ML20198C420

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Transcript of Commission 860515 Briefing in Washington,Dc by AIF on State of Industry.Pp 1-74.Scheduling Notes & 860516 Industry Briefing Presentations Encl
ML20198C420
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Issue date: 05/15/1986
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NRC COMMISSION (OCM)
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REF-10CFR9.7 NUDOCS 8605220450
Download: ML20198C420 (115)


Text

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NUCLEAR REGULATORY COMMISSION In *le matter of:

COMMISSION MEETING Briefing by AIF on State of the Industry (Public Meeting)

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Location:

Washington, D.

C.

Date:

Thursday, May 15, 1986 Pages:

1 - 74 ANN RILEY & ASSOCIATES 86052204S0 860016 Court Reporters PDR 10CFR PDR PT9.7 Suite 921 Washington, D.C.

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1 D l SCLA I MER 2

3 4

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This is an unofficial transcript of a meeting of the 7

United States Nuclear Regulatory Commission held on 8

5/15/86 In the Commissice's of# ice at 1717 H Street, 9

N.W.,

Washington, D.C.

The meeting was open to public 10 attendance and observation.

This transcript has not been 11 reviewed, corrected, or edited, and it may contain i

12 inaccuracies.

18 The iranscript is intended solely for general 14 informational purposes.

As provided by 10 CFR 9.103, it is 15 not part of the formal or informal record of decision of the 16 matters discussed.

Expressions of opinion in this transcript 17 do not necessarily reflect final determination or beliefs.

No 18 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement.

20 or argument contained herein, except as the Comm i-s s i on may 21 authorire.

22 23 i

24

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1 UNITED STATES OF AMERICA

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2 NUCLEAR REGULATORY COMMISSION 3

4 BRIEFING BY AIF ON STATE OF THE INDUSTRY 5

6 PUBLIC MEETING 7

8 Nuclear Regulatory Commission 9

Room 1130 10 1717 "H" Street, N.W.

11 Washington, D.C.

12 13

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Thursday, May 15, 1986 14 15 The Commission met in open session, pursuant to 16 notice, at 9:30 o' clock p.m.,

NUNZIO J.

PALLADINO, Chairman of 17 the Commission, presiding.

18 COMMISSIONERS PRESENT:

19 NUNZIO J. PALLADINO, Chairman of the Commission 20 THOMAS M. ROBERTS, Member of the Commission 21 FREDERICK M.

BERNTHAL, Member of the Commission 22 LANDO W.

ZECH, JR., Member of the Commission 23 24 25

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STAFF AND PRESENTERS SEATED AT COMMISSION TABLI:

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2 S.

CHILK 3

J. HOYLE 4

M. MALSCH 5

D. LYONS 6

S. SMITH 7

J. TAYLOR 8

Z. PATE 9

W.

BEHNKE 10 W. OWEN 11 12

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14 15 16 17 18 19 20 21 22 23 24 25

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3 l

1 PROCEEDINGS f

2 CHAIRMAN PALLADINO:

Ladies and gentlemen, will you 3

please take your seats.

Good morning, ladies and gentlemen.

4 I should report that Commissioner Asselstine will not be able 5

to join us today.

He is in travel status but he does intend 6

to read the transcript very carefully.

7 This morning the Commission meets with 8

representatives of AIF, the Atomic Industrial Forum.

The 9

purpose of the meeting is for the Commission to receive a 10 briefing by AIF on the current status of the nuclear industry.

11 With us today is Donald Lyons, Chairman of the 12 Atomic Industrial Forum and president of the Power Systems p

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13 Group of Combustion Engineering.

I will ask Mr. Lyons to 14 introduce the other representatives at the table.

15 We have set aside two hours for the AIF presentation 16 and Commission questions.

We will have to adjourn at just 17 about 11:30 a.m.

I understand that NRC representatives in 18 Regions I and IV will be listening in to the meeting by 19 telecommunications link-up.

20 Let me ask if any of my fellow Commissioners have 21 any opening remarks at this time?

22 (No response.)

23 CHAIRMAN PALLADINC:

If not, then I will turn the 24 meeting over to Mr. Lyons.

25 MR. LYONS:

Thank you very much, Mr. Chairman.

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4 1

Commissioners, we are pleased to be here this morning.

It is 1

2 not just the Atomic Industrial Forum that is here but a whole 3

delegation from industry representing the Nuclear Power 4

Assembly which meets each year at this time.

5 With me today are Sherwood Smith, Chairman of the 6

Edison Electric Institute and President and CEO of Carolina 7

Power and Light; Mr. John Taylor, vice president for nuclear 8

power, EPRI; Mr. Jack Pate, President, Institute of Nuclear 9

Power Operation; Wallace Behnke, Chairman of the AIF Policy i

10 Committee on Nuclear Regulation and Vice Chairman of 11 Commonwealth Edison Company; and Warren Owen, Vice Chairman, 12 Nuclear Utility Management and Resource Committee and

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13 Executive Vice President of Duke Power Company.

14 Each of these gentlemen will make verbal 15 presentations following my opening remarks.

While we are here 16 today to assess the state of the nuclear industry, it is 17 unavoidable, however, that we divert our attention first to 18 the recent accident at the Chernobyl plant.

19 When an event such as this occurs particularly when 20 it is veiled by incomplete information, a re-evaluation of our 21 current circumstances here in the United States is 22 inevitable.

The accident was a tragedy for all concerned but 23 one which should not be allowed to set back the progress made 24 since the Three Mile Island incident.

25 Unfortunately, nuclear opponents and political

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5 1

opportunists are attempting to exploit the accident.

The 2

public is understandably concerned and in need of reassurance 3

about the safety of nuclear power from both the industry and 4

our government.

5 Throughout the free world, responsible authorities 6

are taking steps to provide that assurance.

Yesterday, we had 7

a discussion with many of the international representatives at 8

the Nuclear Power Assembly which was reported in the press 9

this morning.

10 The accident at Three Mile Island underscored the 11 importance of excellence in the design, construction and 12 operation of commercial nuclear power plants.

Since that

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13 time, the United States nuclear. industry has taken what I 14 consider aggressive steps to upgrade our management, quality 15 assurance and operator training and other elements of nuclear 16 plant operation.

17 We just cannot afford to become complacent, however, 18

'despite the fundamental dif"erences in reactor concepts, 19 engineered safeguard requirements and the regulatory systems 20 employed in the United States as compared to the U.S.S.R.

It 21 is apparent that the accident may offer lessons applicable 22 to the management and regulation of nuclear power throughout 23 the world.

24 There is a need to learn as much as possible about 25 the causes.

We should also review the post accident and i

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1 recovery experience in a deliberate and constructive manner.

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This is not to imply that we really anticipate major changes 3

in our plant design or management systems but rather that we 4

anticipate ongoing evolutionary improvement and look to gain 5

from Chernobyl to the extent that it can contribute to our own 6

experience.

7 Significant events, no matter where they occur, no 8

matter how unrelated to our technology, must be reviewed and 9

acted on as if it had a bearing on safety.

At the same time, 10 I feel that there is no turning back on nuclear power with its 11 nearly three decades of operating experience in this country.

12 Nuclear power, as you know, accounts for 16-percent

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13 of our generation today and with 100 plants licensed to 14 operate and the 27 now under construction, when they are 15 completed about 20-percent of our power will come from nuclear 16 sources.

17 In its recently issued national energy policy plan, 18 the Administration highlighted the value of a balanced 19 energy mix and identifies revitalization of civilian nuclear 20 power as an important objective in our national energy policy.

21 I believe what is called for now is a systematic 22 assessment of the accident.

What we need to avoid is 23 speculation and a premature or piecemeal response.

24 The public is entitled to the facts and the benefits 25 of any safety lescons we learn and we in the industry are

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7 1

prepared to work with the Commission in every way possible

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2 towards that end.

3 Unfortunately, however, the world cannot wait and 4

hold its breath as we learn the lessons from Chernobyl.

There 5

are 100 operating plants to be regulated and the American 6

public to be served.

So while we expect to learn more from 7

this unfortunate event, we believe that the proposals 8

presented today are consistent with the commitment we both 9

have to continue and improve the overall nuclear power plant 10 safety in the United States.

11 Mr. Chairman, you will be stepping down from your 12 position on June 30th of this year becoming the first person 13 to have served this country for a full five year term in a 14 very challenging position.

We sincerely appreciate the 15 service you have provided in a difficult time and I speak for 16 all of my colleagues here in the nuclear industry in extending 17 our best wishes to you and your family.

18 CHAIRMAN PALLADINO:

Thank you.

19 MR. LYONS:

My own two-year service as chairman of 20 the board of the Atomic Industrial Forum draws to a close 21 later this year so perhaps this is a good occasion to review 22 what we have acconplished and what we still have left before 23 us.

24 hhen you took office five years ago, Mr. Chairman, 25 the credibility of the NRC had been attacked repeatedly in

8 1

Congress by the Administration and even NRC sponsored studies 2

of the TMI accident.

I would like to acknowledge some of the 3

many positive accomplishments during your term.

4 One of the first and most effective things you did 5

was to establish the committee to review generic requirements 6

which in turn establish a formality and discipline to the 7

development of new regulatory requirements.

8 You also established the licensing reform task force 9

which defined a framework of future administrative and 10 legislative reforms.

The Commission followed up on the task 11 force recommendation by proposing a licensing reform bill 12 which is now before Congress and will go a long way if enacted 13 toward establishing a fair and rational licensing process 14 while improving overall plant safety in the process.

15 The Commission also put into place a much needed and 16 long sought backfit rule which provides a means to again 17 instill discipline into the retrofit process, and under your 18 Chairmanship the Commission has grappled with safety goals, a

19 topic previous Commissions deemed too hot to handle.

20 In addition, the Commission has come to acknowledge 21 the importance and indeed the necessity of acconmodating plant 22 betterment projects initiated by the utilities, many of whom 23 are represented here with me today rather than allowing them 24 to be constantly displaced by required retrofits.

25 And under your leadership, the Cc= mission has

v 9

1 tackled the matter of accidents beyond design basis and 2

produced a reasonable severe accident policy that pertains to 3

both present and future plants.

4 To the Commission's credit, it is a policy that 5

focuses resources on the main contributors to risk as opposed 6

to spreading resources over general and in consequential 7

concerns.

8 Perhaps, however, the most important change that is 9

taking place is the changing regulatory climate.

I am 10 referring to the NRC's growing awareness that the licensee is 11 indeed the one who is directly responsible for the safe 12 operation of its facilities.

The licensee is therefore in the

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13 best position to determine how to achieve excellence that both 14 the utility and the NRC strongly desire.

15 The staff has also recognized that the industry has 16 more rescurces than the NRC for assessing certain solutions to 17 generic problems and where it can, the staff is providing the 16 industry with the opportunity to address some problems on its 19 own terms before moving to impose regulatory solutions.

20 In our mind this represents enlightened regulation.

21 Accordingly, INPO, NUMARC and the vendor owners group are 22 assuming increased responsibility for self-regulation of its 23 industry.

24 Finally, I would like to take the opportunity to 25 applaud the Administration's foresight in haming the NRC's

10 1

next chairman five months in advance and we congratulate you, 2

Commissioner Zech, on that announcement.

Your leadership and 3

technical credentials are well established throughout over 30 4

years of Naval duty and two-year service here at the 5

Commission and we wish you well.

6 Despite the accomplishments of the Commission that I 7

have sighted I assure you, Chairman designate, that there are 8

many challenges left for all of us who have to serve.

Last 9

year in my address to this group, I stated that there were 10 seven issues that we considered important.

11 By my count, NRC has come to grips with two of those 12 issues; namely, backfitting and the re-licensing of TMI-1.

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13 Though it might be considered presumptuous to assume that 14 those objectives had anything to do with these 15 accomplishments, I am sufficiently encouraged to try again and 16 thus, I would like to enumerate several areas where I feel we 17 could do work together without waiting for the results from 18 Chernobyl.

19 We have noted our satisfaction with the backfit l

l 20 rule.

I hope and trust that the rule has established the 21 necessary disciplines on both sides and structured so that the 22 Commission can quickly and effectively sort through the 23 lessons learned from this accident.

24 Experience has shown, however, that rules simply are 25 a means and not necessarily the solution and we urge a

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11 1

continuous monitoring of the effectiveness of the backfit f

2 rule.

3 Another joint NRC/ industry undertaking which holds a 4

great deal of promise is the voluntary technical specification 5

improvement program.

That is an area where real safety 6

improvements can be obtained simply by structuring a set of 7

clear and unambiguous technical specification provisions.

8 Source term research has shown that the releases 9

from a U.S.

commercial nuclear plant accident would be 10 substantially lower than previously assumed.

11 The Commission, on the other hand, would like to 12 complete all of the evaluations necessary to give it

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13 confidence that the new source term is indeed conservative and 14 we urge you then to press on then with that effort.

15 I would like to encourage the Commission to resolve i

16 the important unresolved and generic safety issues and get rid 17 of the leftover by exercising the leadership necessary to 18 identify things that are trivial and do away with those.

19 I think it is important that we eliminate long lists 20 that leave the impression that nuclear power is beset with all 21 sorts of unaddressed dangers to the public, a perception 22 that we believe is clearly not true.

23 We also agree that t'he licensing process must be 24 changed.

It was right perhaps to launch the industry with a 25 two-step process but it doesn't seem appropriate to us today

12 1

to do it that way but in the process there is a quid pro quo 2

for one-step licensing.

3 We cannot ask you to certify a plant for operation 4

unless we have provided you with all of the information 5

necessary to determine that the plant can be built and 6

operated safely during that process.

7 We are prepared to provide all of the necessary 8

safety information prior to the receipt of the license in 9

order to achieve the regulatory and design stability that is 10 necessary to restore construction times and therefore cost to 11 a manageable level.

12 In the process, construction management unencumbered

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13 by continual changes can be improved, greatly improved, and

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14 vith it, overall quality and plant safety can be increased and 15 that is what I was referring to earlier.

16 Sore would argue that the Commission is not 17 authorized under the Atomic Energy Act to provide one-step 18 licensing.

I think you can provide it and should provide it 19 but in order to give the industry the stability it needs we 20 also need statutory endorsement.

21 We think the best way to demonstrate to Congress 22 your commitment to an improved process is to proceed with 23 rulemaking and put in place the basic tenets of that 24 legislation.

25 Finally, I would like to speak to leadership.

Each

13 1

of us on this side of the table is in a position of leadership 2

within the industry organizations that we represent here and, 3

of course, within our own companies.

4 In our own industry organizations, we are often 5

frustrated by the lack of cohesiveness in that of special 6

interest groups that frustrate our individual efforts.

Thus l

7 it is with a substantial degree of empathy that we address the 8

problem you face; namely, that there are five people still 9

trying to steer this agency on what each in their own mind 10 feel is the right path-for any given issue.

11 I understand that there is a majority who have 12 already told Congress that you feel that it is time to convert 13 the structure of the Agency to a single administrator.

We, 14 of course, support that position and have done so publicly in t

15 our resolutions at the Nuclear Power Assembly.

16 In summary, let me quickly touch base then on the 17 items we feel the industry and the Commission should continue 18 to focus their attention on this year.

19 Backfitting, the process is in place.

Technical 20 specification improvements, this holds much promise and should 21 be pursued.

Safety goals, we are in general agreement with l

22 the guidelines established in the 1983 draft policy and we 23 urge that to go to closure.

24 Source terms, there is a wide spread agreement that 25 source term assumptions of WASH-1400 are substantially l

14 1

overstated.

Timely resolution of these inequities would be f

2 important.

3 Unresolved and generic issues, we urge you to close 4

out lingering topics that I mentioned earlier and on licensing 5

reform, you can and should take action within the limits of 6

the current act.

7 Mr. Chairman, that concludes my remarks.

I 8

appreciate your attention.

Since we are going to be touching 9

on a large number of subjects individually, perhaps we could 10 make each speaker make their presentation and then come to 11 questions if that is acceptable.

12 CHAIRMAN PALLADINO:

All right.

Thank you very

[

13 much.

14 MR. LYONS:

Mr. Smith.

15 MR. SMITH:

Members of the Commission, I am Sherwood 16 A. Smith, Jr.,

and I appear as the current chairman of the 17 Anderson Electric Institute this morning.

I am also chairman 18 and chief executive officer of Carolina Power and Light 19 Company, one of the organizations that has the longest period l

20 of experience in the operation of both pressurized water 21 reactors and boiling water reactors in this country.

22 From the design which was selected for utilization 23 in this country, the safety features associated with it, the 24 steadily, I think, improving and more effective regulatory j

25 system that we have, the many changes that were instituted l

15

'( -

following the accident at Three Mile Island in 1979, it is a 1

2 source of first of all reassurance to our licensees and to 3

our own company that the type of accident that happened at 4

Chernobyl has not and now we know could not happen in the 5

United States.

6 Yet, the fact that an accident of any type occurred 7

anywhere in the world with regard to a nuclear facility, I 8

think, is a challenge to all of us to redouble our emphasis on 9

safety.

10 I can assure you that that is the response of the 11 licensees that are represented by the Edison Electric 12 Institute.

