ML20205S420

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Transcript of 860605 Meeting W/Acrs in Washington,Dc Re Gessar II BWR/6 Nuclear Island Design for Future Plants. Pp 1-53
ML20205S420
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Issue date: 06/05/1986
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REF-10CFR9.7 ACRS-GENERAL, NUDOCS 8606120450
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ORIGINAL UNITED STATES OF AMERICA

' NUCLEAR REGULATORY COMMISSION l

In the matter of: l COMMISSION MEETING Meeting with Advisory l Committee on Reactor I Safeguards (ACRS) on l

GESSAR II 1 I

(Public Meeting)

Docket No.

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Location: Washington, D. C.

Date: Thursday, June 5, 1986 Pages: 1 - 53 0606120450 860605 PDR 10CFR PDR PT9.7 j

ANN RILEY & ASSOCIATES Court Reporters

  • 1625 I St., N.W.

Suite 921  :

Washington, D.C. 20006

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(202) 293-3950

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1 D 1 SCLA 1 MER 2

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5 6 This is an unofficlal transcript of a meeting of the 7 United States Nuclear Regu l a tory Comni ss ion he l d on 8 6/05/86 .

In the Comnission's office 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 12 inaccuracles.

13 The transcript 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 a

18 pleading or other paper may be filed with the Cccenission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Commission may 21 authorire.

22 23 24 25 l

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, 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 - --

4 MEETING WITH ADVISORY COMMITTEE ON 5 REACTOR SAFEGUARDS (ACRS) ON GESSAR II 6 - --

7 PUBLIC MEETING 8 - --

9 Nuclear Regulatory Commission 10 Room 1130 11 1717 "H" Street, N.W.

12 Washington, D.C.

13 14 Thursday, June 5, 1986 15 16 The Commission met in open session, pursuant to i

l 17 notice, at 2:08 o' clock p.m., NUNZIO J. PALLADINO, Chairman of l 18 the Commission, presiding.

l 19 COMMISSIONERS PRESENT:

20 NUNZIO J. PALLADINO, Chairman of the Commission 21 THOMAS M. ROBERTS, Member of the Commission 22 JAMES X. ASSELSTINE, Member of the Commission I

i 23 FREDERICK M. BERNTHAL, Member of the Commissien f

i l 24 LANDO W. ZECH, JR., Member of the Commission l 25

_____m-,m,_ . . _ , - _ _ _ __._--_..__,,,,m., __,,_,,,_---.r_-.7m_m .,.,.,,,,_..m_ ..-,_m , _ _ - - - . -

2 1 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:

2 D. WARD 3 H. LEWIS 4 D. OKRENT 5 C. WYLIE 6 M. CARBON 7 C. MICHELSON 8 W. KERR 9 F. REMICK 10 J. EBERSOLE 11 H. ETHERINGTON 12 C. MARK

( 13 G. REED 14 D. MOELLER 15 C. SIESS 16 P. SHEWMON 17 i 18 AUDIENCE SPEAKERS:

19 H. DENTON 20 21 22 23 24 25 ,

3 1 PROCEEDINGS 2 CHAIRMAN PALLADINO: Good afternoon, ladies and 3 gentlemen. Commissioner Zech informs me or his office informs 4 me that Commission Zach will be delayed and may have to leave 5 early but he will re.ad the transcript.

6 Today the Commission is meeting with members of the 7 Advisory Committee on Reactor Safeguards to discuss ACRS views 8 which are expressed in a January 14, 1986 letter to the 9 Commission on the GESSAR II BWR/6 Nuclear Island Design for 10 futura plants.

11 In its letter, ACRS indicates that although the 12 GESSAR II design has improved safety features, there are t' 13 questions as to whether the design satisfactorily addresses 14 all concerns in NRC's severe accident policy. Appended to 15 this letter are additional remarks of several ACRS members.

16 Copies of the ACRS letter are provided on the table i

17 in the back of the room for those who are interested.

18 The concerns expressed in the ACRS letter raise in 19 my mind the question as to what the Commission's role is with 20 respect to ultimate approval of standard designs such as 21 GESSAR II. While this is not the subject of today's meeting,

) 22 I believe that the Commission should address this question.

23 In the next few days, I plan to send a memo to 24 Commissioners to obtain their comments or suggestions on 25 various approaches to resolving this question. I should point

4 1 out at this point that if we get into safeguards or 2 proprietary matters pertaining to the technical details of 3 the GESSAR II application, we may have to close that portion 4 of the meeting to the public and I will look to OGC and the 5 representative from NMSS to be alert if we drift into that 6 area.

7 Let me ask if any of my fellow Commissioners have 8 any opening remarks at this time?

9 (No response.)

10 CHAIRMAN PALLADINO: All right. Then let me turn 11 the meeting over to Dave Ward, the Chairman of ACRS.

12 MR. WARD: Thank you, Mr. Chairman and

(' 13 Commissioners. We did have a pretty definite consensus 14 position in the letter of January 14th and Forrest Remick is 15 going to summarize that for us here today.

16 Then after that, I would like to give the other 17 members a chance toiexpress their views and in particular, Max 18 Carbon'and Charles Wylie had a minority comment in the letter 19 and David Okrent had an extensive additional comment in the 20 letter. ~

21 CHAIRMAN PALLADINO: All right.

22 MR. WARD: Forrest.

23 MR. REMICK: Thank you, Dave. Commissioners, 24 although I am going to summarize this, I played no principal 25 role. I was not a principal author nor subcommittee chairman i

1 5

1 but I am one of those who, I guess, is in the middle on this 2 situation so I have agreed to try to summarize our findings i
3 and recommendations in the January 14th letter.

i 4

4 If you notice from that letter, it is one that the l 5 Committee spent a considerable amount of time discussing. It 6 was not taken lightly. It involved about 11 days of l

l 7 subcommittee meetings over six months and it involved 11

8 consecutive full committee meetings of which it was discussed l 9 at least for some period of time.

I 10 So a considerable amount of effort went into that 11 and I would just like to summarize our findings and 12 recommendations which were that we believe that the GESSAR II

/ 13 design includes features that have the potential to provide a 14 significant improvement in safety over current BWR designs.

15 We also said in the document then that if this were

16 an application for a construction permit for one or more 17 plants of this design, we would have no hesitation in 18 recommending its approval.

19 However, we were unable to agree with the staff for

. 20 reasons discussed in our document that the design i

! 21 satisfactorily or completely addresses all of the concerns f 22 described in the Commission's Severe Accident Policy Statement l 23 and we give some reasons in the letter for that.

j 24 We have ended by saying we see no harm in the i

25 approval of the GESSAR II design, provided that this approval

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1 is for a limited time and we say five years, and provided that 2 this procedure not be viewed in any way as a precedent for the 3 handling of future applications.

1 4 In particular, the information provided to us in 5 connection with GESSAR II would not be sufficient to support i

6 an application for a one-step process or one-step license.

7 Now there were additional comments added as Chairman 8 Ward indicated. There were two members that indicated that l

l 9 they support the staff's plan to issue an FDA applicable to

! 10 one-step licensing and one member on the other extreme said 11 that he did not think that GESSAR II should receive the 12 qualified FDA recommended by the ACRS at this time and in 13 summary he said, I believe that neither the state of the

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14 design nor the staff's review process is adequate for issuance

, 15 of a forward looking FDA which has taken severe accident and

! 16 safety goal policy properly into account.

17 This morning we received a copy of NUREG-0979, j 18 Supplement. number five, which is the fifth supplement to the i

! 19 GESSAR II FDA and although just before coming up here we had a

, 20 few moments, about seven minutes, I guess we allowed ourselves f 21 to read it, I don't believe we are in a position to say that

22 we have fully analyzed that.

23 So with that, Mr. Chairman, I would open up for 24 broader discussion.

l 25 CHAIRMAN PALLADINO: May I ask you a question? Does i

7 1 the Committee plan to examine this supplement five?

