaluations that we do.
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1 MR. MICHELSON:
What are you doing with IAEA?
()
2 MR. ANDERSON:
In IAEA we have an engineer, and his 3
primary responsibility is to be the team manager on ORST.
4 DR. SHEWHON:
What is ORST?
5 MR. ANDERSON:
That is their--I think the acronym is 6
operatioral reactor safety team.
That's very.close.
They go 7
to various plants at the request of countries, country 8
request, and do about a three-week audit and review.
9 DR. REMICK:
Is that their equivalent of the 10 evaluation visits at INPO?
r 11 MR. ANDERSON:
Yes, sir, it is.
12 MR. MICHELSON:
One like they did at Crystal River?
()
13 DR. REMICK:
Calvert Cliffs.
14 MR. ANDERSON:
Yes, Calvert Cliffs, that's exactly 15 it.
So that is just some of the other activities.
So that's 16 a little background on our current program.
17 Now before I talk about WANO, I just want to--World 18 Association of Nuclear Openers, I just would like to give you 19 a couple of notes on that, just a little bit where it came 20 from.
21 Right after Chernobyl, the INPO Board of Directors 22 was looking for ways to increase the exchange of information 23 not only te our 14 countries, but to other parts of the world,
()
24 so they camposed a special committee, a small committee.
At l
25 the same time, our International Advisory Committee appointed HELITAGE REPORTING CORPORATION -- (202)628-4888
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a small committee.
They,. called it a task force, and they
(_%
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/
2
' looked at the problem and they both came to the same 3
conclusion that we shoald have a meeting of CEOs of nuclear 4
utilities on a worldwida basis so it was recommended to us in 5
the fall of '86 to INPu_to get a Committee together, an 6
planning committee, and organize this meeting and have it in 7
1987.
So we got together an international team.
Taiwan was 8
represented, Mexico--Juan Ivcoos--and France, and the UK, and 9
then I was representing the U.S.
and to make a long story 10 short, we had the conference and it was in October of
'87, 11 sponsored by INPO and UNIPEDE, and this is an organization 12 headquartered in Paris.
It is the union--the acronym doesn't
()
13 follow all the words.
It is the union of electrical producers 14 and distributors.
It is about a 65-year old organization, and 15 the EDF has a lot to do with that organization, and through 16 them, they agreed to sponsor with INFO.
It was hosted by EDF.
17 The chairman was Lord Marshall, and the attendance we thought 18 was good.
19 We invited 32 countries.
We picked out all the l
l 20 countries that had operating reactors or soon to be operating l
l 21 reactors, and there were 32, and 29 of the countries showed 22 up, about 130 pcopie.
The countries that did not attend were 23 the Philippines,Romania and Pakistan.
the Philippines wrote a l
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24 nice letter saying they would like to come but their situation 25 was such they just couldn't make it, and the Pakistanis and HERITAGE REPORTING CORPORATION -- (202)628-4888
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the Romanians, I can't te'.il you why they didn't show up.
Just 2
to sh'ow you the countries that were there as part of the list.
3 (slide) 4 MR. ANDERSON:
And the second one--we met for a day 5
and a half,.and:out of this meeting came a resolution, and the 6
heart of the resolution is is this, that there be a world
-7 association of nuclear operators, and there be four' centers 8
with a small coordinating center, and we have got it marked 9
down in London.
Most of.the countries want London, but the 10 Soviets want Vienna, so that's still up in the air.
Maybe you 11 can tell us how to solve that, but that's'the, that's the 12 organization that we are currently working toward.
()
I 13 (Slide) 14 MR. ANDERSON:
A few other points on the resolution 15 that I would like to show you--this is what the, this is what 16 the mission is.
Exchange information, encourage comparisons, 17 stimulating emulation among all the operators.
18 Then the final item is that there be a Steering 19 Committee established sort of to carry the work forward.
Who 20 is going to do the work?
And in the, one of the speeches on 21 the final day, Zach Pate, our president, recommended that Lord 22 Harsha11 pick up this responsibility to chair this committee, 12 3 to carry the work forward, and Marshall did that, and that's 24 what we are trying to do at the Steering Committee, to set it
()
-25 up.
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- L We would like at the next meeting of the executives,
().
2 and I will mention that just a little bit later--Marshall 3
said, Lord Marshall-said he would like to have the 4
organization all set to go, so he tells the executives well,
~
5
.this is the type of-organization we have set up, is this what-6 you want?
And sign up to it, so that's the objective.
7 (Slide) 8 MR. ANDERSON:
Steering Committee, we met the first 9
time on December 2nd.
10-DR. SHEWMON:
To back up on that, the purpose of the 11 organization is to implement principles.
Have you put those 12 on yet?
I 13 MR. ANDFRSON:
I didn't put all the principles 14 there.
15 DR. SHEWHON:
Basically to operate reactors safely 16 and for the benefit of mankind or something?
17 MR.. ANDERSON:
That is some of them right there.
I 18 think one of ' he themes was emulation, was see what somebody 19 else is doing and do it as well he is doing it and do it even 20 better.
21 DR. SHEWHON:
Okay.
Fine.
Thank you.
22 MR. ANDERSON:
That was the idea.
'23' (Slide)
(])
24 MR. ANDERSON:
So we started to meet in December.
25 We have met twice, and excuse me.
I guess I really have gone
-. HERITAGE REPORTING CORPORATION -- (202)628-4888
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over that.
I don't have to do that again, f's We are going to
(,)
2 Steering Committee, we met twice.
3 meet the third time this month, just in about ten days time.
4 We think we have got a pretty good representation, 14 5
countries there.
6 At the December 2nd meeting from Moscow we had Dr.
7 Obegone--maybe some of you have run into him.
He is the head 8
of the Union Research Institute of Nuclear Power Plant 9
Operations.
And the second meeting we had, there was a 10 Russian from the embassy, the scientific advisor.
We are l
11 trying to get people from. from Russia to attend these 12 meetings, actually from Moscow, but we have had a good O
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13 representation.
14 I would like to just stop here and talk about the 15 Secretariat.
INPO London office--we have a small office in 16 London, two-man office.
About a year and a few months ago, we 17 hired a Swede, Thomas Heckritt, that was changing jobs, and so 18 it turned out that he wanted to work in London, so--and his 19 wife found a job in London, too, by the way, so that's why we l
l 20 got the London office really, but it is what--we sent an l
l 21 engineer from INPO to join him and work with him, but it has 22 turned out that these people, these two people in. London have l
23 done the majority of the paperwork on the world association, i
24 so we did something right, and we weren't sure about it when L ()
25 we first did it.
l l
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Now to carry out the work of the Steering Committee:
(3 T_)
2 or to assist the Steering Committee, we have four expert andIamgoingtogointotheseinalittlebStof 3
- groups, 4
detail here, so I just wanted to show you what the groups 5
were.
6 Expert group 1--their job is to figure out how we 7
are going to communicate around the world, how are we going to 8
get this information from these regions to regions, regions to 9
'the coordinating center.
Now we have offered at INPO to let 10 them use NETWORK for the first year or so of operation, and I 11 believe that will be recommended to the Steering Committee 7
12 here in another week or so.
)
13 The chairman of these committees--I put those down i
14 just to show you.
We have used the internationals, and Scanet 15 Nyman from Sweden heads that group up, and they have done a 1
16 very fine job.
This team here I would like to talk about.
We l
l 17 have always wondered since we started talk about communicating 18 around the world how we were going to do it.
In the Soviet
'19 Union, we didn't know anything about what they had, so about 20 six weeks ago, we went to Moscow.
We were invited to go to 21 Moscow primarily to plan for the next executive meeting.
I 22 will talk more about that later, but while we were there, a 23 couple of our people demonstrated that we could communicate 24 from Moscow to, to the Atlantic computer to the NETWORK, and
-()
25 to describe what happened, George Hupperson, who is the INPO HERITAGE REPORTING CORPORATION -- (202)628-4888
158 1
1 person that did this, he said--we went in this organization n()
2 and.it was another institute beside the one we were visiting, 3
and he said I have sat down to a cloned IBM PC, and dialed in 4
my, my identification code and up came with NETWORK, so we had 5
done a lot of research ahead of time in the land line from 6
Moscow to Helsinki and then telenet over to the U.S, and we
(
7 made that connection, so we were pleased that we could do this 8
and we see no problem with that NETWORK as we start to work on 9
that.
10 CHAIRMAN KERR:
In the context of this World 11 Association of Nuclear Operators, what is a nuclear operator?
12 MR. ANDERSON:
We are talking about right down to
()
13 the person who operates the, the reactor, and those 14 that--because we are very sensitive about him getting the 15 information.
16 J
CHAIRMAN KERR:
The people you have been talking 17 about have not been up to now the people that operate the 18 reactors?
19 ER. ANDERSON:
No, not the actual operator.
We are 20 talking about the people that are responsible for operating a 21 nuclear power plant.
22 CHAIRMAN KERR:
Okay.
23 MR. ANDERSON:
But I am glad you mentioned that, Mr.
()
24 Chairman, because I have heard that mentioned so many times as 25 we must get this information to the operators, you know, HERITAGE REPORTING CORPORATION -- (202)628-4888
F3 159 1
around the world.
I don't want to overdo this, but so many of s
p) 2 our colleagues are so sensitive about getting people informed.
(.
3 This is the expert group 2.
Their job is what are 4
we going to send now that we have decided to do this?
And we 5
are working on that.
We think we have a good plan, and we are 6
going to start out very simply just to do event reports, and 7
then I think this will, the way we will start out, just things 8
that happen in the plants, and then developing some good 9
practices,.and then maybe some operator-to-operator exchanges, 10 send people.
11 CHAIRMAN KERR:
What does operator mean in that 12 context?
()
13 MR. ANDERSON:
That means the people that cperate 14
_the plant literally.
15 DR. SHEWMON:
This is a licensed operator or plant 16 manager?
17 liR. ANDERSON:
I would think we would want to get 18 down to licensed operators, as well as plant managers.
We did 19 a,
we had a, sort of a trial run on this about a month or so 20 ago.
Maybe it was about six weeks now, where expert group 2 21 met in Atlanta.
At their meeting, we asked Duke Power if they 22 could come down there and visit the plant as well as corporate 23 headquarters in Charlotte, and they did, and these people were 24 on the operator level, admittedly supervisors, but operator
[}
25 types, and they talked about sharing of operator experience, HERITAGE REPORTING CORPORATION -- (202)628-4888
160 1
and that was the theme, so that's sort of what we are going to
(_,7 2
try to do in the future.
Again, we have a Belgium as the 3
chairman of the group.
4 (Slide) 5 MR. ANDERSON:
Expert group 3 has a tough job.
They 6
are trying to draft a charter for the organization, and they 7
have done that.
We have, we have done several drafts, and 8
that will be presented to the Steering Committee in our next 9
meeting in a couple of weeks.
10 CHAIRMAN KERR:
Have you adopted an official 11 language?
12 MR. ANDERSON:
Yes--English.
Everybody has accepted
("i
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1?
that.
14 (Slide) 15 MR. ANDERSON:
Expert group 4, that's the group I 16 serve in.
Let me go back to the Paris meeting.
At the 17 meeting, Lord Marshall suggested to Minister Loconon--he was 18 the Russian representative at the meeting.
He is the Minister 19 for Atomic Energy.
He has a Ministry for Atomic Energy, so 20 Marshall said to Loconon, he said we would like to have the 21 next meaning in Moscow, and the Minister was, he didn't say l
22 yes, or he didn't say no, but you know, he indicated he was 23 positive toward it.
And then after that, we were working on I")
24 that, trying to get an answer, can we have the meeting, and it U
25 is, our objective really was to have it within a year's time.
HERITAGE REPORTING CORPORATION -- (202)628-4888
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161 ll We didn't want to lose any momentum so we didn't want to wait
()
I2 forever.
We. wanted to have it in Moscow if we wanted to make l3 '
sure the Russians would be involved'in this project.
4 So about a couple of months ago, we suggested to 5
them'and we, that is our committee, our. expert group, we 6
- suggested-to the Russians that we have our-expert group 7
meeting in Moscow to her plan for the next meeting, and I was 8
somewhat surprised they said yes.
And so about ten of us went 9
over.there, and held our meeting.
They were very receptive.
10 Our primary point of contact was this Dr. Obegone from this 11 institute.
I had met him on two occasions.
When I gave him 12 my card that said INPO, he said on both occasions I am the
+
L().
13 INPO in Moscow.
Now I still don't know how close the
~
- 14
. organizations are, but they have about 3,000 people.
We have 15 400.
They do research, and of course, we don't, but there is
~16 some similarity.
But my primary contact was with him.
17 They were very well prepared for the meeting.
They 18 had really gone all out.
The other contacts we had there at 19 the meeting were from the Ministry, and we were pleased with 20 that because they were a little more in the decision-making 21-category we thought.
In fact, we were welcomed by Minister 22 Lapshun, and then on our final day there we met Minister j
23 Veronun, and I mention those names because maybe you are
()
24 acquainted with them, but we decided on the meeting.
It is 25 going to be on May 16 through 18 in Moscow, and they will HERITAGE kEPORTING CORPORATION -- (202)628-4888
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=
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sponsor it and they seem-very enthusiastic about that.
N)
L 2.
We have had that confirmed by them.
The chairman in
.3 the group is Boris Saitchiski.
I don't know if you have run 4
into him, bu't he speaks,'he is an EDF person and.a' Frenchman, 5
but he speaks Russian so that has been of: great help to us.
6 By the way, our meeting in Russia when we'were there 7'
for our meeting here six weeks ago, it was all translated 8
between Russian and English, but I thought we got along pretty 9
well.
10 We talk about regional centers--just a couple more 11 slides--and as I mentioned, we agreed to sponsor one.
We 12 have, at first we talked about having a se'parate organization, O
A_/
13 separate regional center, but the internationals encouraged us 14 to have a company located within INPO.
They said you just got 15 too many things started.
Why do that?
Why start a separate 16 organization?
So we have gone back to co-locating-with INPO.
17 ~
We are going going to have our first organizational meeting on 18-July the 14th.
We have invited all the countries to attend 19 actually because that's the spirit of the resolution, that i
20 there would be no geographical boundaries, but very 21 specifically, we have invited Canada, Mexico, Brazil, 22 Argentina, and Cuba, and we were prompted to invite the Cubans 23 because just a couple of weeks ago we had dinner with them up R({}
24 in Charlotte.
Zack and I went up there when they were hosted 25 by Duke Power and maybe some of you met them as well.
They 1
HERITAGE REPORTING CORPORATION -- (202)628-4888
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v 163 1
were the two gentlemen that were at the Paris meeting, by the I )
2 way.
One was from their ABC, and another from a radiological 3
institute.
Those are the ones we have invited to our meeting.
4 We just have a lot of work to de getting organized.
5 Obegone's organization will sponsor theirs.
Paris 6
is getting along quite well.
They have moved along.
They 7
have had several meetings.
They have even appointed a 8
director, interim director.
In Tokyo, they are in their 9
second meeting today, as a matter of fact.
10 At the first meeting, you see they had the Chinese 11 mainland.
Chinese Indians did not come at this meeting, and I 12 just got the word on that because somebody called me from
,(j 13 Tokyo, that all of them are there, and 1 think that's quite an 14 accomplishment on the Japanese part.
They are very working, 15 very hard on this to get, to get the, for one thing, get the 16 two Chinese to come.
17 By the way, in the Paris meeting, the way that the 18 Chinese, the Taiwanese and the Chinese would come was for no 19 organizations to be listed and no countries, so that's the 20 only list we had was strictly names, and that's what brought 21 them both there.
22 DR. SHEWMON:
Did the mainland Chinese have any 23 power plants that generate electricity that are nuclear t
24 fueled?
V) 25 HR. ANDERSON:
No, sir.
HERITAGE REPORTING CORPORATION -- (202)628-4888
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DR. SHEWMON:
They have been building several for (n,)
2 years, and may be getting. closer this time.
3 MR. ANDERSON:
That's right.
Well, I don't know how 4
close they are.
You probably--for the one near Shanghai, 5
that's the one they cay they are building, and then there is 6
the project in Dabainee, Hong Kong.
Framtome I think you 7
could say has a lead in--they are building two units down 8
there.
9 DR. SHEWHON:
So they are serious at least.
10 MR. CARROLL:
I talked to them, some of the people 11 from Hong Kong recently, and it sounds like that project is 12 moving ahead.
(*h
(_)
13 MR. ANDERSON:
But that's the story on that center.
14 DR. REMICK:
U.S. membership, is it restricted to 15 U.S.
utilities through INPO, or would places like DOE be 16 invited to participate?
17 MR. ANDERSON:
For the U.S.,
it will be a membership 18 through INPO.
That's INPO will represent the U.S.
plants.
19 Now that's, that's how we see it today.
As far as the 20 region--but that's a good question.
When we have our meeting, 21 our first organizational meeting, let's say Mexico comes, and 22 if they all come and thuy want to join, we want to have a U.S.
23 utility person sitting t' that meeting.
Not me; I will
()
24 be there, too, to help out, because I believe the way we have 25 got it set up, we think I will be double hatted as director HERITAGE REPORTING CORPORATION -- (202)628-4888
165 1
for the first year, but we will have the utility in there.
()
2 But as to, to representation, it will be through INPO.
That's 3
the way we think.
4 MR. CARROLL:
Have there been concerns raised as to 5
the charter of this organization vis-a-vis IAEA?
6 MR. ANDERSON:
Yes; oh, yes.
Thank you for 7
mentioning that.
At the meeting in Paris, all the speakers 8
were U.S.
utility, were utility, were associated with 9
utilities.
I might mention that the CEOs had a very strong 10 contingent.
There were CEOs there and Bill Lee spoke, Joe 11 Farley, and several others, but the only non-utility person 12 was Hans Bricks, and that was done purposely, that he would be
(~.
(/
13 the, that it wouldn't be open to other organizations, the 14 meeting.
They were there as observers, but they were not on 15 the program.
It was done very specifically for that reason.
16 Now on the other hand, our interim Secretariat there l
17 has kept IAEA informed step by step as we have gone along.
18 MR. MICHELSON:
It is quite clear that this is a 19 parallel organization in the sense of many of your proposed
(
l 20 activities are presently IAEA activities as well.
You know, H21 it is not clear how this finally shakes out.
If I underetand 22 your organization correctly, it is quite a parallelism.
l l
23 MR. ANDERSON:
Oh, yes.
We are trying to stay very 1
()
24 close to them.
25 MR. MICHELSON:
But that's, now it just isn't clear i
HERITAGE REPORTING CORPORATION -- (202)628-4888
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how you can have two organizations doing one job when IAEA is
-3
(_)
2 not a, it is a governmental type level organization, but it 3
has no regulatory authority or anything of that sort, is 4
strictly voluntary.
5 DR. REMICK:
I don't think it has a heavy 6
involvement in utilities.
7 MR. MICHELSON:
It has a heavy involvement with the 8
government, but it does inspections, through.
It does 9
technical evaluations which are proposed here.
It does a 10 number of things--operating events.
11 MR. WARD:
Do you think, will this organization take 12 over these, what did you call them, ORSTs?
()
13 MR. MICHELSON:
I should think not.
14 MR. WARD:
Will that sort of disconnect in the 15 logic?
16 MR. MICHELSON:
It will have its own ORSTs.
17 MR. ANDERSON:
It certainly won't have ORSTs in the 18 next couple of years, an ORST, but we would hope--that you l
19 talk about INPO's international program.
All those, the 20 elements of that program, I hope that we see that incorporated l
21 in WANO in years to come, but there are a lot of parallels.
22 We are staying very close to them, and we are trying not to 23 duplicate as well.
l 24 MR. MICHELSON:
By we, you mean WANO versus IAEA?
l
{}
25 MR. ANDERSON:
Yes, staying very close to them, 1
l HERITAGE REPORTING CORPORATION -- (202)628-4888
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trying not to duplicate.
See how well we can do it.
(~h s._/
2 MR. MICHELSON:
A number of your duties you have 3
identified, it isn't clear how you are identifying them.
4 Analysis, IAEA dcas--maybe not well, but it does it.
5 MR. CARROLL:
They have produced standards which are 6
probably comparable in some sense to good practices as we-know 7
them in the INPO context.
8 HR. ANDERSON:
They have a data base.
They have the 9
IRS system.
10 MR. MICHELSON:
It is comparable to the NRC's 11 inspection process versus INPO's inspection process in the 12 U.S.,
but we have a regulatory authority to do this.
)
13 does not, and now you have got two voluntary inspections going
-14 on in parallel.
It is not clear why.
15 MR. ANDERSON:
Well, I think that's a, as I say, I 16 think you have hit on a very Jood point.
We hope that it will 17 be useful, and I have heard a comment, to quote a German who 18 is a vice president for REW--RWE, excuse me, and his comment i
19 on that subject was--because we are close, we do the IAEA, and 20 he said Verner Luken is his his name, and he says let's us do 21 this.
He is talking to his colleagues at the Steering I
22 Committee meeting, let us do this, and he called himself a 23 utility person, industry.
He says let's not have the, you
()
24-know, the government did it for us.
That was his feeling.
25 That's one person.
So I thought it was an interesting HERITAGE REPORTING CORPORATION -- (202)628-4888
168 1
observation that he would make that.
AU 2
(Slide) 3 Mit. ANDERSON:
I think the final slide I will show 4
is that, I was going to show you some remaining tasks, but 5
this is what we are shooting for now.
The~second executive 6
meeting Moscow in May '89, and that's where the decisions by 7
the executives rill be made whether or not they want this 8
organization.
They have been--by the way, they have been kept 9
informed as we have gone along, but that's the objective.
10 MR. MICHELSON:
Can we get copies of slides?
11 MR. ANDERSON:
I can do that.
12 MR. MICHELSON:
Or our staff person will get them.
()
13 MR. ANDERSON:
All right, sir.
14 MR. MICHELSON:
I have in front of me a copy of a 15 paper.that was presented at the May IAEA forum on operating 16 experience in Paris.
This was written by Mr. Ekartin, and it 17 is a--I will have copies also made for the Committee.
It is a 18 verbal description, word description of what you have 19 articulated, and it might be helpful for the members.
20 MR. ANDERSON:
Yes.
Thank you.
21 DR. REMICK:
There was some questions about why 22 supply is in the title of your division and your co-title 23 which you mentioned.
Why is it there?
(])
24 MR. ANDERSON:
At INPO we have--a second part of my 25 responsibility is the supplier division.
There are 14 HERITAGE REPORTING CORPORATION -- (202)628-4888
169 1
countries, companies associated with INPO, NSSSs and AE firms,
()
2 and they meet at INPO three times a year.
We call it the 3
Supplier Participant Advisory committee, and they advise us on 4
INPO programs, review of INPO programs, and they take on some 5
special projects to see if they can help the utilities in 6
working through INPO, so that's the, that's basically what it 7
was.
We have three international companies or three companies 8-that are not not U.S.--AECL, Framtone, and Seamans, but the 9
rest are what, I think the companies you would 10 expect--Westinghouse, GE, Bechtel, Stone and Webster, but 11 that's--
12 MR. MICHELSON:
Is B&W a member of that group also?
()
13 MR. ANDERSON:
Yes, sir.
Chet Harris, who is here 14 today as well from INPO, he takes care of that program 15 specifically, and he is in charge of having our meeting, 16 conducting our meeting here on the next Wednesday.
17 MR. MICHELSON:
Is it correct to perhaps 18 characterize this as an international INPO more than just an 19 international organization of nuclear operators?
Is that, 20 isn't it really going to perform essentially most of the kinds l
l 21 of functions you presently perform in the U.S.?
22 MR. CARROLL:
It's bad politics to call it thatl
(
23 MR. MICHELSON:
I realize that.
I am just trying to i
I 24 get a mind set of my own as to whether this is purely
(}
25 operation or it goes beyond the, you know, how far beyond.
i
---HERITAGE REPORTING CORPORATION -- (202)628-4888
170 1
You think it is, essentially will be a parallel to what you do
,(_)
2 in the U.S.,
is that right?
3 MR. ANDERSON:
I think it can grow into that type of 4
organization.
And as I mentioned, I would hope it would.
Not 5
that INPO is the organization.
I didn't mean to say, even 6
infer that, but if you ask me, I think evaluations, I think 7
accreditations, I think analysis and engineering, and you 8
know, right down the line, are basics for a program.
9 MR. MICHELSON:
But so for instance, analysis and 10 engineering, you really, if it gets beyond, goes very far, you 11 go back to EPRI?
12 MR. ANDERSON:
Oh, yes.
p
(
13 MR. MICHELSON:
For that; you could do it in-house 14 but you don't have the resources or EPRI does it, but in the 15 case of this world organization, it is not clear, you know, 16 how far one would go or where they would go even.
There isn't 17 an international EPRI.