One of the very positive actions which the entire

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13 nuclear community in the United States took following Three k

14 Mile Island was the establishment of the Institute of Nuclear 15 Power Operations along with the establishment of the Nuclear 16 Safety Assessment Center associated with EPRI and gentlemen 17 from both of those organizations will speak in just a moment.

18 But it is appropriate on behalf of we, the 19 licensees, who are the beneficiaries of their simply 20 outstanding work, I think, to report to you that their work is 21 effective, that their work is ongoing, it is evolutionary and 22 it is a constant call and a constant source of assistance to 23 us as we try to attain ever increasing standards of excellence 24 in safoty.

25 In our legislative program of the industry as

16 1

mentioned by Mr. Lyons, our industry does support the

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2 standardization bill that is now before Congress and we feel 3

the adoption of such legislation would enable us at this time 4

well in advance probably of the need to actually present an 5

application under such legislation to develop a gradual system 6

to concentrate our resources both from the industry standpoint 7

and from the regulatory standpoint upon a few improved 8

designs.

9 We think that by stimulating standardized programs 10 that we will have more uniform construction practices, more 11 uniform quality assurance practices, all of which will lead to 12 enhanced safety and efficiency.

13 We think that this would also permit and facilitate 14 a more ready and more useful sharing of information throughout 15 our entire industry.

16 So we think that this is the time for Congress to 17 act and we hope that Congress will move forward.

I recently 18 testified before the Senate Energy and Natural Resources 19 Committee on the legislation and we would hope that Congress 20 will move forward.

21 By the same token we feel that this is an 22 appropriate time for Congress to review, make changes if 23 necessary, if where appropriate in th'e Price-Anderson 24 legislation and re-enact that legislation for the protection 25 of the public and for the purpose of establishing a framework

17 1

so that it will be possible later on in this decade to r

2 consider the option of ordering additional new nuclear power 3

plants for use in the 1990's and beyond.

4 We think that the process of providing for indemnity 5

to the public without the proof of fault is a process and a 6

rule which should be retained and we also think that the 7

limitation of liability feature serves as a reasonable way in 8

which to balance the interests of the public and the need of 9

those members of industry throughout the industry 10 infrastructure to continue to provide support and to provide a 11 basis for going forward.

12 So we will continue to urge Congress to act s

13 favorably on those two matters of legislation.

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14 Last week it was my privilege to meet as the leader 15 of the Edison Electric Institute delegation with a group of 16 our counterparts from Europe representing the International 17 Union of Electric Producers and Distributors.

18 The subject of Chernobyl was one of great lengthy 19 discussion and it was reassuring to me to see the European 20 community develop, I think, new interests in the sharing of 21 information and cooperation and certainly the statement of 22 Mr. Gorbachev last night that the Russian government would 23 support additional sharing of information throughout the international community through the IAEA is something that we 24 25 view with pleasure, i

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18 1

We are pleased to see that statement by the Russian r

2 leader and we hope that at the forthcoming IAEA meeting there 3

will be action certainly on the part of the United States 4

industry, we would pledge our fullest cooperation and our 5

continued encouragement for that to go forward.

6 Following the Three Mile Island accident in 1979, 7

the major organizations that are involved in the utilization 8

of nuclear power in this country and there are now eight of 9

them and I will mention them in just a moment formed what we 10 called the Utility Nuclear Power Oversight Committee.

11 That committee simply serves as a coordinating and 12 umbrella group to make sure that all of the important issues

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13 of nuclear power are appropriately addressed by each 14 constituent organization and that there is the maximum amount i

15 of coordination.

i 16 That committee is currently chaired by James 17 O'Connor, the Chairman of Commonwealth Edison who also serves 18 as the Chairman of the Institute of Nuclear Power Operations 19 currently.

20 Last week under the initiative of this committee 21 which we call by its acronym UNPO, a meeting was held here in 22 Washington with the representatives of the Atomic Industrial 23 Forum, the American Nuclear Energy Council, the American 24 Public Power Association, the Edison Electric Institute, the 25 Electric Power Research Institute, the National Rural Electric

19 1

Cooperative Association, the Institute of Nuclear Power 2

Operations and the U.S. Committee for Energy Awareness to 3

develop a coordinated way in which we will receive and 4

evaluate information that does flow from the Chernobyl 5

incident both to evaluate what we can learn about the causes 6

and the immediate post-accident occurrence there and also to 7

make sure that to the extent that any of that information is 8

relevant for use by our industry that such is promptly done.

9 -

We feel that this will assure that the entire 10 industry in this country does act in a concerted effort to 11 learn as much as possible about the event at Chernobyl, to use 12 that information in the most appropriate way to further

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13 enhance our overall goal for increased and intensified nuclear 14 safety in this country.

15 We feel that as we now look down the road and va 16 look beyond the current events towards the 1990's and beyond 17 that the continued utilization and development of nuclear 18 power in this country and elsewhere in the world is essential 19 in terms of the progress and the welfare of society and it is 20 our goal to make sure that we do our part to promote whatever 21 reasonable and appropriate steps may be taken in order to 22 assure that the benefits of nuclear power in a safe and 23 well-managed way will continue to be made available to the 24 American public.

25 Thank you, Mr. Commissioners.

I~

20 1

CHAIRMAN PALLADINO:

Thank you.

,r 2

MR. LYONS:

Mr. Taylor, Vice President of Nuclear 3

Power for EPRI.

4 MR. TAYLOR:

Thank you, Don.

The primary objective 5

of the EPRI Nuclear Power Program is to provide technology to 6

improve the safety and reliability of nuclear power plants.

7 In keeping with that objective EPRI took a series of 8

initiatives following the TMI-2 accident to further our 9

understanding of nuclear accidents and strengthen our systems 10 for assuring the safety of nuclear power.

11 First, an in-depth review of the TMI-2 accident was 12 carried out to pin-point the causes and to find corrective

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13 actions.

14 Second, a Nuclear Safety Analysis Center was formed 15 to evaluate operating reactor incidents so as to identify the 16 generic accident precursors and communicate them to all 17 U.S.

nuclear utilities.

18 The SEE-IN, the evaluation phase, the network, the 19 communication phase systems initially developed by NSAC have 20 now been turned over to INPO and have become vital and

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21 continual processes in the industry.

22 Third, a major research program was launched to 23 better understand severe accidents and the potential for 24 release of radioactive material to the atmosphere, the source 1

25 term program.

a 21 1

Fourth, the entire EPRI nuclear power R&D program in

(.

2 safety and reliability was reoriented on the basis of the 3

lessons learned from TMI-2 and the recommandations of the 4

Kemeny commission and other investigations of the TMI-2 5

accident.

6 A major relief and safety valve test program was 7

implemented.

Improved devices for valve position indication 8

were developed.

Major attention was given to improvement of 9

human factors in operation and maintenance including 10 diagnostic aides and system oriented procedures for improved 11 emergency response. signal validation techniques and simulator 12 qualification standards.

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13 Development and application of probabilistic risk 14 assessment methodology was intensified particularly in the 15 treatment of human error inputs and common mode failure.

16 Extensive testing of emergency core cooling systems 17 and small break loss of coolant accident transients were 18 implemented.

19 A major effort was devoted to develop improved in-service inspection techniques and establish inspector 20 21 training qualification programs.

22 These programs are continuing and time does not 23 permit even a full summary of these activities.

We have kept 24 Bob Minogue and his staff and the research branch fully 25 advised of our programs and their results and have also

22 1

recently reviewed our total program with Harold Denton, 2

director of Nuclear Reactor Regulation.

3 Our staff has been working diligently to understand 4

the events of the Chernobyl accident and to develop an 5

understanding of what lessons from that event can be applied 6

to our U.S. commercial nuclear power industry.

7 We have found as you have that detailed technical 8

information on Soviet plant designs and operation is difficult 9

to obtain.

We have also found that the lack of detailed 10 accident information at this time has made it virtually 11 impossible to develop a thorough analysis of the event as we 12 did for the Three Mile Island accident.

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13 It is our responsibility to our utility sponsors to 14 do everything we can to develop the best possible technical 15 explanation of the accident nnd its consequences.

16 Industry groups, such as EPRI, INPO and AIF, should 17 work together with your staff, the IAEA and hopefully with the 18 Soviets to obtain adequate information to create a detailed l

19 sequence of events and a thorough understanding of root causes l

20 and consequences of the Chernobyl accident.

21 We want to take this opportunity to express.our 22 appreciation to menbers of your staff who already have been 23 very helpful to us in the gathering of information on 24 Chernobyl.

l 25 One of the most important lessons we learned fron l

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23 1

our nuclear safety analysis center analyses of the Three Mile

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2 accident and other significant events which NSAC analyzed and 3

reported is that a thorough understanding of the sequence of eventdandathoroughunderstandingoftheperformanceofall 4

5 the safety system and operator actions during the event is 6

crucial to developing sound conclusions and recommendations.

7 I am concerned that pressures on the NRC and on our 8

industry to produce quick answers and quick fixes in response

'to the Chernobyl accident may preclude us from doing a 9

10 thorough job of analysis that is so important to rational 11 decision-making.

We must avoid the temptation to shoot from 12 the hip.

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13 One of the major reasons that mandates we analyze 14 this event carefully prior to formulating recommendations for 15 U.S. light-water reactors is the Soviet designs are 16 significantly different from ours.

17 Fundamental design and operational differences 18 exist that make side-by-side comparisons extremely difficult.

19 These fundamental differences lead us to draw two immediate 20 conclusions.

21 First, the differences will make it difficult to 22 draw easy applications to the U.S.

situation.

Many of the 23 lessons from Chernobyl vill not apply to U.S.

plants.

Some 24 lessons will apply and must be analyzed.

25 Initial challenges or event initiators can be very

24 1

similar between U.S.

and Soviet plants.

Also, I believe, the 2

consequences of the Chernobyl accident in terms of accident 3

source terms, radioactive transport, health effects and 4

clean-up efforts are all important areas that U.S.

scientists 5

must study and apply as appropriate to our own safety analysis 6

efforts.

7 Secondly, we must not fail to recognize the most 8

obvious fact about U.S./ Soviet nuclear power program 9

comparisons.

Chernobyl was vastly different from our 1979 10 accident at Three Mile Island, 11 Despite the fact that each experienced major core 12 damage, the public health effects from the Three Mile Island r

13 accident and the Chernobyl accident are dramatically

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14 different.

15 No deaths, injuries or health risks resulted from 16 the Three Mile Island accident.

The exhaustive Pennsylvania 17 Department of Health Study completed last September found no 18 evidence of increased cancer among area residents due to the~

19 1979 accident at TMI.

20 No damage to crops or livestock occurred and no 21 clean-up of land outside the plant boundaries was required.

22 I firmly believe that our U.S.

designs and 23 operations account for that difference.

The analysis of 24 Chernobyl will no doubt reveal some opportunities for further 25 improvements in the design and operation of U.S. reactors.

25 1

But we must not lose sight of the fact that r

I 2

TMI/Chernobyl comparisons indicate that our program is 3

fundamentally sound.

4 This is a credit to your agency, our industry and 5

public scrutiny within our democratic process that have worked 6

together to achieve high standards of safety.

7 I would like to take a few minutes to explain in 8

more detail some of these important differences between 9

U.S.

and Soviet reactor designs.

10 I must again emphasize that our information on 11 Soviet design is incomplete.

My emphasis on the following 12 differences is not intended to suggest that there are no 13 lessons to learn from Chernobyl but to help us focus on the I

14 facts and insure that current lessons are identified.

15 My summary of fundamental design differences will be 16-grouped into three areas; reactor differences, containment 17 differences, and safety system differences.

18 The point of comparison will be the U.S.

light-water 19 reactor.

The Chernobyl reactors are light-water cooled 20 graphite moderated pressure tube reactors.

These thousand i

21 megawatt electric plants called RBMK-1000's by the Soviets, 22 the RBMK reactors are the dominant Soviet design and they 23 comprise over one-half of all operating Soviet power reactors 24 and about 65-percent of their nuclear capacity.

25 The first obvious difference between the Soviet i

26 1

RBMK's and U.S.

LWP's is the use of graphite as a neutron 7-2 moderator.

The RBMK design evolved in a Soviet program from 3

earlier weapons production reactors that used graphite.and low 4

enriched uranium.

5

.The U.S. designers colected light' water moderation 6

over graphite moderation for power reactor applications for a 7

number of reasons.

First, the obvious safety problems 8

associated with a potentially flammable material inside the 9

reactor core are eliminated along with all the complex support

~

10 systems that go with it, modera' tor heat removal, cover gas, 11 fire protection and so on.

12 Second, the unique physical and chemical problems of a

/

13 graphite deformation under a radiation including annealing i

14 requirements and energy effects are avoided.

15 Third, graphite reactors.are huge in physical size 16 and very complex when compared to U.S.

light-water reactors.

17 Over 1,600 individual pressure tubes dre imbedded in the 1,800

~

18 tons of graphite each with its indiv3, dual inlet and outlet 19 piping.

20 Fourth, the few advantages of graphite moderation,

~

21 very low enriched uranium and on-line refueling were.not 22 attractive to U.S. utilities who had no interest in providing 23 material for the U.S. Weapons program.

24 The next major difference between U.S.

and Soviet

-25 reactor designs is in the defense-in-depth barriers provided

-.*-r b-- - -

-+-f e--

a-

'-w--i--

r'-

27 to insure that nuclear fuel and fission products can't escape 1

2 the core.

3 B,oth Soviet RBMK reactors and U.S.

LWR's use UO-2 4

fuel pellets surrounded by a zirconium cladding of about 0.02 5

to 0.03 inches wall thickness.

These fuel elements are 6

similar but the next barrier of defense against relerse is 7

radically different.

8 The Soviets use 1,600 individual pressure tubes 23 9

feet long and three and a half inches'in diameter to contain 10 the fuel elements and light water coolant flowing past the 11 fuel elements.

The pressure tube walls are four millimeters 12 thick whereas the pressure vessel walls on U.S.

light-water

(

13 reactors are about six and a half to eight and a half inches 14 thick, some 50 times thicker.

15 This means that damaged fuel elements on a Soviet 16 RBMK reactor have a much greater chance of penetrating the 17 second barrier of defense than on a U.S.

light-water reactor 18 with its single large pressure vessel.

19 These first two Soviet differences, use of graphite i

20 as a moderator and thin walled pressure tubes, combine to form L

21 a third distinction, the possibility of creating dangerous hot i

22 graphite hot steam reactions from a breach in the pressure 23 tube wall.

24 Although both the RBMK and LWR designs use light 25 water as coolant, the different reactor configurations create i

L

28 1

some unique cooling problems for the Soviets.

(

2 First, with a relatively small water inventory in 3

the reactors little time is available to respond to challenges 4

such as loss of inventory before coolant boil-off and fuel 5

overheating begins.

6 Individual fuel channels may boil dry if there are 7

channel-to-channel instabilities between pressure tubes.

In 8

addition, loss of coolant may not result in a fail safe 9

negative reactivity that exists in U.S. designs.

10 Soviet reactors have exhibited unstable positive 11 steam void reactivity coefficients which require design 12 changes to the metal water ratio inside the pressure tubes by 13 increases in enrichment.

(

14 I have now summarized the major differences in the 15 Soviet RBMK versus U.S. LWR reactor designs and will.say a few 16 words about reactor containment.

17 The subject of Soviet containments has generated a 18 great deal of discussion in the last few days and deserves 19 some attention at this point.

On this subject, we find the 20 technical information on RBMK containment capability is much 21 less available than technical information on RBMK reactor 22 design.

23 We believe this to be a result of relatively slow 24 development of containment technology in the Soviet program.

25 Early Soviet reactors had no containment whatsoever.

29 1

Incremental steps have been taken on subsequent generations of 2

RBMK designs to improve on this situation but to this date we 3

are unaware of any operating or under construction Soviet RBMK 4

with a full primary containment in the sense we in the West 5

define full containment.

6 Fourth, full containment means complete enclosure of 7

all reactor and primary support systems for the reactor such 8

that any design basis accident is fully contained inside.

9 Full primary containment is achieved typically in the U.S. by 10 building a strong thick steel and concrete containment vessel 11 around all primary reactor systems.

12 The containment is either large enough to contain

(

13 the peak pressure anticipated for the worst design basis 14 accidents or has sufficient suppression or steam condensing 15 capacity to contain that. Jorst case peak pressure.

16 Most U.S. LWR's have containments with design 17 pressures of about 60 psi with ultimate yield strength as high 18 as three times that figure.

For some U.S. containments with 19 lower design pressures such as the BWR MARK-III and the ice 20 condensers, sufficient pressure suppression capacity is 21 installed to limit the vorst case accident peak pressure to a 22 much lower value within the containment design.

23 Needless to say the capability of a containment to 24 perform its design purpose successfully is not merely a 25 function of its design pressure but also its size and pressure

30 1

suppression capacity.

l j

{

2 Finally, full containment as defined by the j

3 U.S. implies the ability to isolate completely and rapidly all 4

containment penetrations such as main steam and main feedwater 5

piping.