2 MR. WARD: We have not addressed that at the present 3 time.

4 CHAIRMAN PALLADINO: All right.

5 MR. WARD: Next I guess I would like to ask Max 6 Carbon if he would comment on his views.

7 MR. CARBON: My views are expressed as the first 8 added comments, actually Charlie Wylie and myself and about 9 three sentences there. We believe that the GESSAR II design 10 represents a definite improvement in safety over BWR designs 11 that have been approved in the past and further, it was our 12 view that the Applicant had met all of the NRC requirements.

13 There are a lot of items that are still open and not 14 resolved yet but there is considerable review that will yet I

15 take place. It is not a closed chapter or anything like that.

16 Basically, then, we think that we do support the 17 staff's plan to issue an FDA applicable to one-step licensing 18 or at least what is the staff's plan at the time and as far as 19 I know it still is.

20 I would add a comment of my own and I don't know 21 whether Charlie agrees with it or not. I am personally not 22 totally happy with this as a design for a standard plant. I l

23 am quite happy with it or reasonably happy with it for this 1

1 24 particular thing but I think in terms of getting the kinds of 25 improvements that I would like to see in a long term standard l

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8 1 plant design with lots of plants following, that we ought to

2 go at it in a somewhat different fashion.

3 MR. WYLIE: I agree with what Max said in the 4 context of standard plants being future plants or future 5 design of plants. I think that the staff as Max said did act 6 in accordance with the regulations and the Commission's 7 existing policy statement on standard plants and the Severe l 8 Accident Policy Statement and while there were a number of 9 open items, I think that they did an adequate job of 10 identifyihg those and how they would deal with those in the j 11 process of a construction plant application.

! 12 CHAIRMAN PALLADINO: Max, you said that you would

/ 13 use a different process. I am not quite sure what you meant.

14 Could you expand just a little bit?

15 MR. CARBON: If this were going to be an FDA, for 16 example, for a plant or for a series of plants, if there were 17 going to be lots ofiplants based on this or if we are coming 18 up with approving a design for a standard plant, I think we 19 should be ahead of time telling the vendors some of the kinds 20 of features that we would like to see in plants such that when 21 we got through, we would be able to say, " Gee, we are fully 22 happy with this. We think this is just great."

23 Instead, we tend to wait until they bring something 24 to us and then we have to say, "Well,.this is either adequate 25 or it is notladequate" and that is about all we really can do l

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1 and I would like to see something more than that. I would 2 like to see us getting our pitch in there ahead of time so 3 that some of the desirable features that we think should be in 4 future standard plants, we would be asking for them. We would 5 be trying to get them in.

6 COMMISSIONER ASSELSTINE: Max, are you saying that .

7 your willingness to sign off on what the staff is doing is

8 driven to a large extent by the fact that this probably won't
9 be used or if it will be used, it will be just a very few 10 plants?

i 11 MR. CARBCN: That certainly came in in part. This 12 FDA is good -- I can't remember what it is -- five years or

/ 13 ten years or something like that. There won't be, for sure,

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14 very many plants built on it. But my answer isn't that way 15 completely.

! 16 I am satisfied with this in the sense certainly that 17 it is an improvement over plants that are out there now and 18 over plants that have been approved, designs and so on.

19 It is an improvement. It is better than what we 20 have and I have no problem in sitting here and saying that I

, 21 approve it.

i 22 On the other hand, I can look at an ideal plant and 23 say, " Gee, I can think of things I would sure like to see in 24 all those futura plants down the road." So I have no 25 hesitation approving this but it is not my ideal.

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10 1 COMMISSIONER ASSELSTINE: What are the principal 2 areas of improvement over BWR/6's that are built into the 3 GESSAR design, the things that provide the substantial

,4 improvement in safety that you see?

5 MR. CARBON: One thing that came in, for example, 6 was they have a system called the UPPS, upper --

7 COMMISSIONER ASSELSTINE: Ultimate plant protection 8 system.

O MR. CARBON: Ultimate plant protection system which 10 we thought was a definite step in the right direction.

11 COMMISSIONER ASSELSTINE: Do you know what it is 12 though?

( 13 MR. CARBON: Pardon?

14 COMMISSIONER ASSELSTINE: Do we know what it is 15 other than basically a black box?

16 MR. CARBON: We know in concept by all means. The 17 staff has some appreciation of what it is. We do not yet know 18 the details. It is not yet really what some of us would like l

l 19 to see and we would like to urge them to do more things. But 20 I feel that we do know enough about it to say that it is one 21 example of an improvement over existing plants.

22 COMMISSIONER BERNTHAL: But your letter says that 23 you don't know enough yet or our staff doesn't know enough to 24 have evaluated it yet.

25 (At this point in the proceedings, Commissioner Zech

11 1 entered the Commission meeting.)

2 MR. CARBON: That is what the letter says but my 3 added comment says that I think we know enough. In fact, I 4 think the full committee felt and, in fact, I believe it says 5 so in the second paragraph. We believe that the GESSAR II 6 design includes features that provide a significant 7 improvement in safety over current BWR designs.

8 That is the opening sentence in paragraph two, page 9 one.

10 COMMISSIONER BERNTHAL: I find it interesting that 11 you are expressing the same frustration that, I think, the 12 Commission has felt with respect to getting your car in in a 13 timely manner in reviewing what the industry and the vendors 14 are developing in the way of advanced reactors.

15 You are saying that you feel the same way about the 16 ACRS getting its oar in in a timely manner in evaluating what 17 the staff at the NRC and, I suppose, by implication by the 18 industry is doing in a timely manner.

19 We are about to address our problem in the advanced 20 reactor po?. icy statement but it sounds like you are in an

21 analogous situation almost and were with respect to the 22 Commission, in fact. At least now we are hearing you folks in 23 a timely manner.

24 MR. CARBON: If that was a question addressed to me, 25 it is certainly so. I think the Commission ought to be l

12 1 getting its oar in earlier. I think we should be. I support 2 the kind of thing where the staff has been working with DOE on 3 advanced reactors.

4 COMMISSIONER BERNTHAL: Exactly.

5 MR. CARDON: I just totally support that concept.

6 COMMISSIONER BERNTHAL: Glad to hear it.

7 CHAIRMAN PALLADINO: One of the things we generally 8 say when we talk about future reactor plants is that we should 9 have essentially a complete design. Do you think this UPPS 10 system is essentially a complete design such that we can count 11 on it? Maybe I am speaking for myself. Myself, I feel that 12 we should have essentially complete designs in these kinds of

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A 13 standard plants.

14 COMMISSIONER ASSELSTINE: I agree with that very 15 much, Joe.

16 MR. WYLIE: It is not a complete design. It is a 17 design concept thatiwas proposed.

18 CHAIRMAN PALLADINO: That is how we started in this 19 business with concepts and developed designs as we went along.

20 MR. WYLIE: That's right. It was hitched to a 21 design concept which was described in sufficient detail that 22 it is an understanding of what is proposed but it does not 23 have the complete design and hardware and criteria that goes 24 along with that in the same sense as some of the other parts 25 of the plant.

s 13 1 But the staff made a provision that that would be 2 reviewed in the course of the review with a CP.

3 COMMISSIONER BERNTHAL: But this is not a design 4 certification either. It has not been litigated.

5 CHAIRMAN PALLADINO: I agree.

6 COMMISSIONER BERNTHAL: This is a final design 7 approval. It is not the design certification which is the 8 requirement for standardized plants so there should be no 9 misunderstanding. This is not a standardized plant design 10 approval.

11 COMMISSIONER ASSELSTINE: To what extent, Charlie, 12 is your understanding about the flexibility or the ability of 13 the staff when it looks at something like say the ultimate 14 plant protection system down the line, what is their 15 flexibility in terms of being able to ask for more if they are 16 not satisfied with what they see when they see the specific j

17 design? i 18 For example, would that be a backfit of the 19 Commission's backfit rule? Has the staff given away its i 20 ability to basically say we are not satisfied with the design 21 of this ultimate plant protection system in some respects and 22 we would like to see more, that it would have if it did that 23 before it approved the design?