18 MR. ANDERSON:
No.
I think that--and some of the l
19 people just, I don't think some of the countries are even 20 looking at that sort of an organization.
They are, they don't 21 probably want that, you know, evaluations.
They are not ready l
22 for that.
l 23 MR. MICHELSON:
See, INPO prides itself in doing
(])
24 short-term accident evaluations, but not long-term analysis.
l 25 Long-term analysis you feed out to EPRI to look at, but if you HERITAGE REPORTING CORPORATION -- (202)628-4888
171 1
don't have an EPRI to feed it to, it looks like you would have
()
2 to do it yourself in the international sense.
3 MR. CARROLL:
EPRI does have some degree of 4
international flavor to it.
5 MR. ANDERSON:
Absolutely.
6 MR. MICHELSON:
That wasn't my point.
My point 7
was--
8 MR. CARROLL:
The broad gauge of what you are 9
, talking here.
10 MR. MICHELSON:
Thank you.
11 CHAIRMAN KERR:
Further questions?
12 MR. WARD:
Stan, why are the, why do you think the O
(_/
13 Soviets are interested in, and I guess I am particularly--when 14 ~
you said they are, everybody has accepted English as the 15 official language of the organization, the Soviets have 16 accepted that?
17 MR. ANDERSON:
Yes.
l 18 MR. WARD:
What is their interest in it?
j 19 MR. ANDERSON:
Well, you mean on--
20 MR. WARD:
Under the, to participate in an 21 organization that uses, that is committed to English as its 22 official language, it seems like a big step for the Soviets.
23 DR. REMICK:
It is a bigger step for the French.
()
24 MR. WARD:
At least they got, you know, they are 25 using our technology.
HERITAGE REPORTING CORPORATION -- (202)628-4888
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MR. ANDERSON:
You know, David, when it--that has p/
N-2 been proposed, the English was proposed, and not by the 3
English by the way, but it was decided on, but if you talk 4
about, get real specific with the Russians, actually asking 5
about were'the Russians enthusiastic about that and 6
contribute, I can't say that because they have been involved, 7
as I hope I have indicated their involvement in this program 8
so far, but I think that would be, I would express the French, 9
the Japanese, the Koreans, their acceptance of that more than 10 I would_the Russians.
If I make that clear; I have never 11 heard a Russian say yes, we should have it in English.- I just 12 haven't heard that, but it has been accepted.
13 DR. SHEWHON:
In a mildly irrelevant vein, about a 14 month ago, I heard that the man who made the Russian 15 presentation at Moscow--sorry--at Vienna en the Chernobyl 16 accident committed suicide.
Do you know anything more about 17 that?
l 18 MR. ANDERSON:
I don't know anything more, but that i
19 was Legasoff--tragic.
He was a very young man, as you saw.
I l
l 20 first saw it in, in the obituary in the New York Times.
I l
l 21 think they tried to make something out of it.
l 22 DR. SHEWHON:
Thank you.
l l
23 CHAIRMAN KERR:
He wasn't an operator, but he went
{
()
24 to Chernobyl.
He was with the team who went there.
25 MR. WARD:
He was in charge of their investigation.
HERITAGE REPORTING CORPORATION -- (202)628-4888 t
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He'was from the--
/)
(/
2 CHAIRMAN KERR: 'He was not part of the operation at 3
all.
4 DR. REMICK:
Any other questions of Mr. Anderson?
5 If not, Stan, we thank you and Chet very much for coming and 6
sharing this information with us.
We really appreciate it.
7 MR. MICHELSON:
We can get copies of the slides?
8 DR. REMICK:
Yes.
Would one of staff make copies of 9
Mr. Anderson's slides?
10 MR. ANDERSON:
I have a copy of the slides that I 11 can leave with you to make copies of.
12 It has been a pleasure.
Thanks for inviting us up
)
13 here to make the presentation, and I hope I haven't left you 14 with the idea that we have got this whole thing all wrapped 15 up, but we are enthusiastic about it because we see it is an 16 opportunity to involve'the rest of the operators.
17 Thank you very much.
18 DR. REMICK:
Thank you.
l 19 CHAIRMAN KERR:
Next item is discussion of future
(
20 activities.
Mr. Fraley, are you going to lead this?
l:
21 (Whereupon, at 11:30 a.m.,
the recorded portion of 1
22 the morning session was recessed, with the afternoon session 23 to resume at 1:00 p.m..)
l l
()
24 25 l
HERITAGE REPORTING CORPORATION -- (202)628-4888 l-
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&FTERNOON SES S IQN 1:00 p.m.
g-()
2 CHAIRMAN KERR:
Systems interactions, Dave ward, 3
subcommittee chairman I do believe.
4 MR. WARD:
Okay.
Thank you, Mr. Chairman.
I guess 5
it is a little ait moot whether I am the appropriate 6
subcommittee chairman or not.
7 At a meeting several months ago, the Full Committee 8
discussed the ongoing work related to the resolution of USI 9
A-17, systems interactions, and from a committee standpoint, 10 we decided it would be best if when it became appropriate from 11 the staff's position, that we would have a briefing on the 12 resolution proposal for the Full Committee and the Full
()
13 Committee at that time would then decide what sort of a 14 review, deeper review, if any, it wanted to conduct on the 15 resolution, and if it did want to conduct a deeper L'eview, how 16 that should be done, to which subcommittee it would be 17 assigned.
18 We last had a briefing in, at the Full Committee in 19 January of 1987, and at that time, the Committee had made some 20 recommendations.
Some of these particular recommendations the 21 staff is proposing not to accommodate in their proposed 22 resolution, but there has been some discussion of addressing 23 these in a new generic issue, and I think that is one of the (J~)
24 things we are going to be hearing about today.
25 As I understand it, the staff is not necessarily HERITAGE REPORTING CORPORATION -- (202)628-4888
175 1
asking us to comment on the resolution package at this time,
(.(-)
2 at this meeting, but of course, that is up to us, depending en 3
what we hear, how we want to go about it.
4 If anyone else has anything you would like to say?
5 Carl, do you have any comment yot would like to make at this 6
time?
7 MR. MICHELSON:
Not at tais time-8 HR. WARD:
Okay.
Well then we hnve untti, let's c r.n this as 9
see, we have until 2:30, and rignt avu I em*..
10 a status briefing, and at the end of it F emmituee might 11 want to have a discussion within itself to
-;ide what it 12 wants to do from here on out.
So I will go to the staff.
Mr.
13 Baer, are you going to start out?
14 MR. BAER:
Yes.
Thank you.
I guess that is focused 15 fairly well.
As Dr. War) indicated, we are, staff is here 16 today to discuss USI A-47--A-17.
I'm sorry--systems 17 interaction.
I do have a new slide, Carl.
I was going to 18 give you a little bit of a background, and Dale Thatcher, the 19 task manager, will do the technical part of the presentation.
20 Contrary to what Dr. Ward said, we do want ACRS 21 comments, and hopefully a letter of endorsenent at least to 22 the point of sending out a proposed resolution for public 23 comment, but first let me go through a little bit of
(])
24 background.
25 This is a very old issue, which you all know, and it l-HERITAGE REPORTING CORPORATION -- (202)628-4888
176 1
was, originally concerns were raised by this Committee back in
((.)
2 1974, concern being system interactions, and the vagueness, 3
tnose words vague.
In 1978, it was, the issue was officially 4
designated as a USI by the commissioners.
There was a long 5
period of time between '78,
'83 where the staff tried to work 6
the problem, but was having a great deal of difficulty even in 7
agreeing on what was within the scope of the issue and what 8
was excluded, and back in 1983, '84 time period, there were 9
major revision to the scope and to the task action plan, and 10 there was a meeting with ACRS at that time.
Vic Stello made 11 the presentation, and presented a revised and reduced scope 12 and a task action plan associated with that, and as indicated
(_)
13 on the slide, the revised action plan was approved by NRR 14 management at that time.
15 The next major milestont was a draft resolution 16 package was put together in 1986, and a presentation made to 17 both ACRS and CRGR, and ACRS had a number of comments and out 18 of those we have proposed a new program, multiple systems 19 response program, to try and address comments raised by the 20 ACRS and my staff members on issues, that systems are just 21 hard to deal with in a broad cor. text.
22 The hope there is to carefully define those issues 23 so they can be prioritized and if the priority so indicates,
(~J')
24 to work them as discrete issues, and as indicated by Dr. Ward, 25 we will be discussing that program in somewhat more detail HERITAGE REPORTING CORPORATION -- (202)628-4888
177 1
during Dale Thatcher's presentation.
]
%/
2 The CRGR at that tirae was in agreement with the 3
scope-and the approach the staff was taking, but felt that 4
wording had to be sharpened up and to be more precise, so that.
5
. licensees would be,. clearly know what they were expected to do 6
as a result of the resolution, and we have been trying to 7
accomplish that, among other things, over the past couple of 8
years.
9 As Dr. Ward indicated, we met with ACRS in January 10 of
'87, and that was primarily a status report to say where we 11 were and where we thought we were heading.
12 We are here--slide this up a little.
I indicated we
(
13 are here today to discuss the resolution that we are proposing 14 to publist. for public comment.
The resolution package is, t
15 does contain some modifications to that presented in 1986.
We 16 have today's presentation with ACRS.
We are currently 17.
scheduled to meet with the CRGR later this month, June 22nd.
18
'We are asking for ACRS comments, and hopefully a letter that 19 would endorse publication for proposed, for public comment, 20 the proposed resolution for public comment.
21 MR. MICHELSON:
Are you suggesting that that be l
22 before the 22nd of June?
l 23 MR. BAER:
No.
Realistically, we know we will get
()
24 some comments.
We have never gone through CRGR without some 1
l 25 reword.ing to do, so it will be some time after that, obviously i
HERITAGE REPORTING CORPORATION -- (202)628-4888 g
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while we put together a final package.
%/
2 MR. BOSNAK:
I would like to add something.
If we 3
could, we would like to have a letter from you if possible 4
before the CRGR meeting.
It always comes up that what is the-5 ACRS position?
If you, if you can't comment, if you could at 6
least indicate that you have no objection to going forward for 7
public comment.
8 MR. BAER:
Well, any more questions?
If not, I will 9
ask Dale Thatcher to go ahead with the bulk of the 10 presentation.
11 MR. THATCHER:
I thought I would start out a little 12 bit with a summary of the basic findings of the A-17 program, r'
(_),
13 and then try to relate them to the proposed resolution on the 14 next slide.
15 Basically we broke it down into four general areas.
16 First one, we state that some specific action, we decided that 17 some specific action should be taken.
This was mostly 18 evidence we found in operating experienced searches.
We l
19 thought we found some potential implementation problems, and 20 this is the specific area of flooding.
I will talk about that 21 on the next slide.
l 22 MR. MICHELSON:
Potential implementation weaknesses, 23 what implementation ace you talking about?
You must be l
()
24 referring to some program that was inadequately implemented.
25 MR. THATCHER:
The iruplementation of a number of HERITAGE REPORTING CORPORATION -- (202)628-4888
179 1
requirements, notices to utilities over the last ten, actually (m/
2 more than that, ten years, maybe 12, 15 years, but that's, I 3
can talk a little bit more about that.
L 4
MR. MICHELSON:
I just want to make sure.
5 MR. BAER:
Reoccurrence of the water intrusion type 6
events.
7 MR. THATCHER:
The next one, we decided to rely on 8
other related and ongoing programs.
Basically our decision 9
was that for certain areas, that it will be more logical and 10 maybe better, more effective if we tried to handle certain 11 aspects of systems interaction in certain other issues, and I 12 will talk about that, two specific cases, on the next slide
)
that had to do uith the seismic aspects and also the 13 14 electrical power system aspects.
1S We basically concluded that adverse systems 16 interaction will continue to occur.
There are very 17 plant-specific kinds of things.
I think I presented these l
18 kind of conclusions to you at other meetings, but we just 19 basically concluded that they will continue to occur.
20 We did decide that there may be two ways to lessen 21 their frequency or lessen their impact, and one was to take 22 the lessons learned about characteristics of adverse systems 23 interaction and provide those to, to all the licensees for
()
24 information, and I will talk a little bit more about that.
25 We basically also concluded that we didn't think it HERITAGE REPORTING CORPORATION -- (202)628-4888
180 1
was cost effective to perform a broad search for systems
()
2 interaction, just for the subject area of systems interaction, 3
although that subject area is quite broad and can be 4
interpreted broader than we did in this issue.
5 However, as I will point out in the next slide, the 6
ongoing efforts in the area of probabalistic risk assessment 7
and also in the program for individual plant evaluations that 8
is going on right now, we thought that by providing 9
information to those programs, we could provide tackground and 10 information that may be utilized in those reviews.
11 The last item is basically from ACRS concerns 12 expressed during the resolution of this issue and a number of (J~T 13 other issues, and we just decided that if we could take the 14 concerns as they,ere expressed and define them into safety 15 issues, that we thought they could be worked as individual 16 generic safety issues.
I have more about that as we go along.
17 (Slide) 18 MR. THATCHER:
I basically outlined the proposed 19 resolution on this slide.
The first item, we are not 20 proposing any new requirements.
The review for systems 21 interaction, we basicallir concluded that there was no need to 22 write a new rule or no need for changes in the regulations.
23 The aspects that we thought needed treatment, particularly the 24 area of flooding, would really be coverod under existing 25 regulations, and what we proceeded to formulate for A-17 was a HERITAGE REPORTING CORPORATION -- (202)628-4888
181
~1-propoued generic letter.
I
~ 2 Now the generic letter =we are proposing would be to
~
i 3
all-licensees, and it.would'have three basic parts, one of 4
-which'har t' do with flooding.
The first part of the generic 5
letter is an informe. tion document - that describes the, our 6
basis for resolution..That includes the, a little bit of 7
background of the issue, and it outlines our, what we consider 8
to be the resolution of-A-17.
That's a new piece of the 9
generic letter that you didn't see in 1987.
10 The next item is to provide a section of the generic 11 letter that provides information on lessons learned..That's i
j 12 been in our proposal all along.
There were certain areas as
()
13 we described before in '87 and even back in 1986, there were 14 certain areas that we thought were, that should be highlighted 15 to all utilities for use in our operating experience reviews, 16 and so we wrote a summary document and it is about ten pages i
17 long, and it just provides the lessons learned on A-17 for 18 utilization by the licensees.
19 The next part, portion of the generic letter has to 20 do with the subject area of flooding and water intrusion.
As 21' I said befcre, we thought that over the years there has been a 22 number of initiatives done on that subject area.
The things i
23 were done in 1972 after the Quad cities flood.
There was some
(])
24 generic issues letter.
There has been a number of information 25 notices issued over the last ten years.
Even some recent, as i
HERITAGE REPORTING CORPORATION -- (202)628-4888
-.~,
L 182 1
recent as the last two years; in addition, we know that INPO m
2 is, undertook an effort.
They have issued a SOBR on the 3
subject of flooding, so we thought under present programs that 4
utilities have already performed or are in the process of 5-performing, that the thing that we thought should be done 6
would be to request the licenuees to provide to us 7
certification that they have completed their flooding, 8
flooding reviews.
I have a little bit more on that on the 9
other side slide.
10 MR. MICHELSON:
Are you going to write a set of 11 rules by which you should do such analyses or provide guidance 12 as to how you do a true flooding analysis, particularly one
()
13 dealing with electrical equipment?
14 MR. THATCHER:
It takes the form of guidance.
It is 15 not extremely detailed.
16 MR. MICHELSON:
That has been published in other 17 than the old guidance that went with the O' Leary letter.
18 HR. THATCHER:
It is part of the draft generic 19 letter.
It is in your package, i
20 MR. MICHELSON:
Okay.
You are going to use that 21 one.
That was very helpful.
22 MR. THATCHER:
The next item, and I have more on 23 each one of these items on the other slide, it is sort of
{}
a--depends how much detail you want te go into.
The lessons 24 25 learned, which does relate back to the generic letter, the HERITAGE REPORTING CORPORATION -- (202)628-4888
183 1
lessons we learned there regarding adverse systems (3
(>
2 interaction, we are proposing that they be provided to plants 3
doing PRAs or if a utility does a PRA, or does their IPE, that 4
they ought to take that as background information in those 5
review efforts.
6 The area of seismic systems, seismically induced--
7 MR. WARD:
Dale, how is the last one, provide 8
lessons learned for PRA and IPE, how is that different from 9
the niddle one in the provide information on lessons learned?
10 MR. THATCHER:
It is, it is not really different, 11 but there are two aspects to the one that says provide the PRA 12 and IPE review.
Internal staff, there is a separate group
(}_)
/
13 that will do the review of IPEs, and also does review of PRA.
14 We are providing our lessons learned to those people, in 15 addition to providing to the utilities the generic letter, the 16 same lessons learned.
17 MR. WARD:
You are providing to NRC staff reviewers 18 information.
That's--
19 MR. THATCHER:
That is what that is.
20 MR. MICHELSON:
But you are defining system 21 interaction to encompass this flooding and other things.
That l
22 generally has not been treated in the PRA, so you haven't 23 necessarily learned lessons about it.
I~)
24 MR. THATCHER:
Well, it depends on the PRA that was l
%J 25 performed.
I think the lessons learned, ignoring the flooding HERITAGE REPORTING CORPORATION -- (202)628-4888
184 1
momentarily because we really are treating that separately as
(~%
\\s/
2 far as the lessons learned go, the lessons learned are mostly 3
regarding functional interactions which are the kinds of 4
things that you would put in your models as opposed to maybe 5
the things you would find on a walk-down where you find 6
spatial problems or something like that, so those are the 7
lessons learned more than the flooding.
8 I didn't really mean to include the flooding in 9
that, although there is certainly lessons to be learned about 10 flood, flooding aspects.
We consider at least with regard to 11 the operating plants out there that we are going to take care 12 of the flooding through the generic letter and the (n) 13 certification under 50.54(f).
14 The seismic, the seismic aspects, when we were 15 talking to ACRS--this goes back even before the '86 16 proposal--we talked about a draft that we had prepared in 17 1985, and at that time, we were proposing that we would take 18 some action both on seismically induced systems interaction 19 and flooding type interactions.
20 Along that same time period, USI 46 was coming to 21 somewhat of a closure in the sense that the requirements from 22 that program were being completed, and at that time we started 23 looking at the possibility that the A-46 program could take a
()
24 look at the, some of the seismically induced adverse systems 25 interaction, and over the 1985, 1986 time period, we met with HERITAGE REPORTING CORPORATION -- (202)628-4888
185 1
the A-46 people and through, particularly through my section
('
2 leader Newt Anderson, we had liaison with those people and we 3
got agreement that they would look at seismically induced 4
spatial, systems interaction in their, in their walk-down 5
procedures, and to my knowledge, they are proceeding in that 6
way.
7 HR. MICHELSON:
My knowledge, my recollection of the 8
agreement is somewhat different than on A-46.
The staff said 9
they would not chase down such things as water running out of 10 the tank when it falls over.
They would only look at physical 11 impact.
They would not consider the interactive effects of 12 the water coming out of the tank, for instance.
So they
()
13 certainly had kind of a limited view of system interaction.
14 MR. THATCHER:
I agree that it is somewhat limited 15 view, but the aspect of flooding, we do think that we wil3,
.16 will be covering it somewhat in the A-17.
17 MR. MICHELSON:
Not under the seismic induced 18 failure of the equipment; you are trying to piece these down 19 to where you only think one thing at a time will ever happen.
20 Under the seismic condition, you think that the only thing 21 that could happen is a tank would fall over and physically 22 impact, but no water would come o"t.
23 MR. BAER:
No, but the, the existing requirements on
()
24 water, on potential internal sources of water, consider all, 25 all the sources.
Now they do consider them just one at a HERITAGE REPORTING CORPORATION -- (202)628-4888
186 1
time, but they do, you know, existing requirements say you
()
2 have to protect safety-related equipment from pipe breaks, 3
from tank failures.
4 MR. MICHELSON:
And you and I both know we don't do 5
that very well, if at all in some cases.
6 MR. BAER:
That's where when Dale gets to the 7
flooding, we have tried to deal with that with at least some 8
additional specificity.
He can--
9 MR. MICHELSON:
It wasn't a flooding question.
When 10-the tank was, water drained, it just ran across the floor.
11 Didn't flood the plant, just ran across the floor and got into 12 an inverter.
()
13 MR. BAER:
Well, I think we are careful to say in 14 our guidance that it is, it is water intrusion and flooding 15 from internal sources and point out that it isn't the quantity 16 of water necessarily that matters.
~
17 MR. MICHELSON:
You don't want couple seismic with 18 the flood for some reason.
19 MR. THATCHER:
Well, we don't couple it in the sense 20 that one could argue that during a seismic event, this falls 21 down, that floods and that starts a fire all simultaneously.
22 MR. MICHELSON:
When this falls down, it creates a 23 flood.
It is a part of the first event.
24 MR. THATCHER:
I agree.
{}
25 MR. MICHELSON:
It is an irrational way to go about HERITAGE REPORTING CORPORATION -- (202)628-4888
187 1
it.
2 MR. BAER:
It is the question of multiple components 3
versus single I think.
4 HMR. MICHELSON:
It is a question of what happened 5
when a tank falls over?
Is the only thing it can do is 6
impact?
It can't drain its water?
7 HR. BAER:
That sort of water is looked at from a 8
flooding analysis.
9 MR. MICHELSON:
Without the impact being taken into 10 consideration, that's right.
We do both, but we do them one 11 at a time in separate environments.
See, the tank falls on 12 train B and the water runs over and gets train A.
You don't (A-)
13 do that in our present seismic and you don't do it in our 14 present flood.
You do them one at a time.
That's what system 15 interaction is supposed to be about, considering what really 16 happens.
17 MR. BAER:
When we get to multiple response program, 18 we have a number of seismic events that we are trying to, to l
19 gather together.
20 MR. THATCHER:
I have other slides on all these 21 bullets, so maybe I should move more quickly there.
22 Power supplier interaction information, there is a 23 separate generic issue on a number of power supplies, and let
()
24 me get to that slide to talk more about that, but it is l
l 25 similar to what we are saying on A-46 and about the aspects l
l l
1 HERITAGE REPORTING CORPORATION -- (202)628-4888
188 1
learned on A-17 in handling other programs.
,l 2
The last one, and again I have some more slides, the
(-
3 one we are talking about developing, the other concerns that 4
have been raised for separate treatment as individual generic 5
issues, we call it multiple system response programs.
I 6
should point out that in our response to ACRS in 1986, we 7
talked about, conceptually I think we talked abcut a separate 8
issue, and we talked about, I think we were talking in terms 9
of faulting modes.
10 I think as we moved along, we saw that the results 11 of the program we were working on was probably not going to be 12 just one issue, and it wasn't just going to deal with faulting
(~'t
(_/
13 modes.
Things were being talked about that were much broader 14 than that, so we kind of changed, maybe we gave the program a 15 name for the first time and we called it multiple system 16 responsea to try to reflect some of the aspects that we have 17 just been talking about here.
18 Just the last note, notice the asterisk is what we 19 think has changed or not changed since the last presentation.
20 (Slide) 21 HR. THATCHER:
This is the outline of the generic 22 letter, and I did go over some of this.
As I said, there is 23 three parts, a basis section which outlines the staff's
(( )
24 conclusion on A-17.
25 MR. WARD:
Excuse me.
Do you have the microphone HERITAGE REPORTING CORPORATION -- (202)628-4888
189.
1 on?
{])
2 MR. THATCHER:
No, I don't.
3 MR. WARD:
It might be a good idea.
4 (There was a brief pause in the proceedings.)
5 MR. THATCHER:
Is that better?
6 MR. WARD:
I can't be sure until you say something.
7 MR. THATCHER:
Okay?
Well, I will try to speak a 8
little louder.
9 MR. WARD:
Thank you.
10 MR. THATCHER:
The basis section outlines the 11 staff's conclusions on A-17, and it also tries to describa the 12 interrelationship of the various programs that I have just 13 mentioned like A-46.
'[ }
14 The second portion of the letter is the section that 15 I said was for information only, and it contains number one, 16 an outline of our definitions used in the program, which is 17 rather critical to the way we think these issues should be 18 resolved.
We present the results of our operating experience 19 review in which we have contractors go through a number of 20 events and kind of break them down into various categories.
21 We have got that information in the letter.
22 Out of that review which decided to summarize and 23 highlight five I can't really say specific areas because they 24 are rather general, broad areas, but we thought based on some 25 of the experience that five particular things should be r
HERITAGE REPORTING CORPORATION -- (202)628-4888
t 190 1
pointed out.
They involve the electrical power system in n'
ss 2
general, the_ electric power system specifically, support 3
systems in general, which includes things like service water, 4
component cooling water and so forth.
5 There is a discussion about the overreliance on 6
failsafe principles that has gotten us in somewhat, gotten us 7
in trouble somewhat on certain systems.