6 We have heard of reports based on Soviet technical 7

literature that credit the Chernobyl unit four with a 8

containment.

We believe such claims probably are not 9

correct.

This seems to be substantiated by a recent 10 associated press report that Ivan Yemelyanov, deputy director 11 of the RBMK design organization-- quote -

" confirmed 12 speculation that the reactor did not have a conventional 13 containment. vessel used in the West to prevent radiation leaks 14 in case of a break down"-- unquote.

15 As previously stated, the modern Soviet structural 16 designs we have seen would not quality in the West as 17 containment.

A more appropriate term would be limited 18 pressure suppression capability.

19 We base this conclusion on three observations.

20 First, the only part of the primary system enclosed within a 21 boundary intended to be pressure tight, reactor inlet piping

-22 is enclosed but Soviet literature seems to imply that reactor 23 outlet piping and the four large steam drums or steam 24 separators are outside the pressure boundary enclosure.

25 Also, there is some doubt that the reactor core

31 1

itself is protected by the pressure boundary.

?"'

2 Second, piping penetrations of the pressure boundary 3

don't appear to be equipped with any isolation capability.

4 For example, main steam isolation valves or main feedwater 5

isolation valves.

6

. Third, the pressure suppression capacity appears to 7

be limited to certain specific break size and locations and 8'

does not appear to envelop the full range of possible accident 9

sequences for which U.S. containments are analyzed.

10 In general then Soviet compartmentalization appears 11 directed at limiting the pressures of pipe breaks not 12 containing the radioactivity that could be released An an r

13 accident.

(s.

14 The exact pressure suppression capabilities of 15 Chernobyl-4 are unclear.

The observations I have just made 16 are based on crediting Chernobyl-4 with the most modern 17 pressure suppression capability we could find described in the 18 Soviet literature.

19

.We are not sure that this assumption is accurate but 20 the evidence appears to point towards Chernobyl-4 being 21 equipped with the more modern compartmentalization in 22 comparison to earlier RBMKs that appear to have no pressure 23 suppression capability.

24 The final area of U.S.

and Soviet designs that I 25 wish-to address is safety systems.

This topic is perhaps the l

e

32 1

most difficult area of comparison but also is an area that-is f

i 2

likely to yield the most useful applications to our industry.

3 Soviet nuclear power plant safety systems will be difficult to analyze, not because of a lack of Soviet papers 4

5 on the subject but because we believe that the description of 6

a safety system in Soviet literature does not necessarily mean 7

the system described is, in fact, installed, tested and 8

available to perform its design function on each Soviet 9

reactor.

10 We understand that a Soviet design may call for 11 three emergency diesels where in fact the plant may operate 12 before the third diesel is delivered to the site.

We think 13 that the Soviet paper that describes the safety value of 14 adding a turbine-driven auxiliary feedwater pump may be 15 describing a desired feature that is not yet installed despite 16 the implication that it is part of the design.

17 We also question whether tests or computer analyses 18 of various modes of degraded heat transfer inside pressure l

19 tubes were part of the design process or were conducted later j

20 to study the effects of accidents not originally considered or 21 to study the details and ramifications of flow and heat 22 transfer instabilities observed during actual operations.

23 I bring up the above points not as a criticism of 24 Soviet safety systems but as a caution against conclusions 25 that can be drawn from Soviet literature that may later prove

33 1

to be unwarranted extrapolation.

(

2 We have studied the available literature on RBMK 3

safety systems.

Soviet emergency core cooling systems and 4

modern RBMX designs appear to be similar to Western approaches 5

but appear to lack the degree of redundancy and diversity we 6

have provided in our modern LWRs.

7 For example, we believe that Soviet RBMKs lack the capability to' inject make-up water for post scram decay heat 8

9 removal in the event of a station blackout.

This capability 10 typically is provided on U.S. PWRs by a turbine-drivea 11 auxillary feedwater pump and on U.S.

BWRs by a turbine-driven 12 high pressure coolant injection pump or a high pressure core 13 spray pump as well as a smaller turbine-driven reactor core

\\

14 isolation cooling pump.

15 We also have concluded that Soviet designs don't 16 address the full scope of design basis accidents that we do in 17 the United States nor do they treat low probability high 18 consequence scenarios, accident mitigation and emergency 19 response in the detail we do.

20 Many of the accidents they do consider are unique to 21 Soviet designs such as individual channel blockage and many of 22 the accidents they don't appear to consider are within the 23 U.S. design basis such as earthquakes and missiles.

24 Finally, we think that U.S.

technical specifications 25 for reactor operation, limiting conditions of operation,

o 34 1

emergency procedures, realistic operator training and many 2

other operations related features that are important to 3

reactor safety in the United States may not receive the same 4

level of attention in the Soviet Union.

5 In both the operational safety area that Zack Pate 6

will be discussing and in the technical safety research area 7

that I have discussed, we view a U.S. industry that has reason 8

to be proud of its overall record of improvement since Three 9

Mile Island.

10 We have made major design operational and 11 institutional improvements since TMI to which all in this room 12 have contributed.

Although individual utilities and the NRC 13 have disagreed over prioritization and relative cost benefit 14 of some of these improvements, there is no doubt in our minds 15 that most of those improvements are justified and that safety 16 has been improved as a result of both regulatory actions an>i 17 industry initiatives.

18 I am confident that if we give appropriate credit to 19 the improvements of the last seven years as we search through 20 the lessons of Chernobyl for opportunities for further 21 improvement, we will find that most of the lessons have been 22 learned already and applied in the United States.

23 CHAIRMAN PALLADINO:

Thank you.

24 MR. LYONS:

Thank you, John.

Mr. Chairman, we would 25 not normally go into such detail at these meetings but I think i

O 35 1

in view of the situation it is important that we cover such 2

detail and I am sure that the general public will not be able 3

to grasp the differences but it is important, I think, to the 4

people in this room and the Commissioners to know the things 5

that we are trying to learn by the accident.

6 Now I would like to call on Zack Pate, president of 7

Institute of Nuclear Power Operations.

8 MR. PATE:

Mr. Chairman and Commissioners, it would 9

be difficult to provide the Commission with an adequate 10 update on just one of INPO's programs in the ten minutes that 11 I will take so instead I will just cover a few key highlights 12 of three of our technical programs.

13 over the past five years we have acquired just over 14 400 permanent full-time employees working out of Atlanta.

I 15 can report to you with confidence and pride that our personnel 16 have great dedication to our mission and it is pleasing to us 17 to be able to realize today that our mission is widely known 18 and well understood.

19 In addition to the 400 permanent personnel that we i

j 20 have and equally important, we expand or as we say leverage 1

21 our resources by calling on many talented people from 22 throughout the industry.

Just as examples, we have 23 international liaison engineers from 13 countries that 24 participate with INPO.

I 25 We call on senior reactor operators from reactor

a 36 1

plants all over the country.

We call on corporate executives 2

from throughout the U.S. industry and we are now calling on 3

maintenance peer evaluators in a program that we described to 4

the Commission in our last briefing.

5 of course, in training and accreditation we utilize 6

people with training expertise to support the accreditation 7

effort.

These personnel are hand picked by their utility or 8

by us and we now have over 500 such personnel involved with us 9

on a week-by-week and month-by-month basis.

10 At the present time the largest number of these 11 people are involved in the board of accreditation and the 12 national academy for nuclear training and I will comment more

/

13 on that in a moment.

k.

m 14 Today our technical programs are basically mature 15 and well defined and our efforts focus on refinements to those 16 programs.

We get feedback on methods that we can use to 17 improve the technical programs through many avenues.

Let me 18 just list some of those, the 500 peer evaluators are a 19 valuable resource.

Of course, when they interact with us in 20 an accreditation visit or an evaluation visit, they express 21 their opinion and tell us where they think we can improve our 22 approach.

23 The formalized industry review groups that review 24 the activities of each of INPO's technical divisions are a 25 major resource.

Through NUMARC, senior nuclear executives i

37 1

from throughout the industry have taken a greater interest in r

2 INPO's activities and are quick to point out refinements that 3

will help us carry out our mission.

4 We receive good feedback routinely from the Nuclear 5

Regulatory Commission.

I could give you a long list of 6

program refinements we have made in response to 7

recommendations from your staff.

At the present time, for 8

example, we are adding three new criteria to the accreditation 9

process in response to a recent letter from Mr. Harold Denton.

10 Our advisory council, people from outside the 11 industry, bring a broad perspective to what we do.

Tom 12 Pickford, a member of the Kemeny Commission, is the chairman

{

13 of our council and has been for several years.

14 It is through Tom's recommendation that we added 15 diagnostic training to accreditation as a meaningful and 16 integral part of that program a couple of years ago.

Our 17 accrediting board brings in many others from outside the 18 industry with additional backgrounds.

19 Mr. Ed Carroll who has briefed this Commission and i

20 who is a retired vice-president from United Airlines, Director

~21 of Flight Standards, is a person who first recommended that we 22 add team training to the accreditation program and make that 23 activity a part of the national academy, and of course, our 24 own staff and our board of directors and our board of 25 directors brings me to the next area.

o 38 1

Before I discuss support of IPPO for a brief moment, 2

I can say that with all the feedback we get and all the 3

recommendations for refinement it is truly rare today that 4

someone in the industry recommends that INPO back away from 5

one of its criteria or weaken one of its criteria that is 6

aimed at promoting safety.

7 That has been one of the most encouraging and 8

satisfying parts of my work at INPO.

9 The support of INPO by the industry has been superb 10 from day one.

Our board of directors, dedicated chief 11 executive officers, give us a lot of attention and a lot of 12 time.

I can't say that they give us everything we ask for.

(

13

_They certainly don't.

But they have given us the resources 14 and they have met every reasonable request.

15 Their meetings, for example, typically last four 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> and I.know that is uncommon for meetings of boards of 17 directors.

NRC has supported and encouraged our work 18 throughout this past six years.

We have enjoyed good support 19 from the Department of Energy.

20 For example, the Department of Energy funded much of 21 the early work in job and task analysis that laid the 22 foundation for accreditation.

23 I think the importance of our role is today well 24 recognized and accepted and supported.

At the same time we 25 can only be complimentary to the vitally important and

39 1

essential role of the Nuclear Regulatory Commission in the 2

same area of INPO's activities.

3 The brief highlights of our technical programs that 4

I said I would cover, first, training and accreditation and 5

the national academy.

We all know that training can make the 6

difference between adequate and superior performance.

The 7

Commission is well aware that we set out and made a commitment 8

to the Commission and to ourselves to have ten training 9

programs accredited at each of the 61 stations that were in 10 operation by the end of 1984, to have those ten programs ready 11 for accreditation by the end of this year.

12 Ten programs at 61 stations is 610 training programs

{

13 throughout the country and I am pleased to report to you today 14 that we have 437 SALP evaluation reports in hand from our 15 member utilities as of yesterday and we are optimistic, quite 16 optimistic, that we will have all 610 by the end of the year.

17 One hundred seventy programs have been fully 18 accredited by the accrediting board at 37 sites.

19 In the time allowed I simply can't describe the 20 resources and hard work that are going on throughout the 21 industry and, of course, at INPO in support of accreditation 22 and in support of meeting our commitment to ourselves and to 23 you.

24 I believe we will meet that commitment and I believe 25 achieving accreditation of every training program will be one

40 1-of industry's finest achievements.

It certainly will be for 2

us a*.a I can't think of a more fitting area than in training 3

of the personnel that operate our plants.

4 To support these activities and to integrate them in 5

a common basis, we formed the national academy for nuclear 6

training this past September and as I think you are well 7

aware the academy consists of three parts; the extensive 8

training facilities and activities at each individual utility, 9

the overall management by INPO, and the activities of the 10 National Nuclear Accrediting Board.

11 These training activities and the recognition that 12 the National Academy affords, we believe strengthens the pride 13 and professionalism of the operators and we fully believe that 14 those are two very important ingredients to the superior 15 performance that we are all trying to achieve.

16 A quick highlight of the operating experience 17 program and John Taylor mentioned this briefly and mentioned 18 that NSAC was instrumental in the development of the SEE-IN 19 program, the Significant Event Evaluation and Information 20 Network and also the Nuclear Network Telecommunications 21 Systems that is utilized by all the U.S.

industries and by the i

22 13 international participants as well.

23 A third program that we have added is the nuclear 24 plant reliability data system to report component failures.

I 25 think it is fair to say that the operating experience exchange

41 1

in the industry today represents a landmark success, that we r

2 have met the Kemeny Commission recommendation to exchange 3

avant information among all utilities and to provide a world 4

wide telecommunications network that allows us to quickly 5

report events from plants around the world.

6 To further strengthen this activity, we began a 7

special program just this past month which we will look at ten 8

random utilities, ten random nuclear stations, to see that the 9

recommendations made early in the SEE-IN program, even back in 10 the days when NSAC owned the program, to see that we have 11 achieved a sustained lasting implementation of the 12 improvements that those early lessons learned, those early 13 events call f,or.

[

14 After we have reviewed the programs at ten stations 15 and get a good sense of just how well and how successful we 16 have been in achieving sustained implementation, we will seek 17 to modify and strengthen our program and we plan to exchange 18 that information with the NRC staff.

19 The last area, performance indicators, beginning in 20 1981, INPO has been working to develop and define a set of 21 performance indicators that give us a good sense of how 22 nuclear plants are doing.

23 He have looked'at over 60 areas of specific 24 indicators and settled on a list at the present time of 33.

25 We have made the statement and it has been widely examined and

)

42 1

acclaimed that a plant that is well managed overall can be 2

expected to have higher availability, lower forced outages, 3

fewer scrams, lower personnel exposures and so forth for the 4

other overall indicators and as a consequence of that good 5

management overall, the plants on the average can be expected 6

to have a higher margin of safety.

7 With that in mind, just a little over a year ago we 8

formed three ad hoc groups within and outside the industry to 9

select the best set of overall performance indicators and we 10 settled on ten and those are now being widely used and 11 reported in the industry.

12 The most recent INPO annual report received wide

{

13 distribution and copies were furnished to the Commission and 14 to the Commissioners and shows the tabulation of seven of 15 those ten overall indicators and shows three others.

I think 16 it is fair to say that that annual report shows demonstrable 17 and significant industry-wide progress over the past five 18 years as measured by these indicators.

19 We are updating that information in an easy-to-use 20 folder and the further refinement of some of the data for 1985 21 shows even further improvement than our annual report and we 22 Will furnish that information to the Commission.

23 As a part of this program each utility has now set 24 goals in most of these ten performance indicator areas for 25 1990.

Of course, each utility will set goals i' the 4

43 1

intervening years.

They have already set them for 1986 and 2

use the information that INPO provides on progress in meeting 3

those goals and the success of other utilities in meeting 4

those goals is benchmarks against which to measure their own 5

performance.

6 That is competition in the best American sense and 7

we believe it will pay dividends for the industry over the 8

coming years and we are already seeing the benefits of that.

9 Those have just been brief highlights to keep within my time 10 constraint and I appreciate the opportunity.

11 CHAIRMAN PALLADINO:

All right.

Thank you.

1 12 MR. LYONS:

Thank you.

Wally Behnke is chairman of

(

13 the AIF Policy Committee and Vice President of Commonwealth r

J 14 Edison.. Wally.

15 MR. BEHNKE:

Thank you very much, Don.

Gentlemen, 16 it is my pleasure to join this group today and talk briefly 17 about the activities of the AIF policy committee on nuclear 18 regulation.

19 As you may recall the role of this committee is to 20 coordinate the network of industry committees, owners groups 21 and trade associations with respect to their activities 22 concerning generic improvements in the nuclear licensing and 23 regulation process.

i 24 The policy committee is keeping itself currently 25 informed about the accident at Chernobyl as the facts l

i

o 44 1

concerning this event ard becoming available.

In this regard, 2

we were especially pleased to have Mr. Harold Denton, your 3

director of Nuclear Reactor Regulation, brief our committee on 4

.the accident at our meeting on May 12th and I must say that 5

his presentation was most helpful in broadening our 6

understanding of that tragic event.

7 In our view, it would be premature to rush to 8

judgment on the accident but several conclusions can be drawn 9

it seems to us from the information at hand.

First, as has 10 been described here by my colleagues, there can be little 11 doubt that the 1979 accident at Three Mile Island underscored 12 the importance of our defense-in-depth design philosophy as 13

(

well as the strict adherence to the highest standards of 14 nuclear safety in all aspects of nuclear power plant design 15 construction and operation.

16 As also has been recounted here, the accident did 17 result in aggressive steps being taken both by the industry l

18 and by the Commission to improve the overall performance 19 particularly as it relates to safety.

20 It seems to us that taken together these factors i

21 provide a strong and solid basis for confidence in the safety 22 of civilian nuclear power in the United States.

Adding 23 further to this basis of confidence is the recently completed 24 comprehensive probabilistic risk assessment of potential 25 severe accident sequences of typical light water reactor i

L.

o 45 1

plants sponsored by the industry f'unded IDCOR project.

2 Secondly, as Mr. Taylor has so well described there 3

are fundamental differences between the Chernobyl reactors and 4

those in the United States particularly as regard to the 5

engineering safeguard features as well as our regulatory 6

approach.