24 It may not be a final design certification but it is 25 the staff sign-off that they are satisfied with this thing.

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i 14 1 MR. WYLIE: Certainly, if they decide to change the 2 principal of the design, then I think that would come under 3 the backfit rule but I think as long as they adhere to what 4 has been proposed which I think is fairly complete, there are 5 enhancements that should be made to that system and I think 6 the ACRS members have commented on that in the course of the 7 GESSAR review, that certain features of that UPPS system 8 should be enhanced and I think to that extent, I don't think 9 it would fall in the backfit rule.

10 I think sufficient information has been conveyed 11 that it would not.

12 MR. CARBON: I would like to add to that if I may.

13 The final design details are not firm at present but they will 14 be submitted to the staff and reviewed by the staff as well as 15 the ACRS before either they or we sign off and it is the 16 staff's intention to state bhat or condition the FDA on those 17 further reviews by both the staff and the ACRS.

18 CHAIRMAN PALLADINO: Let me suggest we hear from the 19 others before we go into more detail on some of these 20 questions.

l 21 MR. WARD: YEs. I think Dave Okrent has some 22 comments.

23 MR. OKRENT: - In fact, I have a considerable number

. V 24 of coChents.- I would first note that I did have a chance to 25 look at the staff's recent SER last night since Dr. Savio of

15 1 our staff got me a copy at the hotel. It seems that the staff 2 finds no major merit in any of the ACRS comments.

3 I think that leaves us and you something to think 4 about. I will just leave it at that.

5 The history of Severe Accident Policy developed as I 6 recall it, in fact, started with the Commissioners having a 7 short list of things that ought to be in future plants to 8 improve their safety.

9 Then for one reason or another, one moved away from 10 that and there was a proposal you would do it by having the 11 applicant do a PRA which the staff would review and you may 12 recall the committee questioned whether you would be able to I 13 judge adequacy for a single plant by just reviewing a PRA let 14 alone trying to get some equivalent levels of safety between 15 two different designs in this fashion.

16 Eventually, the staff came in and said, "Well, we '

17 will do it deterministically and probabilistically and with 18 engineering judgment." I am sure the ACRS was worn down and 19 maybe the Commission was worn down when you adopted a Severe 20 Accident Safety Policy.

21 I don't know why the Commission did it.

22 CHAIRMAN PALLADINO: Why the Commission did what?

23 MR. OKRENT: Adopted what it did. I found myself 24 sort of worn out on this subject, I must confess.

25 In any event, the first plant to come in to be

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l looked at under the Severe Accident Safety Policy as I 2 understood it was GESSAR II. I happened to be subcommittee 3 chairman, not by choice.

4 I wrote down some of the kinds of questions that I 5 thought we needed to explore and I will read some of them to 6 you so you can think about them not necessarily today but as 7 you review this matter.

8 What is an FDA? What committment is the NRC making 9 when it issues one? What commitments would it be making if 10 it approves GESSAR II? How much detailed information should 11 be provided by an applicant for an FDA? What should be the 12 level and depth of the PRA? Should it treat uncertainties as

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13 well as the state-of-the-art exists? How should interface 14 requirements with the balance of plant be specified in view of 15 the fact that the PRA makes assumptions on the performance of 16 the balance of plant?

17 What seismic fragility requirements are and should 18 be established by the GESSAR PRA and by the staff review?

19 What performance requirements for GESSAR II systems are 20 established by the PRA if any? What level of PRA evaluation 21 and review is required of the NRC staff for it to accept an 22 FDA? Should the staff report mean modea evaluated -- mean 23 values evaluated as well as the state of the art permits?

24 What should be the quantitative safety objectives 25 for a future plant? Is there is some kind of containment I

17 1 criterion that a future plant should meet? How to deal with 2 the design for terrorists and sabotage in future plants? How 3 do the cost benefit analysis for possible design 4 improvements? How to ensure defense-in-depth at the same 5 time? How to ensure that the frequency of challenges is 6 acceptable?

7 These are some of the Pinds of questions that 8 crossed my mind and which, I fact, I tried to bring before the 9 full committee in very many meetings so that they would be in 10 front of the committee when they were writing whatever letter 11 they did write as a committee on GESSAR II.

i i 12 I think as you can see from the letter that was 13 sent, I didn't disagree with the letter except that I thought s

14 rather than saying it is okay even though this isn't what we 15 would call a proper review, to issue a limited FDA, I thought 16 it would be better to call this an interim letter and to talk 17 the matter over with the Commissioners and then I added some 18 additional comments. I would like to dwell on some of them, 19 not all.

20 As one example, the staff and its consultants 21 evaluated the seismic design and the seismic PRA. They 22 conceded that this was inadequately designed for purposes of a 23 full review. Their point estimate included those things which 24 they thought in their best judgment should be included was of 25 the order of four or five times ten to the minus five per year

18 1 as the seismic contribution to core melt frequency and they 2 say if we can eliminate chatter, that would be on the order of 3 two times ten to the minus five.

4 A question that I raise and that I think the 5 Commissioners should think on is for a future plant what 6 should be the safety goal vis-a-vis core melt. What should be 7 the rough contribution of any single scenario to this overall 8 core melt frequency? Would you permit it to be dominated 9 90-percent by a single contributor which itself had a factor 10 of ten or 50 uncertainty?

11 These are policy positions and I think the 12 Commission should give advice downward. My own feeling is

13 that for future plants, a single scenario should come in at 14 that large a number.

15 I don't know what the real number is but this was 16 the staff's estimate.

17 A second point has already been alluded to and that 18 is although a considerable claim in safety was made for the 19 UPPS or ultimate plant protection system it was really 20 ill-defined. In fact, it had no seismic capability as l

21 proposed and if seismic was a major contributor, it would not, 22 in fact, have alleviated this aspect of the risk.

23 With regard to sabotage protection, the staff and 24 General Electric said they really couldn't discuss that matter 25 with GESSAR II beyond what was already in the existing l

19 j 1 regulations which relates primarily to access control and 2 fences and so forth.

3 The ACRS wrote a letter to the Commission several 4 months ago suggesting a re-evaluation of this subject 5 particularly in terms of future plants. I, for one, think 6 this is not a time to tarry on that subject and in fact, I 7 have made some specific proposals that i would include in any 8 plan which incorporated the GESSAR II design among other 9 things as proposed.

10 The control room was vulnerable to the kinds of 11 things that have caused severe damage in the Middle East. Let 12 me put it that way.-

13 Just one last point, it was really very late in our 14 review, but you might say by chance I asked the staff, what 15 would happen to the containment if we had a core melt and the 16 core in part or much got through the vessel, would the drywell 17 maintain its integrity because all along we had been hearing 18 that the staff had looked hard to see whether there was any 19 way of drywell by-pass and in the end, they decided this was 20 not an important threat and so fission products if they i

21 escaped would you go through the wet well, be captured.

. 22 You would get a really large decontamination factor.

l 23 I am rather convinced that whatever the factor is, '

1 24 it is appreciable assuming that the water is there and the 25 material is forced through it and it doesn't then boil away 1 1

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20 1 carrying everything with it.

2 When we asked the question about the stability of 3 the sacrificial shield that supports the reactor vessel in the 4 drywell back around last July roughly, the staff said, "Well, 5 our rough estimates are that this sacrificial shield won't 6 held" which says that what is holding up the reactor vessel 7 won't held which, to me, says that things like steam lines may 8 start pulling on their penetrations. I don't know how this 9 vessel will tip over or fall or what is level of the vessel, 10 that is, in this case.

11 CHAIRMAN PALLADINO: Under what conditions, Dave, I 12 lost you?

, 13 MR. OKRENT: You have melted the core, part of it is 14 melted through the vessel. It is sitting on the concrete 15 below the vessel and it is heating up the concrete structure 16 around inside the drywell and there is a sacrificial shield 17 around the reactor vessel into which somehow supports the 18 reactor vessel.