Also the certain 8
engineered safety feature type systems that don't always have 9
a preferred failure mode, we have seen some systems 10 interactions in those, those kind of situations, and the last 11 one is a little bit more specific in the power supply area, 12 and that has to do with the instrumentation and control power
()
13 supplies themselves.
14 Basically the bottom line of the information section 15 is that licensees should consider these adverse systems 16 interaction in their ongoing programs to review operating 17 experience, and to consider these types of adverse systems 18 interaction when performing other plant evaluations, PRAs, 19 IPE, walk-down for various reasons, whatever.
20 The last part is this part that requires the i
21 response to us, and it is, it has to do with flooding and l
l 22 water intrusion analysis which we think they already should 23 have done, and it requires licensees to certify to us
()
24 basically four things--that the analysis was done, that they 25 have established what deficiencies, if any, they had, they
[
HERITAGE REPORTING CORPORATION -- (202)628-4888
191 g
1 have made modifications if they needed to, and if certain 2
things weren't done, justification for continuing operation.
'3 MR.'MICHELSON:
Did you provide guidance to the 4
4_
person doing this certification as to how he should view 5
equipment when it is intruded by water?
For instance, in 6
other words, what is its failure state going to be when it 7
gets wet so that he can do a systems interaction analysis?
8 Really isn't~in the guidance as I see it, but perhaps you can 9
correct me I'm wrong.
10 MR. THATCHER:
Well, I think we could not really 11 specify, to use your words, what failure state the equipment 12 would be in if it got wet.
I think they would, again they
(
13' would have to almost assume any kind of failure mode, 14 depending on what the equipment is.
15 MR. MICHELSON:
Is that what you want them to 16 certify?
They considered all possible failure states of the 17 equipment under the wetted condition and analyzed each?
Is 18 that what you are asking for?
19 MR. THATCHER:
Well, we are aski:.g them to certify 20 that they have done water analyses.
We are not asking for the 21 details.
22 MR. MICHELSON:
I can do a water analysis by simply 23 assuming if it gets wet, I no longer can obtain the function
()
24 of that, safety function of that squipment, and leave it go at 25 that.
That's one analysis.
That's the one generally done,
. HERITAGE REPOATING CORPORATION -- (202)628-4888
192 1
but that's not a systems interaction analysis by any means b(-
2 because we know from, we know from the experience that we have 3
seen that's not the way equipment fails when it gets wet.
4 MR. THATCHER:
We have highlighted the experience.
5 That's the one thing that we were able to gather up and 6
provide to them, and I think if, if they look at the, if you 7
look at the experience, you find those kinds of things.
8 MR. MICHELSON:
What are you asking the utility to 9
certify?
10 MR. THATCHER:
To certify that they have done the 11 analysis.
12 MR. MICHELSON:
They have considered those kind of
()
13 things?
14 MR. THATCHER:
Considered those kinds of things.
15 MR. MICHELSON:
It isn't clear, 16 MR. THATCHER:
I have got to admit that we went 17 around and around on what form we wanted this certification to 18 be in.
At various times we kind of oscillated between asking 19 for a lot of information or asking for a little bit, and we 20 are kind of in between.
We do expect that subsequent to 21 getting these certifications, that we will be doing some plant l
22 inspections to look at the analysis, how it was done and so 23 forth, but only on an audit basis.
We are not going to look l
()
24 at everybody's flooding analysis.
25 MR. MICHELSON:
Well, if you know what you want, it HERITAGE REPORTING CORPORATION -- (202)628-4888
193 1
is easy er.ough to ask for it.
If you don't know what you n(-)
2 want, you will get whatever they feel like sending you, which 3
is perhaps an analysis that was done back in 1972; perhaps 4
not.
5 HR. BAER:
One point we do make is that the analyses 6
have to be valid for the current plant configuration.
7 HR. MICHELSON:
That's true.
8 MR. BAER:
At least we try to mover that point.
I 9
think in most cases that will eliminate most of the 1972 10 analyses.
11 MR. THATCHER:
We also list the current operating 12 experience that, well, if they, you know, they could claim
()
13 that their '72 analysis did cover all those kinds of events, 14 but I kind of doubt it for a lot of the plants, so there is 15 something that they have to tell us about having considered 16 more recent information I guess is the best way to put it.
17 MR. MICHELSON:
Well, we will go ahead, but there is 18 a very fundamental question about how you do the analysis, and 19 what you are expecting when you get a certification, what kind 20 of analysis do you expect that they did?
And it isn't clear 21 what you were expecting of them at all in that regard.
22 HR. THATCHER:
The A-46 seismic program, I guess I 23 really covered all these, these items.
A-46, for those of you f~')
24 who are unfamiliar, deals with seismic qualification in a l
v 25 number of older plants, and it is requiring plant walk-downs l
l l
l HERITAGE REPORTING CORPORATION -- (202)628-4888
194 1
to evaluate the equipment needed for safe shutdown.
As I
/~')
(/
2 stated before, they have agreed to, in those walk-down 3
procedures, to include seismically induced systems 4
interactions in the walk-down.
5 MR. MICHELSON:
I think we should make it clear to 6
the Committee that unless--correct me if I am wrong, but I 7
believe you asked only to look at physical impact kind of 8
interactions during those walk-downs?
Is that correct?
9 MR. THATCHER:
I think that is correct.
10 Unfortunately, the person that would know more about that--
11 MR. MICHELSON:
Bob Bser probably can give us an 12 answer.
(
13 MR. BAER:
I'm sorry.
I was reading something else.
14 MR. MICHELSON:
The question is, his third bullet, 15 when we asked that they do seismically induced system 16 interactions, as I recall, we asked them only to look at the 17 physical interacting of equipment, particularly the non-safety 18 equipment that was falling down, and that was the extent of 19 the interaction.
20 MR. BAER:
That's primarily it.
The question 21 that--we have had some discussions with the owners group about 22 doing some supplemental flooding walk-downs, haven't reached a 23 resolution yet.
()
24 MR. BOSNAK:
There was also functionally 25 interaction, electrically, for the shutdown systems.
That was HERITAGE REPORTING CORPORATION -- (202)628-4803
195 1
also part of A-46.
()
2 MR. MICHELSON:
Yes, but the part, that's the 3
physical interaction part that we had'a great deal of 4
difficulty on.
5 MR. THATCHER:
I guess I just wanted to. note ~that 6
the staff concluded that newer plants were subject to more 7
thorough review in the area of seismic capability, and we 8
think that's,-that's the basis for not, not doing anything 9
more for newer plants.
I want to point that out only because 10 A-46 really dealt with a set of older plants.
11 MR. BAER:
Well, it is 70 plants.
It isn't a small 12 set.
It is somewhat the majority of plants.
13 (Slide) 14 MR. THATCHER:
The issue that I talked about, 15 Generic Issue 128, which is titled electric power reliability, 16 the three main issues that are being looked at in that generic 17 issue are a number of generic issues that have been around for 18 a number of years also.
Generic Issue A-30 dealt with 19 safety-related DC power supplies.
Generic Issue 48 dealt with 20 the limiting conditions for operation for the safety-related 21 class 1E vital instrument buses, and Generic Issue 49 dealt 22 with interlocks and limiting conditions of operation for tie i
23 breakers which connect redundant safety-related buses.
l 24 As a result of the information developed on A-17, 25 the staff decided that the best, since we already had a number
- HERITAGE REPORTING CORPORATION -- (202)628-4808
196 1
of generic issues on the electrical INC power supplies, and J
2 since they were being brought together in one issue that we 3
should factor into that, that particular issue we should 4
factor the results of that information developed on A-17, and 5
so that's what--
6 MR. MICHELSON:
Is A-47 going to go the same route 7
then, too?
8 MR. THATCHER:
A-47.
9 MR. MICHELSON:
The non-safety end, the interactions 10 on the non-safety end are under A-47.
11 HR. BAER:
One of the things that we responded to 12 the Committee's comments was to try and beyond the items you
/~S
(,)
13 mentioned, we said we as part of this multiple systems 14 response program, we would take a look--well, I taght to go 15 back.
The assumption made in A-47 based on our review of 16 operating experience was that control system failure although 17 it could lead to failure of one protection system, would not 18 fail redundant protection systems, and so we saw at that time 19 no evidence that it did, i
20 We said that we will take another look at that, that 21 assumption, as a distinct issue.
22 MR. MICHELSON:
Go ahead, i
23 MR. THATCHER:
Right now, since I'm the task manager l
(,)
24 for GI 128, I guess I could say that it appears that right now 25 that we will be coming to a resolution within about three HERITAGE REPORTING CORPORATION -- (202)628-4888
'197 l1 months in which we'will probably look like a generic request'
--(
2 for information under 50.54(f)..specifically we feel that the 3
-issues of, the 48 and 49 issue aspects-are really within 4
current regulations, and we are proposing.that plants provide 5
limiting condition for operation similar to present day plants 6
or provide the-justification for why their plant.doesn't have 7
to do those kinds of things, and with regard to A-30,- there 8
has been a significant amount of action taken in the area of 9
batteries and DC power supplies in general, particularly IEE 10 standards have been updated.
A number of information notices 11 and bulletins regarding those power supplies have been issued.
12 We are proceeding to try to correlate all that
(])'
13 information with the recommendations coming, that come from i
14
'the original generic issue on A-30 and see if there is not a 15 basis for asking utilities if they haven't done all these 16 things already, and if we find cases where maybe someone 17 hasn't done them, we may have to do backfits on individual i
i 18 case basis, but that's kind of a preliminary information.
We i
19 haven't really finished with these issues, but that's the way 20 they are going right now.
21 MR. MICHELSON:
GI 128 deals with the electric power f
22 system up through the emergency generator and the higher--
23 MR. THATCHER:
The title is bad.
24 MR. MICHELSON:
What does it deal with?
O.
25 MR. THATCHER:
It deals with DC, INC low voltage, HERITAGE REPORTING CORPORATION -- (202)628-4888
198 l'
120 volts.
i
\\
2 MR. MICHELSON:
When you are dealing with that end, 3
what part of system interaction are you considering?.
4 MR. THATCHER:
As far as what was learned in A-17, 5
that instrument power supplies, buses and so forth, can cause 6
significant upsets in the plants, and we think that coupled 7
with what we are working on in 48, 49 and 30, they kind of 8
reinforce each other in that sense.
I don't think we found 9
any power supply problem that if you lose one power supply, 10 you know, you go directly to core melt or something like that.
11 MR. MICHELSON:
Keep in mind system interaction now 12 is dealing with such things as the chiller and the cooler and l
(
13 the corner of the room that is keeping that particular power 14 supply cool, because it is getting coolant out of the room,
'15 and it is the chillar and the, or the cooler in the corner 16 that went sour and at the same time that power supply was 17 affected, so were several others, whether it'is two train or 18 not and so forth, is very plant-specific.
That is systems 19 interaction now, and you have got to go back into the 20 initiating cause of the particular power supply problem and it 21 could very well be water in the room, smoke or heat in the 22 room.
There could be loss of roou cooling the whole--number t
23 of different ways in which the power supply would start going, l
()
24 and admittedly I hope we haven't designed one power supply 25 gets more than one train, but one cooler might.
I don't know HERITAGE REPORTING CORPORATION -- (202)628-4888
9 199 1
yet.
n'k-2 MR. THATCHER:
I am more optimistic than you.
3 Hopefully we have fixed it that one cooler won't do that.
4 MR. MICHELSON:
We haven't gone in and looked at 5
some of thes_.
Cooler is probably a poor example in this 6
case.
Flooding is a better example.
7 MR. THATCHER:
Well, to jump from cooling to 8
flooding, that, to me that is jumping from equipment to h'
9 general safety concerns.
10 MR. MICHELSON:
That is systems interaction I 11 thought relative to these electric power supplies, but maybe 12 not.
I don't know.
)
13 MR. THATCHER:
Well, we are looking, systems 14 interaction, we are looking at when power supplies go sour on 15 you, what kinds of things happen.
Now they could go sour 16 because they fail themselves.
They could go sour due to 17 flooding I guess.
We havs had cases where we put water--
18 MR. MICHELSON:
You are starting with the power 1
19 supply.
If you now, if you say it is flooding, you don't 20 start with the power supplies.
You go back with the 21 initiating event being a flood and see where all the flood 22 goes to, to see now if the loss of that power supply is still 23 acceptable.
t
()
24 MR. THATCHER:
All I will say, we are not proposing 25 to go look at flooding under GI 128.
We are proposing to look HERITAGE REPORTING CORPORATION -- (202)628-4888
200 1
at flooding under A-17.
r~T
(_)
2 MR. MICHELSON:
That was the part I misunderstood.
3 MR. THATCHER:
All right.
I have probably said more 4
than I should have on that issue.
5 Again to reiterate, as far as IPEs, IPE, and PRA, 6
right now the individual plant evaluations involve a 7
plant-specific look for vulnerabilities, and it does involve 8
some types of systematic reviews, and it, it is to include the 9
general subject area of dependent-type failures which we 10 consider systems interaction to be a subset of the general 11 class of dependent failures, so we feel that A-17 type of 12 information is the kind of lessons learned that should be
(~'s
(_)
13 looked at in that area, so we feel that supplying this 11 information for use in both IPEs and PRAs is appropriate, and 15 also as I said before, this is also not only to licensees, but 16 it is to internal staff lessons learned for future review of 17 the IPE since that hasn't been performed yet.
18 MR. THATCHER:
The last aspect of the resolution has 19 to do with our program on multiple system responses.
I do 20 have some back-up slides on this.
I don't know how far we 21 want to get into this.
22 I did want to just make the point that there were a 23 number of concerns raised on USI 17, A-46 and A-47, and I 24 think we have actually been talking about soma of those here.
()
25 We also think that there is some other major programs involved HERITAGE REPORTING CORPORATION -- (202)628-4888
201 1
because some of the concerns involve questions as to what was (3
(/
2 done in fire protection reviews or what was done in equipment 3
qualification programs and so forth, sc we are looking at more
'han just those, the three USIs that I mentioned.
4 c
5 The basic objective of the program is to take the 6
concerns and to define them into potential generic safety 7
issues, so from that point, we can develop the information and 8
then supply that information to the group that does 9
prioritiations, and that's basically the objective of this 10 program.
11 We have been having a lot of problems, I will admit.
12 The concerns are very broad, and we are trying to group them (n_) 13 into some pieces that we think are doable.
We start 14 postulating a seismic event and various things simultaneously 15 happening, it gets pretty complicated very quickly.
16 We are trying to group the concerns based on 17 initiating events.
Maybe that gets a little bit to what Dr.
18 Michelson was referring to.
So we have a--maybe I will put up 19 some, some of my back-up information, if I can get them apart.
20 MR. MICHELSON:
Is there a timetable, kind of a 21 program plan now for this program?
Is there a timetable and 22 that sort of thing?
23 MR. THATCHER:
No.
There is not really a--I don't (v~)
24 know if you will be able to read that.
There is not really a 25 timetable.
HERITAGE REPORTING CORPORATION -- (202)628-4888
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MR. MICHELSON:
It is really a program, though?
[~)
As 2
MR. THATCHER:
It is a program.
It is not, it is 3
not an issue.
It is a program to find the issues, to find the i
44
. issues and then proceed based on what their priorities are.
5 Unfortunately, I don't have copies of this.
I just--
6 MR. WARD:
Is this from a document?
7 MR. THATCHER:
This is a draft from a report from 8
our contractor in which they tried to take the various 9
concerns that were raised and--as you see, we are trying to 10 couple them to the initiating type of event.
Then there is a 11 description of the concern and there is a reference to the 12 report section in which that issue is identified.
()
13 We are also in the last column trying to see if the 14 question is one of regulations, that is, the regulations don't 15 go that far or they don't cover a particular area, or whether 16 it is more a question of well, we have a fire protection 17 guidance or rule, or GDC that says you shall protect from thus 18 and such, but the implementation may be through operating 19 experience.
We have seen cases where they apparently haven't 20 implemented that kind of guidance, and as a result, events 21 happened or something, ao we are trying to break them down 22 that way.
That's more of a--when we get to the point of 23 trying to decide how something should be resolved, there is
(])
24 various paths, and one is to change the regulat?.ons and one is 25 to just see if what we are, already require, see if it is
[
HERITAGE REPORTING CORPORATION -- (202)628-4888
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being done, so that's the reason we are doing that last O
K/
2 column, but these various concerns have been raised on, mostly 3
from issues or letters from the Committee.
The major section 4
of references on all these is ACRS letters on A-46, A-17 and 5
A-47.
In fact, I guess the A-47 letter just came out in April 6
where we--that is reflected in here, although you couldn't 7
tell from this slide because the numbers don't mean anything.
8 MR. MICHELSON:
All right.
There is going to be 9
some more?
This one is on seismic.
There is going to be 10 others?
11 MR. THATCHER:
Dean took the other two that were on 12 fire, design basis events, plant transients, those kinds of g)
(_
13 things that could be initiated from control systems.
14 MR. MICHELSON:
On the seismic, it is a little 15 better, but let me tell you what the problem is.
16 If in the case of flooding, for instance, or in the 17 case of fire, you have got the challenge to the equipment now 18 which is in one case water intruding into the equipment, 19 another case, heat intruding into the equipment.
20 In order to do some kind of a, an analysis of what 21 happens thereafter, it is necessary first of all, to 22 understand how the equipment behaves once water has intruded 23 in or you have heated the equipment and we have got plenty of
()
24 experiences to indicate the funny things that are happening.
25 Without that understanding of how the equipment is HERITAGE REPORTING CORPORATION -- (202)628-4888
204 1
going to behave when it receives the challenge, it is very (f
2 difficult to do the response analysis, and in the case of 3
seismic, we have done a pretty' fair amount of work now to know 4
how relays chatter and that sort of thing, and we know that 5
the equipment behaves structually well, although the 6
non-seismic equipment we are not sure of as much about, but in 7
the case of the flooding problems and the heating problems, we 8
know very little about how the equipment behaves when it sees 9
this event, and until we do, how can we do some kind of a 10 systems interaction study?
11 And I don't find those items generally in your 12 program, but maybe you will tell us today yes, they are.
We
(}
13 are going to go back and start figuring out how to do, how can 14 you give guidance to the utility to do a flooding study if you 15 don't give them guidance and what kind of either good 16 assumption or what kind of data they must have on the 17 equipment being flooded?
18 MR. THATCHER:
I guess I somewhat disagree.
I think 19 as far as this program goes, you are almost getting to after 20 we define the concern, and prioritize it, now you go about 21 fixing whatever you decide to?
I mean we haven't--
22 MR. MICHELSON:
How do you decide whether you need 23 to fix it or not?
24 MR. THATCHER:
The thing is, though, I think we do 25 have a lot of experience with heat and water in electric, for HERITAGE REPORTING CORPORATION -- (202)628-4888
205 1
your example, electric equipment, we probably have more f'N i
(_/
2 experienco, and all the experience sa?fs that it doesn't lite 3
those things, and the solution is to keep the water out of the 4
equipment.
That's why we have waterproof enclosures.
5 MR. MICHELSON:
The events that you are going to r
6 analyze still have water entering the equipment.
For 7
instance, inadvertent--the equipment under a fire protection 8-sprinkler is not necessarily waterproof.
There was never a 9
requirement with, for the agency you had to put in waterproof 10 device or waterproof device under a sprinkler head, so it 11 varies from plant to plant all the way from wide open on up to-12 some pretty good caps and whatever kind of protection, but O
(_j 13 there is no guidance from the agency, so what does the utility 14 do when it tries to do this analysis?
Generally he assumes he 15 loses the function of the equipment.
7 16 MR. BAER:
Yes.
17 HR. MICHELSON:
That is not necessarily what really 18 happens.
It may be far worse than that.
[
19 HR. BAER:
Well--
1 20 MR. MICHELSON:
He gets unwanted actions.
21 MR. BAER:
If it is a protection system, as long as 22 you don't affect both the protection systems, I think it is a 23 reasonable assumption.
I think the sublety that you are i
24 driving at is if you fail a protection system, and that also
(}
25 had a control system tied to the same power source, and now I 4
l HERITAGE REPORTING CORPORATION -- (202)S28-4888
206 1
get some greater voltages, fail loss of function, but I get a 2
partial voltage in that control system, now impacted somehow 3
another protection system, the requirement that the protection 4
systems be independent sort of goes back to what Dale 5
said--keep the water away, well, also keep the protection 6
systems independent, so a failure in a single protection 7
system doesn't, shouldn't work over to another protection 8
system.
But that's one of the things that we said in response 9
to the A-47 we will try and look at.
i 10 MR. MICHELSON:
That is one, only one.
That's a 11 secondary type of interaction.
I was sticking with the big 12 ones, the primary ones-,two pieces of equipment receiving the
()
13 two different trains are in the same room, and under the same 14 fire protection and flooding challenge.
In those cases, what 15 do you do when you flood both of them?
Hopefully the utility 16 has thought very carefully and tried to figure out what to do, 17 but I know of at least one case where it didn't work out that l
18 well, and probably many others.
I don't have time to look at 19 very many cases.
20 HR. BAER:
Where two protection systems were both 21 flooded out or affectd by water?
l 22 MR. MICHELSON:
In the same fire protection system, 23 absolutely.
Now the assumption is heat can never get from one
(}
24 side of the room to the other.
That's what saves them.
So 25 you don't set off the fire protection on the other side of the HERITAGE REPORTING CORPORATION -- (202)628-4888
207 1
room during the same physical plant, in the same physical (ks) 2 room, so theae are getting--but you do have to know how 3
equipment responds once you wet it or heat it, and the correct 4
assumption isn't to say we lose its function.
5 The correct assumption is to say I know what it is 6
going to do.
Here is how it is going to affect other pieces 7
of equipment, because if the power supply adverter may not 8
fail at zero voltage when it is wet.
It may fail at high 9
voltage or low voltage, both of which can be detrimental to 10 all the attached equipment, to that adverter, and you have to 11 chase it.
12 MR. BAER:
Then somebody has to chase it.
Also O)
(.
13 another protection system is also affected at the same time.
14 MR. MICHELSON:
That's right.
Now that's when you 15 find out that some cf your chillers are not truly independent 16 of each other, for instance.
17 MR. BAER:
As I said, said at one previous meeting, 18 I think you are out of the regime of looking at generic issues 19 and doing very well plant--
20 MR. MICHELSON:
Reads LERs like I do.
Tell me that 21 never happens in LERs.
If you wish, I will bring you the LER 22 to read.
23 MR. BOSNAK:
I think the thrust of exercise that we
()
24 would characterize here would be the, as Dcle pointed out, the 25 prevention.
That's not to say you are going to, you are HERITAGE REPORTING CORPORATION -- (202)628-4888
208 1
always going to be a hundred percent assured that you are
()
2 never going to have this situation, but if you have some 3
obvious paths or intrusions of water, you can prevent those, I 4
think you are going to improve the safety of the plant.
5 That's what we are trying to do.
6 HR. MICHELSON:
Do we require prevention?
7 HR. BOSNAK:
That would be the exercise going 8
through this water intrusion.
That would be the bottom line 9
or the--in other words, the guidance, that if you have an 10 obvious path of intrusion, flooding, that you are going to 11 have to prevent it.
12 HR. MICHELSON:
We only require protecting the other 13 train of equipment.
We have a flood in a given area, but we
{}
14 don't check to see if they are interacting with each other.
15 We are just seeing what ccaponents are flooded and total those 16 components.
That's it.
17 HR. THATCHER:
Let's see.
I guess you have got 18 copies of these two.
The general type of description is on 19 there.
The section of the report--I will talk about it in a 20 little more detail, but we still are struggling, as you can 21 see, with some,retty broad areas.
Each one of these would 22 maybe suffer the disease that Dr. Michelson is talking about 23 in the sense that whether it is seismic flood, fire or 24 whatever, if you are really going to proceed with the
-s 25 assumption that water, for example, water is going to get into HERITAGE REPORTING CORPORATION -- (202)628-4888
209 1
redundant equipment, that you are going to have to know how 2
the equipment is going to respond, but I don't, I don't know
~
3 of anybody that has really done those kinds of analyses.
They 4
really try to prevent the water from getting into sensitive 5
electrical equipment.
They can let water run around on pipes 6
and pumps and so forth, but as far as sensitive electrical 7
equipment--
8 MR. MICHELSON:
We already had the example at Surry 9
to show how water from the break gets to the fire protection, 10 which in turn got down on the panel which in turn ran and set 11 off the CO2 and so forth.
You're dreaming if you don't think 12 these things can happen.
(D sj.
13 MR. THATCHER:
We also have to put a lot of dreaming 14 to find these things, too.
15 MR. MICHELSON:
Well, you have got one to look at 16 that killed a few people and also made quite a mess.
You 17 don't believe that was real?