7 At this point it is unclear what if any lessons 8

from the Chernobyl event will have application for the 9

management and regulation of civilian nuclear power in this 10 country.

11 From what we have learned to date concerning the 12 accident, we see nothing about the event that undermines the

[

13 basic confidence in the safety of nuclear power in the 14 U.S. and by the same token, we have detected nothing about 15 the accident that at this point calls for any significant 16 change in the design and procedural requirements now in place.

17 We will, of course, seek to learn all we can about 18 the event and will remain sensitive for the lessons applicable 19 to the situation here.

20 While Chernobyl is important for a variety of 21 reasons, the event should not be allowed to side track the 22 ongoing efforts to improve the regulatory process.

For 23 example, implementation of the Commission's backfitting rule 24 will enable both the NRC and the licensees to focus their, 25 resources on safety in a more constructive manner.

46 1

The systematic analysis called for'in the rule will

?

2 help to minimize unproductive expenditures of resources and 3

time on proposals that promise only marginal improvements.

4 Finalization of the Commission's policy statement on 5

safety goals will be another important step in this direction 6

and the policy statement should also help to put the Chernobyl 7

accident into even sharper perspective.

8 It seems to us that Chernobyl also gives greater 9

urgency to timely updating of the source terms used in the 1

10 regulatory process so as to reflect the new data from TMI and 11 the subsequent research because this will provide a more 12 realistic assessment of the potential releases from 13 U.S. plants.

14 We concur with the Commission's deliberate and 15 thorough approach to assuring that a sound scientific basis is 16 established for the changes dictated by the new s :lence and 17 urge that this matter continue to receive your priority 18 attention.

19 To the extent that Chernobyl can contribute to the 20 scientific basis on which decisions are made, it should, of 21 course, be considered.

On the other hand, it would be 22 unfortunate to needlessly delay finalization of NUREG-0956 and 23 publication for comment of UUREG-1150.

24 Looking ahead, our committee plans to move on with 25 the job of urging improvements, still further improvement in

47 1

the regulatory process.

We will continue to learn what we can

(*

2 from Chernobyl but our priorities will remain unchanged.

3 Our highest priority is, of course, for the ongoing 4

safe, reliable and cost effective operation of the plants now 5

licensed for service.

6 Our second priority is for timely completion and 7

start-up of the plants currently under construction and finally, we will continue to work for lifting the regulatory 8

9 barriers to further deployment of nuclear power in this 10 country that we will surely need in the decades ahead.

11 Thank you very much.

12 MR. LYONS:

Thank you, Wally.

Our last 13 representative is Warren Owen, vice chairman of NUMARC and s

14 Executive Vice President of Duke Power Company.

Warren.

15 MR. OWEN:

Don, thank you.

Good morning.

The 16 earlier speakers have already described some of the 17 significant progress that has been made by our industry since 18 TMI.

Much has been accomplished but there is much still to be 19 done.

20 NUMARC, the utility management and resources 21 committee was created by the 55 nuclear utilities in.this 22 country to assist us in a pursuit of excellence in the 23 operation and management of our nuclear power plants.

24 NUMARC has met with this Commission frequently over 25 the past two years and you have been handed a copy of my

48 1

remarks so I do not intend to cover that.

I want to make only' 2

a few brief remarks before I turn it back over to Don so we 3

will have some time for discussion.

4 NUMARC was formed in 1984.

In essence, NUMARC was 5

and continues to be an experiment intended to provide an 6

effective alternative to regulation as we have known it in the 7

past at least for some of the tough issues facing nuclear 8

utility management today.

9 This experiment is intended to help you and us focus 10 the regulatory efforts in a way that is complimentary to the 11 industry initiatives for excellence without in any way 12 compromising your obligations and responsibilities.

(

13 The copy of my remarks provided to you identify in 14 some detail several of the utility efforts undertaken ~through 15 NUMARC.

Rather than read through that, let me summarize my 16 view of the results of our efforts to date.

17 The utilities through NUMARC over the past two years 18 made a number of commitments intended to provide this 19 alternative form of regulation.

You accepted our pledge to do 20 these things and we have met those commitments and with this 21 approach, in my view, improvements have been realized much 22 quicker than they we d have been through the traditional 23 regulatory approach.

24 The experiment seems to be working and we all thank 25 you for the opportunity to truly seek excellence in all

49 1

aspects of our operations.

2 There has been and will continue to be close 3

coordination of NUMARC efforts with AIF, EEI, EPRI, the owners 4

group and others.

5 The handout highlights many of the key industry 6

initiatives of NUMARC and INPO.

Time does not permit us to 7

discuss the many other initiatives ongoing by individual 8

utilities, owners groups, professional societies and industry 9

organizations but it is evident they contribute greatly to the 10 overall safety and reliability of our plants.

11 Through NUMARC, INPO and othnr industry initiatives 12 communication on key issues has been improved among utility

(

13 managers and with you and the NRC staff.

14 In my view, we have made significant prog.uss in 15 this two-year period.

We now have an opportunity for even 16 greater progress in the future provided we can communicate 17 with each other and a completely open and professional manner 18 with the realization that we have a common goal of safe and 19 reliable operation of our plants.

20 I am sure everyone at this table joins me in a 21 pledge to seek ways to continue this enlightened, positive and 22 progressive approach as we work together to improve the 23 operation of our plants.

24 Thank you.

25 MR. LYONS:

Thank you, Warren.

Mr. Chairman, that

50 1

completes the presentation so we would like to open up to

,/

2 questions if you would like to do that.

3 (At this point in the proceedings, commissioner 4

Roberts exited the meeting.)

5 CHAIRMAN PALLADINO:

Well, thank you very much.

I 6

have a couple of observations I would like to make and then I 7

would like to pose two questions to open up the discussion.

8 one, I think we have achieved a new milestone this 9

morning.

We have had the Commission sitting here for an hour 10 and ten minutes and not interrupting the presentation.

11 (Laughter.)

12 CHAIRMAN PALLADINO:

We do very much appreciate your

{

13 input.

It is gratifying to have the accomplishments of the 14 Commission recognized and particularly the importance and I 15 think the credit goes to the totality of the Commission 16 including the staff and the Commissioners themselves.

17 I do appreciate your best wishes and I am sure that 18 I will remain active some way or another in nuclear safety 19 because I have lived with it for a long time.

20 You covered a number of areas for the future and I 21 am not going to try to summarize them but there was one that 22 either maybe I missed or wasn't mentioned as strongly as it i

23 should have been and that is the need for attention to 24 maintenance problems and the whole area of maintenance in the 25 nuclear industry including components and systems.

1

51 1

(At this point in the proceedings, Commissioner

(

2 Roberts re-entered the Commission meeting.)

3 CHAIRMAN PALLADINO:

Let me talk briefly about the 4

Chernobyl reactor accident and our reaction to it.

I 5

certainly believe and I know you believe that this is an 6

accident to which we have to give a great deal of attention.

7 It is a very sobering experience and one from which we must 8

learn as you indicated.

9 However, I think we must now become complacent 10 because we note the differences between our reactors and the 11 Russian reactor that was in the accident.

I note that a great 12 deal of attention is given both by us and the industry and

{

by other people on the differences between these reactors but 13 14 there may be generic implications that we want to make sure we 15 don't overlook.

16 For example, we can't eliminate based on the 17 information we have to de.te scenarios that involve fire of 18 cables or distribution syster.s and it focuses importance on fire protection in our own plants and that particularly 19 20 relates to cables and control systems and to alternate shut 21 down systems and I think as we get information we should look 22 to some of these generic areas as possible areas in which we 23 can learn some lessons.

24 But meanwhile, let me take this opportunity to 25 emphasize the importance of accelerating the completion of the

52 1

remaining work on fire protection and alternate shut down

[

2 systems.

3 Now let me go to my two questions.

The first 4

question really relates to the comment I just made about 5

learning from the Chernobyl reactor accident.

Sherwood did 6

mention that the utility nuclear power oversight committee was going to look at the accident but I was wondering whether you 7

8 had yet thought about looking at the various areas in which 9

you might want to develop your analysis, evaluation and 10 knowledge base and also whether there was going to be any 11 other organization that is going to focus on the studies that 12 are needed.

4

{

John Taylor mentioned about the work that they are 13 14 doing and I was wondering whether any coordinating body other 15 than this utility oversight committee was going to be 16 instituted?

17 MR. SMITH:

The utility oversight committee has 18 established a technical review committee to bring together all 19 of the relevant information that we can learn from Chernobyl 20 which will be chaired by Byron Lee, executive vice president 21 of Commonwealth Edison and he will be working with staff from 22 the AIF technical personnel and will be working with the NSAC 23 staff from EPRI.

24 Much of the initial analysis, of course, will be i

25 done by NSAC has Mr. Taylor has also reviewed on behalf of

__.,__- __-_-,. -~

w r-eer---

" - ' ' ~ * ' * ~ - - ' ' " " - ' ~ ~ ' ' ~ ' ' ~

53 1

EPRI.

As we move further into the process of gathering the l'

2 information and completing it, we feel that different 3

constituent organizations such as INPO insofar as management 4

systems and training are concerned, NUMARC insofar as the 5

matters that Mr. Warren Owen mentioned will perhaps be 6

involved and we feel that the constituent existing 7

organizations that we have now do have the capability to fully 8

and effectively analyze all the information that indeed we 9

must and shall analyze and to take the appropriate response 10 and we intend to keep the Commission, of course, informed as 1

well as Congress and other bodies of government and the public 12 at large.

I 13 CHAIRMAN PALLADINO:

Has that technical task force

\\_

2 14 been created yet?

15 MR. SMITH:

As I said, the technical review 16 committee will be chaired by Byron Lee and we are in the 17 process now of assembling the appropriate personnel and 18 assigning the responsibilities for that work.

19 CHAIRMAN PALLADINO:

Yes.

I think it would be good 20 for them to think ahead to make sure that all aspects of the 21 accident are being looked at and evaluated.

I know there are 22 always shortcomings in trying to do that but by looking ahead, 23 you may be able to identify an area in which you want to get 24 additional information while the information is still 25 available, i

I

--e.., --, -.

54 1

MR. SMITH:

Yes.

Thank you.

2 MR. ONEN:

I can assure you it is started.

I had a 3

long telephone conversation with Byron Lee Sunday afternoon!

4 concerning a list of things just along the lines that you have 5

suggested.

6 CHAIRMAN PALLADINO:

All right.

7 MR. PATE:

To give you an indication of the 8

importance we attach to the technical review comnittee that 9

Sherwood Smith describes, Mr. Chairman, we have assigned Bill 10 Conway who is a member of the INPO staff and who, I think, the 11 Commission recalls was some years ago plant manager at Vermont 12 Yankee and later chief executive officer at Vermont Yankee, he

/

13 will call on our other resources but Bill will be our

(

14 interface with that committee and we attach that kind of 15 importance to it, top priority.

16 (At this point in the proceedings, Commissioner 17 Bernthal exited the Commission meeting.)

r 18 CHAIRMAN PALLADINO:

All right.

Let me turn to my 19 second question and I am turning from Byron Lee to Bill Lee if 20 I may quote Bill.

Bill says that we are all in the same boat 21 and we are captive to the weakest member in that boat and he 22 was referring to the fact that_we have to give attention to 23 all the utilities that own reactors 'ecause an accident at any b

24 one of them can have an extensive impact on everybody else.

l 25 I wac wondering if you had any ideas or e

s 4

e

~'

- =.

o 55 1

recommendations and if you don't let me try to stimulate some g

2 attention to it, any recommendations on dealing with problem 3

plants where either INPO finds things that don't seem to be 4

going well or we find them.

5 We have certain things that we can do but the things 6

we can do are sort of punitive in a sense, either you shape up 7

or we do this, that or the other thing.

Whereas, I think the l

8 industry has the opportunity to say, " Hey, look, you guys, we 9

are all in the same boat and if you don't shape up, we are 10 going to suffer the consequences."

11 I would be interested in any idcas or comments or 12 work that is going on with regard to recommendations for 13 dealing with problem plants.

14 (At this point in the proceedings, Commissioner 15 Bernthal re-entered the Commission meeting.)

16 MR. PATE:

Mr. Chairman, that is a matter of great 17 interest and ongoing attention by the Institute of Nuclear 18 Power Operations.

I probably spend, in fact I know I spend 19 more personal time worrying about and taking action on matters 20 that relate to the question you pose than any other activity 21 and as a part of our evaluation process we systematically identify nuclear stations that are not performing to industry 22 23 standards or to our standards and we deal with that in a very direct way with the top management in the company and 24 75 specifically with the chief executive officer in the company a

r

56 1

when the standards are not being met.

r' 2

If necessary, we go to the board of directors of the 3

company to bring about the change and management direction and 4

control that is so important, the management involvement that 5

is so essential to the proper operation of these plants.

That 6

is an ongoing thing for us.

7 In many cases we cooperate and coordinate with your 8

staff in both the identification and nhe resolution of that 9

kind of problem.

I think your staff would agree with me or 10 the senior members of your staff would agree with me that that 11 is one of the most difficult challenges that we both face in 12 first of all identifying the plant that really does need that

{

kind of help and that kind of turnaround and then helping 13 14 them achieve it.

15 As you know we keep the activities that we carry out 16 in that arena confidential expect for selected discussions 17 with key members of your staff.

18 CHAIRMAN PALLADINO:

You did mention performance 19 indicators as a way of finding out where the problem plants 20 are and I appreciate your efforts in trying to work with the 21 utilities to bring them around but I find quite a bit of t

22 difference between the attitude a lagging utility has before 23 it has an incident and then after it has had an incident and 24 it recognizes that maybe they had a bit of good luck in 25 surviving it as well as they do.

57 1

What we need to do is see if we can't get action to

(

2 take correction or make corrections before they lead to an 3

incident.

I know it is one that we always have to face in 4

responding to Congress any time an incident occurs and if we 5

have had some precursor information and didn't follow through 6

on it, we are subject to great criticism and I think 7

appropriately so.

8 So I would encourage development of any specific 9

approaches that can be taken in bringing the weaker utilities 10 along and getting them up to the standard of excellence that I 11 know you are all striving for.

12 MR. PATE:

Mr. Chairman, I can assure you that we

(

13 have assigned the very highest of priority to that.

I know 14 that in some ways people view 1985 as not our best year in 15 consideration of the somewhat institutional problems that we 16 have seen at some utilities and in addition to the events that 17 we have seen.

18 I want to point out though that we keep track in a 19 systematic way of the significant events that occur throughout 20 the industry and as that summary in our annual report shows, 21 industry-wide we have seen an improvement in the number of 22 events that must be classified as significant per unit from a 23 number that ranged to 1.64 in 1981 down to 0.53 in 1985.

24 So I think there is overall progress but the 25 elinination of those events that tend to cause concern for all

58 1

of us is one of the primary goals that we have and that we

.?

2 share with your staff in identifying the plant that may be 3

headed for trouble.

4 MR. LYONS:

Mr. Chairman, may I also comment on your 5

observation that we did not specifically cover maintenance of 6

components or systems.

In the ten performance indicators that 7

Mr. Pate has discussed, the actual maintenance of systems and 8

components is considered and is part of the overall process of getting to that for reducing forced outages and improving 9

10 availability.

So maintenance is extremely critical to 11 achieving those objectives which are set and each utility puts 12 down as their own goals.

13 So while owe haven't covered it here today, it is at 14 the center of some of the things that INPO is also doing and 15 the individual utilities have to do to achieve those 16 objectives.

17 CHAIRMAN PALLADINO:

I should point out that I 18 don't think that we have any regulations really that deal with 19 maintenance.

It is a gap that is going to have to be 20 corrected some way or another.

It is an area where while we 21 are thinking about the problem industry initiative might bring 22 about resolution of questions so as to minimize the need for i

'3 any more regulation than that is absolutely necessary.

24 MR. OWEN:

Mr. Chairman, I know you recall at our l

25 last NUMARC meeting with you we spent a great deal of time

59 1

talking about our maintenance initiative.

I maybe should not r

2 have sloughed over my printed remarks here today but they are 3

covered in that.

4 I would just say that since then we have started to 5

achieve many of those things that we talked about at that 6

meeting.

We are now supplying peer evaluators that accompany 7

the INPO program evaluation teams that concentrate on 8

maintenance.

Many of the kinds of things that we worked out 9

with you staff now are underway and I think will produce 10 results.

11 MR. TAYLOR:

May I add just a word or two about our 12 own efforts.

I did mention in the testimony that in our 13

{

response to Three Mile Island we entered into a work which 14 would improve the human factors in maintenance as well as 15 operation.

16 In addition to that, we have established at the

~

17 non-destructive evaluation center in Charlotte a maintenance 18 equipment application center which permits the utilities and 19 the contractors and ourselves to feel and prove out improved maintenance tooling and provide training for people to use 20 i

21 those techniques before they go into the power plant-22 themselves.

23 Recently, just six months ago, our board upped our 24 maintenance R&D program to a major project status and we are l

25 developing a substantial effort looking very carefully at the L

60 1

work that has been done by the French and the Japanese in r

2 particular to see that every bit of their experience and 3

elements of their success are applied.