19 If that loses its integrity, the vessel will tip 20 over, fall or whatever in some way and pipes attached to it 21 will tend to go with the vessel, let's say, and it is not 22 clear to me, I have seen no analyses, as to just what is the 23 future course of that event.

24 The staff at the time with Brookhaven said, "Well, 25 we think that is going to be a late containment failure, a

21 1 very small release and it should be important." That may be 2 true but it seems to me it is an important enough question 3 that it should have been analyzed before the question was 4 asked.

5 It certainly should have been analyzed by now but 6 when I was last at Sandia a month ago they had not looked at 7 it although they are doing the rebaselining of reactors 8 including Grand Gulf which is a MARK III and in any event, it 9 raises a question, does the Commlusion want for future 10 reactors there automatically to be release of at least the 11 noble gases plus some other stuff that revitalizes or whatever 12 for each and every core melt or is your goal something better 13 even if the risk doesn't seem to be large compared to early 14 release and so forth.

15 But at the moment I have not seen enough analysis to 16 be convinced that, in fact, we know it is a late small l 17 release. So these are some of the kinds of things that led me l

l 18 to feel that this was not a job, a review job or really a job 19 by the applicant that was up-to-snuff for a future FDA.

20 I agreed with the committee that if we were just 21 going to build a few of these and we weren't talking about 22 this new process, it was okay. Everybody in the room said, 23 "Yes" to that question, no disagreement.

24 But it seemed that we were entering a new process, 25 a process the staff itself had asked for by proposing that we 1

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22 1 are going to be examining them one-at-a-time using PRA's and 2 engineering judgment.

3 I would like enough quality in that process that we 4 don't and up where we are with Sequoia or at this sort of 5 thing if you know what I mean. Well, I will leave it at that 6 for the moment.

7 COMMISSIONER BERNTHAL: Question. Why does your 8 catastrophic scenario imply release if you pull pipes with 9 you?

10 MR. OKRENT: If you rupture the primary --

11 COMMISSIONER BERNTHAL: If there are slashes into 12 the core, but you still have a contpinment building.

13 COMMISSIONER ASSELSTINE: You punch a hole in the 14 side. ,

i 15 MR. OKRENT: No , I think you punch a hole -- again, 16 I have not seen the analysis, but I think you are likely to 17 rupture the drywell.

J 18 COMMIESIONER BERNTHAL: Right.

19 MR. OKRENT: You then don't go through the wetwell.

20 There is a building outside of this --

21 MR. WARD: You have by-passed the suppression pool.

22 MR. OKRENT: What happens here to that building, I 23 haven't seen analyzed.

24 COMMISSIONER BERNTHAL: It is uncertain.

25 MR. OKRENT: Exactly.

23 1 COMMISSIONER BERNTHAL: But it is not certain that 2 you have given away a large scale release of all noble gases 3 or volatiles?

4 MR. OKRENT: It might be a small release. It might 5 be quite significant but it seems to me that it should have 6 been analyzed before an FDA is issued so that you knew enough 7 about it that you could either put it aside or at least weight 8 it into the balance for what it was. -

9 CHAIRMAN PALLADINO: Dave, you indicated that you 10 would not mind having a few of these plants built which, to 11 me , takes several years. Does this imply there is a period of 12 time for which you would find let me use the word "FDA" 13 acceptable?

(

14 MR. OKRENT: Again, in my own opinion future plants '

15 including GESSAR II should include the features that I liated 16 in my remarks.

17 CHAIRMAN PALLADINO: Even the ones that would be 18 built E- that you would ellow to be built today?

19 MR. OKRENT: New plants, yes. I would have i

20 independent decay heat removal systems, other features for 21 sabotage than we now have. I listed a few things and I would 22 look real hard at the containment capability. I think future 23 plants should have what we think is a real good containment 4

24 for core melt accidents.

25 They happen to vary. They weren't designed for core i

I i

24 1 melt accidents and some seem to do pretty well and others not 2 as well but that is the current ones. For future ones, I 3 would look for each and every one to do quite well as well as 4 one can anticipate and understand. They are no perfection.

5 That is impossible.

6 MR. WARD: I don't know if anyone else on the 7 committee had some comments they would like to make.

8 MR. REMICK: I would like to add one, Dave. It goes 9 back to the discussion with Max and Charlie. Early on I came 10 out, I think, pretty close, not exactly where Max and Charlie 11 do, that I would have felt comfortable if this was an FDA 12 limited to CP, Construction Permit.

13 CHAIRMAN PALLADINO: To what?

14 MR. REMICK: To construction permit only and the 15 thing that turned me in the direction of joining the majority 16 on maybe a five year was the concern over the fact that there 17 was not a final design of the UPPS system and therefore, how 18 could it either be a final design approval if there was no 19 final design on that system and also how could it be adequate 20 for operating iicense if you did not have that design of the 21 system.

22 So I just throw that in going back to the earlier 23 discussion. I do not differ much with them but the fact that 24 you did not have a final design of that system, I could not 25 see how it could be an FDA, OL or one-step licensing.

25 1 MR. EBERSOLE: I have been looking for a nuclear 2 workhorse for the country for 25 years, I guess, and --

3 CHAIRMAN PALLADINO: Please speak into the 4 microphone, Jesse. I don't think the people in the back of 5 the room can hear you.

6 MR. EBERSOLE: I would just like to say that in the 7 early phases of the evolution of all the reactors even the 8 organic cooled and so forth, I think I focused on the 9 practicality of the boiler as that potential workhorse and I 10 rather observed that the PWR's were enormously distorted in 11 extrapolated versions of submarines which didn't seem to be a 12 particularly 1cgical way to get a large scale power plant.

13 But the boiler on the other hand has what I would 14 call commercial characteristics and even as long ago as 1968, 15 we well knew that there were cooling methods for the boiler 16 which were super simple if you would just invoke them which is 17 reflected in the UPPS which I deny is even complete in its 18 conceptual content here.

19 GE thinks it is for, I think, the loss of power 20 primarily or really the problem of a boiler is to get the heat 21 out of the containment. The boiler still has to me a 22 completely inadequate reactivity control systen with its 23 hydraulic dumps and its multiplicity of valves and 24 complications and we have continuing records of its 25 mal-performance.

. . i 26 1 I see in this GESSAR II a close approach but not a 2 completion of what we should have, a model plant with which to 3 renew the nuclear initiatives and I think that could be 4 obtained by a relatively modest increases to GESSAR design, 5 one of which would be to completely describe the UPPS system, 6 give it full qualifications and tell it not just for a 7 specific set of minor capabilities but in totality recognize 8 it for what it is, about the simplest system with which you 9 could shut down the reactor that anybody can devise.

10 I presume you all know how simple it is. My cartoon 11 version is it enables you to close out a reactor safely with 12 an old man with a shack in the yard and a jockey pump in a

, 13 caged glass. That is quite true.

\

14 You need to make it seismic. You need to treat the 15 sabotage problem. You need to see that you protect for fire.

16 There are lots of things to do. Only the front edga of that 17 has been touched. The reactivity control system is notably 18 along with a few minor characteristics, notably susceptible to i 19 the most spectacular form of sabotage and yet it is not even 20 mentioned in the sabotage problem.

21 In short, it is a design so close to what I would l 22 call our practical workhorse, that it seems criminal not to go 23 ahead and complete it.

24 CHAIRMAN PALLADINO: Not to go ahead with what?

25 MR. EBERSOLE: Complete it and polish it off and

27 1 then turn it loose. There are lots more details to go into 2 but those are the front edge things I would like to mention.

3 CHAIRMAN PALLADINO: Thank you. Other comments by 4 ACRS members?

5 MR. WARD: It looks like there aren't any more from 6 the members, Joe.

7 (At this point in the proceedings, commissioner Zech 8 exited the Commission meeting.)

9 CHAIRMAN PALLADINO: All right. Let's see what 10 other questions the commissioners may have?

11 COMMISSIONER BERNTHAL: Could I just ask Jesse in 12 view of your comments and they are expressed very candidly, 13 does the ACRS in general agree that that is what you are all N

! 14 trying to tell us or is there a shading of opinion here?