18 MR. BAER:
No.
I do.
Dale earlier had a slide up 19 that said some of your questions, some of the Committee's 20 concerns bring in the whole question of fire protection, and I 21 think--
22 MR. MICHELSON:
Among others.
23 HR. BAER:
I'm not sure that as long as you have
()
24 fire protection systems, that you are not, it is a competing 25 risk.
You have a higher degree of assurance that you will put HERITAGE REPORTING CORPORATION -- (202)628-4888
210 1
out fires, and you have a lower degree of assurance that you
~k-)
2 won't have thes, sort of interactions.
3 MR. THATCHER:
I think we have promised to, as part 4
of this program, we would keep the Committee informed as we go 5
along developing these concerns into issues and then in 6
addition to that, I would expect, as I think you had this 7
morning, we would see, eventually see a presentation on the 8
prioritization of those issues that came out of these S
concerns, so in that sense, you would be seeing a lot more of 10 some of these things.
11 MR. MICHELSON:
Let me ask a related question before 12 you go on.
There is some things that aren't presently rm
(_)
13 included too well, and what are your thoughts when you do e 14 systems interaction study?
How are you going to consider the 15 maintenance-related kind of failures where people leave the 16 bonnet off the valve, flood an area maybe you never predicted 17 would flood in such a way or you have an operator doing other 18 ltinds of things that you hadn't predicted?
How, what kind of 19 events are we going to consider credible for A-17 analysis 20 purposes?
21 MR. THATCHER:
Well, as far as--you are referring to 22 the flooding kind?
23 MR. MICHELSON:
I am referring to what can
(}
24 maintenance people do to you, as human beings, do to you, the 25 human factor.
HERITAGE REPORTING CORPORATION -- (202)628-4888
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MR. THATCHER:
I think the thing that we pointed out
(')-
2 in our generic letter is that, you know, things can come about 3
through maintenance.
That's about--
4 MR. MICHELSON:
That doesn't help the utility to 5
decide'how to do the study, but you want them to certify it, 6
that he has done it.
7 MR. BAER:
On the flooding, because the flooding is 8
a source pathway target, and I agree with Dale.
I think what 9
you are, you try and do is disrupt the pathways.
10 MR. MICHELSON:
The old flooding said it didn't 11 require you to take the big breaks like I get if he leaves the 12 top works off 12 inch valve.
()
13 MR. THATCHER:
You had to c.,
the snubber.
14 MR. MICHELSON:
I am talking outside of containment.
15 I am talking about out of the pump rooms and so forth.
16 MR. BAER:
The original Quad City was the boot on 17 the condenser.
It filled pretty much the turbine building.
18 MR. MICHELSON:
Oh, yes.
It did more than that.
It 19 it did a good deal more than that.
Are we telling them to 20 look for those kind of failures then?
I 21 MR. BAER:
My opinion, I think the licensees have 22 probably done a better job on the big--just a guess on my 23 part--on the massive amounts of water than on the, the toilet 24 got clogged up and overflowed and went down the ducts and O
25 tripped into a power supply somewhere.
I think--and there HERITAGS REPORTING CORPORATION -- (202)628-4888 i
212 1
wasn't a lot of water and one toilet bowl flush I guess, or O
'()
2 two.
My impression, just impression, is that they probably 3
have done a better job on the massive flooding than on the 4
smaller amounts.
5 MR. MICHELSON:
You aren't going to give any special 6
guidance on human factor at this time?
Just I couldn't find 7
it in there and I wasn't, I found the word maintenance and 8
that inferred the human factor, but I wasn't sure what was 9
meant by maintenance.
10 MR. BAER:
You are talking about in terms of 11 flooding analysis?
12 MR. MICHELSON:
In terms of certifying that you have
()
13 done the analysis.
14 MR. BAER:
I don't think we thought about that one 15 specifically.
16 HR. MICHELSON:
I couldn't find too nuch really on 17 the environmental control systems, although I found a little 18 bit.
That's a great potential source in a lot of ways, 19 conduct water through the duct work, losing the coolant to 20 more than one room and that sort of thing.
The guidance 21 provided some--
22 MR. THATCHER:
Well, the water through the ducts, I 23 think we got that in the flooding analysis, but then as far as (J~h 24 the cooling water, cooling equipment, that's not a flooding 25 concern.
That's a support system concern which would only HERITAGE REPORTING CORPORATION -- (202)628-4888
213 1
appear in the information portion of the letter.
We are not
- (~%
(_)
2 asking them to certify that.
3 MR. MICHELSON:
Well, it was part of system 4
interaction because the flood got the cooler where I in turn 5
got a whole lot of'other equipment you haven't included in the 6
analysis.
It is what, the way these events go.
So I don't 7
know.
8 MR. THATCHER:
Well, again, I guess we are not, we 9
are not being prescriptive in the type of flooding analysis 10 that we think they perform.
That's, we think that there is a 11 lot of good experience that's out there that has been 12 documented in information notices.
We have reiterated all
.()
13 that in the letter.
I guess we don't really know what else to 14 tell them I guess.
I really didn't have anything more than 15 that.
16 MR. WARD:
Dale, would you go back to your slide on 17 the A-17, input to PRAs, the next, your next to the last 18 slide?
19 MR. THATCHER:
This one?
20 MR. WARD:
Yes.
I guess I am wondering, how, are 21 there PRAs that have successfully included the sorts of system 22 interactions, systems interactions you are talking about here?
23 I mean how is it done?
Is it another--when I think of PRAs, I 24 think fault trees developed from the design drawings in i
25 essence, and you are talking here about interactions that HERITAGE REPORTING CORPORATION -- (202)628-4888
214 1_
~ don't show up on' design drawings.
So how do you--
' (~)
s-2 MR. THATCHER:
Some'of them; yes.
There are some 3
that'show up on the design drawing.
If you have a functional 4
interaction between power supply, X and pump Y and so forth, 5
that will, that can show up on a functional, I mean in a fault 6
tree type of document.
7 MR. WARD:
PRAs should be identifying that sort of 8
thing now.
I see that's not what this program should be.
9 MR. MICHELSON:
It isn't doing that one well, David.
10 Don't forget, PRAs don't go in and say okay, this equipment 11 fails in a mode that reduces its voltage 30 percent or raises 12 it 30 percent.
The air pressure drops down to 40 pounds.
()
13 PRAs don't pick up those.
14 MR. WARD:
They tend to be off on--
15 MR. MICHELSON:
They don't have data on how the 16 equipment responds under theJe conditions, so they don't know 17 how to do it, so they say okay, lost the function completely.
18 That's what t PRA will do, says okay, the voltage drops 30 19 percent, equipment will no longer function.
That's what it i
20 will say.
21 HR. WARD:
I can see that's a problem.
Was that a 22 problem being addressed, that you think should be addressed by 23 A-17?
24 MR. MICHELSON:
I didn't--I asked the question a
(}
25 little earlier, you know, that looks like a fundamental thing HERITAGE REPORTING CORPORATION -- (202)628-4888
215 1
you need to know to do these analyses, how the equipment fs kl 2
responds under these degraded conditions, and whether or not 3
any work was being pursued or proposed or whatever in that 4
area.
5 MR. WARD:
I don't see why that is an A-17 question.
6 MR. MICHELSON:
Because there is 50 pieces of 7
equipment on the mir system maybe, about a hundred and--and 8
each of them sees this drop in air pressure from 90 pounds to 9
40 pounds.
This one will behave in its own way and now you 10 have to look at that collective reaction and make sure it is 11 acceptable and if it gets into both trains of equipment, train 12 A,
train B got the same error.
()
13 MR. BAER:
There is now a separate generic issue 14 with high priority.
15 MR. MICHELSON:
The errors are being picked up I 16 think quite well.
I don't find the comparable pickup on 17 electrical.
18 MR. THATCHER:
Well--
19 MR. BAER:
But the distinction is that the basic 20 plant design did try to have independent electric protection 21 systems, not necessarily control systems.
22 MR. MICHELSON:
Not air.
23 MR. BAER:
Not air.
The plant vulnerability to that
()
24 problem in air is much greater personally.
25 MR. THATCHER:
I guess I'm not a PRA advocate, I HERITAGE REPORTING CORPORATION -- (202)628-4888
216 1
mean super-advocate, but in defense of the fault tree type 2
analysis, If you can establish that the off failure mode is 3
the most conservative type of failure you can have, I see no 4
problem with this, analyzing that one.
Halfway doesn't mean i
5 anything.
Forty percent doesn't mean anything if all the way 6
shut is the worst one.
7 MR. MICHELSON:
If you can show that.
8 MR. THATCHER:
And they do spend a lot of time 9
trying to show that.
10 MR. WARD:
But I mean it seems to me that is within 11 the capability of PRA as practiced now.
I mean there has to 12 be maybe more elaboration in the fault trees or something, but
()
13 an issue like whether a flood from one system, failure of one 14 system is going to affect another system won't show up on a 15 PRA.
16 MR. THATCHER:
It won't show up.
17 HR. WARD:
That is developed from the plant 18 drawings..
19 HR. THATCHER:
I agree.
20 MR. WARD:
In a million years, so that's what you 21 have got to identify in this program.
What I am saying, how 22 do you work that into a PRA?
Do they add a fault tree or 23 something?
24 MR. THATCHER:
Well, yes.
You don't necessarily add
/}
25 a fault tree, but let me just say that if their IPE and PRA HERITAGE REPORTING CORPORATION -- (202)628-4888
217 1
didn't deal at all with flooding, we think it would be covered
(")-
2' by our request that they certify--they did that in our generic v
3 letter, a part of our generic letter.
So transferring lessons 4
learned on flooding to IPE is almost redundant, but I, to 5
answer your other question, as far as can you--
6 MR. WARD:
You are telling them to do that.
I mean 7
you are saying A-17 inputs to IPE and PRAs.
8 MR. THATCHER:
Yes, but only as input to when you do 9
your fault trae analysis, consider all these subtle type 10 support system linkups and so forth; functional, mostly 11 functional types.
12 MR. WARD:
Not the non-functional ones.
13 MR. THATCHER:
No.
The information we are
{
14 providing, the information part of the generic letter is, I 15 don't want to say it is totally functional because some of it 16 is on a system information basis.
I mean that 17 differentiation, but admittedly the PRA fault tree type of 18 analysis can, can best deal with functional, but clearly you 19 know the ARMI program which is PRA based--look at LaSalle.
20 They are doing a lot of spatial work.
You have to, you have 21 to work that into your models before you declare that this 22 part of the fault tree and this part of the fault tree involve 23 independent systems.
You have to verify that those two things 24 to be simplistic are at least in different rooms to some, so 25 you do get the spatial kind of information in those types of HERITAGE REPORTING CORPORATION -- (202)628-4888
_ ~
218 1
analysis.
It is, sometimes it is a question of_ degree, but 2
certainly--I think PRA type of analysis or the modeling that s
3 takes place can certainly utilize spatial type inforraation.
4 It has to really.
5 MR. WARD:
It can theoretically.
I guess I 6
would--do you know to what extent that has really been done 7
successfully?
You say in the LaSalle.
-8 MR. THATCHER:
I think this LaSalle, there has been 9
quite a bit of work done.
10 MR. MICHELSON:
What about LaSalle assuming once 11 they decide a room gets hot?
You have got to have, the PRA 12
.has to know something about the response of the equipment to
()
13 the challenge and so it can draw more branches on its trees.
14 MR. WAkD:
Or connect trees that you wouldn't l
15 believe were connected.
.16 HR. MICHELSON:
Maybe I am wrong, but I believe what 17 they do if the room gets over the rated temperature of the
'18 piece of equipment, they take it out of the tree.
They sav it 19 fails.
It no longer can perform its function, and they go on 20 to see what else can perform that safe shutdown.
l 21 MR. THATCHER:
You have got to be careful what tree l
l 22 you are in.
When you say you, you L111 it and you take it out 23 of tree, that, that that could show up as a real problem.
I
(}
24 mean that's like a conditional probability.
25
'MR. MICHELSON:
It fails to a known safe state, and HERITAGE REPORTING CORPORATION -- (202)628-4888 l
219 1
iri order to do the PRA, you have to know the state of the
({)'
2 failed equipment.
You'can't do a PRA in an unknown state of
'3' failure.
4 MR.-THATCHER:
I-think the difference is what they 5
are analyzing in.their. fault' trees versus what you are talking 6
Jabout because in fact I was sitting down with one of the guys 7
that is trying to work on the common cause f.silure analysis 8
yesterday on ARMI and he was having a-problem with his.
.9 contractors, their evaluation, and he had a drawing of a room 10 that was going to get water in it, and he said they are i
11 assuming with the conditional probability of one, that those 12 cabinets failed.
And I said well, they may not fail.
I mean 13 the equipment may not fail, but that's coming down in event
[
14 tree where you are trying to see what you have remaining'to L
15 mitigate.
I don't even know what the initiating event was, so l
16-in that1 sense, in that fault tree, that's probably a L
17 conservative assumption.
18 MR. MICHELSON:
It may be.
19 MR. WARD:
But you are having the, you are having to 20 add some logic to the logic that was there, you know, on a l
21 traditional PRA approach.
l
- 22 MR. THATCHER:
Yes.
You mean to get the common l'
23 cause?
24 MR. WARD:
Yes.
That--yes.
25 MR. MICHELSON:
PRA should be able to do any of thia HERITAGE REPORTING CORPORATION -- (202)628-4888.
... ~_..
r 1
~
220 1
once you have got the-information and are knowledgeable enough
-v 2
to draw the case.
3 MR. WARD:
Whether it is practical enough or not,.
4 can be practically accomplished is another matter.
5-MR. THATCHER:
Yes.
6 MR. MICHELSON:
The methodology certainly exists to 7
do it.
8 MR. THATCHER:
I think, you know, if we go back on.
9 A-17, over the year, at various times this program seemed to 10-be searching for a panacea method, something to solve all-11 systems interaction, and you know, I think we basically f
12 conclude that there are a lot of different methods you can O
(_/
13 use, but it is a matter of how deep you want to go, how much 14 money you want to spend, and all these kind of things, and 15 really is it going to be worth it?
Is it cost effective in f
f 16 the end?
17 Systems interaction, the subject area, establishment 18 of the USI, all predates any of this PRA type stuff we are 19 talking about.
You know, my opinion, my opinion, is that we 20 have gone so far down the PRA and IPE route that systems a
21 interaction is just a, a small subset of that big, big rc tew i
22 of plant safety in general because we could go off and do a 23 systems interaction review and we had it done in some of the 24 plants, and you find all kind of systems interaction but you
(}
25 don't always know how important they are in a context if you l
HERITAGE REPORTING CORPORATION -- (202)628-4888 f
221 l~
start with the probabalistic risk assessment type analysis, k-2 event trees, and fault trees and developed it that way when 3
you find'a systems interaction, the toilet overflows and hits 4
the control rod drive A or something like that, you can go.
5 back to your PRA and see how important that is, so you know.
6 I don't know if we were ahead of ourselvec 7
establishing systems interaction, or whether, you know, maybe 8
we were chasing the wrong things or we were just chasing a 9
subset, but I think the whole development of PRA and 10 systematic look at plants through the IPE is, has kind of 11 overtaken us in a sense.
But that's all right.
Maybe we shut 12 off the record!
()
13 MR. MICHELSON:
We won't debate it.
I don't agree.
14 MR. BAER Well--
15 MR. MICHELSON:
I say I wouldn't debate it and this 16 is not the time to do it, but I certainly can give you plenty 17 of arguments to point out that PRA is still way behind the 18 kinds of things that systems interaction is trying to point 19 out.
It just hasn't caught up.
Its modeling and its data i
?
t 20 bases haven't caught up to where it can do this sort of thing.
21 MR. WARD:
I agree.
I don't think it has, either.
22 MR. MICHELSON:
I am sure it hasn't.
When I start 23 talking to the PRA people in detail and explain the kind of
()
24 things I would like to see in the model, they say I don't have 25.
the data.
HERITAGE REPORTING CORPORATION -- (202)628-4888
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CHAIRMAN KERR:
It is not a question of technique,
(')%
's 2
not being able to deal with it.
It is a don't know what the 3
interactions are.
In some case you don't know what the 4
probabilities are.
Neither does anybody else.
5 MR. MICHELSON:
That's right, but that doesn't mean 6
then that this is, that this PRA is way ahead of system 7
interaction.
8 MR. WARD:
Oh, I don't think it is.
9 DR. LEWIS:
But not to give PRA a bad name, if PRA 10 hasn't caught up to it, it hasn't caught up with itself.
You 11 know, if you cannot formulate it well enough to get a PR.A, you 12 haven't understood it so well, and that is the situation.
()
13 MR. MICHELSON:
They can draw the models.
What they 14 can't do is put the numbers in.
15 DR. LEWIS:
If you can draw the model, you can put 16 the numbers in. -They may be bad numbers, but I, hell, there 17 is no problem putting in numbers, and putting in numbers is 18 better than not putting in numbers.
19 MR. WARD:
I think the problem is that if you add 20 a'.1 the logic of possible interactions among systems, you are 21 complicating a PRA by a factor of seven, and I think that the 22 practicality of it is, you know, theoretically it may be 23 possible, and bits and parts of doing that are being explored 24 I guess in this LaSalle ARMI or whatever it is called.
(}
25 MR. MICHELSON:
Some of the PRA people have gone HEP.ITAGE REPORTING CORPORATION -- (202)628-4888
223 1
Lback and taken these events they never thought about after 2
they occurred.
They go back and model them and they do a fine
.3 job of modeling them,-showing exactly what will happen.
That 4
is after the fact.
5 MR. WARD:
Trying to model the universal 6
possibilities is--
7 MR. MICHELSON:
Difficult.
8 DR. LEWIS:
That is just the whole point.
If you 9
-think of all possible systems interactions, you are taking 10 very large end and multiplying it by another very large end 11 and you get an even larger end and the whole point of a 12 probabalistic risk assessment is to be able to know which ones
()
13 to throw away, and so it is better than not doing it at all, 14 and another way to find out whether something has a finite 15 probability is to notice whether it has ever happened.
If it 16 has happened, it obviously has a finite probability, but there 17 are two ways, and one way is to do something resembling a PRA.
18 If you don't do it, of course, you can bury yourself in 19 garbage.
20 MR. WARD:
One aspect of observing whether it has 21 ever happened is to just make the, I mean kind of a case study
'22 approach.
I mean you sort of give up on trying to go back 23 totally systematic about this, so you have case studies, and 24 they have included that in this program as I see it.
()
25 MR. MICHELSON:
I don't know that they have gone HERITAGE REPORTING CORPORATION -- (202)628-4888
224 1
through the LERs.
3 s
2' CHAIRMAN KERR:
Just a minute.
If we are going to 3
get that recorded, we can't have more than three people 4
talking at the same time!
5 DR. LEWIS:
We have an excellent recorder.
She can 6
handle four!
7 (Comments were made off the record.)
8 MR. WARD:
Okay.
Is that all you have?
9 MR. THATCHER:
Yes, I think that's about it.
10 MR. WARD:
Okay.
We have a few more minutes. Mr.
11 Chairman, and at this time I guess we have to figure out what 12 the Committee thinks about this or would like to, would like
()
13 to do.
14 I would start out by saying that what we think, what 15 we are going to have to do at this point was deciding who and 16 what subcommittee was going to look into this a little 17 further.
I mean the staff has said they are really ready to 18 go with this.
They would like to go ahead with it now.
They 19 would like to get endorsement and/or comments from the l
l-20 Committee even today, this week.
l l
21 DR. SIESS:
I would think it requires a subcommittee 22 interaction.
23 MR. WARD:
System.
(}
24 CHAIRMAN KERR:
I thought I heard the comment that l
25 that, that they would at least like us to say it is okay to go HERITAGE REPORTING CORPORATION -- (202)628-4888
-. - ~
225-1-
.out for public comment.
[( )
2 MR. WARD:
That's true.
3 CHAIRMAN KERR:
Would be one possibility.
4 MR. WARD:
That's a good statesman-like comment.
5 Well--
6 CHAIRMAN KERR:
What do you think, Committee?
7 DR. SIESS:
Well, if the reason for saying go on to 8
public comment is to give us more time to get our comments, 9
the reason is we want to wait to hear that what the public 10 says, I have mixed feelings.
11 MR. WARD:
Yes, I do, too, but I think if we, if we, 12 if we say you go ahead, ju:st that simply means we just aren't
'( }
13 ready for comment.
14 DR. SIESS:
We need more time.
15 MR. WARD:
That's all right, but I should, I should 16 think we ought to give some indication whether you think they 17 are going in the right direction or not on that.
If we are 18 going to be eventually in some sort of total. disagreement with 19 them, I think we ought to say what we can about that now.
20 DR. SIESS:
What I have heard here today, we think 21 that they are going to the right direction, they are just not 22 going far enough.
4 23 MR. WARD:
But I'm not sure we can tell them or 24 anybody can tell them how to do it better.
I mean--
25 DR. SIESS:
I think that is true.
I think if we HERITAGE REPORTING CORPORATION -- (202)628-4888
226 1
expect them to wait until the system interaction issue is 2
resolved completely, then that will take forever.
That's 3
ridiculous.
I think they ought to go out and tackle it in as 4
many directions as they can, and as many fronts as they can, 5
and keep working on it.
It ain't going to go away.
6 HR. WARD:
That's what they are proposing.
7 MR. MICHELSON:
They are proposing it go away?
8 MR. WARD:
No.
9 MR. MICHELSON:
It goes away except for this next 10 interaction program which is yet to be defined, yet to be I 11 think a real program.
We don't know what that, what--that's a 12 unknown.
()
13 DR. SIESS:
Systems interactions are not going to to 14 go away.
15 MR. MICHELSON:
Program plan any kind of detail.
16 DR. LEWIS:
I just think there is a level--I am here 17 because when this first came up, long before I was on this 18 Committee I believe, it was, it was a sort of negative 19 reaction to ignoring interactions between systems.
People 20 said quite frankly that you could have deleterious--everyone 21 said look.
Nobody ever defined the problem, and I don't think l
22 anybody has defined the problem yet, so what the staff has l
23 done is to at least take some, you know, subsets of ways in
(}
24 which as I understand it, which systems can interact with each i
25 other, and do them, and they want to gat rid of the job and HERITAGE REPORTING CORPORATION -- (202)628-4888
227 1
after that point because it is a never ending job unless you
' (')
(/
2 do a PRA reasonably well to narrow the universe of discourse 3
or you do it anecdotally which is the other way, to find out 4
what place systems do interact with each other, I don't think 5
there is any natural end to this in which it can be done 6-right.
There is no right way for doing this, so I would be 7
happy to bless them and let them go on to something more 8
useful.
9 CHAIRMAN KERR:
It seems to me that they are making 10 significant progress, and I would be inclined to say, you 11 know, let's bless them, and tell them to publish a report, and 12 we will have another set of systems interaction next week or
()
13 the week after that, and we wait a couple of weeks.
14 MR. WARD:
Wait a minute.
They are proposing this 15 multiple system response program which is going to attempt to 16 sort through something or other to identify other specific 17 pieces of this overall issue.
18 CHAIRMAN KERR:
I think they can't quit.
19 DR. LEWIS:
I agree with what Bill said it, that is 20 to say bless them and let them go, but I wouldn't bless a 21 comment saying this takes care of the subject and systems 22 interaction.
23 CHAIRMAN KERR:
Mr. Siess?
24 DR. SIESS:
Systems interaction is going to continue
{}
25 to occur at various times, even times we haven't thought HERITAGE REPORTING CORPORATION -- (202)628-4888
228 1
about.
I don't think the staff should forget about the
.(w 5
2 potential for systems interactions.
I don't know what their 3
mechanism is to continue to be concerned, but that mechanism 4
is not closing the generic issue or something else.
I don't.
'S think the industry should overlook systems interaction.
I 6
think PRA should be conscious of it.
You never are going to 7
find them all, and you are never going to eliminate them all, 8
and from here on out it seems to me that as they occur, you 9
are going to take that one as an example, try to expand it 10 into a class, and then look at it.
And it isn't already 11 covered.
12 When you have taken care of those, the next one
()
13 occurs, you do the same thing and you continue to learn from 14 experience, and do what you can to fix it.
The problem isn't 15 going to go away.
Our concerns'is not going to go away.
The 16 staff should not go away.
How they formally continue that 17 concern I don't know.
That's--
18 DR. LEWIS:
You know--
19 MR. WARD:
Wait a minute.
They do have a prograr I
20 for formally continuing it.
That's this.
21 CHAIRMAN KERR:
You can put that in your letter.
22 DR. SIESS:
That could be it.
That program will 23 come to some kind of end and systems interactions won't.
It l
[}
24 is just something that isn't going to go away, and we 25 shouldn't kid ours that there is any way we are going to close l
1 l
l HERITAGE REPORTING CORPORATION ---(202)628-4888
229 l'
it out, period.