4 So that represents for us a very major priority 5

effort.

6 MR. SMITH:

Mr. Chairman, on that point, I think the 7

Commission's effort and interest in maintenance is certainly 8

well founded and there should be recognition given to what the 9

Commission has already initiated in terms of the pilot studies 10 of maintenance programs at several plants.

11 One of our plants has participated in the pilot 12 study and we are quite pleased to be involved in it.

We think 13 the study is useful.

We think that the results highlighted 14 good practices and also areas for increased attention and I 15 think the record should show that this step on the part of the 16 Commission is appropriate in the area of maintenance and from 17 all of these efforts, I think that it will be possible for the 18 industry to place improved and increased emphasis on 19 maintenance and that is going to lead to the overall 20 improvement in safety and reliability.

21 CHAIRMAN PALLADINO:

Well, I do think the training 22 for maintenance is a very important aspect of the whole 23 program.

Let me turn to my colleagues.

Tom, any questions?

24 MR. PATE:

If I could just make one kind of summary 25 comment on maintenance.

In coordination with NUMARC and with i

61 1

EPRI we put together a comprehensive maintenance action plan I

2 including a description of activities that were ongoing before

+

3 we did this which coordinated that activity very closely with 4

your staff.

5 I think it is fair to say that the Commission and 6

the staffs interest in maintenance was instrumental if not the 7

catalyst that brought us to integrate all those activities and 8

to lay out an action plan for the future.

9 It is comprehensive and we would be pleased to 10 furnish the Commissioners a copy of that.

I think you would 11 be pleased with what you see.

12 CHAIRMAN PALLADINO:

All right.

Yes.

We would like 13 to get that.

We would appreciate that.

Tom, any questions?

14 COMMISSIONER ROBERTS:

No.

15 CHAIRMAN PALLADINO:

Fred.

16 COMMISSIONER BERNTHAL:

Yes.

I would just like to 17 make a few comments and maybe ask at least one question.

18 First of all, I would note that yesterday the Commission 19 licensed another power plant.

I don't know whether it is the 20 99th or the 100th or 101st but a reporter came up to me 21 afterwards and asked me whether there was any significance to 22 that action in light of the Chernobyl incident.

23 I said that I didn't think there was except that I i

24 thought it was appropriate that it was a plant that is run by 25 Duke Power Company, Warren, because Duke has a strong record

62 1

and a record of being one of the most capable of the utilities

'~

2 in this business and I think most of us at this table would 1

3 agree often provides some of the easier decisions that we are 4

faced with when it comes to licensing time.

5 I am pleased to note by the way and I trust your 6

public utility commission might note that you are also a 7

frugal company, Warren.

You are the only one that gave us a 8

statement on two sides of the paper today.

9 (Laughter.)

10 COMMISSIONER BERNTHAL:

I just wanted to comment on 11 some of the statements that were made here.

First of all, 12 Mr. Lyons, I think that what you were referring to at one

(

point when you commented on the need to resolve and dispose of 13 14 certain issues here that tend to hang out before the public as 15 unresolved safety issues was the fact that it is those 16 unresolved safety issues that we do need to clear up.

i 17 The public often does not understand that an 18 unresolved safety issue does not mean that a plant is unsafe.

19' It means that there is something that we don't know yet in 20 entirety about a plant but I.couldn't agree with you more that 21 both for the sake of public understanding and also for the 22 sake of Congressional understanding that we need to get more 23 systematic, I think, in the way we approach those problems and 24 probably in the way we ask for funding from the Congress to i

25 resolve those problems.

1

63 1

John, John Taylor, that was an outstanding and 2

excellent summary of the differences between the charnobyl 3

graphite moderated type reactor and the typical U.S. LWR.

I 4

would hope that the press would take note of your comments and 5

make full use of your comments.

They are written down.

They 6

are a matter of record.

7 I have to say I wish we had something that was as 8

thorough and as cautious where it needs to be but as thorough 9

and detailed as you gave us.

That was just outstanding and I 10 hope that it gets wide use and dissemination.

11 One of the points that I would emphasize that you 12 alluded-to in your statement today that came up in our public

(

13 briefing by our own staff a couple of days ago and frankly 14 still sonewhat surprises me and I am reserving a degree of 15 skepticism to tell you the truth is the point that as far as i

16 we know, there was none of the pressure boundary on top of 17 the reactor itself that apparently we have in this country, 18 that apparently those are biological shields, normal seals, 19 for operational purposes and I gather that though you may be 20 reserving judgment on that as am I, that appears to be the 21 case.

Is that the way you understand it?

22 MR. TAYLOR:

As best we know at this time, Fred.

We 23 have poured over the drawings that we have available which 24 tend to be primarily the original Leningrad design and we have l

25 talked to peopi, who have been at least involved in some

=._-__

64 1

elements of it and that is the picture we are given.

,e 2

We are not sure.

We are going to continue to probe 3

as hard as we can to get all of the facts.

4 COMMISSIONER BERNTHAL:

I agree.

I am not sure yet 5

either.

I was surprised to learn that and again would 6

emphasize that if that is indeed the case I am sure the 7

Soviets had their reasons for whatever compromises they may 8

have made there but that would be simply a major and 9

significant difference, I think beyond any question in 10 containment concept quite aside from the issue of 1,000 or 11 2,000-odd penetrations into the core region.

12 MR. TAYLOR:

The difficulty of providing a true

{

pressure boundary for that wide expanse in that lay-out is 13 14 very evident and further, as I mentioned, the steam drums are 15 definitely outside the pressure boundary which would violate 16 our criteria.

17 COMMISSIONER BERNTHAL:

Would you care to comment 18 also, I did have one question related to that, you spoke about 19 the design and the intent of both their systems and ours to 20 cope with what we tend to call design basis accidents that 21 very often involve the classical large pipe break or.small 22 pipe breah, the many things that you know more about than I 23 do.

24 But I think it may be worth a comment or two if you 25 are prepared to make comment on what happens when you are

65 1

beyond the design basis because clearly that accident there 2

was far beyond the design basis and I think Three Mile Island 3

was beyond wht: we anticipated when we designed plants.

4 But then it becomes a question of how you cope with 5

accidents beyond the design basis.

Maybe you could comment a 6

little bit on that.

7 MR. TAYLOR:

Yes, sir.

Fred, as you know, the 8

entire thrust of the source term program, our research to 9

understand all the ptenomenon in the IDCOR analysis is to 10 evaluate the circumstances if you get beyond the design basis 11 and what that means in terms of the characteristics of 12 our system, relative weaknesses, relative strengths and the

(

ultimate impact on public risk.

13 14 As you know, we have been very encouraged at the 15 results that have been generated since the Three Mile Island 16 again which directed our attention in two ways.

17 One, it made it more apparent that such a beyond 18 design basis event could occur and was worth more careful and 19 thorough study and secondly, carrying out that work to see if l

20 we could verify the finding from Three Mile Island that the 21 amount of material that was airborne, radioactive material 22-airborne, literally was 1,000 times lower in that particular l

i 23 case to see if we could develop enough experimental and 24 analytical data to generate a more generic inclusion as to 25 what the potential for airborne contamination would be for a l

\\

0 66 1

wide variety of accidents and a wide variety of circumstances

('

2 over the envelope of our plants.

3 We are getting very encouraging results that 4

indicate that the material that can get out of these systems 5

even if we lose containment which did not happen at TMI-2 is 6

much less than we would previously have predicted and which is 7

built into our present regulation.

8 COI:MISSIONER BERNTHAL:

I appreciate that.

9 MR. TAYLOR:

We are unaware of this kind of work in 10 the Soviet Union but as I think we have mentioned, here is 11 scue extremely potentially important data that could be 12 obtained from that accident.

13 COMMISSIONER BERNTHAL:

No question about it.

k' 14 MR. TAYLOR:

We would love to be able to get our 15 hands on that.

16 COMMISSIONER BERNTHAL:

Yes.

Again, thanks for giving all of us a concise and authoritative summary on paper 17 18 that I think reflects the expertise that I found in your shop 19 when I visited EPRI not more than a couple of weeks ago.

I i

20 I couldn't agree more on the issue of source term 21 and wanted to refer for a moment, Wally, to some of your 22 comments.

23 (At this point in the proceedings, Commissioner 24 Roberts exited the Commission meeting.)

25 COMMISSIONER BERNTHAL:

It can't be stressed enough

67 l

1 1

how important I think it is to our source term knowledge, to

('"

2 the final resolution of many of these source term issues that i

1 l

3 finally now in a most unfortunate and tragic circumstance we 4

may very well have the limiting, the bounding case or the 5

worst case scenario here and I know that we all are 6

' anticipating that the Soviet Union will share that very 7

important data not only with us but with the rest of the 8

world.

9 It is just a crucially important body of data that 10 we hope to have made available.

11 Finally, I would just like to support what I think, 12 Joe, you have already commented on and some others here that

('

13 appears to be already an industry initiative, an initiative on 14 the part of all of you at this table to gather and collate and 15 analyze and address whatever substance we may learn from the 16 Chernobyl incident.

17 Whether that is done via is it UNpAC, I can't 18 remember all these acronyms anymore, or an IDCOR style effort, 19 collaborative effort, it doesn't particularly matter but I 20 would strongly encourage that you get ahead of the curve on 21 this.

22 It is much better for the industry to speak to these issues ahead cf time rather than having to explain things 23 24 after the fact.

25 I would also strongly support the comments that one

68 1

or two of you have made here about the utility of the

?

2 International Atomic Energy Agency serving at least as a 3

vehicle for this international sharing of information that we 4

all anticipate will occur in the wake of the Chernobyl 5

incident.

6 The IAEA has many important responsibilities not the 7

least of which or perhaps the greatest of which in fact is, of 8

course, their oversight of non-proliferation matters but they have a number of other functions and I would hope that 9

10 we might make use of that function as a vehicle by which we 11 can learn about that important accident.

12 With that, I think I will give our chairman-to-be a

(

13 chance here.

Go ahead.

14 CHAIRMAN PALLADINO:

Lando.

15 COMMISSIONER ZECH:

First of all, I think it is very 16 clear that everyone agrees that the Chernobyl incident was a 17 very, very serious one and we certainly must learn all the 18 facts about that very serious accident.

19 I agree that it is premature to take specif'ic l

20 actions but I do think that we should be very vigilant to t

21 learn any lessons we can and certainly there are lessons to be 22 learned from that incident.

23 I think we have to carefully review the facts when 24 we get them and analyze the information very, very carefully.

j 25 It was not only an extremely unfortunate situation but I agree l

,y

69 1

that it is something that we certainly have an obligation to 7-2 learn from and not only in our country but in all of the other 3

countries of the world involved in nuclear power.

4 (At this point in the proceedings, Commissioner 5

Roberts re-entered the Commission meeting.)

6 COMMISSIONER ZECH:

As far as your presentation this 7

morning is concerned, I think that it is important for us at 8

the NRC to be aware of what your technical review committee 9

will be coming up with and in that regard I think it is 10 important perhaps that your technical review committee 11 interface as much as they can with the IAEA and other 12 countries.

(

13 I think that is something that would be a s

14 responsible action.

15 As far as our country is concerned, I believe that 16 progress has been made in the past few years in the nuclear 17 power industry.

On the other hand, I don't think that having 18 visited a number of your facilities throughout the country 19 now, I don't think that we should become complacent.

20 My view is there is room for improvement in our own 21 operations.

I think we should continue our efforts towards 22 improved operations.

I agree with Bill Lee and Zack Pate and 13 others of you here this morning that would agree that there is 24 room for improvement.

25-I think we should concentrate on those plants that

70 1

while they may be meeting our minimum requirements, they are f

2 not performing as well as they can and they should.

Those are 3

the plants that I think INPO and other organizations can act 4

in a responsible manner to ensure that we do get improved 5

performance.

6 There is room for improvement and we should be 7

mindful of that and we should be acting in a professional and 8

responsible manner to get that improvement.

9 I think it is important this morning to see that 10 there is a significant cooperation and coordination among 11 industry and utility groups that you represent at the table 12 and others and I think that is important to recognize as so 13 many of you have that your own responsibilities and objectives 14 to achieve safe and reliable nuclear power operation.

15 So the collective, the willingness on industry and 16 utilities part to work together in very close cooperation, I 17 think, is significant.

18 I would like to point out the fact that NRC in my 19 view does indeed have responsibilities to regulate, provide 20 those regulations and requirements in order to provide 21 reasonable assurance that the public health and safety will be 22 protected.

23 Now the utilities, the industry also has 24 responsibilities to ensure that the public health and safety 25 will be protected.

Those responsibilities, of course, are a,

m,

-__n

71 1

for construction, maintenance, operation of your facilities.

.?

2 So we have a shared responsibility system in our country for 3

public health and safety.

4 We have regulatory responsibilities and you 5

essentially have operational responsibilities.

That means as 6

far as I am concerned that we should' work together with you as 7

closely as we can when it is appropriate with the one goal in 8

mind and that is our shared responsibilities for public health 9

and safety.

4 10 It does not help public health and safety or the 11 American citizens in my view that we do not work together.

It' 12 is important that we work together.

(

13 I think that NRC's relationship with the industry 14 should be one of encouraging excellence and improve 15 performance.

I think we should cooperate with the industry 16 and the utilities within our bounds of responsibility whenever 17 possible and I think we should when necessary demand 18 compliance with our regulations and again when necessary to 19 impose enforcement action if it is demanded.

20 As far as I am concerned, we at NRC, I am sure, all 21 of us, the Commission and the staff, intend to carry out our 22 responsibilities of public health and safety and we expect 23 you to carry out your responsibilities for public health and 24 safety.

1 25 In my view, we both can serve the American people by

72 1

working together whenever possible to carry out our joint

.f 2

responsibilities.

3 I think that is an important message that we should 4

all take from this table this morning.

We have joint 5

responsibilities.

We will better serve the American people in 6

my view if we work together keeping in mind that the public 7

health and safety is our business, ours and yours.

8 Thank you, Mr. Chairman.

9 CHAIRMAN PALLADINO:

Thank you.

We have a few more 10 minutes but that doesn't mean we have to use them.

11 COMMISSIONER ROBERTS:

We could set a precedent 12 here.

/

13 (Laughter.)

\\

14 CHAIRMAN PALLADINO:

But I don't want to thwart 15 any wish to comment.

16 MR. TAYLOR:

May I make one comment if I might, 17 Mr. Chairman.

Commissioner Zech's point, very important one 18 of the importance of an international communication and 19 cooperation in the evaluation of this accident.

I think the 20 accident itself has said that the movement toward an 21 international set of standards shared by the entire world in 22 nuclear power is something we have been working toward but we 23 have a ways to go yet and we should pursue it.

24 In terms of the immediate matters, we have good 25 relationship with the utilities overseas in the Free World and

73 1

we received before it was in the papers specific quantitative

/~

2 data on air and water radioactive concentrations in both 3

Sweden and Finland which at least got us moving on the 4

evaluation program.

5 Floyd Collar, the president of EPRI, is on the 6

technical advisory board of IAEA and as a result of that we 7

are able to communicate by phone with Blix and Rosen upon 8

their return from the Soviet Union and are maintaining that 9

close cooperation and along with Harold Denton, Wal Lowenstein 10 attended the CSNI meeting in Paris a week ago where the first 11 responses and evaluations of the OECD community were pursued.

12 My judgment is that it is through those contacts

/

13 that we are going to.get the information to do our evaluation 14 work and we will pursue them as hard as we can.

15 COMMISSIONER ZECH:

Very good.

16 CHAIRMAN PALLADINO:

Thank you.

Any other comments?

17 (No response.)

18 CHAIRMAN PALLADINO:

Well, we thank you very much 19 for taking the time to come and give us your thoughts and we 20 look forward to further progress in making sure that these 21 plants are operated safely and protect the public health and 22 safety and still serve the need for generating of electricity.

23 MR. LYONS:

Thank you, Mr. Chairman.

24 CHAIRMAN PALLADINO:

Thank you.

We stand adjourned.

25 (Whereupon, the above-entitled Commission meeting

74 1

was adjourned at 11:18 o' clock a.m.,

to reconvene at the Call

.f 2

of the Chair.)

3 4

5 6

7 8

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

1

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2 REPORTER'S CERTIFICATE 3

4 This is to certify that the attached events of a 5

meeting of the U.S. Nuclear Regulatory Commission entitled:

6 7

TITLE OF MEETING: Briefing by AIF on State of the Industry (Public Meeting) 8 PLACE OF MEETING:

Washington, D.C.

9 DATE OF MEETING: Thursday, May 15, 1986 10 11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the Commission taken 13 stenographically by me, thereafter reduced to typewriting by 14 me or under the direction of the court reporting company, and 15 that the transcript is a true and accurate record of the 16 foregoing events.

17

,b' 18 Ann Riley 20 21 22 Ann Riley & Associates, Ltd.