15 MR. WARD: I think at least, yes.

j 16 MR. KERR: May I emphasize that the fact at least 1

17 that I haven't saidianything was because we did write to the 18 Commission a rather long letter after a considerable 19 deliberation and I assume you read those carefully.

20 CHAIRMAN PALLADINO: Yes.

21 MR. KERR: It isn't that these people who have i 22 spoken are the only ones who have looked at this design and 23 how have opinions.

l 24 COMMISSIONER BERNTHAL: Nevertheless, the reason I i

l 25 asked the question is that the letter is, I guess, sometime l

l

. i 28 1 back already and I haven't looked at it for a while, but I do 2 recall my lasting impression having been that it was pretty 3 grudging support of this design. It is sort of okay but you 4 have this and this and this and Jesse is maybe taking it a 5 step further but I am not sure I see all that much difference 6 between what he is being rather blunt about and what I See to 7 get as a rather softer approach in the letter.

8 MR. WARD: I think there was grudging support for it 9 only as a standard for the future and only as something that 10 could be licensed under a one-step process and was 11 incorporating the Severe Accident Policy and I think that is 12 all. We felt it had not addressed those issues properly.

13 COMMISSIONER ASSELSTINE: Dave, I guess the broader 14 question that I have is why shouldn't we be seeking now for 15 any new design including this one what Dave and Jesse seem to 16 be talking about which is let's make sure that if we approve 17 designs for future reactors in this country that they really 18 are ths kinds of designs that all of us want to see, the kinds 19 of designs that are not going to lead to many new surprises, 20 to constant changing of the plants, constant modifications of 21 the plants, constant adding to the complexity of the plants.

22 Why not once and for all do what is really needed to 23 be done to make sure that you do have a high quality design, 24 that it has margins of safety that really provide the kind of 25 protection that we want and that we understand the many

29 1 questions that the committee itself identified in its letters 2 as being sources for some continuing concern.

3 MR. KERR: May I try to respond at least from my 4 point of view?

5 MR. WARD: Certainly.

6 MR. KERR: If we knew how to do that and I guess 7 Mr. Ebersole does, I would be very pleased to endorse it. It 8 has been my experience and it is limited because I have been 9 around a university much of my professional life that severe 10 or large changes made in large industrial systems are subject 11 to considerable surprises.

12 It takes us a long time to learn how to get the bugs 13 out of a system. We have re9ctors that I think are safe. I 14 think they can be improved. But one does not necessarily get 15 out of a rather drastic cha.nta that may be proposed what one 16 always expects to get. There are inevitably surprises.

17 I feel more comfortable with an evolutionary 18 approach to changes with a goal in mind than I do with a 19 complete design.

20 I can remember the days when reactors were going to 21 be nothing but a pot in which you put fuel that would feed 22 steam to a turbine and they were going to be simple and safe.

23 I still think they are safe. They are not all that simple.

24 It is all well and good to say let's whatever you 25 want to call the decay heat removal system that is better than

30 1 we now have and that is okay, but once you start building the 2 thing, it becomes part of a reactor and an existing reactor 3 and it may have interactions. It may have weaknesses. It may ,

4 have effects on other parts of the system that we have not 5 anticipated and to say, "Why not let's build this thing so it 6 will have all of these characteristics we want it to have" is 7 a goal that is not automatically achievable from our point of 8 view.

9 COMMISSIONER ASSELSTINE: I guess the perspective i

i 10 that I have is that I am just not sure I understand what we 11 are gaining by approving something like this where there are 12 widespread concerns about whether this is really what we want 13 for a longer period of time. We are talking about a five year 14 approval. I have yet to meet any utility executive --

15 MR. KERR: That was not the question to which I was 16 responding. <

i 17 COMMISSIONER ASSELSTINE: Yes.

18 MR. KERR: I had some misgivings about the process 19 of review which were primarily associated with the use of the 20 PRA in arriving at some sort of decision about severa 21 accidents. I do not think this review should represent a 22 completed process because I don't think it was a very good l 23 process. I only hope it can be improved.

24 COMMISSIONER ASSELSTINE: Assuming for the moment f

25 that somebody isn't likely to buy one of these things in five .

l t

I - _ _ . _ - - , . . , . . _ , - _ _ - - - . - .

31 1 years, why shouldn't we insist that the process be done right, 2 the way that I think the ACRS letter reflects really should be 3 done for a future design?

4 MR. WARD: We did not assume that. .

5 COMMISSIONER ASSELSTINE: Do you think somebody is 6 going to buy one of these?

7 MR. WARD: I don't know. We took in good faith the 8 proposal that someone had some commercial use for it and we 9 evaluated it on that basis. I think if we were going to make 10 the other assumption, it would have been pointless for any of 11 us to spend our time with it.

12 MR. EBERSOLE: I would like to say something about 13 Bill's statement. I regard this improved BWR with good 14 features and some of the rather modest changes as in fact an 15 evolutionary change compared to that weird thing we call bias 16 and a host of other ideas that we currently have.

I 17 I don't see this as non-evolutionary and in fact, i

18 it has'been talked for 20 years. It is just really the i 19 materialization of long pre-existing ideas and i think a 20 rather modest extension of what we already have.

21 It is virtually tragic in my view not to incorporate 22 these features to make this ultra simple process of a basic 23 problem, getting the heat out of the reactor out into the l 24 sink, the heat sink, and we should have it in the design.

25 COMMISSIONER BERNTHAL: Would somebody explain to me l

l

l 32 1 for a moment, what are we going to do with this thing? Before 2 April 29th or whatever the day was --

1 3 COMMISSIONER ASSELSTINE: The 26th. l 4 COMMISSIONER BERNTHAL: I didn't get back until the 5 29th, that is the problem, or the 30th, but I realize that the 6 investment had already been made but it strikes me that we are 7 now looking at the year 2000 here and therefore, I would like 8 to know what we would do with this FDA today or what anybody 9 else would do with it and why, therefore, my attitude should 10 not be one of erring on the side that Jesse suggests here, 11 that since we have lots of time here, maybe we ought to take 12 our time.

13 Maybe I ought to ask that of the staff.

14 COMMISSIONER ASSELSTINE: That's right.

15 COMMISSIONER BERNTEAL: Is this a fire drill that we 16 are going through here that doesn't have a lot of meaning 17 right now? i 18 MR. WARD: I will speak for myself, I certainly 19 suspected that but as I said I think the committee took on 20 good faith that it was a sincere proposal for something and 21 we aren't in the business of judging which way the commercial 22 winds are blowing. We certainly have opinions.

23 COMMISSIONER BERNTHAL: Nor could you have at the 24 time.

25 MR. WARD: Right.

33 1 COMMISSIONER BERNTHAL: Now we are where we are on 2 June 5th, I guess.

3 CHAIRMAN PALLADINO: We were all sort of pushing 4 standardized designs and seeing if we couldn't get some of 5 them before us and examine them.

6 COMMISSIONER BERNTHAL: To an extent, we still 7 are. What I am saying is that the time table may have slipped 8 a bit.

9 MR. WARD: I think to an extent it might have been 10 just a useful exercise among the staff and the industry and 11 the ACRS for that matter in trying to figure out what was 12 meant by a standard design.

13 I think the ACRS thinks that the staff has come up 14 short in defining this sort of thing as an appropriate 15 standard design.

16 COMMISSIONER ASSELSTINE: Dave, by signing off on 17 this thing even fori some limited and perhaps meaningless 18 period'of time, aren't we sending the wrong signal to the 19 industry in terms of our seriousness of purpose in what we 20 really are looking for for the future.

21 Why should the industry believe us when we say that 22 we will sign off on this for five years but we really want 23 something better for the future. The next time you come in, 24 we really are going to be serious then. The next time we 25 really are not going to sign off on something that doesn't

34 1 reclly give us everything we are looking for.