.O
\\~/
2 CHAIRMAN KERR:
Does that give you enough guidance?
3 MR. WARD:
You were going to say something?
4 DR. LEWIS:
No.
5 MR.'MICHELSON:
When did we expect to hear about_the 6
multiple systems response program?
We heard today that you 7
think there is such a program, but you certainly didn't tell 8
us much more.
9 MR. BAER:
We are spending money on it, Carl.
-10 MR. MICHELSON:
I don't doubt that.
When will we 11 hear of something substantive and documented as to what your 12 plan.and procedure will be?
()
13 MR. BOSNAK:
The only answer we can give out is that 14 we are continuing to study it and if we can identify several 15 of the kinds of interactions that you have been talking about, 16 then we would put them through the generic issue process.
In 17 other words, that they'would be identified, prioritization 18' would.come out, and either, they would either fall by the 19 wayside or they would be continue to be worked on, depending I
I 20 on how they are prioritized.
21 I just want to add one other thing.
I think--I 22 don't know if this is any help, but I look at this much the l
23 same as I have looked at water hammer.
Water hammer is a, was
(}
24 USI 1.
It was an area that the staff quote, closed out, but 25 we are still concerned.
That water hammer will never go L
HERITAGE-REPORTING CORPORATION -- (202)628-4888
230 1
away.
System interactions will never go away.
.{';
2 MR. BAER:
That is part of the guidance we do give 3
to the industry.
4 MR. THATCHER:
I was going to say we do want to come 5
down to the Committee and talk about this multiple system 6
response program to make sure that, that we have the kinds of 7
things on those lists that the Committee is concerned about.
8 MR. MICHELCON:
We have been asking for a year and a 9
half, maybe two years, to hear about it.
I haven't yet heard 10 you present the first--
11 MR. BAER:
Let me make a very specific proposal.
12 We, in responding to the A-47, we listed a bunch of items we 13 said we are going to put in there, and we said we are going to 14 get together with the ACRS staff.
Let me commence to talking 15 to Med next week about maybe building on A-47 once we collect 16 some that are associated with A-17 just as our letter said, 17 and at least try and define those issues well enough, bring in 18 our contractor, and have the subcommittee meeting.
19 MR. MICHELSON:
I have no real problem with the 20 difficulty of what you are trying to do.
I recognize that, 21 and I realize that perhaps we have to take off a small piece 22 of A-47 and identify it as resolved.
The rest of it, though, 23 must be clearly identified as not resolved, and in a part of 24 the new USI.
That process is not in--reading this document, I O#
25 am not sure whether you think it has now gone away, what you HERITAGE REPORTING CORPORATION -- (202)628-4888
231 1
think is going to go into the multiple systems program, and it (3
k#
2 is not clear to me what your real plan is, and therefore, what 3
are we resolving when we say A-47 is resolved, or A-17?
4 CHAIRMAN KERR:
Why don't we leave it we are not 5
sure what is resolved.
Must have resolved something.
6 DR. SIESS:
You report to Congress every six months.
7 MR. MICHELSON:
USI is being closed out, is that 8
correct?
9 MR. BAER:
A-47.
10 MR. MICHELSON:
A-17.
31 MR. BAER:
Depends partially what you say, what this 12 Committee says, and partially what CRGR says.
m 13 MR. WARD:
Let's get that clear.
Isn't that your s
14 intent?
You think you have got a resolution to A-17?
15 MR. BAER:
We think that the major seismic risk is 16 being taken care of by A-46--not all of it, but the major 17 part.
We think if licensees will go back and relook and see 18 that they have done a thorough flooding study, that that takes 19 care of a large portion of the flooding risk, and I think the 20 residuals we are progressing to go look at multiple system 21 response progress.
22 MR. MICHELSON:
You intend to be close out A-47 as 23 the issue and create new ones?
()
24 MR. BAER:
A-17--I got you off on the wrong track.
25 MR. MICHELSON:
You will close out A-17?
j HERITAGE REPORTING CORPORATION -- (202)628-4888
232 1
MR. BOSNAK:
A-17, the scope that you see before 2
you, the seismic, and the flooding, and that's the issue that 3
is being closed out.
4 MR. WARD:
You may identify other issues under this 5
MR, whatever it is, program.
6 MR. BOSNAK:
Exactly.
7 DR. SIESS:
Hope you don't make them USIs.
8 DR. LEWIS:
I am just hoping for a bit of education 9
here.
I have already said I don't know--a seismic event that 10 destroys 17 things, common cause failure, is a kind systems 11 interaction, but a seismic event that topples a battery off a 12 shelf that falls on top of an operator is a systems
()
13 interaction, is that correct?
14 MR. BAER:
We have the same difficulty.
And many 15 years ago, Vic Stello came down with slides showing common l
16 cause failures and then what subset was system interactions, j,
17 And I don't know if you have a copy of it.
i 18 DR. LEWIS:
If a pump overheats and catches fire, l
19 and the fire destroys six other pumps, is that in your view a l
20 common cause failure or systems interaction?
21 DR. SIESS:
Common cause failures during systems 22 interaction.
23 DR. LEWIS:
Which is it?
24 MR. WARD:
It is a systems interaction leading to
(}
25 common cause failure.
HERITAGE REPORTING CORPORATION -- (202)628-4888
m._
t 233
/.
1 MR. THATCHER:
We define systems interaction as a subset of common cause failure.
- 2-3
-DR. LEWIS:
Oh, really?
That is a strange-4 definition.
I' disagree'with that, but okay.
5 MR. MICHELSON:
We are getting there.
6 CHAIRMAN KERR:
Is that sufficient education for one 7
afternoon?
8 DR. LEWIS:
Oh, that is sufficient education.
9 CHAIRMAN KERR:
Are we finished with this topic?
-10 DR. SIESS:
I want to say one thing.
-11 CHAIRMAN KERR:
On this subject?
12 DR. SIESS:
Yes.
I think it is a mistake if they do
(/
13 continue systems interactions, to continue it as a USI, 14 because there is a great pressure on the staff to resolve 15
-USIs, not to: write them off, to end them, and I put resolve in 16-quotes.
I would hope that it would end up as a generic issue, 17 for the pressure to resolve has not been the same general i
18
. nature.-
i 19 MR. MICHELSON:
Which the importance is not as great 20 perhaps as warranted by USI.
21 CHAIRMAN KERR:
Any further comment?
Next 22 topic--thank you, gentlemen--ACRS subcommittee activities, CM s
23 slash RKM.
Carlyle?
()
24 MR. MICHELSON:
Are we ready to go?
This is to be a 25 brief report of the Advanced Boiling Water Reactor I
HERITAGE REPORTING CORPORATION -- (202)628-4888 l-
(.
234 1
subcommittee.
}'
2 The subcommittee held a meeting this week in which 3
we started the formal review of the advanced boiling water 4
reactor, and Mister--just a minute.
5 The FSAR for the advanced boiling water has been 6
received.
In part what the staff has done is divided the FSAR 7
into four modules.
Each of these modules consists of several 8
chapters.
In the case of the first module, which we just 9
finished our preliminary review on, that included Chapters 4, 10 5,
6, and 51; and the next module then showed Chapters 1, 2
11 and 3, and then on down, but there will be four sets of these, 12 of these chapters, so that the staff intends to write off, 13 prepare a safety evaluation on each module, so the ACRS has 14 been asked to also prepare its lettor as we go on each module.
15 Now clearly as we writs a letter on a partial 16 incomplete FSAR, we can put in whatever caveat we wish, to i
L 17 hold items open maybe until the end because we will also l
18 prepare a final letter at the time that the final SER is being 19 prepared.
It would be an input to that final CER.
[
20 So that is the basic, the basic approach that we are i
21 using.
The SER dates, and unfortunately maybe you have 22 get--do you have a copy of the schedule?
I seem to have I
23 misplaced, I have misplaced mine.
I didn't realize I was on l
24 the agenda quite at this moment, so I didn't have time to dig
()
25 for it, but it would be helpful if I had it in front of me.
I l
HERITAGE REPORTING CORPORATION -- (202)628-4888
235 1
have got it somewhere.
i 2
CHAIRMAN KERR:
Here it is, Carl.
3 MR. MICHELSON:
Yes.
That's the one.
That's 4
helpful.
The first staff SER is going to be issued in March 5
of next year, and then the, and again in September, and 6
December of next year, and then the January and--of 1990, 7
along with a final integrated SER whose target now is July 8
1990, so we are trying to fit our review schedule into that 9
basic approach that the staff is using.
I see no particular 10 problem with it, at least at this time.
11 The subcommittee will be holding about eight 12 subcommittee meetings over the next two 'lears to cover the
(
13 full spectrum of the FSAR.
We will be looking at each module 14 once, an overview, and then a second meeting in which we will 15 ask any detailed or follow-up questions, and generally all the 16 latter meetings will also require that we write final letters, 17 only one of the chapters or one of the modules at each of the 18 meetings, but not always.
' 19 So fairly large piece of work; the staff is getting 20 nicely underway.
Our subcommittee review I think is also 21 getting nicely under way.
22 There is one small change that has been made to the 23 schedule at the request of the Chairman of the Conmission, and
()
24 that is that he has asked GE to, or at least has suggested to 25 GE that they include that turbine balance of plant in this
-HERITAGE REPORTING CORPORATION -- (202)62b-4888
236 1
FSAR, and keep in mind now the FSAR is going to do, we are
'2
{'
going to do two things--first of all, issue a final design 3
approval, and then go through the certification process.
That 4
is the plan.
5 DR. SHEWMON:
There has been talk about with the 6
advanced reactors, that the vender would have a larger 7
fraction of balance, balance of plant things built ten years 8
ago.
9 Is that the case here, or do we know or is your 10 review, what, is your review any different from what it was 11 when you reviewed the BWR 6?
r 12 MR. MICHELSON:
Yes.
It is different in that it is 13 a,
it is, well, generally at the FSAR stage of normal plant, 7-V 14 normal plant in the past, that all the balance of plant flow 15 diagrams, that sort of thing, are basically FSAR at that time, l
16 available for whatever interest that the agency may have in i
17 it.
18 It was thought first in this process we would not i
i 19 have turbine building, for instance, balance of plant 20 information, other than interface requirements.
Now I 21 understand we will include the turbine building, and the rad 22 waste area, but we will not include the service water system l
l 23 out at the river or ultimate heat sink since that is very site l
24 specific really.
So that's the present plan, I think 25 basically to includo everything that might affect safety at l
l HERITAGE REPORTING CORPORATION -- (202)628-4888
~
237 all, except the service water.or ultimate heat sink intake-1 2
plant structure.
That's the way I understand it.
3 DR. SHEWMON:
Is GE specifying more of this now or 4
will they be putting more restrictions on that than earlier 5
plants?
6 MR. MICHELSON:- That I don't know, but I--are you 7
asking how much information will the_ staff have available?
8 DR. SHEWHON:
No.
I guess I am asking whether the 9
standard plant will include things which used to vary so much 10 from plant to plant, depending on who does the--
~11 MR. MICHELSON:
Hopefully those kind of things will 12 all be standardized under the GE scope of supply or at least
()
13 under the GE design control.
R14 CHAIRMAN KERR:.That is really the direction--
15 MR. MICHELSON:
Apparently right now the only thing 16 that is hanging'out there that isn't tied down is that service 17 water thing.
18 DR. SHEkdON:
Fine.
19 MR. MICHELSON:
That we haven't seen, I haven't at l
l 20 least seen the information, but presumably it will be tied 21 down with interface requirements.
Maybe there will be more 22 than that before we get done.
I don't know, but that was my 23 understanding.
(])
24 The subcommittee met, as I say, last week, or this 1
25 week, and our next meeting will be in November of this year.
HERITAGE REPORTING CORPORATION -- (202)(28-4888
.. ~
238 1
At that time, we will do our follow-up questioning on module 1
'( )
2 and get our overview of module 2, and by that time, any 3
questions that the subcommittee members have or the Full 4
Committee would like to see certain subjects discussed in 5
greater detail or whatever, I would need to know that 6
information hopefully by the first of October so I could get 7
it on the agenda because GE has indicated a, you know, they 8
are quite happy to provide any kind of information, any kind 9
of presentation, but they would need to know in advance 10 because these people are being, their people are being tied up 11 mostly with the ese work since this plant is being built 12 in Japan right now, or will be.
It is being reviewed.
It is
/'T 13 a sole plant to be put on line about 1993, '96 now,
'96.
It V.
14 is considered to be about a 48 month construction schedule, 15 but about a two or three-year licensing and in-ground 16 preparation, so that's right, so they are, 48 months is from 17 first laying of concrete until final commercial operation, but 18 they are digging all the holes and things.
They are counting real time when they power the concrete.
19 I
i 20 So we think we have got a realistic schedule, but we 21 don't know--when we get to module 3, for instance, that 22 contains about eight chapters of the FSAR, and clearly it vill i
23 take more than a one-day meeting to cover that much ground.
l 24 We anticipate, the next meeting we are already planning on a 25 two-day meeting simp 3y because the ground will be covered.
It i
l HERITAGE REPORTING CORPORATION -- (202)628-4888
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takes about one day just to overview the chapters.
(
2 DR. SHEWHON:
Is that next meeting is November or 3
the next meeting is when?
4 MR. MICHELSON:
The next meeting is November 15, 16, 5
at which time we would hope to discuss all the materials 6
parts.
7 DR. SHEWMON:
Fine.
8 MR. MICHELSON:
Now this is kind of a new experience 9
for the ACRS because generally in the past we have come in 10 late in the game and kind of looked only at the compelling 11 issues that have been brought up during the licensing review 12 process, and in this case, we are sort of going in parallel 13 with the licensing process, hopefully not ahead of it because 14 we don't want to be ahead of it.
We want to be closely behind 15 so that as they write off these modules, that we are already 16 on board, and in agreement, because they taant our, basically 17 our approval of the modules as they come up, and the first one 18 will be next March.
19 Now I hadn't, my present plan is not to have 20 technical presentations made to the Committee.
We had one not 21 too long ago which overviewed the ABWR.
Unless you wish to 22 reoverview the ABWR, I would intend to bring forward only the, 23 those technical issues that are obviously getting into 24 difficulty for one reason or another, and for which we think
(
25 the Full Committee concurrence would be needed.
As we go such l
HERITAGE REPORTING CORPORATION -- (202)628-4888
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1 things--and I am sure severe accident is going to get sticky.
I 2~
The resolution of certain, the use of certain USIs and GSIs 3
which have to be included in the design, things of that sort, 4
that might be, get difficult.
I think I would like to bring 5
to the Committee those particular issues, but with just enough 6
overview to understand the connection.
7 If it deals with reactor vessel, certainly want to 8
tell us more abo c reactor vessel before we got to the 9
specific issues, but I didn't plan on any more overviews than 10 what we already had unless the Committee wishes, and after the 11 November meeting, then te will see what has come up during 12 that meeting as to whether or not to bring it to the Full
()
13 Committee, say in December or January.
That would be the 14 plan, to bring to you only our problems instead of all the 15 good information, unless you wish to get maybe mere than one 16 briefing on the overview, or general information.
17 Now we do have to keep in mind that when we write l
l 18 our individual module chepters, we are essentially writing off 19 on that and do not intend to go back to those issues unless we l
P0 have reserved certain problems for later, the final l
21 consideration, and now once we write our final letter and 22 that's purely final, this will be frozen, further 23 consideration, as you heard frcm our standardization p]'
24 discussion yesterday, this is the part of the standardization i
l
~
25 process that means these matters go back final as far as our HERITAGE REPORTING CORPORATION -- (202)628-4889
w 241 1
continuing review.
Unless some new safety issue appears or b)
N/
2 some real serious problem appears, we would not expect to 3
visit the area again.
4 Now there are a number of problems that I can 5
foresee that we will have coming up.
One thing is the EPRI 6
work on the improved light water getting out of phase with the 7
ABWR.
EPRI is falling behind it.
It is going to be a little 8
bit of a problem to be writing letters on ABWR in a semi-final 9
state before we write the first letter on the comparable EPRI 10 requirements.
I am a little concerned about getting too far 11 behind.
Right now GE says we are going to do whatever EPRI 12 requires.
If that's the case, we would have no problem, and
()
13 I'm a ;t sure how this will work.
14 The severe accident is clearly a problem because the 15 Japanese are not addressing severe accident as such, and this 16 is a Japanese design.
There is every intention that we, they 17 do not make any changes to it, and if severe accident problems 18 require changes, the Committee would have to decide how to 19 handle it.
20 DR. SHEWHON:
I presume the Japanese will do things 21 to prevent severe accidents?
It is the mitigation aspect that 22 they are tending to ignore?
23 MR. MICHELSON:
They don't want to see a core
(
24 catcher or something like that.
25 CHAIRMAN KERR:
As far as I can tell, the design and f
HERITAGE REPORTING COR ORATION -- (202)628-4888
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containment on this thing is. virtually what it would have been
- ()
2 when we were only looking at design basis accidents.
One or 3
two--
4~
t.A. MICHELSON:
I can point out one that is I'm sure 5
going.to require a lot of Committee attention, and that-is it 6
will not be vented.. There is no provision for vented 7
containment during severe accident.
8 DR. REMICK:
That was a question I asked.
Then I 9
got thinking today there is a requirement in Part 50 that they 10 provide provision for vents.
Now I don't know if that applies 11 to the ABWR because that was a post-TMI or near term, but next 12 time it comes up, I want to see re they going to have the 13 capability?
I don't know if they misunderstood the question, 14 said no, we aren't planning on vent, but if they will still 15 have those access penetrations through the primary 1
16 containment.
17 MR. MICHELSON:
I don't think we pursued it quite 18 that way.
I undarstood, though, that the, the agency is now 19 considering, you know, they are considering rulemaking for 20 severe accident, and how it will apply to new plants, cnd 21 until I see that, I don't know whether we have a problem or 3
22 what.
I think we just have to wait and see, but that is, I am 4
i 73 just trying to point out to you some of the things that--
24 DR. REMICK:
We said we would alert GE to, for the O
25 November meeting what to address, and that is something that i
b HERITAGE REPORTING CORPORATION -- (202)628-4888
1 243 1
we should point out because I don't think that was--
ja)
\\~
2 MR. MICHELSON:
Will the agency have its rulemaking 3
well enough formalized for that time to we can have a good 4
discussion on severe accidents?
5 MR. SCALETTI:
Because the ABWR will not be until 6
January of
'89--
7 MR. MICHELSON:
It is premature for November.
Put 8
it on the first available meeting after we think we are ready 9
to talk about it, and if we have to write a final letter early 10 on. which we will, on the chapter with that in it, we put 11 in--we are going to talk about severe accident later, and we 12 are not writing on that.
()
13 The other thing, what do we do with A-17, A-47, some 14 of these, and it is not clear yet where we will be, we have a 15 problem with scope of certi?.ication.
Let me say that I think 16 we have probably covered the others, other things I was going 17 to talk about, and just a second.
18 I believe you understand how the subcommittee is 19 proceeding.
The main question right now is does the Committee 20 have any problem with the way in which we will bring the 21 information to the Committee?
22 In other words, do you want more technical 23 presentations and are you satisfied with the idea of writing a
(}
24 letter on each of the four modules and final letter on the l
25 whole project?
HERITAGE REPORTING CORPORATION -- (202)608-4888
244 1
CHAIRMAN KERR:
Any disagreement with what Mr.
(D 3_/
2 Michelson proposes?
I see none.
3 MR. MICHELSON:
Then I am finished.
Thank you.
4 CHAIRMAN KERR:
Mr. Remick?
5 DR. REMICK:
I would like to provide a brief report 6
on the meeting of the Regional Program Subcommittee which was 7
held on 24 May in Atlanta at Region 2 headquarters.
Those of 8
the Committee present were Mr. Ward, Wylie, Moeller, myself, 9
Paul Boehnert as the cognizant ACRS staff member.
10 One thing I can say, that the accommodations in 11 Region 2 are quite pleasant on the 27th or 29th building 12 overlooking Atlanta, very nice facilities compared to probably
()
13 what we will have out in the Phillips building.
14 I will say after all, though, when we started these 15 meetings with the regions, and we have been now to Region 2 16 and Region 5, and now Region 3, there was some concern I think 17 at the EDO level, and out in the regions, of what is ACRS i
I 18 doing out here?
But I feel that, that we are being welcomed 19 sincerely by the regional people.
They really do seem to 20 appreciate the fact that ACRS is taking the time in coming and 21 talking with them.
22 Now maybe they are pulling the wool over our eyes, 23 but I don't believe so.
They really make you feel that they 24 are glad to have you there.
They have the tcp level people, 25 and they spend time, and they are very candid in answering HERITAGE REPORTING CORPORATION -- (202)628-4888
245 1
questions on the topics that they cover, so I think there are
(~h s_/.
2 definite benefits from it.
3 Just to give you a few of the highlights, of course, 4
Nelson Grace is the regional administrator.
Hal Earnst, who 5
most of you know, is the deputy regional administrator; about 6
275 employees in Region 2.
They have a fairly large attrition 7
rate, about 30 per year, so that's about 11 percent.
They had 8
some in, replaced those, but indicated last year they hired 9
about 60 people, Jo I guess they are back at, back at level, 10 but they do have a fair turnover.
However, some of that is 11 rotation within the agency moving to other positions and 12 things.
()
13 They are, eight of the ten states that they cover 14 are agreement states, so they don't have a particularly high 15 level of materials license load.
The two states that are 16 exceptions to that are Virginia and West Virginia.
- However, 17 they do have 32 operating power reactors at 20 sites.
Five of 18 those are under construction.
They have nine non-power 19 reactors in the region, five fuel facilities.
20 They load the plant sites fairly heavily with 21 resident inspectors, all of whom with one or two exceptions I 22 believe have engineering degrees, but they have two, three, or 23 four resident inspectors at each site, depending on the 24 competency of those sites and whether they are construction 25 sites or not.
They view SALP as being a very effective tool HERITAGE REPORTING CORPORATION -- (202)628-4888
246 1
for identifying licensee performance.
They hold the SALP
/~s 2
review meetings or exit meetings at the plant site, and as 3
open meetings, and they emphasize that they get a large 4
attendance, particularly plant personnel that attend those, 5
and they last for several hours and have a thorough 6
discussion, so they think that's the way to go, have them at 7
the plant site for increased communication.
8 Also Region 2 was the first region to have the pilot 9
operator licensing requalification program which is being 10 conducted in each of the regions.
That was conducted at 11 Robinson.
They seemed very enthused about this process, 12 admitted it is very resource intensive from the standpoint of (3
(,/
13 the NRC, but they think it is the way to go even though there 14 have been some modifications in the procedures that were used 15 at Robinson.
16 They point out that recruiting and retaining 17 licensing examiners in the region is a major problem.
It is 18 not surprising.
I think it is true in all the regions.
They l
l 19 were quite forthright I thought in discussing problem i
l 20 facilities in their region.
They didn't pull any punches on 21 what facilities and what the problems were.
Yes?
22 DR. SHEWHON:
Where do they get their examiners?
I 23 mean what pool do they draw from that they used?
They have l
l
(~}
24 changed where they get them?
x/
t 25 DR. REMICK:
A lot of ex-Navy; few utility people, I l
i HERITAGE REPORTING CORPORATION -- (202)628-4888
247 1
think very few.
_ {'-
2 MR. MICHELSON:
Where do they come from?
In 3
national laboratories or--
4 DK. REMICK:
They are consultants.
They have 5
national laboratories, but they are licensing--they are hiring 6
themselves.
Large portion of those were ex-Navy nukes.
7 DR. SHEWMON:
Someone came out of the Navy, set 8
himself up as a consultant, and did that for most of his, 9
tried to support himself in this way?
10 DR. REMICK:
Not as consultants; these are employees 11 I am talking about.
They do have--
12 DR. SHEWMON:
Examiners is what?
()
13 MR. CARROLL:
The guy may have come out of the Navy 14 and gone to wark for the Commission to keep federal service.
15 DR. REMICK:
They have a training program for those I
16 people on their own, simulators and so forth.
17 MR. MICHELSON:
These are NRC employees that are 18 used as examiners?
19 DR. REMICK:
The ones I talking about are, yes.
Now 20 the--
21 DR. SHEWMON:
They quit and go someplace else?
22 DR, REMICK:
Get paid higher somewhere else.
Get 23 paid more.
[}
24 DR. MOELLER:
I guess in the rotational scheme, if 25 you are rotating people in-house, that is not necessarily a l
HERITAGE REPORTING CORPORATION -- (202)628-4888 I
248 1-favored step.-
2 DR. SHEWHON:
A dead end job-or something like that.