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24 25

5/15/86 SCHEDULING NOTES i

'ITLE:

BRIEFING BY AIF ON STATE OF THE INDUSTRY s

SCHEDULED:

9:30 A.M., THURSDAY, MAY 15, 1986 (OPEN)

DURATION:

APPROX 2 HRS AGENDA:

  • STATE OF THE NUCLEAR INDUSTRY DONALD E. LYONS, CHAIRMAN, AIF AND PRESIDENT, POWER SYSTEMS GROUP COMBUSTION ENGINEERING, INC.

SHERWOOD SMITH, CHIEF EXECUTIVE OFFICER CAROLINA POWER AND LIGHT JOHN J. TAYLOR, VICE PRESIDENT ELECTRIC POWER RESEARCH INSTITUTE

(

x ZACK PATE, PRESIDENT INSTITUTE OF NUCLEAR POWER REACTORS WALLACE B. BEHNKE, CHAIRMAN AIF COMMITTEE ON NUCLEAR REGULATION AND VICE CHAIRMAN COMMONWEALTH EDISON CO.

WARREN H. OWEN VICE CHAIRMAN, NUMARC AND EXECUT!vE VICE PRESIDENT DUKE POWER COMPANY

o.

Industry Briefi;: to the

.Lemmission Nuclear Regulatory on the State of the Nuclear It.dustry May 15, 1986 Donald E. Lyons Chairman of the Atomic Industrial Forum and President, Power Systems Group Combustion Engineering Company Sherwood H. Smith, Jr.

Chairman of Edison Electric Institute and President 6 CEO Carolina Power 6 Light Company John J. Taylor Vice President, Nuclear Power Electric Power Research Institute Zack T. Pate President Institute of Nuclear Power Operations Wallace B. Behnke Chairman, AIF Policy Committee on Nuclear Regulation and Vice Chairman Commonwealth Edison Company Warren H. Owen Vice Chairman, Nuclear Utility Management and Resources Committee and Executive Vice President Duke Power Company

Presentation by Donald E.

Lyons Chairman of the Board of the Atomic Industrial Forum, Inc.

To the Nuclear Regulatory Commission On The State of the Nuclear Industry May 15, 1986 Each year at the culmination of the Nuclear Power Assembly, the Chairman of the Atomic Industrial Forum is tasked to assess the state of the nuclear industry so that you on the Commission may have a first-hand opportunity to hear and discuss the industry's perspective of the future of this industry and of the role of the regulators in that future.

It is unavoidable that we divert our attention first to the recent accident at the Russian Chernobyl Plant.

When an event such as this occurs, particularly when it is veiled by incomplete information, a reevaluation of our current circumstances in the United States is inevitable.

The accident was a tragedy for all concerned, but ene which should not be allowed to set back the progress made since Three Mile Island.

Unfortunately, nuclear opponents and political oaportunists are attempting to exploit the Chernobyl accident.

Tie public is understandably concerned and in need of reassurance about the safety of nuclear power from both the industry and our government.

Throughout the free world, responsible authorities are taking steps to provide that assurance.

The accident at Three Mile Island underscored the importance of excellence in design, construction, and operation of commercial nuclear power plants.

Since then, the United States nuclear l

industry has taken* aggressive steps to upgrade management, quality i

assurance, operator training, ano other elements of nuclear plant operation.

We cannot afford to become complacent.

Despite the funda-r mental differences in reactor concepts, engineered safeguards requirements, and regulatory systems employed in the U.S. and the U.S.S.R.,

it is apparent that the accident may offer lessons applicable to the management and regulation of nuclear power throughout the world.

There is a need to learn as much as pos-sible about the causes of the accident as well as the post-accident and recovery experience in a deliberate and constructive manner.

This is not to imply that we anticipate any major changes in our plant designs or management systems, but rather that we anticipate ongoing evolutionary improvement and look to gain from i

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Chernobyl to the extent that it can contribute to our own exper-ience.

Every event, no matter where it occurs, no matter how unrelated to our technology, must be reviewed and acted on as if it had a bearing on safety.

At the same time, there is no turning back on nuclear power with its nearly three decades of operating experience in the United States.

Nuclear power currently accounts for 16% of our electrical power generation.

There are 100 plants licensed to caerate and, when the 27 now under construction are completed, about 20'. of our electric power will come from nuclear sources.

In its recently issued National Energy Policy Plan V, the Administration highlighted the value of a balanced energy mix and identifies revitalization of civilian nuclear power to be an important objective of national energy policy.

What is called for now is a thocough and systematic assessment of the Chernobyl accident.

What we.need to avoid is speculation and premature or piecemeal response.

The public is entitled to the facts and the benefits of any safety lessons we can learn, and we in the industry are prepared to work with the Commission toward this end.

Unfortunately, however, the world cannot wait and hold its collective breath as we learn the lessons from Chernobyl.

There are 100 U.S. operating plants to be regulated and an American public to be served.

So, while we expect to learn more from this extremely unfortunate event, we believe the proposals presented today are consistent with our commitment to continue to improve overall nuclear power plant safety in the United States.

Moreover, the Chernobyl event makes us appreciate even more the American system of laws and attendant interaction among government agencies like NRC, the industry, and the public in our open society.

This free and open exchange among such parties should be cherished.

Recognition that the perceptions and actions of any of these parties are imperfect and can be improved is a first step toward collectively assuring overall safety, our primary objective.

Mr. Chairman, you will be stepping down from your position on June 30th of this year, becoming the first person to serve your country in this challenging positior. for a full five-year term.

We appreciate the service you have provided in a difficult job, and I speak for all of my colleagues in the nuclear industry in extending to you our best wishes.

My two-year service as Chairman of the Board of Directors of the Atomic Industrial Forum also draws to a close later this year.

Perhaps, then, this is an appropriate time to review what we have accomplished -- and what we have still left undone.

i Five years ago, Chairman Palladino, when you took the reins of this Agency, the credibility of the NRC had been attacked by repeated congressional, administration, and even NRC-sponsored studies of the TMI accident.

I would like to acknowledge some of the many positive accomplishments during your tenure as Chairman.

The first, and one of the most effective things you did was to establish the Committee to Review Generic Requirements, which established a formality and discipline to the development of new regulatory requirements.

You established a Licensing Reform Task Force, which definen a framework for future administrative and legislative reforms.

The Commission followed up on that T::k Force's recommendation by' proposing a licensing reform bill which is now before Congress and will go a long way -- if enacted -- toward establishing a fair and rational licensing process for future plants while improving overall plant safety.

It also put into place a much needed -- and long sought -- backfit rule which provides the means to instill discipline into the retrofit p roce s's.

Under your chairmanship, the Commission has grappled with Safety Goals, a topic previous Commissions deemed "too hot" to handle.

In addition, the Commission has come to acknowledge the importance, and indeed the necessity of, accommodating the plant betterment projects initiated by the utilities, rather than allowing them to be constantly displaced by NRC-required retrofits and surveillance items.

Under your leadership, the Commission has tackled the matter i

of accidents beyond design bases and produced a' reasonable Severe Accident Policy that pertains to both present and future plants.

l To your credit, it is a policy that focuses resources on the main contributers to risk as opposed to spreading resources over general and inconsequential concerns.

Perhaps, however, the most important change that has taken i

place during your~ chairmanship has been the planting of seeds of change in the regulatory climate that exists between the regulators and the licensees.

I am referring to the NRC's growing awareness that the licensee is indeed the one who is directly responsible for the safe operation of its facility.

The licensee

.is, therefore, in the best position to determine how to achieve the excellence that both the utility and the NRC so strongly desire.

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1 We are pleased with the Commission's acknowledgement that the industry has matured sufficiently to become its own "first-line" regulator.

We further appreciate the Commission's recognition that, if excellence is to be achieved, it will not be because of escalating requirements and their enforcement by a regulatory body, but rather by means of the financial and professional incentives which accrue when sights are set higher than regulatory standards and when punitive action is not automatically imposed if that higher goal is not net.

The NRC staff has also recognized that the industry has more resources than the NRC for assessing solutions to generic problems, and it is therefore providing the industry with the opportunity to address some of those problems on its own terms before moving to impose regulatory solutions.

In our minds, this represents enlightened regulation.

Accordingly, INPO, NUMARC, and the vendor Owners Groups are assuming increased responsibility for the self-regulation of the industry.

Finally, I would like to take this opportunity to applaud the Administration's foresight in naming the NRC's next Chairman five months in advance, and we congratulate you, Commissioner Zech, on that announcement.

Your leadership and technical credentials are well-established throughout over 30 years of naval duty and your two years of service at the Commission.

We wish you well.

Despite the accomplishments of the Palladino Commission that I have cited, I assure you, Chairman-designate Zech, there are many challenges left for you and those who will serve with you.

Last year in my address to you, I stated there were seven major issues the NRC must address if it does not wish to see the nation abandon the nuclear option.

By my count, the NRC has come to grips with two of those issues, namely, backfitting and the relicensing of TMI-1.

Although it might be considered presumptuous to assume my speech last year had anything to do with these accomplishments, I am sufficiently encouraged to try again.

Thus, I would like to enumerate several areas which I feel are ripe for Commission action without waiting for the results from Chernobyl.

We have noted our satisfaction with the backfit rule put in place last year.

I hope and trust that the backfit rule will establish the necessary discipline and structure so that the Commission can quickly and effectively sort through the lessons to be learned from Chernoty1.

Experience has shown, however, that rules are simply a means and not a solution.

The industry and the NRC staff are currently engaged in a series of workshops which will help us to understand how best to implement the provisions of the rule.

We will be watching closely to ascertain the effective-ness of the backfit measures and urge you to do likewise.

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r Another joint NRC-industry undertaking which holds a great deal of promise is the voluntary Technical Specifications improvement program.

This is an area where real safety improvements can be obtained simply by structuring a set of clear and unambiguous Technical Specification provisions.

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Source term research has shown that the releases from a U.S.

commercial nuclear plant accident wouldibe substantially lower than previously assumed.

The industry is obviously desirousoof applying these.more reasonable values to the existir.g set-cf requirements which rely on source term assumptions..The Commis-sion, on the other hand, is still trying to complete all of'the evaluations which will give it complete confidence that the new source term data are substantially conservative.

We recognize that it is not likely you will make revisions in existing regula-tions until all the evaluations and documentation a're complete.

Therefore, we urge you to press on with_all due diligence.

In the meantime, we recommend that you issue no further regulations or rules based on the existing source terms, as that would clearly be counterproductive; instead we recommend you use the best infor-mation available.at the time a decision is necessary.

I would also like to encourage the new Commission to resolve the important outstanding unresolved safety issues and generic issues and to get rid of leftover generic issues by exercising the leadership necessary to call a trivial item a trivial item and write it off.

The long lists of unimportant issues create and nurture the impression.that nuclear power.is-beset with all sorts of unaddressed dangers to the public -- a perception that is clearly not true.

Regarding standardization, we agree that the licensing process must be changed.

Two-step licensing is an anachronism.

It was the right way to launch this industry, but, in recent years, it has been.a, major factor in the attempt to scuttle the industry.

There is a quid pro quo for one-step licensing:

We cannot ask you to certify a plant for operation prior to construction unless we 4.

have provided you with all the information necessary to determine that the plant can be built and operated safely.

We are prepared to provide all of the necessary safety information prior to the receipt of'the license in order to achieve the regulatory and design stability that is necessary to restore construction times

-- and thus' costs -- to manageable levels.

In this process, construction management, unencumbered by continual design changes, can be greatly improved -an~d with it overall quality and plant safety can be increased. __. _ _

O As the licensor, you want all of the information up front.

As the licensees, we cannot and will not any longer tolerate the vulnerability to untimely design changes, or the potential for the operation of the plant to be suspended because an issue was addressed in an untimely manner.

The solution is simple:

Provide for us one-step licensing, and we will provide for you up front all the details that are needed to make your safety determination -- once and for all.

Some would argue the Commission is not authorized under the Atomic Energy Act to provide one-step licensing.

To that we respond: -You could provide it, and you should provide it.

But, in order to give the industry the stability it needs, we also need statutory endorsement.

We think the best way to demonstrate to Congress your commitment to an improved process where safety is improved is to begin to proceed with rulemaking -- which would administrative 1y put in place the basic tenets of that legislation.

Finally, I would like to speak to leadership.

Each of us on this side of the table is in a position of leadership within the industry organizations we represent and within our own companies.

In the former areas -- industry organizations, we are often frustrated by our own lack of cohesiveness on issues and by our own proliferation of "special interest groups" which take independent tacks on various given topics.

Thus, it is with a substantial degree of empathy that we address the problem you face

-- namely, that there are five of you trying to steer this Agency on what you each feel is the right path for each given issue.

I understand that there is a majority who have told the Congress you feel it is time to convert the structure of the Agency to a single administrator.

The reality, however, remains -- there are still five of you.

I cannot overemphasize that it is very important that you send l

clear signals.

Oftentimes in the past this has not been the case.

The NRC management and staff, the nuclear industry, the l

Congress, the media, and especially the public have suffered l

because the NRC has found it necessary to compromise and delay decisions on important issues.

In summary, let me quickly touch base on the items which we feel the industry and the Commission should continue to focus I

their attention this year:

1 o

Backfitting - The process is in place.

Please monitor its implementation carefully.

Technical Specifications Improvements - This holds much l

o promise and should be pursued.

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o Safety Goals - We are in general agreement with the guidelines established in the 1983 Draft Policy Statement and we urge you to bring this exercise to a close this year.

o Source Terms - There is widespread agreement that source term assumptions of WASH-1400 are substantially over-stated.

Timely resolution of these inequities is very important.

o Unresolved Safety Issues and Generic Issues - We urge you to close out the lingering topics which remain in the USI list and to get rid of the long list of unimportant issues swept under the heading " Generic Safety Issues."

In-resolving these issues, we believe the staff must consider their combined impact on.the plant.

o Licensing Reform - You can -- and should -- take action within the limits of the current Act.

That concludes my remarks.

Thank you for your attention.

Presentation by Sherwood H. Smith, Jr.

President 6 CEO Carolina Power 6 Light Company To the Nuclear Pegulatory Commission On The State of the Nuclear Industry May 15, 1986 From the Three Mile Island incident in 1979 we learned to upgrade our plant designs and strengthen our systems for management, training, and regulation of nuclear power.

But at Three Mile Island we also learned that our safety systems did work as intended.

As a result of what we learned at TMI and our subse-quent actions, we have not, and will not be confronted with, the problems facing the Soviet Union as the result of the Chernobyl accident.

One of the positive actions following TMI was the establishment of I'

INPO.

Later in our presentation today, Mr. Zack Pate, President of INPO, will elaborate on the organizations' program to achieve excellence in the construction and operation of nuclear power plants.

Chernobyl should serve as an incentive for us to redouble our efforts to provide America with safe, commercial nuclear power, as.

t pointed out by President Reagan and other leaders at the Economic l

Summit.

Nonetheless, as Mr. Lyons previously suggested, we should not allow it to interfere with the ongoing operations of the' plants now in service or the timely completion and operation of the plants still under construction.

i The Chernobyl accident points out the superiority of our design and safety systems as compared with the Russians.

We now should reaffirm our commitment to safety.

The next step we need to take to increase our confidence in commercial nuclear power is the development and regulatory approval of standardized nuclear power plant designs.

Standardized designs will promote safety by l

l

concentrating resources on a few improved designs, by stimulating standardized programs of construction practice and quality assurance, and by f acilitating a more ready sharing of construction and operating experience within the industry.

But in order to take this step, the nuclear licensing and regulatory process must be reformed.

It is for this reason that we will continue to urge Congress to pass the Nuclear Power Plant Standardization Act.

This legislation is based on the recommendations of the numerous commissions that studied Three Mile Island.

In addition to stimulating standardized nuclear power plant design, H.R.

1029 will enhance public participation by providing the information the public needs long before any construction begins.

By the same token, we will continue our drive for renewal of the Price-Anderson Act on a responsible basis.

Chernobyl underscores the importance of a reliable and responsive nuclear indemnity system of the type embodied in the current statute.

Chernobyl was a most unfortunate event.

The American public and the world at large are entitled to full disclosure, a thorough systematic assessment of the facts and, from these facts, reassurance as to the safety of civilian nuclear power programs.

You may recall that the Utility Nuclear Power Oversight Committee f

(UNPOC) was established in the wake of the Three Mile Island I

accident to coordinate the overall industry response to that event.

Among the industry initiatives which evolved from the Committee's early activities were the formation of INPO, NSAC, and CEA.

UNP0C's membership consists of the most senior utility l

officials associated with each of the major industry associations, including AIF, ANEC, APPA, EEI, EPRI, NRECA, INPO and CEA.

i

UNPOC met last week and concluded that it will be important for the nuclear industry to, (1) learn as much as possible of the causes of the accident as well as the post-accident response and recovery experience; (2) identify whatever lessons there may be for us; and (3) respond to the legitimate questions raised by this tragic event.

At the same time, the industry desires to keep Congress, the Administration, the Nuclear Regulatory Commission and the public informed concerning'its assessment of the a.ccident.

In this context, it also agreed that the matrix of industry organizations already in place is well equipped to assess the facts surrounding the accident and respond accordingly.

We in the industry intend to work closely together to seek the best information available on the Chernobyl accident within our own organizations and from U.S. and international agency sources.