2 Why aren't we better off by saying this doesn't --

3 it is an improvement but --

4 MR. KERR: Are you going to tell the industry what 5 it is you want?

6 CHAIRMAN PALLADINO: What is that?

7 MR. KERR: I said, are y;u going to tell them?

8 COMMISSIONER ASSELSTINE:' Oh, yes, I think we 9 should.

10 MR. KERR: The industry would say, I think, and I am 11 in no position to judge this, that it did what the commission 12 suggested that it do and the staff, at least, has concluded 13 that indeed the industry has met the standards that the 14 Commission set up.

15 It seems to me that the industry might get 16 discouraged if it thought it had done that and then suddenly 17 someone said, " Wells we didn't really quite know what to ask 18 you but we want to ask you something different but we aren't i 19 quite sure what except we want it better."

20 If indeed and this is I think an extremely important l

l 21 policy question but it seems to me if one tries to go through '

22 the exercise, then it should be made reasonably clear to the 23 industry what it is that the Commission wants.

24 COMMISSIONER ASSELSTINE: I agree with that very 25 much, Bill, and it does seem to me that the committee's letter l

l

\

35 l

1 1 provides a good foundation on which to do just that if for 2 nothing else than saying, "If you are going to have a safety 3 system that you are placing great reliance on like this 4 ultimate plant protection system, we really want to enough of 5 the details at least to understand the concept and better yet 6 to really understand the details of what this system is going 7 to be and we also want to understand how the nuclear steam i

8 supply system is going to work with the balance of plant so 9 that we don't have the oodles and oodles of interface problems 10 that we have had in the past."

11 MR. KERR: I don't quarrel with that. It seems to 12 me these are in the nature of minor changes and not major 13 ones.

14 CHAIRMAN PALLADINO: Let me make a couple of 15 points. I think we got some very valuable comments here but 16 we ought to also hear from the staff. They went through a 17 process and they came out with some conclusions. They are not 18 prone to jump at conclusions but like all of us, there are 19 places where improvements can be made. I think we ought to 20 hear them.

21 Then we ought to decide for ourselves what our role 22 is in this FDA process. We have never defined that. That is 23 why I made my comment in my earlier statement and I would like 24 to rather than jump to a conclusion of what our role ought to 25 be, I would like to solicit and suggest and get comments on

O *1

/

36 1 what our role might be.

2 But nevertheless, we are always in a supervisory 3 role as well so I think we ought to hear the staff even before 4 we get to settling that issue rather than just say that it is 5 all bad because I gather ther6 are some good things in here.

6 We shouldn't lose the good things.

7 We have tb make sure that 'we don't set objectives 8 such as sometimes set for airplanes that if you met them all, 9 the plane would not* fly. But we want it to fly and we want it 10 to be safe, both. So we are always in that dilemma of

~

11 choosing among good things.

12 I think we should not leave with the idea that this 13 is all something that we ought to throw away. I think we 14 ought to hear the' staff and build on it.

1 15 COMMISSIONER ASSELSTINE: 'I agree with that.

16 ~ I am sorry, Max.

CHAIRMAN PALLADINO.: I knew you

/

17 had your hand up but I was moved to make these comments.

18 MR. CARBON: That was fine. I just wanted to

- 19 respond, too, to a couple of your comments, Jim.

20 One is, there seems to be sort of an implication in 21 what you were saying that this isn't a quality product and I 22 think we can't say that because both the staff and the 23 committee ag}eg that it is better than what exists now.

24 COMMISSIONER ASSELSTINE: Yes. I think in my view 25 it is more not ' finished than not quality.

1 1

4 e 37 1 MR. CARBON: Yes, but it is better than what we 2 have. The second point that goes with that, the vendor and 3 the staff both believe that they have met all of the NRC 4 requirements and regulations. So when you ask how can you 5 prove it, you almost have to ask also, how can you not prove 6 it.

7 COMMISSIONER BERNTHAL: Would somebody explain to 8 me, I realize that is not why we are meeting today, but I 9 would like to know how the Commission is supposed to take 10 this? Would somebody explain to me what is going to be done 11 -with this FDA even assuming we gave it?

12 (Laughter.)

13 COMMISSIONER ASSELSTINE: It is going to sit on the 14 shelf.

15 COMMISSIONER BERNTHAL: Is there someone from the 16 staff that has a remote idea of what GE intends to do with it?

17 COMMISSIONER ASSELSTINE: They are not going to go 1

18 to hearing?

19 COMMISSIONER BERNTHAL: Is this an academic exercise 20 or what are we doing?

21 MR. CARBON: I am not from the staff but we were 22 told by the staff and the Applicant two, three, four, five 23 months ago before Chernobyl that what they hoped to do was to 24 be able to go overseas with this approval to sell plants.

25 COMMISSIONER BERNTHAL: Thank you.

l 38 1 COMMISSIONER ASSELSTINE: To help the export market.

2 COMMISSIONER BERNTHAL: I think Harold is going to 1

3 volunteer here. l 4 CHAIRMAN PALLADINO: Harold.

5 COMMISSIONER ASSELSTINE: It is just evaporating 6 away.

7 COMMISSIONER BERNTHAL: Having just been overseas.

8 MR. DENTON: I can't add a lot to the discussion 9 but--

10 (Laughter.)

11 MR. DENTON: You approved a policy statement that 12 provided certain provisions for two plants that had been under 13 review for along time. That was CESSAR and GESSAR. We 14 attempted to review those applications against the standards 15 you established and we think they are met. Now what GE is 16 going to do with it, I don't know and perhaps GE would like to 17 address that question.

18 But you hinted in your policy statements that you

19 wanted the staff to continue with this and so we did but to 20 the actual utilization of it, I wouldn't want to speculate.

21 Perhaps GE would like to answer.

l 23 staff's defense that you are right. I think the Commission, 24 something that I disagreed with, but I think the Commission 25 said what they were prepared to be satisfied with on future

39 1 standardized designs and my impression is you tried to meet 2 those standards.

3 MR. DENTON: Yes. This plan had been under review 4 for a long time. Now we do know that GE has another plan 5 under development called the ABWR that they are now talking to 6 us about and I presume that you want us to review that one.

7 (Laughter.)

8 COMMISSIONER ASSELSTINE: That one holds more 9 promise.

10 MR. DENTON: Although I don't know what the market 11 is for that one but we are talking to them about that one 12 which incorporates even more safety features than the one 13 that is here. We reviewed it under the Commission's 14 direction.

15 CHAIRMAN PALLADINO: I would like to add a couple of 16 comments. I think it is all right for us to ask what is going 17 to be done with this but our job is when we get serious 18 proposals from industry and wants to get an approval which we, 19 the Commission, have authorized, I think it is incumbent upon l

20 us to go through the process.

21 They are the ones that have to decide whether it is 22 worth it to them and whether or not they might sell it. Our 23 job is to make sure it is a good design, a safe design and 24 meets the regulations and the objectives that we set forth.

25 So even though there might in our eyes not seem to l

{

40 1 be a market, it was a good faith proposal in accordance with 2 our rules and regulations and it is up to us to review it.

3 MR. OKRENT: As I understand it, there is a 4 difference of opinion between the staff and the majority of 5 the committee as to whether in fact the Commission's severe 6 accident policy was properly implemented in this review. So 7 the staff thinks it has done this and I think if you just look 8 pro forma at the words, they have gone through the motions 9 that are asked.

10 So then it becomes a question, I think, of has this 11 met the standards and has it accomplished the purposes that 12 the Commission expected when plans were being reviewed 13 with regard to severe accidents.

14 CHAIRMAN PALLADINO: That is a fair question and I 15 think is part of the review and that is why I raised the 16 question about what the Commission's role is in this and I 17 think the Commission's role ought to be clarified by the 18 Commission.

19 COMMISSIONER ASSELSTINE: Joe, I think it is fair 20 for us to ask ourselves having approved a process, is the 21 product that we ended up with in that process what we 22 expected? Is this the way we expected the process to work?