'3 DR. REMICK:
However, I think they indicated that 4
that, those licensed' examiners are good sources of resident 5
inspectors, but the other way round is not necessarily true 6
because all the resident inspectors haven't had the. operating 7
experience.
8 Okay.
They indicate, indicated that their quality 9
assurance inspections are now performance based, and not paper 10 based, that they are really trying to look at quality, not 11 paperwork.
L 12 On the question of safety conscience, they say that 4
()
13 in~ th eir region, they feel all the plants do have a saf ety 14 conscience. -However, the degree of that conscience varies 15 from plant to plant.
They agree with where we came out 16 earlier, that safety conscience cannot reside in one 17 individual or one organization, but it must be throughout the 18 line organization.
All the regions so far agree with that.
19 I think our ACRS cognizant staff member was at a
)
20 different meeting than I was because in the minutes it talks 21 something about corporate broads, and either way, asleep or at 22-the wrong meeting, we did talk about corporate boards, and j
23 they pointed out that the best corporate safety review boards 24 have external members on them.
They indicated that not many
{}
25 of the utilities in their regions do have external members in l
HERITAGE REPORTING CORPORATION -- (202)628-4888
249 1
their corporate Board of Directors and that maybe something
(/
2 in the future, that if we want to talk about suggested good 3
practice, we might, might consider.
4 On fitness for duty, they indicated that all 5
licensees, all power reactor licensees, in the region do have 6
fitness for duty programs.
They indicated that a majority of 7
those in the region have random drug testing in their fitness 8
for duty programs.
They said that all those licensees have 9
experienced some kind of fitness for duty incidents, and 10 including drugs on site found on vehicles or personnel, cases 11 of employees not fit for duty, and I think that was primarily 12 due to alcohol, and also some employees whc have been arrested f')\\
13 for various offenses off site.
They indicate that s_
14 approximately 5 percent of licensee employees use the employee 15 assistance programs as part of those fitness for duty 16 programs.
17 Those are the highlights that I made note of, and I 18 look to the other subcommittee members who were present if you 19 wish to add anything.
20 DR. MOELLER:
I would just support you in that they 21 certainly project a genuine appreciation for the visit.
They l
22 do share thoughts with us, and of course, one message that 23 comes through clearly is that there is more to the NRC than
(~}
24 the headquarters office.
v 25 MR. WYLIE:
I would agree that the, in having the l
l HERITAGE REPORTING CORPORATION -- (202)628-4888
250 1
presentations from the people, particularly the license, the
(~p
~'
2 person in charge of the licensing examination, we had the 3
opportunity to ask them a question.
That question was what 4
their opinion was on having the degree requirement for SROs, 5
and I asked it in a way that if it was a requirement, would it 6
improve safety, and make no difference, or maybe be 7
detrimental to safety in the long run?
And they didn't hedge.
8 They came out and said in their opinion, it was 9
unnecessary that they be d(Jreed people, and even advanced 10 that it may be detrimental and that they just basically said, 11 you know, it can become a boring job for a good engineer.
12 They were very frank about it.
()
13 MR. WARD:
Well, you know, I guess I remember.it a 14 little bit different.
15 MR. WYLIE:
Do you?
16 MR. WARD:
Something additional--no.
Something 17 additional they said, and I want to connect this with 18 something else.
19 MR. WYLIE:
All right.
20 MR. WARD:
I think, I remember you asked them that, 21 and they said they don't think it is necessary or helpful to i
22 make it a requiremont.
23 MR. WYLIE:
The fellow said that.
Then Grace 24 commented on it.
[}
l 25 MR. WARD:
I remember he said he thinks it is HERITAGE REPORTING CORPORATION -- (202)628-4888
_ _.___ _._.. __.___._.~.,..
251 1
desirable to have some SROs with degrees.
Okay.
The point I 2
want to make, when we were-in Japan at the OE plant I think it 3
was, we asked them about this, and they said they don't, their 4
shift leader, whatever they call them, shift supervisor, is 5
the only guy with license, does not have'a degree.
They take 6
and put him through the training progrsm.
7 However, they said they are thinking of going to a 8
system where one of the five shifts will have a shift leader 9
or shift supervisor with a degree, which is the same sort of 10 thing.
It sort of sounds like the. utilities are finding it 11 useful to salt in some engineers into that organization, 12 although not have it necessarily a requirement.
()
13 DR. SHEWHON:
I was interested in that answer, that 14 discussion where they clearly said some come out of college, 15 some don't.
They both go into this training program which was 16 long and arduous, but I have a very distinct memory of having 17 been to Japan several years ago, and having somebody beat on 18 me that all of their operators were university trained, and 19 after there was some discussion about well, uafversity is so 20 much time, after which somebody else said there is a 21 tremendous range of universities in Japan, and they go from 22 community colleges basically to very selective organizations.
23 DR. LEWIS:
It is like California!
(}
24 DR. SHEWHON:
I just didn't want to say that.
I am i
25 sure you can get that from here.
Whether indeed it varies HERITAGE REPORTING CORPORATION -- (202)628-4888
252 from utility to utility, or whether my memory is playing 1
2.
tricks on me, I-don't know.
I 3-MR. CARROLL:
Forrest, did I understand you 2
'4 correctly that they~ indicated that a number of Region 2 5
utilities were practicing true random drug screening?
6-DR. REMICK:
Timey said a majority, which surprised 7
me and I think others, majority of the licensees in the 8
region..
9 MR. CARROLL:
They didn't mean for cause?
They 10
. meant--
11 DR. REMICK:
No, no--random.
12 MR. CARROLL:
Pure random, okay.
()
13 DR. REMICK:
And I think in response to a question 14 they did say that there was one licensed person who had had a L
15 problem.
16 MR. BOEHNERT:
Yes, one licensed person.
17 DR. REMICK:
In most cases, licensed personnel have 18 not, that we aware of one licensed person.
19 CHAIRMAN KERR:
Forrest, on page 5 of the minutes 20 prepared I assume by the broad chaser, there is a statement at 21 the bottom of the page that Mr. Grace is concerned with l
-22 complacency brought on by plant consistency being given top l
23 rating.
I don't understand that statement.
24 DR. REMICK:
Well--
+
(
l 25 CHAIRMAN KERR:
I don't see how you get a top rating HERITAGE REPORTING CORPORATION -
(202)628-488C
263 1
by being complacent.
(e s/
2 DR. REMICK:
I think the point that they were making 3
is that it is a never ending process, and they are worried 4
about some plants even though they have had a good history of 5
people not getting complacent, and I think he was talking 6
about his own staff also, and just assuming that that's going 7
to continue.
And they were giving some examples of some of 8
the utilities where they are prospectively looking at 9
potential problems, and I forget which one, but I think it is 10 in Paul's minutes here, that where they can foresee that a 11 number of top people with long operating experience are going 12 to be retiring, I guess it is Carolina Power and Light, so
()
13 they have been working with the utility to plan for that.
14 What are you going to do when all these people leave 15 and so forth?
And so they gave us some examples of the type 16 of things that they are going to do.
17 CHAIRMAN KERR:
We have got to give those guys a 18 certain number of times each year just to make sure they don't 19 become complacent.
20 MR. WARD:
I think that is kind of attitude.
I 21 mean--
22 MR. CARROLL:
That is very typical of regional 23 administrators.
Complacency is a very big word in their
(}
24 vocabulary, and probably ought to be.
25 MR. WARD:
Yes, but I think definitely they, you HERITAGE REPORTING CORPORATION -- (202)628-4888
254 1
know, if everybody gets to be, they will ratchet up the t
(
2 requirements.
3 CHAIRMAN KERR: _Then on page 6, I see that Mr. Grace
.4 said Region 3 goes beyond routine compliance with the 5
regulations to assure safety.
6 What does he do?
How does he go beyond the 7
requirements of the regulations?
8 LR. REMICK:
They definitely said that, and I must 9
admit at the time it got me-to thinking.
They are definitely 10 talking seeking accidents and going beyond the regulations, 11 and--
12 CHAIRMAN KERR:
Start managing the plant?
. ()
13 DR. REMICK:
Could be.
14 MR. WARD:
I remember what we heard when we went to 15 Region 2 on that score.
1 16 CHAIRMAN KERR:
They are going beyond the i
17 regulations now.
i 18 MR. CARROLL:
What did you hear when you went to a
19 Region 5?
Or should I ask?
20 MR. WARD:
They not only go beyond regulations, they l
21 see it as necessary and proper to do that.
I mean a regional i
22 administrator, you know, at the Region 2 when we asked him do 2.
you, de you thin' :cou are managing the plant, and he said 24 w6.1, when somebody screws up, I am the one that has to i
25 telling the congrersman what happened, so he feels a certain l
l HERITAGE REPORTING CORPORATION -- (202)628-4888
255 11 responsibility.
I. don't know.
L2 CHAIRMAN KERR:
You know,.I do not think that the 3
NRC staff knows how to run plants, and if they are starting:to 4
do-this, it bothers me.
Am I the only one that is concerned?
5-MR. WARD:
Oh, no.
6 DR. R3 MICK:
I don't think thay are trying to run 7
plants, but I think unquestionably they~go beyond the 8
regulatioras, and they openly admitted it here.
9 DR. LEWIS:
A distinguished NRC employee, who is now 10 EDO, some years ago when asked whether he was trying to manage 11 an accident from Washington, he said we-wouldn't of i
12 engineering unless the utility was doing something wrong.
()
13 That's how--I saw the transcript somewhere.
14 CHAIRMAN KERR:
On page 4, there is a statement that 15 regarding service system plants, most provide surveillance I
16 testing.
i 17 I wondered if this means the failures were caused by 18 surveillance testing, or they were discovered during testing?
19 Was the distinction made?
I j
20 DR. REMICK:
I don't remember.
Anybody remember?
21 MR. WARD:
I think we asked if they had any sort of 22 breakdown on that, but we didn't get a good answer.
23 DR. REMICK:
Other questions or comments from
(}
24 members?
Mr. Chairman?
25 CHAIRMAN KERR:
We will take a break and begin again P
HERITAGE REPORTING CORPORATION -- (202)628-4888
256~
.1 at 30 minutes after.
2 (A brief recess was taken.)
3 CHAIRMAN KERR:
Mr. Moeller?
4 DR. MOELLER:
This is a' report of the subcommittee 5-meeting which we had on Tuesday, May the 31st, in which we 6
reviewed the proposed revision to Title 10, Part 20 of the 7
Code of Federal Regulations.
I will give some-background on 8
it and then we have with us Hal Peterson and Dr. Cool, Don 9
Cool, who will be speaking for the staff and bring us up to 10 date on this subject.
11 At the subcommittee meeting, Charlas Wylie was there 12 and Carlyle Michelson and then we had two consultants in, Mel
()
13 Carter and Jacob Shapiro.
14 To comment on this, the effort has been underway 15 since, certainly for almost a decade, and it began with the 16 ICRP issuing a revision of their own recommendations which 17 they published as ICRP Publication 26 in 1977, and then in the 18 meantime, the NCRP has made changes in its recommendations and 19 the EPA in January of '86 was it--
20 MR. PETERSON:
Eighty-seven.
21 DR. MOELLER:
January of
'87, President Reagan 22 signed update of their recommendations for occupational i
23 exposures, which applied to all federal agencies, and so all 24 of those things are being factored in in having to be i
25 considered.
HERITAGE REPORTING CORPORATION -- (202)628-4888
'k P
257 l'
And the new 10 CFR, the proposed revision as I see
()
.2 it has a number of beneficial aspects.
Number one, it 3
introduces the SI units.
That's not necessarily number one, d
4 but-it is something we have to do at some point in our life.
5 It-adopts a' risk based approach.
It incorporates and updates 6
the basic data used in calculating permissible concentrations 7
of radioactive material that you can take into the body, 8
better decay schemes, better data on metabolism, and so forth.
9 It incorporates then to the best of the NRC staff's 10 ability, the recommendations of the ICRP and the NCRP and EPA, i
11 tid thousands of public comments that they have received, and 1'
12 everyone has to realize they can't incorporate everybody's
(}
13 comments even if they wanted to because the various sources of 14 these comments even if they are ICRP and NCRP, they are not 15 one-on-one or one-to-one correspondence, so what they have 16 tried to do is go through there and do the very best job and 17 take the best of everybody, and put it into a regulatory i
18 package which will promote better health and safety and better 19 radiation protection.
j 1
l 20 The new proposed revision will contain ALI, annual 21 limits for intake, for both inhalation and ingestion and not l
j 22 only for the worker but also for the general public.
In a l
23 sense, there the staff is to be complimented because they are 24 a step ahead of ICRP and the NCRP.
Neither one of those have
(
25 published ALI,s for the public, but NRC has moved ahead and HERITAGE REPORTING CORPORATION -- (202)628-4888
258 1
done that.
And the data are good.
I mean they have gone to p()
2 very good sources.
They have gone to the same place that the 3
ICRP will ultimately obtain its numbers.
They have 4
incorporated a limit for the embryo fetus which we all know 5
should be in there, and they have now done it.
6 They have also for the first time set a limit for 7
the general public.
We have in de facto way or whatever the 8
word, Hal would know, we have used the, a half of a rem for 9
years for members of the general public, but it wasn't really 10 part of the regulations.
Now they have a limit for the 11 public.
They are, they want to move along and they want to 12 get the job done because they recognize as well as everyone
("}
13 else that it has taken seemingly too long a period of time to t
14 do it, so to keep moving forward, periodically in the new 15 rule, or the new regulations, they will say, in their 16 commentary on them they will say this bottleneck we are going 17 to resolve over here is a separate matter, and then factor it 18 in later as needed.
19 Some of those are being resolved by the development l
20 of a new regulatory guide, and to give you some for instances, 21 like the whole subject of below regulatory concern and de l
22 minimis.
That's being handled through a separate effort and 23 ratner than hold up 10 CFR 20, they are doing it as a separate 24 effort.
(^)
l 25 Another thing they have said is the dose for the HERITAGE REPORTING CORPORATION -- (202)628-4888
259 1
embryo fetus, but people will say well, how do you determine
?()
2 the dose to the embryo fetus?
Well, rather than stopping all 3
-the 10 CFR 20 program at this point, they say we will handle 4
that in a separate effort, so there must be certainly six, 5-
.eight or ten of these items that are being handled that way.
6 It also requires that doses internal and external be 7
summed and reported as the total dose, the total effective 8
dose equivalent to the worker.
9 Now those are the good things.
In terms of--
10 CHAIRMAN KERR:
Dave, why is it a good thing to 11 include the dose to the fetus when you don't know how to 12 measure it?
(}
13 DR. HOELLER:
They, the people know how they are 14 going to set up as a separate regulatory guide or some other 15 proper item, guidance to the industry on how to calculate the j
16 dose.
17 CHAIRMAN KERR:
So it isn't that it is not known?
18 It is just that it was concluded that shouldn't be put in 19 there?
20 DR. MOELLER:
The procedures or the methodology for l
21 calculating it, they just did not want to stop, and I don't i
l 22 even know that it would be proper if you say to put it in 10 23 CFR 20 so it will be handled.
24 CHAIRMAN KERR:
I thought you said that they didn't 25 know how to measure it at the present time.
That is not the HERITAGE REPORTING CORPORATION -- (202)628-4888
260 1
case?
,-(\\)
2 Dk. MOELLER:
It is not all that straightforward, so 3
they want to develop a guidance for how to do it.
The doses 4
to the fetus and the embryo is not the same as the dose to the 5
mother, so--
6 CHAIRMAN KERR:
I just question about why there was 7
a lot of virtue to include something in a regulation that 8
nobody knows how to measure at this point.
9 DR. MOELLER:
They are certainly going to--I will 10 let them speak to it--keep this mind, but they are going to 11 offer what will be considered by the staff an acceptable 12 procedure for making such estimates.
(T 13 CHAIRMAN KERR:
It would seem to me that argument O
14 now would be on the part of someone who is concerned look, 15 here is the regulation, there isn't any way that you can 16 assure that this is being followed.
17 DR. MOELLER:
Well, as a very conservative approach, 18 it is just take the whole body dose to the mother and say 19 that's the dose to the fetus.
We know it is less than that, 20 but you can take that as a--now in the way of questions or 21 items that you may want to think about, in terms of offering 22 commentary on this work, there are three or four items that I 23 would like to cover.
24 One is as traditiona.'.ly, as has traditionally been
/~')
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25 done for 30 years, they exempt natural background and the HERITAGE REPORTING CORPORATION -- (202)628-4888
261 1
purposeful application of radiation in the healing arts.
They
()
2 exempt those two doses from the occupational dose limits, or 3
even the general public dose limits, so they have done that, 4
but now they have added in a third phrase, doses incurred by 5
patients in medical research are to be exempt.
6 Well, we found it interesting that they are 7
branching out and including that.
8 As in the past, secondly, or Part A, sub B, they are 9
still exempting excreta from patients to whom 10 radiopharmaceuticals have been administered.
Now they do have 11 a separate regulation that they reminded me of that no patient 12 can be released from a hospital on an outpatient basis and go
/~h 13 home until the quantity of radioactive material in their body,
\\_)
14 you know, depending on the nuclide, had reached some certain 15 lower level so when they go out and cook in the kitchen or you 16 know, interact with other family members, they won't have the 17 chance of overlycontaminating or exposing them, but the 18 excreta from those patients and the excreta even from a 19 patient in the hospital is exempt, and as, originally as a 20 sanitary engineer, I cannot see any way or any reason under 21 the sun why a hospital, if you really wanted to practice 22 ALARA, couldn't have a delay tank or septic tank or something 23 which they have one or two toilets that discharge to that 24 tank, and most of these materials are short lived, and have 25 all patients use those toilets or use the toliets in the l
HERITAGE REPORTING CORPORATION -- (202)628-4888
262 1
particular wing of the hospital.
And so at the subcommittee 2
meeting, we asked that the staff do two things.
.\\
3 One is find out what the practica is in other 4.
countries, and if everybody the world over does it this way, 5
then you know, that would offer some support, but secondly, to 6
gather together if such studies have been done, gather i
7 together what this means in terms of population dose, how much 8
radioactive material is being released without control because 9
of this exemption.
10 And I know--I work at a university in the northeast, 11 and there is no question but thet the teaching hospitals 12-associated with Harvard discharge daily far more radioactive 13 material airborne and into liquid waste than any nuclear power 14 reactor anywhere, certainly in this country, and I don't 15 understand, you know, why this difference.
16 DR. LEWIS:
Does Governor Dukakis permit this?
17 DR. REMICK:
They obviously know what they are 18 doing.
19 MR. CARROLL:
Admittedly it is short half-lived i
20 material.
21 DR. MOELLER:
It is short half-lived material.
22 DR. LEWIS:
Therefore, 'rery radioactive.
23 DR. MOELLER:
They know how much, you know, they 24 know when they administer to the patients, the patient can't
(
25 create more or anything like that, but it is interesting.
HERITAGE REPORTING CORPORATION -- (202)628-4888
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265 1
DR. LEWIS:
Are we talking about.real dosages here
(}
2 or talking about millirem or microrem?
3 DR. MOELLER:
You are talking probably millirem, 4
maybe two.
I don't--Tom Jessell or someone did a study for S
Houston, Texas, or somewhere in Texas, and the concentration 6
in the bay or whatever is there, and then what it meant in 7
terms of fish, and he calculated the population dose.
It is 8
very small, but before they just blanketly stamp their, put 9
their stamp of approval on this, I thought why don't they at 10 least look at it and tell us what it means?
11 DR. LEWIS:
If you can do a back of envelope and 12 decide that it is millirem to the fish and we don't live in 13 the water--
r~
14 DR. MOELLER:
Well, I don't know personally that you 15 can do that.
I was surprised in looking at that the other day 16 to find out that every day in the United States, there are 17 10,000 shipments of packages of radioactive material in the 18 mail, 10,000 every day.
That was a large number, and again, I 19 am not saying that is good or bad.
20 DR. LEWIS:
There is more than that.
21 DR. SHEWHON:
By having the staff say that they will 22 exempt this and exempt natural background, and exempt X-rays, 23 is this in essence because they feel this is below de minimis 24 with regard to what will hurt anybody?
25 DR. HO ELL *JR :
No.
The material background again HERITAGd REPORTING CORPORATION -- (202)628-4888
264 1
will--they are listening and we will let them comment, but 2
natural background is exempt because it has been there since
(,,5
( /
3 the beginning of time, and when you say exempting natural 4
background which they are not careful to do in the proposed 5
revision, they should have said the natural background in its 6
undisturbed state.
7 If you have altered the situation such as radon in 8
the home, then it comes under control, or it is being proposed 9
that it be brought under control.
Now the medical exemption 10 is because the very person running the risk who gets the dose 11 is the person who is getting a better diagnosis, c r.d 12 supposedly the benefit clearly outwei7hs the risk, so it is a 13 one-on-one basis, and it is a decision of the physician to g
l' 14 administer either the radioactive material or the X-ray or the 15 dentist does that, and so they believe in that case thtt to 16 set limits on medical exposures would be interfering with the 17 private practice of a physician, and they don't do that.
18 Let me get through a couple more and give them then l
19 as much time as we can.
20 This change.
.'f 10 CFR 20 is revised, it is going to 21 mean tnat other federal agencies are going to have to revise a 22 number of their regulations, and take a, for instance, EPA and 23 40 CFR 190 sets dose limits for. members of the public from 24 certain nuclear, cingle nuclear facilities, and those dose Q
l
(_j 25 limits are 25 millirem a year whole body, 75 millirem thyroid.
l l
HERITAGE REPORTING CORPORATION -- (202)G28-4888
265 1
Well,-75 millfrem ic not compatible with 25 millirem 2
whole' body.
It should be 250 millirem for the thyroid if you qr 3'
use th'
'sk based approach, and then next they say or 25 4
millirem >
1r to any other single organ in thu body other 5
than. the t'
.,id.
Well, that is totally incompatible with 6
this new scheme'and so they recognize that, but it means that 7
people are going to go, to have to go through the whole 8.
federal system of standards and try to make them compatible.
9 Now the basic question, and I have asked Hal 10 Peterson and Don Cool to spend most of-their time on this, the 11 basic area of controversy in the revised 10 CFR 20 deals with 12 how you handle the committed dose or the dose commitment, 13 whichever one you want to call it.
If you, if in an 14 occupational situation, a person accidentally inhales a 15 short-lived material or a long-lived material which has a 16 short turnover in the body so that its effective half life is 17 short, if you injest or inhale radioactive material with short
'18 effective half 3ife, the dose that you receive, its results 19 occur within a very short period of time, so it, for all l
20 practical purposes, it will occur during the same year in l
l
.21 which you inhaled or injest the material, so there is no 22 problem there.
23 The committed dose or the does commitment occurs in l
l 24 the year in which you were exposed, and everything coincides.
.O i-
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25 But if you injest or inhale a long-lived alpha ( aitting l
l l
HF.RITAGE REPORTING CORPORATION -- (202)628-4888
266 1
radionuclide or beta emitter strontium 90, which has a slow
,es 2
turnover in the body and therefore has a very long effective
(_)
'3 half life, the dose that you get from having injested or 4
inhaled a quantity today will string out for years.
It can 5
string out decades from now, and so what they recommend is 6
that you calculate the dose commitment for the next 50 years, 7
and then the NRC says to assign to the year in which you 8
injest or inhale this material that total 50-year commitment, 9
that total dose that you are going, yet to receive over the 10 next 50 years, the next 49 years beyond this year.
You assign 11 all of that to the year of intake or ingestion.
12 Well, what are the pitfalls in that?
I am going to 13 let them explain it, but there are two that readily come to
.J 14 mind.
15 one is this record in the person's record a dose 16 which has not yet occurred, so if you were using those records 17 for epidemiology, you are kidding yc7rself.
Those doses, 18 certain portion of them, have never occurred.
19 Secendly, it results in a dose, a recorded dose, 20 occupationally which from long-lived alpha emitting sources, 21 the recorded dose, will be twice whatever occurs, what can 23 ever occur under any circumstances, because if I am 60 years 23 old, they will put on my, between 60 cnd 61 years of age, they 24 will record my dose for the next 50 years, from 60 through n(-)
25 110.
Well, I am only going to live to 105, so five of that HERITAGE REPORTING CORPORATION -- (202)628-4888
267 1
never will have occurred.
So for that ree. son, the only place 2
where it really accurately applies is to about a 25 year old 3
who is going to die at 75 if he or she lives the normal life 4
expectancy.
5 DR. LEWIS:
This is a preventable dose because you 6
can shoot yourself.
7 DR. MOELLER:
Yes, you can shoot yourself.
Also i
8 what worries me, and these are things that Hal has raised in 9
the past, I believe in the medical profession, if the medical-10 profession can get exemptions for excreta and everything, 11 there is nothing to prevent them within the next decade 12 developing a pill that I swallow and it cleanses my bcdy of 13 all the positive radioactive material so this dose will never O
14 even occur.