Presentation by John J. Taylor Vice-President, Nuclear Power Division Electric Power Research Institute To the Nuclear Regulatory Commission on the State of the Nuclear Industry j

May 15, 1986 I am John Taylor, Vice President, Nuclear Power, Electric Power Research Institute (EPRI). A primary objective of the EPRI nuclear power program is to provide technology to im-prove the safety and reliability of nuclear power plants.

In keeping with that objective EPRI took a series of initi-atives following the TMI-2 accident to further our under-standing of nuclear accidents and strengthen our systems for assuring the safety of nuclear power:

(1) An in-depth review of the TMI-2 accident was carried out to pinpoint the causes and define corrective actions.

(2) The Nuclear Safety Analysis Center was formed to evalu-ate operating reactor incidents so as to identify generic accident precursors and communicate them to all U.S. nuclear utilities. The SEE-IN (the evaluation phase) and NETWORK (the communication phase) systems, initially developed by NSAC, have now been turned over to INPO and have become vital and continuing processes in the industry.

(3) A major research program was launched to better under-stand severe accidents and the " potential for" release of radioactive materials to the atmosphere (the " source term").

(4) The entire EPRI nuclear power R&D program in safety and reliability was re-oriented on the basis of the " lessons learned" from TMI-2 and the recommendations of the Xemeny Commission and other investigations of the TMI-2 accident. A major relief and safety valve test program was implemented.

Improved devices for valve position indication were developed. Major attention was given to improvement of human factors in operation and mainten-ance, including diagnostic aids and system-oriented procedures for improved emergency response, signal J

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validation techniques, and simulator qualification stan-dards. Development and application of probabilistic risk assessment methodology was intensified, particular-ly in the treatment of human error inputs and common mode failure. Extensive testing of emergency core cool-ing systems and small loss of coolant accident transi-ents were implemented. Major effort was devoted to develop improved in-service inspection techniques and establish inspector training qualification programs.

Time does not permit even a full summary of these activ-ities. We have kept Bob Minogue and his staff in NRC/RES fully advised of our programs and their results and have also recently reviewed our total program with Harold Denton, NRC/NRR.

Our staff has been working diligently to understand the events of the Chernobyl accident and tc develop an understanding of what lessons from that event can be applied to our U.S. conniercial nuclear power industry. We have found, as you have, that detailed technical information on Soviet plant designs and operation is difficult to obtain.

We have also found that the lack of detailed accident information at this time has made it virtually impossible to develop a thorough analysis of the event, as we did for the Three Mile Island accident.

It is our responsibility to our utility sponsors to do everything we can to develop the best possible technical explanation of the accident and its consequences.

Industry groups such as EPRI, INPO, and AIF should work together with your staff, the IAEA, and hopefully with the Soviets, to obtain adequate information to create a detailed sequence of events and thorough understanding of root causes and consequences of the Chernobyl accident. We want to take this opportunity to express our appreciation to members of your staff who already have been very helpful to us in gathering design information on Chernobyl.

One of the most important lessons we learned from our Nuclear Safety Analysis Center's analyses of the Three Mile Island accident, and other significant events which NSAC analyzed and reported, is that a thorough understanding of the sequence of events and a thorough understanding of the performance of all the safety system and operator actions during the event, is crucial to developing sound conclusions and recommendations.

I am concerned that pressures on the NRC and our industry to produce quick answers and quick fixes in response to the Chernobyl accident may preclude us from doing the thorough job of analysis that is so important 2

to rational decision making. We must avoid the temptation to ' shoot from the hip.'

One of the major reasons that mandates we analyze this event carefully prior to formulating recommendations for U.S.

Light Water Reactors (LWRs) is that the Soviet designs are significantly different from ours.

fundamental design and operational differences exist that make side-by-side comparisons extremely difficult. These fundamental differences lead us to draw two immediate conclusions:

1.

First, the differences will make it difficult to draw easy applications to the U.S. situation. Many of the lessons from Chernobyl will not apply to U.S. plants.

Some lessons will apply, and must be analyzed.

Initial challenges or event initiators can be very similar between U.S. and Soviet plants. Also, I believe the consequences of the Chernobyl accident, in terms of accident source terms, radioactive transport, health effects, and cleanup efforts are all important areas that U.S. scientists must study and apply as appropriate to our own safety analysis efforts.

2.

Second, we must not fail to recognize the most obvious fact about U.S.-Soviet nuclear power program comparisons: Chernobyl was vastly different from our 1979 accident at Three Mile Island.

Despite the fact that each experienced major core damage, the public health effects from the Three Mile Island accident and the Chernobyl accident are dramatically different. No deaths, injuries,orhealthrisksresultedfromthe Three Milt. Island accident. The exhaustive Pennsylvania Department of Health study completed last September found no evidence of increased cancer among area residents due to the 1979 accident at TMI. No damage to crops or livestock occurred, and no cleanup of land outside the plant boundaries was required.

I firmly believe that our U.S. designs and operations account for l

that difference. The analysis of Chernobyl will no i

doubt reveal some opportunities for further improvements in the design and operation of U.S. reactors, but we must not lose ~ sight of the fact that TMI-Chernobyl comparisons indicate that our program is fundamentally sound. This is a credit to your agency, our industry, and public scrutiny within our democratic process that have worked together to achieve high standards of safety.

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i I would like to take a few minutes to explain in more detail l

some of these important differences between U.S. and Soviet reactor designs.

I must again emphasize that our j

information on Soviet designs is incomplete. My emphasis on l

the following differences is not intended to suggest that

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there are n_o lessons to learn from Chernobyl, but to help us focus on the facts and ensure that correct lessons are identified. My summary of fundamental design differences will be grouped into three areas: reactor differences, containment differences, and safety system differences. My point of comparison will be the U.S. light water reactor.

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The Chernobyl reactors are light-water cooled, graphite l

moderated, pressure tube reactors. These 1000 MWe plants I

are called "RBMK-1000's" by the Soviets. The RBMK reactors l

are the dominant Soviet design. RBMK-type designs comprise over one-half of all operating Soviet power reactors and about 65% of their nuclear capacity.

l The first obvious difference between Soviet RBMKs and U.S.

l LWRs is the use of graphite as a neutron moderator..The RBMK design evolved in the Soviet program from earlier weapons production reactors that used graphite and low enrichment uranium.

U.S. designers selected light water moderation over graphite moderation for power reactor applications for a number of reasons.

First, the obvious i

safety problems associated with a potentially flamable material inside the reactor core are eliminated, along with all the complex support systems that go with it (moderator heat removal, cover gas, fire protection, etc.).

Second, the unique physical and chemical problems of graphite deformation under irradiation, including annealing requirements and Wigner energy effects are avoided. Third, graphite reactors are huge in physical size and very complex when compared to U.S. LWRs. Over 1600 individual pressure tubes are embedded in the 1800 tons of graphite, each with its individual inlet and outlet piping.

Fourth, the few advantages of graphite moderation, very low enrichment uranium, and on-line refueling were not attractive to U.S.

utilities, who had no interest in providing materials for the U.S. weapons program.

The next major difference between U.S. and Soviet reactor designs is in the defense-in-depth barriers provided to l

ensure that nuclear fuel and fission products cannot escape the core. Both Soviet RBMK reactors and U.S. LWRs use UO j

fuelpelletssurroundedbyazirconiumcladdingor'can'$f l

about.02" to.03" wall thickness. These fuel elements are I

similar, but the next barrier of defense against release is A

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d radically different. The Soviets use over 1600 individual pressure tubes, 7 meters (23') long, and 88 m (31/2") in diameter to contain the fuel elements and light water coolant flowing past the fuel elements. The pressure tube walls are 4 mm thick (~.16"); whereas the pressure vessel walls on U.S. LWRs are about 6 1/2 to 8 1/2 inches thick, or about 50 times thicker.

This means that damaged fuel elements on a Soviet RBMK reactor have a much greater chance of penetrating this second barrier of defense (the pressure tubes) than on a U.S. LWR (a single large pressure vessel).

These first two Soviet differences, use of graphite as the i

moderator and thin-walled pressure tubes, combine to form a third distinction, the possibility of creating dangerous hot-graphite / hot-steam reactions from a breach in the i

pressure tube wall.

Although both the RBMK and LWR designs use light water as coolant, the different reactor ccnfigurations create some unique cooling problems for the Soviets.

First, with a relatively small water inventory in the reactors, little time is available to renond to challenges such as losses of inventory before coolant boi'.:.'f and fuel overheating begins.

Individual fuel channels may boil dry if there are channel-to-channel instabilities between pressure tubes.

In addition, loss of coolant may not result in the fail-safe negative reactivity that exists in U.S. designs. Soviet reactors have exhibited unstable positive steam void reactivity coefficients which required design changes to the metal-water ratio inside the pressure tubes, by increases in enrichment.

I have now summarized the major differences in Soviet RBMK i'

vs. U.S. LWR reactor designs, and will now say a few words I

about reactor containment. The subject of Soviet containments has generated a great deal of discussion in the last few days, and deserves some attention at this point.

On this subject, we find that technical information on RBMK containment capability is much less available than technical information on RBMK reactor designs. We believe this to be a result of relatively slow development of containment technology in the Soviet program.

Early Soviet reactors had no containment whatsoever.

Incremental steps have been taken on subsequent generations of RBMK designs to improve on this situation, but to this date we are unaware of any operating or under-construction Soviet RBMK with a full primary containment in the sense te in the West define full j

containment.

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1 To us, full containment means complete enclosure of all reactor and primary support systems for the reactor such that any design basis accident is fully contained inside.

Full primary containment is achieved typically in the U.S.

by building a strong, thick steel and concrete containment vessel around all primary reactor systems. The containment is either large enough to contain the peak pressure anticipated for the worst design basis accidents, or has sufficient " pressure suppression" or steam condensing capacity to contain that worst case peak pressure. Most U.S. LWRs have containments with design pressures of about 60 psi with ultimate yield strengths as high as 3 times that figure.

For some U.S. containments with lower design pressures, such as BWR MK-3 and ice condensers, sufficient pressure suppression capacity is installed to limit the worst case accident peak pressure to a much lower value

-within the containment design. Needless to say the capability of a containment to perform its design purpose successfully is not merely a function of its design pressure, but also its size and pressure suppression capacity.

Finally, " full containment" as defined by the U.S. implies the ability to isolate completely and rapidly all containment penetrations, such as main steam and main feedwater piping.

We have heard of reports based on Soviet technical literature that credit the Chernobyl Unit 4 with a containment. We believe such claims probably are not correct. This seems to be substantiated by a recent Associated Press report that Ivan Yemelyanov, Deputy Director of the RBMK design organization, " confirmed speculation that the reactor did not have a conventional containment vessel used in the West to prevent radiation leaks in case of a breakdown." As previously stated, the modern Soviet structural designs we have seen would not qualify in the U.S. as " containment." A more appropriate term would be " limited pressure suppression capability."

We base this conclusion on three observations.

First, only part of the primary system is enclosed within a boundary intended to be pressure tight. Reactor inlet piping is i

enclosed, but Soviet literature seems to imply that reactor outlet piping and the four large steam drums or steam separators are outside the pressure boundary enclosure.

Also, there is some doubt that the reactor core itself is protected by the pressure boundary. Second, piping penetrations of the pressure boundary do not appear to be equipped with any isolation capability (e.g., main steam isolation valves, main feedwater isolation valves).

Third, 6

1 1

the pressure suppression capacity appears to be limited to certain specific break size and locations, and does not appear to envelope the full range of possible accident sequences for which U.S. containments are analyzed.

In general then Soviet compartmentalization appears directed at limiting the pressures of pipe breaks, not containing the activity that could be released in an accident.

The exact pressure suppression capabilities of Chernobyl-4 are unclear. The above observations are based on crediting Chernobyl-4 with the most modern pressure suppression capability we could find described in Soviet literature. We are not sure that this assumption is accurate, but the evidence appears to point toward Chernobyl-4 being equipped with the more modern compartmentalization, in comparison to earlier RBMKs that appear to have no pressure suppression capability.

The final area of U.S. and Soviet designs that I wish to address is safety systems. This topic is perhaps the most difficult area of comparison, but also is the area that is likely to yield the most useful applications ta our industry. Soviet nuclear power plant safety systems will be difficult to analyze, not because of a lack of Soviet papers on the subject, but because we believe that the description 3

i of a safety system in Soviet literature does not necessarily mean the system described is in fact installed, tested, and available to perform its design function on each Soviet reactor. We understand that a Soviet design may call for.

three emergency diesels where in fact the plant may operate before the third diesel is delivered to the site. We think that a Soviet paper that describes the safety value of adding a turbine driven auxiliary feedwater pump may be describing a desired feature that is not yet installed, despite the implication that it is part of the design. We also question whether tests or computer analyses of various modes of degraded heat transfer inside pressure tubes were part of the design process, or were conducted later to study the effects of accidents not originally considered, or to study the details and ramifications of flow and heat transfer instabilities observed during actual operations.

I bring up the above points not as a criticism of Soviet safety systems, but as a warning against conclusions that can be drawn from Soviet literature that m g later prove to be unwarranted extrapolation.

We have studied the available literature on RBMK safety systems. Soviet ECCS systems in modern RBMK designs appear to be similar to Western approaches, but appear to lack the 1

7 i

degree of redundancy and diversity we have provided in our modern LWRs.

For example, we believe that Soviet RBMKs lack the capability to iniect makeup water for post-scram decay heat removal in the event of a station blackout. This capability typically is provided on U.S. PWRs by a turbine driven Auxiliary Feedwater AFW Pump, and on U.S. BWRs by a turbine driven High Pressure Coolant Injection (HPCI) pump, or High Pressure Core Spray (HPCS) pump, as well as a smaller turbine driven Reactor Core Isolation Cooling (RCIC) pump.

We also have concluded that Soviet designs do not address the full scope of design basis accidents that we do in the U.S., nor do they treat low probability high consequence scenarios, accidant mitigation and emergency response in the detail we do. Many of the accidents they do consider are unique to Soviet designs, such as individual channel blockage; and many of the accidents they don't appear to consider are within the U.S. design basis, such as earthquake and missiles.

Finally, we think that U.S.

technical specifications for reactor operation, limiting conditions of operation, emergency procedures, realistic operator training, and many other operations-related features that are important to reactor safety in the U.S.

may not receive the same level of attention in the Soviet Union.

In both the operational safety area that Zach Pate covers, and in the technical safety research area that I cover, we view a U.S. industry that has reason to be proud of its overall record of improvement since TMI. We have made major design, operational, and institutional improvements since TMI to which all in this room have contributed. Although individual utilities and the NRC have disagreed over the prioritization and relative cost-benefit of some of those improvements, there is no doubt in our minds that most of those improvements were justified, and that safety has been improved as a result of both regulatory actions and industry initiatives.

I am confident that if we give appropriate credit to the improvements of the last seven years as we search through the lessons of Chernobyl for opportunities for further improvement, we will find most of the lessons have been learned already and applied in the U.S.

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J Presentation by Zack T. Pate President Institute of Nuclear Power Operations To the Nuclear Regulatory Commission On the State of the Nuclear Industry May 15, 1986 BACKGROUND In the aftermath of the Three Mile Island accident, the nuclear industry did significant detailed review in order to develop improved operation.

In the Kemeny Commission report, the Commission recognized "that merely meeting the requirements of the government regulation does not guarantee safety; therefore, the industry must also set and police its own standards of excellence to ensure the effective management and safe operation of nuclear power plants."

The establishment of INPO (in 1979) to promote the highest levels of safety and reliability -- to promote excellence -- in the operation of nuclear electric generating plants clearly demonstrated to the U.S. public and to the world that the U.S.

nuclear industry was not satisfied with meeting minimum standards.

In the years since Three Mile Island, INPO has grown from a small organization staffed by.a handful of loanees to a-substantial organization of over 400 dedicated professionals who have extensive experience in nuclear power plant operations.

PROGRAM REFINEMENT INPO programs have matured and are now well-defined and are continuously being refined in order to support INPO's mission.

r The Institute's programs are constantly examined for effectiveness by a number of mechanisms -- the INPO staff, the Industry Review Groups, the Advisory Council and the Board of Directors.

We also obtain feedback from the end-users at the plants and the i

corporate offices of our member utilities.

This formal feedback, as well as INP0's experience, has shaped and refined Institute programs in many areas.

One example is our emergency preparedness program.

Until late 1984, INP0's emphasis in the emergency preparedness area was on program review. It was determined that the industry would benefit more if actual performance was observed.

So, INPO began a formal assessment of utility emergency preparedness by observing nuclear plant emergency drills and exercises.

INP0 SUPPORT INPO support continues to be strong from both the industry and the NRC.

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The industry supports INP0 in many ways.

Some examples are the involvement of senior reactor operators and executive advisers on plant evaluations; accreditation peer evaluators on accreditation I

team visits; special assistance visit advisers; and observers on evaluations and emergency preparedness drill reviews.

The NRC has also cooperated with and supported INPO in many areas.

One example is the NRC support of the industry's Accreditation Program by the deferral of rulemaking in the area of training.