23 Did we come up with a product that we are really pleased with 24 and that we are really satisfied with? Is this the way we 25 wanted the process to work and is this the result we were

l 41 l

1 looking for?

2 CHAIRMAN PALLADINO: I think Chet had a comment.

3 MR. SIESS: I was going to try to summarize this but 4 I looked back at the letter and I can't add anything to it.

5 But there have been a lot of references here to future 6 plants. This is a future plant in the sense that if one of 7 them gets built, it is going to get built in the future.

8 But it is not a future design.

9 COMMISSIONER ASSELSTINE: Yes.

10 MR. SIESS: It is a design that has been sitting 11 around for a long time and it is nothing like what we expect 12 to see as future designs for new plants or new designs for 13 future plants or something.

14 I think we looked at this and said that the health 15 and safety of the public is not going to be endangered if one 16 or two of these things get built. Our main concern was with 17 with the process. I think what we said is if you come in with 18 another FDA under the Severe Accident Policy and the Safety 19 Goals, it better be done better than this or we are not going 20 to stand for it.

21 Now there is not that much disagreement on the 22 committee about that. Max and Charlie maybe disagreed mildly 23 on it but it isn't a future design.

24 COMMISSIONER BERNTRAL: I thought that is what Jesse 25 was saying.

i 42 4

1 (Laughter.)

2 MR. EBERSOLE
Let me comment on that. I worked on 3 the standards committee for years and I found early on that a 4 standards committee was doing precisely just developing 5 standards, what we are already going by-in-large, an averaging 6 process, a standards process. What is everybody doing? It is 7 a leveling process that says what are we all doing. It is not 8 necessarily a process of extrapolating or improving anything.

9 To this extent, the connotation of a standard plant is that it ,

10 is what we are already building.

11 I consider this plant to be a warmed over heart 12 swell.

13 MR. KERR
That is what it is. I agree.

14 CHAIRMAN PALLADINO: Charlie had a comment.

15 MR. WYLIE: I agree with both what Dr. Siess and 16 Jesse had to say but it is a standard consideration of a 17 standard design is a matter of degree and when we talk about 18 future' designs and consideration of future design, that is the 19 tough issue that has to be addressed as how much detail is 20 going to be put in these applications.

21 Of course, I am sure you are familiar with the AIF 22 proposal and they are groping with that problem and that yet 23 has to be determined. That is one of the tough parts about 24 this one. It is not determined and a lot of the controversy 25 here is about how much degree is in this proposal.

l l

43 1 COMMISSIONER BERNTHAL: Let me just comment. I

~

2 didn't want to have the staff misunderstand. I think it is 3 important to go through this demonstration process of what the 4 Commission expects and in any case if a vendor wants the 5 Agency's opinion on the safety characteristics of a design, we 6 are obliged, I think, to give it to them.

7 But I did want to hear it said which is what I 8 suspected that this really is a question of the NRC saying I 9 what it can say by way of FDA if it is willing to do that for i 10 a design that is far more likely to be exported than to be 11 used here in the next five years.

12 So then the question becomes one of whether today on

/ 13 June 5, 1986 the Commission wants to put an FDA stamp cnt this 14 particular design, whether it meets the criteria that we are 15 pleased to say should be exported. I am not presuming to 16 answer that question. It is a serious question but it seems 17 to me that is the policy issue that is before us.

18 We ought to understand what we are doing here. If a 19 five year final design approval rest assured we all agree will 20 never be built in this country at least so since we all know 21 what we are talking about here, I think the policy issue is 22 one of what the NRC and the Commission is willing to say is 23 going to get an FDA with whatever weight that carries for the 1 24 sake of export to other countries.

25 COMMISSIONER ASSELSTINE: You are not suggesting it l

l l

44 1 is okay to build one as long as you don't build one here.

2 COMMISSIONER BERNTHAL: There won't be one built 3 here. I am not making a judgment on that point at all.

4 CHAIRMAN PALLADINO: Well, I am not that smart about 5 the future but I think we do want to encourage improved 6 designs. If plants are built, we want to make sure they are 7 improved plants and I again say we went through a process that 8 was set up by the Commission, we ought to follow through on 9 our review and make a decision.

10 What suddenly occurred to me was that I didn't know 11 what our role, the Commission's role, in this whole process 12 was and I would like to clarify it and then see what ought to 13 be done to make this process produce the kind of thing that we 14 want.

15 COMMISSIONER BERNTHAL: Just to repeat again, I 16 think it is crucial that we understand what we are doing here 17 and I am not very good at seeing into the future either but I 18 would bet that this plant will not be built here. That is 19 okay. There have been other circumstances where it appeared 20 that someone might come before us even foreign vendors in one 21 or two cases and say, "We want the NRC to review a plant 22 because it is important to us in the world market to know what 23 the NRC thinks and to get an FDA if we can get it."

24 That is fine. There is nothing wrong with that but 25 that is what we are talking about here from a practical

45 1 standpoint. We are not probably talking about anything likely 2 to be built on American soil.

3 CHAIRMAN PALLADINO: I remember Eugene Wigner saying 4 ne wasn't very good at predicting or even picking the designs 5 that were going to develop in the future.

6 He said if he had been working on automobiles in the 7 early days of the automotive industry rather than nuclear

, 8 reactors he would have said, " Well, by golly, the one car that 9 will never be built, never be commercially viable is the 10 internal combustion engine." '

11 He says, "

It has a complicated cooling system, it j 12 has a very complicated electrical system. It has start-up

13 problems. It has mechanical design problems, thermal stresses 14 you wouldn't even believe."

i i 15 He said that he would have said, "And it had 4

16 clutches and gears and what-not" and he would have said, 17 "Never, never be the one that becomes commercial."

18 So he says, "See, history would have proved him 19 wrong" and so he doesn't try to make predictions about the l

20 future.

21 Now I am not saying we shouldn't make predictions 22 about the future. We have to look at the future and we have l 23 to make sure that what we are designing is going to meet the i 24 requirements of safety for all the people in the country.

25 So whether it is going to be built in this country i

1 v-----. - - - - , , - - - - - - - - - - - - - - - - , -,---en - ,

- e,n, - - - - ---.,-,.~,,,-a,, ,,m- -.-.-,,-, rwa --- - , = -= _,r-

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46 1 or not, I would hate to take a position but rather go on with 2 the process and improve it so that what we get out of it is 3 what we think we ought to have.

4 COMMISSIONER BERNTHAL: If I can say so, Eugene 5 Wigner was referring to internal combustion compared to maybe 6 a steam engine or an electrical car.

7 CHAIRMAN PALLADINO: No, he was comparing it to an 8 electric car.

9 COMMISSIONER BERNTHAL: Oh, to an electric carl 10 MR. LEWIS: Steam engines are better.

11 CHAIRMAN PALLADINO: Yes, they are.

12 COMMISSIONER BERNTHAL: The point being that in this 13 case we are comparing GESSAR II to the Advanced Boiling Water 14 Reactor already on the drawing board which is a little more 15 like comparing the internal combustion engine in 1915 to 1920 16 or 1925.

17 CHAIRMAN PALLADINO: To tell you a little bit about 18 the steam car, if the improved boiler from the steam car had 19 come a bit earlier, we might have been driving more steam 20 cars.

21 COMMISSIONER BERNTHAL: Absolutely.

22 MR. LEWIS: But they are slow to start. The problem 23 is you have to get up a head of steam and that is what makes 24 them not viable.

25 COMMISSIONER BERNTHAL: But I entirely agree with I

47 1 what you have said but tell it to the people who are saying we 2 can't handle complex technology. Look at the space program 3 and look at Chernobyl. I agree with you, Joe.

4 COMMISSIONER ASSELSTINE: Joe, I would say for 5 myself if I were making predictions about the ordering of 6 nuclear power plants for the next five years or so, what I f

7 rest my judgment on is those people that have to put the money 8 down to buy one.

1 9 CHAIRMAN PALLADINO: That's right.