15 Well, that is the major problem, that the 16 subcommittee argued this, and it is not black and white.
If 17 it were, we could easily reach a decision.
It is a gray area..
18 And I have asked Al Pushkin to get Hal and Don to present l.
19 their remarks with emphasis on that key controversial issue.
20 CHAIRMAN KERR:
If this is the same set of changes 1
21 10 CFR 20 that we discussed several years ago, it will require 22 significant new record keeping of licensees or operating L
l 23 nuclear power plants, would it not?
24 DR. MOELLER:
Yes, and we, they can quickly do that.
)
25 CHAIRMAN KERR:
As a result of this, everybody would l
HERITAGE REPORTING CORPORATION -- (202)628-4888
268 1
be a lot safer?
2 DR. MOBLLER:
We will let them comment on that.
Let 3
me say, though, this, the current revised version is not 4.
verbatim what we have seen before.
It is close, but I would 5
say that the staff has done an excellent job.
It was much 6
shorter than I ever dreamed it would be.
It's clearly worded.
7 There is no question about what they are asking be done, and 8
to repeat, I think they have done a very good job.
9 MR. CARROLL:
Does this revision of Part 20 do 10 anything with respect to the particle skin dosage?
11 DR. MOELLER:
You don't--I know we talked about what 12 area of the skin to consider.
Well, will that be handled, 13 Hal, as a separate effort?
-14 MR. PETERSON:
That will be handled probably by a 15 separate or amendment.
The problem was we have gotten a draft 16 report from the NCRP, but it is not a final record, and we 17 didn't want to rush out with something that hadn't been 38 finalized yet.
19 DR. LEWIS:
You say this is going to have an impact 20 well beyond the nuclear community, that is to say, force a lot 2
of other agencies--
22 DR. MOELLERr To revise and upgrade.
23 DR. LEWIS:
Will it make it impossible for me to 24 throw away the antistatic brushes 1 use in photography and
('l s
N-25 that kind of thing?
HERITAGE REPORTING CORPORATION -- (202)628-4888
269 1
DR. MOELLER:
No.
It is mainly a matter of cleaning 2
up and making accurate what we are doing.
What we are doing V(~g 3
now is simply not right.
It is all outmoded and behind the 4
time.
Not all, but a lot of it is outmoded.
5 DR.-LEWIS:
You are sayin1 generally this doesn't 6
make the regulations tighter?
Just makes them clearer?
7 DR. MOELLER:
Five rem a year will still be 5 rem a 8
year.
9 DR. LEWIS:
Okay--except in SI units?
10 DR. MOELLER:
Right--500.
11 MR. PETERSON:
And only if you choose SI units.
12 DR. LEWIS:
You do have to reform the rest of us 13 before you want the rest of us to reform.
O, 14 MR. CARROLL:
What is the system of units?
15 MR. PETERSON:
We allow, the new Part 20 will allow 16 either the SI, or the so-called special units, providing the 17 licensee is consistent, he does not mix the two systems, and 18 starts it at the beginning of a year.
19 DR. MOELLER:
To comment on that, I was talking to a 20 fellow from a nuclear power utility this morning, and he said i
21 his utility is going to switch over to SI units, but he said 22 overy time they have a visitor from another utility who 23 sometimes uses the old units, they will have to report the 24 dose to that utility in the old units, so he said they are 25 going to have to have a parallel effort.
HERITAGE REPORTING CORPORATION -- (202)628-4888
f l-270 1
1 DR. SIESS:
Which one is the bigger; 500 SI is how 2
many millirem?
(_)4 f-3
.DR. MOELLER:
Five thousand millirem, 5 rem.
4 DR. SIESS:
Sounds a lot smaller.
5 DR. MOELLER:
Oh, sure.
Okay.
6 DR. REMICK:
Is it true the population dose is now 7
combinalion, is now Cverts?
8 MR. PETERSON:
Collective person Cverts, that's an 9
old--no, we don't use that.
10 DR. MOELLER:
Go ahead.
You only have what, 40 11 minutes, so take advantage of it.
12 MR. PETERSON:
Let me take the biggest question 13 first, and that's the issue of dose commitment.
While I am b,~
14 doing that, let me also answer another question.
15 The thing that will really drive other agencies to 16 adopt the same system of Part 20 is not Part 20, although many 17 agencies are licensees.
The thing that will drive them to 18 adopt that system is the federal guidance that was tsyued by 19 the President, so that will have a far bigger effect than Part 20 20 would.
21 There has been a considerable lack of understanding 22 of the committed dose equivalent, having talked to a number of 23 licensees.
What we have as a system really that the concept 24 dates back 30 years to ICRP 2, but the name dates back to 25 1977, and basically what the committed dose equivalent is, it HERITAGE REPORTING CORPORATION -- (202)628-4888
271 1
is the future dose that, from a body burden of radioactive r^
2 material,.from radioactive material in the body.
(g/
3 If we were to assume a single expoential clearance 4
function, that the material is instantly assimilated into the 5
body, and then is cleared expoentially due to biological 6
processes and radioactive decay, if we were to plot the dose 7
rate from that material every year, or every time period as 8
you can assume the years, then you would expect an expoential 9
decreasing dose rate with time.
10 Now the dose commitment, or the committed dose 11 equivalent to be more orecise, is the total of all of these 12 little blocks.
It is the time integral of the dose rate from 13 that single intake.
~
14 (Slide) 15 DR. REMICK:
I assume the time that a worker could 16 work in an environment is affected by that decision to use the 17 integ:'ated total over 50 years?
18 HR. PETERSON:
Let me work into that because it 19 develops into something that the thing we are not interested 20 in cor. trolling so much is this integral, but the dose rate to 21 the worker at the end of his working lifetime.
That's the key 22 parameter that is being controlled.
23 Now if we make an assumption that each year the 24 worker hec the same intake, then after a certain number of 25 periods, in this case, three years of intake, you can see that HERITAGE REPORTING CORPORATION o-(202)628-4888
272
.1 each of the contributions--this is the first ysar's intake and 2
the dose from that.
The second year's intake is here by the 3
~ striped area, and the third year's intake by the solid, and 4
'then they add up.-
Now at the end, after a long time or short 5'
time, short-lived radionuclide or long time with long-lived 6
radionuclied, one that has a long clearance half life, you get 7
a build-up in the dose rate, annual dose rate that looks like 8
this.
9 Now it happens mathematically that the dose rate, at 10 some point when equilibrium has been obtained, the dose rate 11 at that point is equal to the sum of all of the little pieces, 12 and you can see I have colored them in these different colors, 13 that the dose rate in this year is equal to, exactly equal to 14 the sum of all the little pieces from the first year's intake, 15 so by controlling on the basis of the committed dose 16 equivalent, what we are really doing is controlling the future 17 dose rate and ensuring that this dose rate is below the limit 18 we want for the worker.
19 DR. REMICK:
I don't follow that.
I mean I 20 understand what you are saying, but I don't see how my 21 controlling the committed dose--you are controlling the sum of 22 those individual pieces at any particular year.
It seems--
23 DR. LEWIS:
On the assumption that it is the same 24 year after year after year.
'25 MR. FETERSON:
Assumption it is the same year after HERITAGE REPORTING CORPORATION -- (202)628-4888
I 273 1
year, right, but by doing that, it is, it is a 2
mathematical--you can, one can actually show what, the 3
integral calculus that it is equivalent mathematically.
4 DR. LEWIS:
It is trivial on that-assumption?
5 DR. REMICK:
On that assumption.
6 MR. PETERSON:
But the assumption--at this point, of 7
course, what is done is going back and what has been dc.le in 8
the past is to go back from this dose rate, and then calculate 9
what concentration would have to be given in each of the past 10 years to give you that dose rate, and that is the basis for 11 all the concentration limits in Part 10, both present and 12 proposed.
13 DR. LEWIS:
Doing an integral?
14 MR. PETERSON:
No.
It has to do with how you 15 control back here what is going to happen up here.
16 DR. SHEWMON:
What you said is if you make my 17 particular limiting set of assumptions that I did the same 18 amount, the worker gets the same amount each year, I get the 19 right answer.
20 Why don't you do it right in the first place?
Is it 21 so hard to cope with these variable quantities and the half 22 lives?
23 MR. PETERSON:
I think you are concentrating too 24 much down here.
The point of this is when you are setting a 25 concentration that you want to start exposing the worker to HERITAGE REPORTING CORPORATION -- (202)628-4888
274 1
here, you have to figure this result out first.
2 DR. LEWIS:
Why, I think the question is a fair one.
,/ \\
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3 Why not add up the doses and whe you get to be at the point at 4
which the predicted dose later on is too large, stop?
5 DR. SHEWHON:
What they can tolerate up front.
6 MR. PETERSON:
You can do that retrospectively.
You 7
can add up the doses, but you also have a problem that because 8
of this effect, that once you have exposed the worker back 9
here, there is a future contribution.
10 DR. LEWIS:
You can add up the actual unit, make 11 assumption of uniformity, just add it up.
12 MR. PETERSON:
First of all, the difference is 13 between control of the work place and control of the worker, r~h -
kl 14 and I think Dr. Moeller explained it quite carefully, the fact 15 that in some systems, in DOE, for example, they can control, 16 they are paying the building, they can control what happens to 17 a particular worker who gets a high internal exposure.
The 18 NRC cannot.
19 One of the things with the use of the committed dose 20 equivalent is that we keep from mortgaging the employee's 21 future out here due to e. body burden he got back there because 22 we are already accounting for that future dose.
23 MR. CARROLL:
Let me ask this very basic question.
24 Is this a really practical concern in the nuclear power
()
25 industry?
How many people have received internal doses of l
HERITAGE REPORTING CORPORATION -- (202)628 4888
275 1
nuclear power plants that go back significantly in any sense f^
2 in terms of their total allotted dose to the whole body?
b) 3-MR. PETERSON:
You don't have so much of a problem 4
at nuclear pcwer plants primarily because the radionuclides 5
either have a short radiological half life or a short 6
effective half life.
Cobalt 60, for example, is five years.
7 The problem occurs in places like fuel fabrication 8
facilities where you are inhaling insoluble uranium, and then 9
you have a fairly low clearance time and can build up a body 10' burden.
11 DR. LEWIS:
I still don't see why one has to build 12 in a prediction of future performance because at any given, in 13 any given year, whateve; the dosage is that provides a 7_V 14 commitment for the future, that year's dose provides a 15 commitment for the future for the rest of the guy's life, 16 whether he goes off and lives in the Rockies, or stays home or.
17 goes and moves to a high altitude.
18 It is not hard to add these things up.
You know, 19 there is a certain decay rate which is calculable, and 20 therefore whatever the dose commitment for the rest of my life 21 can be calculated by adding up the doses that I have in and 22 using the appropriate formulas.
23 Why do you have to build in an assumptien and play a 24 game like this?
25 HR. PETERSON:
I think what--the assumption of what?
HERITAGE REPORTING CORPORATION -- (202)628-4888
- =.
276 1
Uniformity?-
2 DR. LEWIS:
Yes.
u) 3-MR. PETERSON:
That is just for drawing the diagram, 4
and in stating what the annual average dose rates.
The 5
concept is more used for going bsck and deriving the basic 6-concentration limits than it is in terms of basic dose 7
assessment.
8 DR. LEWIS:
In that case, I didn't understand the 9
distinction between NRC and DOE that you made.
10 MR. PETERSON:
Okay.
11 MR. COOL:
Maybe--let me take a shot at it now.
You 12 have got to the exact heart of the problem.
There are two 13 possible ways for controlling this worker if you will, your A
14 employee.
If you employ him now and keep him employed for the 15 next 30 years, I can do as you suggest, and each year look at 16 the amount of material which is in his body, add up all the t
17 contributions for previous years, go back and say okay, you 18 got three last year, and two years ago he got a two, and what 19 that means when you stack that all up, and so I know how much j
20 I am allowed to give him this year, and then control him this 21 year so that his dose rate in the current year never exceeds 5 22 rem, the occupational limit.
23 That's, that's the approach where I can do my 24 integral and always keep him under 5 rem.
That means going
()
25 down line, sometimes practically speaking, I can't allow him L
HERITAGE RGPORTING CORPORATION -- (202)628-4888 l-L
277 1
to do a job because he already has a built-in does rate over 2
which I no longer have cont. ~ simply because of what I had 3
him do last year, so I am limited to only allowing him to do 4
certain things this year.
5 DR. LEWIS:
That's the current situation.
6 MR. COOL:
That is one approach.
7 DR. LEWIS:
That's the current situation.
That is 8
if I, if a radiation worker gets too much dosage in January, 9
it is too goddamn bad.
They have got to give me a different 10 job for the rest of the year.
11 DR. HOELLER:
Even if it is external.
12 DR. LEWIS:
Sure.
That's right.
That's the 13 current--that's life.
14 MR. COOL:
And when I get to the end of this year, 15 then I start over again.
16 DR. LEWIS:
Yes.
That's because we are on an annual 17 budget!
18 MR. COOL:
Next year, the internal dose, next year, 19 you are going to have some carryover, but that system can be 20 be done that way, and that is what the Department of Energy 21 does.
22 DR. REMICK:
Department of Energy for a limited 23 number of people.
24 M9. COOL:
For limited number of people.
25 DR. REMICK:
You are tailoring your system for 1 HERITAGE REPORTING CORPORATION -- (202)628-486.
278 1
percent or less.of the people affected by the rule, and there
s 2
aren't many people that you are going to give a, who will be
. (g 3
exposed to a routine concentration over a whole work life in 4
the nuclear induscry with DOE or NRC licenses.
There are 5
some.
6 MR. PETERSON:
A fuel fab, again, fuel fabrication 7
plants; nuclear reactors, true, most of the nuclides cleared 8
quickly and it is not much.
9 DR. REMICK:
The whole works.
10 MR. PETERSON:
It will affect nuclear plants to some 11 extent.
12 MR. COOL:
In many cases, there is in fact no 13 difference for the short, shorter lived material.
That is,
- hs 14 you are going to run into in reactor the by-product, a lot of 15 by-product redionuclides of shorter half life, fairly rapid 16 biological elimination.
There is no difference, because it is 17 essentially gone in one year.
That's a wash.
It makes no 18 difference which one I use because there is no tail that goes 19 on in the future years from that integral.
20 There are a few where it does make a difference.
21 The big one of concern as we understand it is uranium, in 22 particular fuel fabrication facility insoluable uranium which 23 is retained in the body for a long period of time.
Now we can 24 control by looking at what he has got this year and adding 25 them all up, or we can control on the basis of what he gets HERITAGE REPORTING CORPORATION -- (202)628-4888
279 1
now is going to' commit him to, simply because he inhaled it 2
this. year, to things in the future, and we can take them into.
3 account'now.
In my little budget I can draw my little budget 4
and I can limit.
Next year I start over again with that clean 5
slate as you did-with your internal dose.
6 It.is--in some sense I will grant you how are you 7
going to budget your dose?
Am I going to account for it all 8
now, or am I going to mortgage it to the future and keep track t
9 of it down line?
10-One of the problems which I believe that the NRC
.1 must deal with is the fact that there are a wide variety of 1
12 licensees out there with a wide variety of capabilities in 13 terms of being able to go back and look at previous exposure, L
14 abilities to go and measure body burdens.
It is not 15 inconceivable that someone who was employed with say a fuel 16 fabrication facility could'then move to some other kind of 17 licensee who would not handle insoluble radiocactive 18 materials, night not handle anything except sealed sources and 19 therefore would only be concernad with external.
He would 20 nevertheless have to, if this individual went to work for that
.21 other license, then the new licensee would have to go in and 22 assess the internal exposure of that individual now and would
~
23 only be allowe.d to have external exposure up to some fraction 24 of the limit.
Otherwise he would be in non-compliance were we 25 to allow this annual approach to the situation, go back and HERITAGE REPORTING CORPORATION -- (202)628-4888
^
~
280 l'
pick up:whatever portion of the integral from the internal 2
exposure points,
~
f 3
MR. CARROLL:
How serious is the uranium problem in 4~
fuel fabricating-plants?
What percentage of body burden does 5
the typical worker in such plant have?
6 MR. PETERSON:
Something like 10 to 15 percent--Don?
7 MR. COOL:
Most of fuel fabrication facilities right 8
now under the present system are averaging something on the 9
order of 10 to 15 percent of MPC in their airborne samples.
10 Now-one of the problems driving this is that the 11 allowable value intake for insoluble uranium is coming down by 12 a,
roughly a factor of six, between five and six, such that 13 for a facility that was bumping along at 15 to 20 percent of
()
14 the limits under the old metabolic systems generated 25 years 15 ago, suddenly they are right up eyeball with the limit.
i 16-MR. CARROLL:
What is the reason for this?
17 MR. COOL:
The reason for this factor of six change 18 comes about due to changes in the metabolic parameters 19 associated with the metabolism of uranium, results that they j
20 have a longer half life in the body than the model had given 21 credit for previously.
There are a number of factors that we i
22-can go into, transfer to lymph of nodes which continue to l
23 irradiate the lungs, and on and on.
I 24 MR. CARROLL:
It is uranium on low enrichment.
()
25 Uranium my impression has always been, it is more of a l
HERITAGE REPORTING CORPORATION -- (202)628-4888 l
281 1
chemical toxin than radiological hazard.
r~s 2
HR. COOh:
If it is soluble, if it is soluble
( l~
3 uranium, it is a chemical toxin.
If it is insoluble uranium, 4
it is then the concentration given time in the kidney doesn't 5
reach that chemical heavy metal poison level, and you are 6
.looking at the radiological hazard, so there is that 7
distinction between soluble uranium.
8 We are--in fact a number of Part 20 is based on the 9
chemical toxicity, and the insoluble where it is based on the 10 dose.
11 DR. LEWIS:
I just want to put on, since we have a 12 record, I want to--I don't want to engage in long debates, but 13 I want to put on the record that I am unin pressed by the very,
/~)
V 14 very long answer I had to my question, Just for the record.
15 MR. PETERSON:
I would like to clear up a few things 16 that were brought up.
17 One regarding the uniformity of intake, the number 18 that is recorded as the dose is proportional to the intake l
19 associated with the intake received that year, so it has j
20 nothing--it is actually a number that is known from what is i
21 taken in that year.
22 Secondly, the quote, fictitious doae, and the 23 epidemiology is not just due to this numoer, but it is also l
due to the fact that we have a new quantity called effective 25 doso equivalent which is the sum of all the body organ doses l
HERITAGE REPORTING CORPORATION -- (202)628-4888
m s
282 1
times the statistical risk weighting factor and then summed 2
up.
The National Cancer Institute was very much concerned g
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3 with that particular unit, because once you had that sum, you 4
could not then decompose it into the individual organ doses.
5 And of course, the solution to both problems is to record the 6
fundamental quantities in the individual's record, and that 7
will be required.
8 You don't have, unfortunately have to, the 9
subcommittee did not see the revised Form 4 and Form 5 that go 10 with the record keeping system.
We will be recording the body 11 burdens of the nuclides directly as well as this committed 12 dose as well as the effective dose so that you can go back to 13 the original record and decompose it in any way you want to, O
(_/
14 get back the original conditions, so as far as fictitious 15 doses for epidemiology, we have been working very closely with 16 the National Cancer Institute to make sure that anything we do 17 doesn't destroy the utility of the record as far as anything 18 they might want to do with an epidemiology study.
19 CHAIRMAN KERR:
How accurately do you think the body l
20 burden will be measured?
21 MR. PETERSON:
Excuse me?
l 22 CHAIRMAN KERR:
How accurately do you think the body 23 burden will be measured?
24 MR. PETERSON:
It would depend on what you were
()
25 measuring, and the level.
Obviously a large body burden, you HERITAGE REPORTING CORPORATION -- (202)628-4888
- 283 1
have a better chance of measuring accurately.
One that is 2
probably close to the limit of intake, there may be a great 3
deal of uncertainty.
I think this was an argument that was 4
made by Mr. Stansbury.
5 CHAIRMAN KERR:
I am not arguing.
I am just trying 6
to find out how accurately you thin *a these data--
7 MR. PETERSON:
I can't give you a general answer to 8
that, how accurately can you measure body burden.
9 CHAIRMAN KERR:
I mean you are going to a great deal 10 of detail to preserve something because you think it is going 11 to have value in an epidemiological study or something, and it 12 seems to me that value depends on the accuracy of the data and 13 not just on the fact that the data exist.
14 MR. PETERSON:
Truly.
15 CHAIRMAN KERR:
You don't have any idea how accurate 16 the data might be?
17 MR. PETERSON:
I don't think you can make a sweeping 18 generalization.
19 CHAIRMAN KERR:
I am not asking for a sweeping 20 generalization.
I am asking for an estimate.
21 MR. PETERSON:
What condition are you talking about?
22 CHAIRMAN KERR:
I am talking about the conditions 23 that exist.
24 HR. PETERSON:
I can do tritium very accurately.
25 CHAIRMAN KERR:
You are making regulations which HERITAGE REPORTING CORPORATION -- (202)628-4888
284 1
presumably are-going to affect operating organizations, and 2
you are getting data for some reason.
I assume because it is 3
. going to be useful.
Unless you have given some thought to the 4
accuracy of those data and whether this is practical to get 5
them, I don't see these data are going to be worth very much.
6 HR. PETERSON:
.I think we have given it a good deal s
l 7
of thought, but you are asking me what is the estimate of--
1-8 CHAIRMAN KERR:
Your answer is you have given it l
9 great deal thought, you don't have any idea?
10 MR. PETERSON:
I don't have a specific case.
11 DR. LEWIS:
Rough estimate, any kind of rough 12 reasonable estimate.
13 MR. PETERSON:
But that's the thing.
It depends.
O 14 If you are, get very, down low, probably a factor of five, if 15 you get down to low activity, a factor of five, a hundred 16 transuranics like tritium, probably very closely because you 17 can do a urinalysis very accurately.
It tends to be 18 distributed with the body water.
19 It does--I am saying there is such a range of 20 uncertainties in how you measure it, again, a whole body 21 counting in some cases you can do very accurately, but again, 22 depends.
If you are high, you have got a high level, then you 23 are way above background and the statistics are favorable.
24 CHAIRMAN KERR:
Count whole body very accurately--I 25 wasn't asking about that.
l HERITAGE REPORTING CORPORATION -- (202)628-4888
B 285 1
MR. WARD:
He gave us examples.
I think that is all 2-they are looking for was examples, and you gave two, which I L.)
3 think that is useful.
4 MR. PETERSON:
It has a big range of uncertainty 5
associated with it, depending upon what you are measuring.
6 DR. REMICK:
I can see where you have a concern over 7
uranium fuel cycle personnel, and what you are doing there 8
makes some sense, but I can't see why you are tailoring a 9
system for that small number of people relative to the total 10 population that will be affected.
Why can't you have 11 basically two systems?
12 HR. PETERSON:
I guess--
13 DR. REMICK:
S'in total eich year for those people 14 who aren't going to be exposed to concentrations of 15 non-soluble uranium and so forth, going to be the people out 16 there who occasionally are using radioisotopes, occasionally 17 have exposure.
Today it is one thing.
Next month it is 18 another thing, and so forth, and do that under the more 19 straightforward logical way of summing it up rather than 20 putting the committed lifetime dose over 50 years up front.
I 21 don't--for everybody.
I don't understand that.
22 MR. PETERSON:
Okay.
23 DR. REMICK:
Why can't you have today and alternate 24 B,
depending on the circumstances?
()
26 DR. MOELLER:
Let me interject I think, Forrest, HERITAGE REPORTING CORPORATION -- (202)628-4888
286 1"
that's what we are saying or that's what the subcommittee was 2
asking'.
In other words, the blanket 10 CFR 20 at the moment 3
we have no problem with nuclear power plants, beta, gamma
'4 emitter short-lived materials and so forth.
5 However, appearing before us at the. subcommittee 6
meeting several people asked as members of the public and one 7
was Paul Stansbury from General Elc.tric Fuel Fabrication 8
Facility, and he said if you go through with this, you know, 9
it is going to wreck us in essence, and so the question is 10 what exactly you are saying.
Should you have a blanket rule 11 or regulation then with an exception for this one group, not 12 necessarily identifying them, but just for anyone working with i
13 long-lived alpha emitter, should we have an exception?
And
()
14 they are pleading for an exception.
15 DR. REMICK:
I-see.
16 MR. PETERSON:
Yes.
They were pleading for 17 exception.
That was in the proposed rule.
I think you should b
18 realize, though, that the system I am talking about using, the 19 committed dese--excuse me--the committed effective dose 20 equivalent, or the committed dose equivalent, is_the simpler 21 of the two systems to implement.
The annual dose system 22 requires annual bioassays and continual tracking of that body 2
23 burden which we do not require.