The NRC nominates one individual to serve on the National Nuclear Accrediting Board.

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INP0 also gains extensive experience from its staff of loaned personnel, both from domestic U.S. utilities and from the 13 countries in the free world that have major nuclear programs and participate with INPO.

A small group of utility loanees first staffed INP0 in 1979.

Through the years, loanees have-provided INPO_with current industry experience in many technical areas.

Today, loanees from members and participants, as well as international liaison engineers, make up almost 20 percent of the Institute's technical work force.

These professionals are among the best and brightest in the industry.

They are proven, experienced managers from nuclear plants and related organizations in the U.S. and abroad.

TECHNICAL PROGRAM OVERVIEW INPO's initial programs were established in four major areas:

evaluations, training and accreditation, sharing of operating experience information, and assistance.

It's interesting to look at the wisdom of the INPO founders and.of that at the Kemeny Commission as to how important and critical those four major programs have been to improvements in the industry..

The evaluation process has been an important activity for INP0 since its early days.

Each INPO member utility receives regular, performance-based evaluations of nuclear plant operations about every 15 months - 223 total as of May 1 - 18 so far in 1986.

Each utility's corporate support of its nuclear plants is also evaluated periodically - as at May 1, there have been 61 total corporate evaluation and assistance visits.

Both individual utilities and the entire nuclear industry can benefit from each other's operational experience.

This fact guides INP0's events analysis and information exchange programs.

Through these programs, the nuclear utility industry has a system for collecting, reviewing and analyzing plant operating experience and for sharing and acting on the lessons learned.

These programs enable each of INP0's member utilities to benefit from the combined. experience of the entire nuclear utility industry.

INPO conducts a wide-ranging assistance effort for its members and participants, with an emphasis on special assistance visits -

those visits made at the request of a member or participant.

These special assistance visits, which allow INP0 teams to help utilities deal with specific technical concerns or problems, span all areas within INP0's scope.

In 1985 alone, the Institute conducted 102 special assistance visits, on request, in such areas as training, radiological protection, chemistry, emergency preparedness, operations, operating experience analysis, technical support and construction.

TRAINING AND ACCREDITATION Let me share some thoughts on accreditation and operating experience.

The training of operators, technician and craftworkers can mean the difference between adequate and superior plant performance.

The INPO accreditation program was established in order to elevate the quality of nuclear power plant training programs.

High quality performance based training programs are essential to the industry's quest for excellence.

As you recall, the 61 nuclear plants that loaded fuel before 1985 have committed to have 610 training programs ready for l

acc reditation by the end of 1986.

Progress towards achievement of that goal has been excellent.

To date, 367 training programs are ready for accreditation and the remainder are expected to be ready for accreditation by the end of 1986.

INP0 has received accreditation self evaluation reports covering 436 programs.

A total of 170 training programs have been accredited at 37 sites.

To make even further improvements in the overall training of nuclear power plant personnel, the industry established in September, 1985 the National Academy for Nuclear Training.

Industry-wide training and accreditation activities are brought together, strengthened, and appropriately standardized by the Academy.

The Academy consists of three major elements:

o Individual utility training facilities and staffs; o

INPO training and accreditation activities; and o

Activities of the independent National Nuclear Accrediting Board.

INP0 administers the Academy and is responsible for its day to day operations.

Each nuclear utility is a member of the Academy and has assigned a senior executive as its representative.

When a nuclear plant's first training program is accredited, the plant becomes a branch of the Academy and is eligible to issue certificates to graduates of accredited programs.

When the utility achieves accreditation of all 10 training programs for all of its operating nuclear plants, it becomes a full member of the Academy.

To date, there are 3 full members of the Academy and 34 branches.

Quality training programs coupled with the recognition the Academy affords enhance the professionalism and pride in nuclear station personnel and lead to improved plant performance.

~

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OPERATING EXPERIENCE

'To help bolster each plant's operating experience review program, i

INPO is' conducting in-depth reviews of operating experience l

programs at eleven plants along with regular plant evaluations.

These special evaluations began in April and will be complete in October.

At the end of that effort we plan to further strengthen l-operating experience exchange among utilities--an area that is already a landmark success for the industry.

PERFORMANCE INDICATORS Since early 1981, INPO has been working to develop a performance indicator program to support utility efforts in achieving high level performance.

INPO has been collecting data in over 40 areas related to power plant safety and reliability.

It's widely recognized that nuclear plants with high equivalent 4

i availability, small numbers of forced outages, few unplanned scrams, few significant events, and low personnel radiation exposures are generally well-managed overall.

Such plants are more reliable and can be expected to have higher margins of I

safety.

Thus, the performance indicator program and its use by utilities in setting long range goals directly support improvements in plant safety and reliability.

In recognition of I

this,.in 1985 INPO, together with three outside ad hoc review groups, looked closely at how performance indicators could be used I

to' foster long term improvement.

Ultimately 10 overall indicators were agreed upon as the best measures of nuclear power plant performance.

Utilities are now l

tracking their performance in these 10 areas and establishing long-term goals in most of them.

Each utility began reporting 6-

data to INPO on a quarterly basis during 1985.

INP0 analy:es this

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data and'provides periodic reports to its members on progress and trends.

We also share this industrywide data with the NRC.

EXAMPLES OF PERFORMANCE IMPROVEMENTS As an example, the number of significant events that have occurred per unit, is showing a reduction from 1.64 significant events per unit in 1981 to.53 significant events per unit in 1985.

A similar decrease is shown in the number of unplanned automatic scrams occurring in nuclear power plants from 1980 - 1985.

With effort by each individual utility, the number of unplanned automatic scrams has been reduced from 6 in 1980 to 3.5 in 1984.

The industry's equivalent availability has improved also, showing a rise from 59.9 percent in 1980 to 60.7 percent in 1985.

Collective radiation exposure per boiling water reactor unit decreased from 1230 man-rem per unit year in 1980 to 896 in 1985, a decrease of 27 percent.

For pressurized water reactors, this figure dropped from 597 in 1980 to 394 in 1985.

Low-level, solid radioactive waste shipped per BWR unit dropped from 1113 cubic yards per unit year in 1980 to 799 in 1985, a 28 percent decrease.

For PWRs, this figure dropped from 586 in 1980 to 324 in 1985, a 45 percent decrease.

The lost-time accident rate for worker injuries involving days out of work for every 200,000 man-hours worked has decreased from 2.14 one of in 1980 to.64 in 1985, making the U.S. nuclear power plant the safest industrial facilities in which any person can work.

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Presentation by Wallace B.

Behnke, Jr.

Chairman of the AIF Policy Committee on Nuclear Regulation To the Nuclear Regulatory Commission On The State of the Nuclear Industry 11ay 15, 1986 My name is Wallace B.

Behnke, Jr.

I am Chairman of the AIF Policy Committee on Nuclear Regulation.

The role of this Committee is to coordinate the network of industry Committees, owners groups and trade associations with respect to their activities concerning generic improvements in nuclear licensing and regulation.

The Policy Committee is keeping itself currently informed about the accident at the Chernobyl Nuclear Power plant in the Soviet Union as the facts concerning this event become avail-able.

In this regard, we were especially pleased to have Mr. Harold Denton brief our Committee on the accident at our meeting on May 12.

His presentation was helpful in broadening our understanding of this tragic event.

It would be premature to rush to judgement on the accident, but several conclusions can be drawn from the information at hand.

First, there can be little doubt that the 1979 accident at Three Mile Island underscored the vital importance of the

defense-in-depth design philosophy and strict adherence to the highest standards of nuclear safety in all aspects of nuclear power plant design, construction and operation.

TMI also resulted in aggressive steps being taken by the nuclear industry as well as_the Nuclear Regulatory Commission to upgrade the management, quality assurance, operator training and other elements of nuclear power plant construction and operation.

Taken together, these factors provide a strong basis for confidence in the safety of civilian nuclear power in the U.S.

Adding further to the basis for confidence is the recently completed comprehensive probabilistic risk assessment of potential severe accident sequences for typical light water reactor plants sponsored by the industry funded IDCOR project.

Second, there are fundamental differences between the Chernobyl reactors and those operated by the U.S. utilities as well as differing engineered safeguard requirements and regulatory approach employed by the U.S. and the Soviet Union.

At this point, it is unclear as to what, if any, lessons the Chernobyl event may have for the management and regulation of civilian nuclear power in this country.

From what we L 1r learned to date concerning the accident, we see nothing about i

the event that undermines the basis for confidence in the safety of nuclear power in the U.S.

By the same token, we have detected nothing about the accident that calls for a change in 2-

S the design and procedural requirements now in place.

We will, of course, seek to learn all we can about the event and remain sensitive for lessons applicable to the situation here.

While Chernobyl is important for a variety of reasons, the event should not be allowed to side track the ongoing efforts to improve the regulatory process.

For example, implementation of the Commission's backfitting rule will enable both the NRC and the licensees to focus their resources on safety in a more constructive manner.

The syste-i matic analysis called for in the rule will help to minimize unproductive expenditures of resources on proposals which promise only marginal improvements.

Finalization of the Commission's Policy Statement on Safety Goals will be another important step in this direction.

The Policy Statement should also help put the Chernobyl accident into even sharper perspective.

Chernobyl also gives greater urgency to timely updating of the source terms used in the regulatory process to reflect the new data from TMI and subsequent research because this will provide a more realistic assessment of potential releases from the U.S. plants.

We concur with the Commission's deliberate and thorough approach to assuring that a sound scientific basis.

is established for the changes dictated by the new science and urge that this matter continue to receive your priority attention.

To the extent Chernobyl can contribute to the scientific basis on which decisions are made, it should, of course, be considered.

On the other hand, it would be unfortunate to needlessly delay finalization of NUREG-0956 and publication for comment of NUREG-1150.

Looking ahead, our Committee plans to move ahead with the ongoing task of improving the regulatory process.

While we will continue to learn what we can from Chernobyl, our priori-ties will remain unchanged.

Our highest priority is for the ongoing safe, reliable and cost-effective operation of the plants now licensed for service.

Our second priority is for timely completion and start-up of the plants currently under construction.

Finally, we will continue to work for lifting the regulatory barriers to further deployment of the nuclear power this country will need in the decades ahead.

4

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PRESENTATION BY WARREN H. OWEN EXECUTIVE VICE PRESIDENT DUKE POWER COMPANY TO THE NUCLEAR REGULATORY COMMISSION ON THE STATE OF THE NUCLEAR INDUSTRY MAY 15, 1986 I - -

Good morning gentlemen.

I'm here to discuss the pursuit of excellence by the nuclear industry in the operation and management of our power plants.

I will discuss some of the initiatives of the Nuclear Utility Management and Resources t

Committee (NUMARC) as well as some of the INPC programs that support these initiatives.

I will also touch on a few of the achievements that have been made in the past few years.

As you.know, NUMARC was formed in 1984 as a step towards industry self management.

NUMARC IS the 55 nuclear utilities.

Through NUMARC, the industry is tackling.many of the tough issues facing nuclear utility management.

Nuclear Utilities have committed to these efforts by empowering NUMARC to represent the entire nuclear utility industry in matters dealing with nuclear regulation.

NUMARC activities are founded on three fundamental principles:

one, we believe the nuclaar power utility industry must pursue-excellence in all its activities to ensure the highest levels of plant safety and reliability.

Two, in our pursuit of excellence, the nuclear industry must have the flexibility to manage its resources to achieve the best possible results.

We believe that prescriptive regulations can only result in lower standards.

And three, the nuclear utility industry is a rich resource and has the experience and knowledge to most effectively handle issues related to nuclear plant design, construction, and operation.

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i With these principles in mind, NUMARC works within the industry and with the NRC to review issues, develop appropriate solutions and implement corrective actions.

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l-What issues has NUMARC tackled thus far?

First of all, in the fall of 1984, NUMARC worked closely with the NRC in the area of training and operator qualification.

As an industry, we have made some impressive progress in training since 1979:

. A four-fold increase throughout the industry in the number of instructors and training professionals involved in plant training; e Each plant increased the number of shifts--usually from j

four to five or six--allowing one shift of operating personnel to be in training at all times; e An industry-wide move towards employing specially designed, state-of-the-art training facilities.

Utilities have dedicated nearly 1.6 million square feet of space exclusively to training--more than 3 times the amount 5 years ago.

  • And an increase in the number of computer-based control room training simulators.

Ten training simulators were in use in 1979; today 48 are in operation and when those that are planned or under construction are completed, 73 will be in operation.

The nuclear utility industry's commitment to excellence in training was clearly demonstrated by the recent formation of l

the National Academy for Nuclear Training.

The Academy, which began formal operation in September of 1985, strengthens and improves nuclear training by integrating the training related activities of:

the individual utilities the Training and Education Group of INPO the independent National Nuclear Accrediting Board

Ecch utility that oporatos or is building a nuclear power plant has made a commitment to achieve accreditation of its training programs by the National Academy for Nuclear Training.

The Academy is the primary mechanism which will assure continued success in upgrading and maintaining quality in nuclear plant training.

Quality training, coupled with the recognition the Academy affords, enhances the skills, professionalism and pride of station personnel.

What other issues has NUMARC dealt with?

NUMARC has also developed a position on nuclear plant employee fitness for 3

duty.

A commitment was made by each nuclear utility through NUMARC to have a basic fitness for duty program in place by January 31, 1985.

The industry has met this commitment.

All nuclear utilities have pledged to upgrade these programs in accordance with the EEI guidelines.

INPO evaluates implementation of these Fitness for Duty programs as part of their on-going evaluation process.

This initiative was in recognition of the necessity to provide reasonable assurance that all nuclear plant personnel working in vital areas are fit for duty.

Our industry's concern for safety and productivity of our employees and consumers is also reflected in this initiative.

NUMARC is also involved in several significant emerging issues.

NUMARC has eight active working groups -- four in the l

management category and four in the technical category:

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  • Maintenance Investigation of NRC licensed activities MANAGEMENT e

Security e

Operator Requalification e Station Blackout TECHNICAL e Residual Heat Removal Safety Goals and Cost Benefits-e e Prioritization of Issues 1

I have spoken primarily on NUMARC efforts thus far.

The industry is also benefitting from the efforts of INPO.

INPO activities are housed in four general program areas:

  • Evaluations.

INFO regularly evaluates all operating nuclear plants in the United States.

INPO evaluators identify operational strengths and weaknesses and make recommendations for improvements.

  • Training and Accreditation.

The Institute manages programs designed to help utilities develop and maintain performanced-based training programs and achieve accreditation of those programs.

Additionally, INPO coordinates the activities of the industry's National Academy for Nuclear Training.

  • Events Analysis and Information Sharing.

Programs in this area provide for the collection, analysis and sharing of information on plant operating experience.

INPO also facilitates the speedy flow of information among nuclear utilities by maintaining a computer-based communications network.

These activities allow utilities to learn and benefit from the experience of others.

. Assistance.

INPO provides assistance on a variety of technical areas and issues to its members.

One of INPO's many programs is the Plant Performance Indicator Program.

Through this program, INPO collects, analyzes and trends data in some 45 areas of plant performance.

This data is collected through existing data sources and through reports by member utilities.

I'd like to look at the results of just a couple of the performance areas that INPO is tracking:

  • Radiation Exposure In 1980, each boiling water unit in the United States had

e an average total exposure of 1,230 man-rems.

Through hard work, that number was reduced to 896 man-rems in 1985.

A 27% reduction.

The same trend was evident in pressurized water units.

In 1981, PWRs experienced an average total of 707 man-rems.

That exposure was reduced to 394 man-rems in 1985.

A 44%

reduction.

All U.S. plants adopted a personnel exposure limit of 5 rems per year for each permanent employee at one facility.

Note that this is not a regulatory limit.

I am happy to tell you that for the second year in a row, not one person in the industry exceeded that limit.

This is in contrast to 1980, when more than 300 persons received greater than 5 rams exposure.

4 e Significant Operating Events The number of significant avents has dropped steadily each year since 1981 even though the pressure to report events has increased.

That year, each of the 69 operating units in the United States experienced an average of 1.64 significant events.

By 1985, there were 94 operating units and each experienced an average of.53 significant events.

Looking at the efforts of NUMARC and INPO, I would have to say that they have paid handsome dividends for our industry.

Utilities are much more aware of key issues and the potential impact of NRC action on their operations.

I might add that there has been, and will continue to be, close coordination of NUMARC efforts with AIF, EEI, EPRI, the Owners Groups and others.

I have highlighted some of the key industry initiatives of NUMARC and INPO.

Time does not permit me to discuss the many other initiatives ongoing by individual.

utilities, owners groups, professional societies and industry organizations that contribute greatly to the overall safety and reliability of our plants.

Industry initiatives are extensive and'have been made in recognition of the need for excellence in all facets of nuclear power -- excellence that is best achieved through self improvement.

Communication lines have been established among utility managers and with the NRC.

Utility managers are working I

together on key issues related to plant safety and reliability.

The industry has made significant progress.

We now are faced with the opportunity to move along the road to excellence through self-management of our industry.

We look forward to the continued NRC support of the industry's self improvement initiatives.

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