24 DR. REMICK:
I really don't see it is simpler, 25 Maybe you are right, but I don't aee it.
l HERITAGE REPORTING CORPORATION -- (202)628-4888
287 1
MR. COOL:
I would also like to point out to the 2
Committee that that is the system under which the present Part 3
20 operates, as well as the proposed Part 20.
4 DR. MOELLER:
The main.
5 MR. COOL:
Mathematically they are the same.
We 6
have not changed the' philosophy of the regulation for internal 7
radionuclides.
Mr. Stansbury requested an exception from the 8
standing regulatory practice of this agency.
9 DR. REMICK:
You are saying that is how you got your 10 concentration, maxi,ium permissible concentrations, in Part 20 11 now.
On that system?
12 DR. MOELLER:
See, the problem is he could live with 13 the current system until they reduce the acceptable annual
(
14 intake by a factor of six, and he now is in trouble, and I 15 don't think, you know, we could make er exception to permit 16 unusual exposure or anything, but it is very confusing.
There 17 is another or--confusing, it is very confidential.
18 There is another aspect that enters here.
The new 19 propos.d regulations state that in order to control the 20 exposure of a worker, or to know you are effectively 21 controlling it, you can monitor the air he breathes.
You can 22 do urinalysis or bioassay, or you can in vivo, you know, lung 23 counting, whole body counting or whatever it is, and then I am 24 a little hazy here, but if, obviously if the air concentration 25 said he should add one unit of activity in his body and you HERITAGE REPORTING CORPORATION -- (202)628-4888
e 288 1
whole body count him, you can get got statistics on whatever 2
it is your you are counting.
He only has a part of a unit in
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3 him, it means your air concentrations were wrong.
4 You know, it is hard to tell where, how he moves 5
around within the plant.
You had a fixed monitor and so 6
forth, so the NRC is saying in the proposed rule that you--and 7
Don, can you help me?
You don't, you say that you can 8
consider several measurement capabilities, and use what is the 9
most reliable or what?
10 MR. COOL:
Compliance may be determined by any one 11 of those possible methodologies, and the licensee is permitted 12 upon obtaining a more accurate measure, to modify the estimate 13 that is reported.
(n) 14 I should, would just like to note to the Committee 15 that the present Part 20 requires the use of air sampling.
It 16 says shall make measurements of concentrations of radioactive 17 material in the air and as appropriate do other things.
The 18 proposed revision would allow them to do air sampling or 19 bioassay, or in vivo counting such that the proposed revision 20 I believe provides the licensee with more flexibility for 21 determining compliance.
l 22 DR. REMICK:
To make sure I understand your previous 1
23 answer, the current appendix, Part 20, Appendix B Tables 1 and l
l 24 2 and MPCs were arrived at by taking a committed dose over 50
(~)
25 years and that's how the concentrations were arrived at?
wi l
l i
HERITAGE REPORTING CORPORATION -- (202)628-4888
289 1
HR. COOL:
They were arrived at by looking at the
(^)
2 amount of material which if taken in each year at the maximum
\\~/
3 level would result in that limiting dose rate in the last year 4
being able to derive 5 rem mathematically.
It is exactly the 5
same as this one.
6 DR. REMICK:
I didn't realize that.
7 MR. FETERSON:
There is quite a bit of uncertainty 8
among the licensees based on the comments, too, as to what the 9
committed dose equivalent.
That is a new concept.
10 The other thing I should mention is another concern 11 with the fictitious nature of the dose is, of course, if the 12 person, as Dr. Hoeller indicated earlier, is in his, latter 13 part of his life, he is not going to get that 50 years dose 7,
(_)
14 come in, and however, the importance of that is you can see 15 from that curve--this is one year's intake--is that the 16 biggest part of the commitment is in fact the first year's 17 dose, and then it decreases, so the part, if he were to stop 18 here, with the commitment, or let's say here.
This is what 19 the body burden would do if there were no further intakes, 20 drop like this, but the biggest part of the commitment say is 21 in fact still already delivered, so you are not talking big 22 factors in terms of a dose change.
23 And the other thing is while this person is alive, 24 that does represent an estimate of the future potential total 25 dose that he will have gotten from that body burden.
He has HERITAGE REPORTING CORPORATION -- (202)628-4888
290 1
the body burden.
2 DR. REMICK:
What is the justification for the 50
_f3 N.)
3 yearn?
Is it too conservative?
4 HR. PETERSON:
It is on the basis of, based on being 5
eunservative for a worker beginning work at age 20 or 18.
6 HR. COOL:
I think the answer to your question, sir, 7
if you have got an old work force, yes, it is probably too 8
conservative.
If you have the, got all of your workers up to 9
50, 60 years of age, for whom barring medical breakthroughs, 10 that they are not going to live for another 50 years, yes, it 11 is overlyconservative.
12 DR. LEWIS:
Why don't you make it age dependent?
We 13 know people's ages.
14 HR. COOL:
That certainly would be possible.
That I 15 think, without taking a great deal of time to think about how 16 it might be implemented, would lead to a tremendous plethora 17 of numbers that licensees would have to sort their way 18 through.
For each werker every time they may have to go find 19 the appropriate Table X, W,
sub prime, double star or 20 something to see what his values would be.
21 DR. LEWIS:
It is not hard to make such tables.
I 22 am just troublGd by piling conservatism on conservatism.
23 HR. PETERSON:
It is really not that.
If you go 24 back to this and view it as the purpose of the system is to
,m
-()
25 limit that organ dose rate out here, this is not to limit the HERITAGE REPORTING CORPORATION -- (202)628-4888
291 1
integral.
It is just--
rw 2
DR. LEWIS:
That organ dose rate is governed by the U
3 exposure out chere for the most part.
4 MR. PETERSON:
Partially, but it has component from 5
an exposure back here.
6 DR. LEWIS:
You can't have it both ways.
You 7
answered him by saying most of it is in the early period, and 8
now you are emphasizing the tail.
You really can't have it 9
both ways.
10 CHAIRMAN KERR A little earlier on I believe our 11 presenter said he is going to answer the first question, and 12 we are still answering the first question.
13 DR. MOELLER:
Well, we have six minutes, and this is
/_T 14 really the only thing that I think needs to be discussed.
15 MR. PETERSON:
I think to try to sum it up, I think 16 the previous, the problem really lies in the fact that 17 previously we have not required the licensee to put a dose 18 down for internal doses.
He is allowed to use DAC hours, for 19 example, or MPC hours as a measure of radionuclied intake, or 20 body burden, and we are now requiring him to use a dose 21 estimate.
22 CHAIRMAN KERR:
How much risk reduction would be 23 produced by this new version of 10 CFR 20?
24 HR. PETERSON:
Excuse me?
tO
\\>
25 CHAIRMAN KERR:
How much risk reduction?
HERITAGE REPORTING CORPORATION -- (202)628-4888
292 1
HR. PETERSON:
The risk reduction in 10 CFR falls r"y 2
mainly in two areas.
One is protection of the unborn, the LJ 3
embryo fetus, for which there is no current limit.
4 The other is in reduction of the limit from, for the 5
general public from 500 to a hundred, and that's not a very 6
significant change due to EPA standards which are down at 25.
7 MR. CARROLL:
What is the fetus limit?
8 MR. PETERSON:
Half a rem over the gestation period.
9 CHAIRitAN KERR:
So we are going to make these 10 changes, and aside from the fetus, and the general public.
11 effect on general public vill be negligible?
There will be no 12 significant reduction in the risk?
13 MR. PETERSON:
There is not a major significant 14 reduction in risk other than that, no.
15 DR. LEWIS:
Can somebody educate me?
General public 16 means the average general public, or anyone not categorized as 17 a radiation worker?
So--this is just education--so that the 18 federal gu'idance means that whatever you decide on, the 19 general public will apply to all workers who are not declared 20 to be radiation workers?
I am just wondering how this binds 21 other agencies.
I am asking a dumb question probably.
22 MR. PETERSON:
No.
It is an interesting question 23 because we would generally treat people who were not radiation 24 workers as members of the public.
s/
25 DR. LEWIS:
Okay.
So does this mean we can put no HERITAGE REPORTING CORPORATION -- (202)628-4888
293 1
astronauts'in orbit, for example?
2 MR. PETERSON:
No, because these limits only apply
(~~)' _
y.
3 to norma' peacetine application.
4 DR. LEWIS:
To normal what?
5
-MR.
PETERSON:
Normal activity; they get a special 6
exemption.
And also I would point out that cosmic radiation 7
is not a licensed source.
8 LR. LEWIS:
That is certainly true.
But that time 9
will comet 10 That answers that particular question.
11 DR. MOELLER:
I would ask that the Committee-think 12 about this and tomorrow we will have to tackle it and say one 13 thing or the other.
14-MR. CARROLL:
One of my pet peeves with Part 20 over 15 the years has been the over zealous inspector who says not an 16 atom shall escape and starts hassling me over unmonitored 17 releases, quote, and I sav I could show you, for pity sakes, 18 that you know, this protective clothing is worn in the 19 monitored area.
It has gone out that vent, can't be a 20 problem.
Well, you don't moniter it.
Have you done anything j
21 about that?
l 22 MR. PETERSON:
Well, it is hard in the rule to take 23 care of overzealous inspectors.
There are a few areas in the 24 statement of consid? rations where wa have put in an
(
25 admonition.
It applies both to the licensee, cnd we hope will HE'.ITAGE REPORTING CORPORATION -- (202)628-4888
294 g e.
1 be useful to the licensee to explain things to the inspector, 2
in certain areas where we felt that that made, wrong O
3 interpretation might occur.
There is quite a bit of problem 4
in terms of trying to decide whether to monitor this 5
quite--there is some differences between inspectors in regions 6
as to what can be released, but Part 20 doesn't, I think can't 7
really address--
r.
8 MR. CARROLL:
Doe 3n't say that every vent from a, 9
from a controlled area must be monitored?
10 MR. PETERSON:
No, it does not.
11 MR. CARROLL:
It used to say that.
You could 12 interpret it that way.
13 HR. COOL:
It has been interpreted that way, and the 14 wording used in the waste disposal section which corresponds 15 to the wording about how your licensee can dispose of material 16 or get rid of material either by tranr.fer to anotner licensee 17 or by a pathway permitted by the Commission, or under 18 certain--that has not been changed.
That wording still stands 19 approximately the same way it did before, so I think the very short answer to your question is no, I don't think that 20 21 revision has helped with the overzealous inspector.
22 Now one of the things which Dr. Moeller had noted is l
23 a set-aside if you will, is the below regulatory concern 24 issue, what amounts of material or what pathways evaluated to
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at?
That was the sub.iect of the separate action.
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The staff has been directed by the Commission to (G
3 develop a below regulatory concern policy and bring it to the 4
Commission by the end of August.
That is being handled on a i
5 separate track, and if permitted one brief moment before we 6
have to close here, the Chairman had 1 believe mentioned the 7
large amount of recording and record keeping requirementn.
8 Without going into any detail, the revision, this 9
final revision which is brought before you now has reduced 10 those reporting and record keeping requirements in several 11 areas, particularly with regard to records and reports 12 necessary for ALARA, which was the biggest single factor noted 13 by commenters on the proposed rule.
()
14 CHAIRMAN KERR:
It is not reduced to below that 15 currently required, is it?
16 MR. COOL:
No, it is not, but some of the things 17 that had been added which were perceived rightly or wrongly as 18 adding a large burden, have been rolled back to some extent.
l 19 CHAIRMAN KERR:
Now we have only maybe a medium l
l 20 large burden?
l l
21 DR. MOELLER:
Mr Chairman, I think that wraps it l
22 up.
Let me thank Hal and Don for coming down.
l 23 CHAIRMAN KERR:
I do thank you.
Let's see.
Next 24 session will be recorded I think.
Do we need to record
/^Ns l
kl 25 anything else this e'aning?
l HERITAGE REPORTING CORPORATION -- (202)628-4888
296 1~
MR. WARD:
Doesn't look lika it.
s 2
CHAIRMAN KERR:
Mr. Fraley, what do you think?
It gd.
3 does not appear to us that anything else needs to be recorded.
4 Do you agree with that assessment?
5 MR. FRALEY:
For this evening, I agree.
6 CHAIRMAN KERR:
Okay.
Forrest Remick and I can 7
absent ourselves because we are in conflict on this next 8
session.
9 Let's take a five-minute break.
5 10 (Whereupon, at 4:30 p.m.,
the recorded portion of 11 the meeting was adjourned.)
12 13 14 15 16 r
17 l
l 18 l
19 20 l
21 22 i
23 i
24 25 i
9 HERITAGE REPORTING CORPORATION -- (202)628-4888 i
--n.-
1 CERTIFICATE 2
(2) 3 This is to certify that the attached proceedings before the 4
United States Nuclear Regulatory Commission in the matter of:
5 Name:
Advisory Committee on Reactor Safeguards 338th General Meeting 6
7 Docket Number.:
8 Place:
Washington, D.C.
9 Date:
June 3, 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 record of the foregoin proceedings.
15
/S/ [ a M e -
<f
/
17 (Signature typed): Catherine S. Boyd 18 official Reporter 19 Heritnge Reporting Corporation 20 21 22 23 24 1
25 Os Heritage Feparting Corporation (202) 628-4888
e
.g.
' O 9
PART 20 REVIS10N
{l,
o DEFICIENCIES OF PRESENT 10 CFR PART 20:
- 1. Scientific information underlying concentration limits is outdated (proposed rule 1955, finc1 1959).
- 2. Protection of public primarily based on concentration limits, no explicit annual dose limit.
- 3. No explicit limit for protection of the embryo / fetus.
- 4. Does not employ ICRP-26 system and newer concepts such as the "affective dose equivalent."
- 5. Does not reflect January 1987 revised Federal 9aidance.
- 6. Has been amended over 90 times in piecemeal fashion without a major overall revision.
O
____._______--___J
i
- r. 9 PART 20 REVIS10N o
PURPOSES OF REVISION:
- 1. Update scientific basis for dose and concentration limits.
- 2. Provide explict limits for protection of the public.
- 3. Provide explict limits for protection of'the embryo / fetus.
- 4. Adopt ICRP-26 risk-based dose limitation system.
- 5. Implement revised Federal guidance on occupational radiation exposure.
- 6. Provide better organization of 10 CFR Part 20.
O 2
I O
2
~
'O PART 20 REV1SI0N o
BENEFITS OF PART 20 REVISION:
- 1. Conformance to Federal guidance provides compatability with standards of other U.S. agencies and with most of NCRP's recent reconnendations.
- 2. Adoption of ICRP-26 Dose Limitation System provides high degree of compatability with national standards of other countries and international standards (CEC, OECD/NEA, and IAEA Basic Safety Standards).
- 3. Risk-based approach should provide better understanding of basic protection goals.
/3
- 4. Use of updated metabolic and dosimetric parameters (ICRP-30, U
ICRP-48) provides better scientific basis for derived (concentrationandintake) limits.
- 5. Provides consistency in treatment of internal and external doses.
l i
Q 3
l-
(:)
PART 20 REVISION o
COSTS ASSOCIATED'4ITH PART 20 REVIS101:
- 1. New quantities (e.g. effective dose equivalent) and system of dose limitation introduce greater complexity into radiation protection practice.
- 2. Changes in fundamental approach and new quantities will require revision of recordkeeping and reports.
- 3. Reduction in air concentration limits for natural uranium and uranium-238 may necessitate expensive modification of fuel fabrication facilities and procedures.
- 4. Requirement to notify workers annually of their dose has significant cost.
/~T
(_/
t t
l 4
- m-n----v- -
...-v
- o PART 20 REVISI0N o
CHANGES MADE TO REDUCE IMPLEMENTATION COSTS:
- 1. Eliminated requirements for detailed documentation of ALARA actions.
-Counterproductive to encouraging ALARA levels.
-Large associated recordkeeping cost.
- 2. Reduced requirement for surveying package upon receipt to:
-Packages labeled as containing radioactive materials under 00T regulations.
-Packages showing visible damage or leaking.
- 3. Modified allowable record formats to include "electronic media"
- 4. Eliminated term. nation reports to NRC.
t 4
O 5
(OJ PART 20 REVISION o
CHANGES MADE TO PROPOSED RULE THAT INCREASE COSTS:
- 1. Deleted exception to use of "committed dose eq)uhalent" for long-livedradionuclides(proposed 6 20.205.
-Exception would have allowed control of annual doses rather than comitted dose aquivalents.
-Would have been inconsistent with NRC policy to provide for control of the workplace rather than the worker.
-Coupled with decrease in Derived Air Concentration for uranium has large impact on fuel fabrication facilities.
-Statement notes that Comission will consider requests for longer implementation times in order to make physical modifications to facilities.
E. Require annual reporting of individual doses by certain G
licensees:
kJ
-Power reactors,
-Radiopharmaceutical and large source processors,
-Radiographers,
-Low-level Radioactive Waste Disposal Sites.
-High-level Radioactive Waste Repositories.
-Independent Spent Fuel Storage Facilities,
-Receivers of Radioactive Waste for processing.
- 3. Require annual reporting of dose to individual worker
-Present Part 19($19.13) requires such data be provided at least annually "upon request."
-Deletion of "upon request" necessary for conformance with revised Federal guidance on occupational exposure.
-Change has significant cost, particularly to smaller licensees.
-Some licensees already furnish annual dose reports to workers without prior requests.
O 6
. O s_/
,P A R T 20 REVI$10N o~
OTHER CHANGES FROM PROPOSED RULE:
- 1. Reinstated detailed protection req)uirements for large irradiators [present i 20.203(g ].
- 2. Changed recot d retention periods from 2 to 5 years or c'=te of next inspection of radiation protection program.
-consistent with NRC standardization of record retention requirements.
-Dose records and survey data must still be held for duration of license.
- 3. Eliminated cutoff on calculation of collective doses.
-Deferred until consideration of overall NRC "below regulatory concern" policy.
O--
-Part 20 does not require calculation of collective doses.
-No cost impact from deletion.
- 4. Codified long-standing staff position that release' of radio-active materials into sewer systems for sole use of licensees does not constitute "disposal into sanitary sewer systems."
- 5. Modified terminology for radiation warning signs:
-Restricted use of "DANGER" to radiation warning signs for "High" and "Very-high" radiation areas;
-Use of "CAUTION" restricted to "Radiation Areas" and "High Radiation areas."
. Change eliminates use of "DANGER" for "radiation areas "
- 6. Reinstated incident notification criteria based on monetary loss and loss of use of the facility.
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.O UNRESOLVED SAFETY ISSUE A-17 "SYSTEMS'TNTERACTIONS IF NUCLEAR POWER PLANTS" PRESENTATION TO THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS JUNE 3, 1988 PRESENTERS:
ROBERT BAEP, BRANCH CHIEF DALE THATCHER, TASK MANAGER EFGINEERING ISSUES BRANCH DIVISION OF FNGINEERING OFFICE OF PESEARCH
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l ItlTRODUCTION/ BACKGROUND
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'ACRS PAISED CONCERN IN CONTFXT OF STANPARD PLANTS 1978 DESIGNATED AS A IISI 1983-8f1 MAJOR REVISION TO SCOPE / TAP MET WITH ACRS i
1 PEVISED TAP APPPOVED BY NRR MAFAGEMENT 1986 DRAFT RES0LitTION PPESEPTFD TO ACPS P. CRGR MULT!PLE SYSTEM PESPONSE (MSR) PROGPAM INITTATED AS A PESIILT OF ACRS COMMENTS
.i CPGR IN AGREEMENT WITH SCOPE AND APPPDACH j
1987 MET FITH ACPS IN JANilARY 1987 1988 PROPOSED RESOLUTION TO BE PUBLISHED FDP PllBLIC COMMENT 1986 DRAFT PESOLUTION MODIFIED SOMEWIIAT PRESENTATION TO ACRS TODAY q
PPESENTATION TO CRGR ON JUFF. 22ND
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O A-37 FINDINGR SOME SPECIFIC ACTION SH0llLD BE TAKEN EVIDENCE INDICATED POTENTIAL IMPLEMENTATION WEAKNESSES RELY ON OTHER RELATED, ONG0ING PROGRAMS DECIDED MORE LOGICAL AND EFFECTIVE TO HANDLE IN OTHER ISSUES t
ADVERSE SYSTEMS INTERACTIONS (ASIS) WILL CONTINUE TO OCCUR LESSONS LFERNED ABOUT THEIR CHARACTERISTICS NOT COST-EFFECTIVE TO PERFORM BROAD SFARCH FOCLIS OTHER "CONCERNS" FOR PRIORITIZATION RECOGNIZED NEED TO DEFINE "CONCERNS" INT 0 SAFETY ISSIIES 4
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'A-17 PROPOSED RFSOLIITION NO NEF REQUIREFENTS l
GENERIC LETTER TO ALL LICENSEES-PROVIDE THE BASES FOR RESOLUTION OF USI A-17 l
PROVIDE INFORMATION ON LESSONS LEARNED l
REQUEST CERTIFICATION OF FLOODING EVALUATIONS i
i PROVIDE LESSONS LEARNED ABOUT ADVERSE SYSTEM INTERACTIONS FOR PRAs AND IPE REVIEW i
ACKNOWLEDGE RELATIONSHIP 0F USI A-46 ON SEISMIC QUALIFICATION i
i PROVIDE POWER SUPPLY INTERACTION INFORMATION TO GI-128 ON i
ELECTRIC POWER
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DEVELOPING OTHER CONCERNS FOR SEPARATE TREATMENT MULTIPLE SYSTEM RESPONSES-PROGRAM 1
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ESSENTIALLY UNCHANGED FROM THE 1986 PROPOSED RESOLUTION
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O A-17 GENERIC LETTER BASES OllTLINES CONCLUSIONS DISCUSSES RELATIONSHIP 0F.THE VARIOUS ISS!!ES AND PP0GPAMS INFORMATION ON ADVERSE SYSTEM INTERACTIONS LESS0FS LEARNED OllTLINES DEFINITION PRESENTS RESULTS OF OPERATING EXPERIENCE REVIEW SUMMARIZES / HIGHLIGHTS FIVE AREAS RECOMMENDS T0:
1.
CONSIDER THESE-ASIS IN OPERATING EXPERIENCE REVIEWS 2.
CONSIDER THESE ASIS WHEN PEP. FORMING OTilER PLANT EVALUATIONS, (E.G. PRAs)
CFRTIFICATION OF FLOODING / WATER INTRUSION ANALYSES REQUIP.ES LICENSEES TO CERTIFY ANALYSIS DONE DEFICIENCIES DETERMINED MODIFICATION DOCllPENTED JI!STIFICATION FOP. CONTINUED OPERATION 00CllMENTED IF NECESSAPY
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- O A-17 RELATION TO A-46 I
l A-46 DEALS WITH SEISMIC QUALIFICATION IN 01.DEP PLANTS RE0 VIRES PLANT WALKDOWNS TO EVALUATE EQUIPMENT NFEDED TO ACilIEVE SAFE SHilTDOWN i
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AGREFD TO INCLUDE SEISMICALLY-INDUCED SYSTEMS INTEPACTIOFS IN Tile WALKDnyNS d
NEWER PLANTS WEPE SUBJECTED TO PORE THOROUGH REVIEW REGARDING SFISMIC CAPABILITY b
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A-17 INPUT TO GI-1?8 "FLECTRIC POWER PELIAPTLITY" w
iP:TEGRATED EVALUATIONS OF:
GI A-30 "ADE0VACY OF SAFETY RELATED DC SUPPLIES" GI-48 "LCOs FOR CLASS IE VITAL INSTRUMENT BUSES" GI-49 "INTERLOCK AND LCOs FOR CLASS 1E TIE PREAKERS" t
i A-17 DEVELOPED INFORMATION ON IPC POWER SUPPLIES 1
l FACTORING TIIIS INTO RESOLUTION OF GI-128 i
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A-17 INPUT TO iPE/PRAs IPE-INVOLVES A PLANT SPECIFIC LOOK FOR VULPEPABILITIES USE OF SYSTEMATIC TECHNIQUES TO INCLUDE DEPENDENT' TYPE FAILURES A-17 IFFORMATION IS APPLICEBLE FUTURE PLAPTS WILL PERFORM PRA A-17 INF0PMATION IS APPLICABLE FOR DEPENDEPT FAILURES S
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P'l!LTIPLE SYSTEP PESPONSFS PROGRAM DFVELOPED TO CONSIDEP "CONCERFS"RAISED ON llSI A-J7, UST A f46, USI A l'7 OTHER PREVI0llS PROGRAMS BROUGHT INTO OllESTION IPCll'DE:
I FIRE PROTECTION EQUIPMENT DUALIFICATION L
OBJECTIVE IS TO DEFINE CONCERNS INTO POTENTIAL, GENERIC SAFETY ISSllES 1
SllPPLY INFORMATION FOR PRIORITIZATION I
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