10 COMMISSIONER ASSELSTINE: All those people are 11 saying, "No way." So I think to the extent that I make a 12 prediction, it is based upon that and I think that is a pretty 13 reasonable basis to base the judgment on.

14 CHAIRMAN PALLADINO
Even the "no way" thinking 15 changes over a period of time but let's not divert ourselves 16 from the fact that we have a very valuable set of comments.

i 17 We ought to hear from the staff to understand the result of 18 their sork which was quite significant, quite lengthy over a 19 long period of time and examine for ourselves what role, we 20 the commission, should play in it.

21 I would like to see us follow through on all those 22 although it won't be before June 30th, I don't believe, but I 23 will get my memo out for you to think about. Forrest.

24 MR. REMICK: Could I make one comment on something 25 you said in your opening address, Mr. Chairman? You talked

48 1 about standardized plants and some things that the Commission 2 should address.

3 CHAIRMAN PALLADINO: Designs, not plants.

4 MR. REMICK: . Designs, yes. It takes me back a 5 couple of years to OPE days when the Commission was talking 6 about standard plants and one-step licensing and that is still 7 a matter up for discussion.

8 I always thought that when you talked about you were 9 going to do this by rulemaking, that sounded very neat but I 10 never quite understood what it meant. So from time to time 11 whenever I have an opportunity and it has not been a 12 concentrated effort, but I have talked to colleagues in OPE.

13 I have talked to them at OGC. I have talked to members on the 14 staff.

15 Does anybody know what you mean when you say that it 16 is going to be done by rulemaking? I have yet to find anybody 17 who could tell me that there was an understanding of what 18 those terms meant.

19 I was told once that somebody either in OGC or OELD 20 began to look at it but then they got diverted. I could be 21 wrong but my impression is that this whole process of handling 22 these things, the one-step licensing, by rulemaking hasn't 23 been flushed out.

24 COMMISSIONER BERNTEAL: Full litigation and hearings 25 just like making a rule and I would also comment --

l

t 49 1 MR. REMICK: So with hearings?

2 COMMISSIONER BERNTHAL: Yes, indeed. One of the 3 tragedies I would say perhaps more than the hardware of the 4 Clinch River process is that it has been overlooked, I think, 5 somewhat in retrospect that that was probably a good 6 demonstration of how we are going to go procedurally on a 7 standardized plant design approval. It will be something like 8 that at least in my mind.

9 MR. REMICK: Like Clinch River, Appendix K, those 10 types of things. That is what it is?

)

11 COMMISSIONER BERNTHAL
Full litigation of the 12 complete design essentially ahead of time.

13 COMMISSIONER ASSELSTINE: Yes. Forrest, I think the

(

14 Commission's legislative proposal calls for an adjudicatory 15 hearing on the design issues prior to the Commission issuance 16 of a design certification.

! 17 COMMISSIONER BERNTRAL: Right.

i 18 MR. REMICK: I see.

i 19 COMMISSIONER ASSELSTINE: Now once that was done, 20 then those issues would not be fair game in the follow-on

! 21 hearings on issuing the combined construction permit and 22 operating license. You would only look then at the issues of 23 the sites basically, any issue that was left over that was not 24 considered as part of the design, the design interface with j 25 the site.

i

~ .. _.. - -- - -- -- .- . _ - - .

50 1 MR. REMICK: Would there be staff review in advance 2 of the hearing? I assume there would be.

3 COMMISSIONER ASSELSTINE: Oh, yes.

4 MR. REMICK: It would be similar to the process that 5 is now used.

6 COMMISSIONER ASSELSTINE: That's right.

7 COMMISSIONER BERNTHAL: The staff would be a party 8 to the proceeding.

9 COMMISSIONER ASSELSTINE: Yes.

10 COMMISSIONER BERNTHAL: Everybody would cose to this i

11 giant party and it would go on for years.

12 COMMISSIONER ASSELSTINE: The design approval that

( 13 we are talking about would precede that. In essence, the 14 staff would just as it does now would arrive at its position 15 to the point where they were satisfied with the design. Then 16 you would go to hearing on these.

17 MR. REMICK: So you feel that that process if fairly i

18 well fieshed out?

19 COMMISSIONER ASSELSTINE: It is not spelled out.

20 CHAIRMAN PALLADINO: In concept.

21 COMMISSIONER ASSELSTINE: Yes, in concept, that is 22 right.

23 MR. WARD: It is sort of like UPPS.

24 COMMISSIONER BERNTHAL: I think in many respects, 25 perhaps even in the respect that DOE may and up playing some

r 51 1 role in this standardized hearing process, the Cinch River 2 proceeding may form the closest thing we have had to a model.

3 I want to reserve that comment a little bit but it 4 has not been much talked about but I suspect that that is the 5 case. It is thoroughly adjudicated before it died.

6 COMMISSIONER ASSELSTINE: Some of the issues were

(

7 any way.

8 COMMISSIONER BERNTHAL: I agree it wasn't completed, 9 that is right.

10 COMMISSIONER ASSELSTINE: Yes, that is right, and it 11 was still a two-step process.

12 COMMISSIONER BERNTHAL: It was still a two-step.

13 That is true.

14 CHAIRMAN PALLADINO: Let me ask if the committee 15 members have any other comments or Dave, do you have other 16 comments?

17 MR. WARD: jI do have one other comment.

18 Mr. Chairman, I think that unless something extraordinary 19 happens, this will be the last time we meet with this 20 distinguished body with you as its head.

21 CHAIRMAN PALLADINO: Do you mean the commission is i

22 losing its head?

i

! 23 (Laughter. )

24 MR. WARD: Right.

25 (Laughter.)

l l

e 52

1 CHAIRMAN PALLADINO
Excuse me, Dave.

2 MR. WARD: It might seem like a long five years to I

3 you, but I would like to congratulate you on your record and 4 accomplishments in those five years. It has been, I think 5 everyone will acknowledge, an extremely difficult time for the 6 Commission, for the whole business. But I think your 7 experience and judgment will be missed by your fellow I

8 Commissioners and by the staff.

9 I think the ACRS has appreciated your thoughtful ear 10 and understanding ear relative to the advice we have given 11 you. Five years of advice, think of that. Isn't that great?

12 (Laughter.)

13 MR. WARD: You have, I think, shown an understanding

{

14 of what we are trying to say and sometimes we need help in 15 getting it across. I don't know what your plans are. There 16 is an opening on the ACRS.

17 (Laughter.)

18 MR. WARD: I will just call that to your attention.

i 19 COMMISSIONER BERNTHAL: You are not allowed to tell i

20 him that.

I 21 (Iaughter.)

1 22 CHAIRMAN PALLADINO: Thank you very much for your 23 kind remarks. I am not used to kind remarks so I don't know 24 how to respond.

25 (Laughter.) j d

e

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53 1 CHAIRMAN PALLADINO: But I have to say that it has 2 been a very challenging job, often a very arduous job, I think 3 almost always a frustrating job because of the time it takes 4 to get things done but it is a deliberative process and i 5 think we have to face up to making sure that we cover all 6 bets.

7 Let me say that I am not worried about the future of 8 the commission. I think I leave it in good hands, very 9 dedicated people and a comparably dedicated ACRS and I think i

10 this Commission will continue to benefit from the advice that 11 you give and will heed it in many respects.

12 So tha'nk you very much. I will look forward to

[

13 sitting in the audience once in a while and see how these 14 meetings go from that side. Anything more?

15 (Applause and standing ovation.)

16 CHAIRMAN PALLADINO: Thank you. We are adjourned.

f 17 (Whereupon, at 3:26 o' clock p.m., the Commission 18 meeting was adjourned, to reconvene at the Call of the chair.]

19 20 21 22 23 24 25

l a e 1

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: Meeting with Advisory Committee on Reactor Safeguards (ACRS) on GESSAR II (Public Meeting) 8 PLACE OF MEETING: Washington; D.C.

9 DATE OF MEETING: Thursday, June 5, 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 i 18 .

- b.gjl246!- Mt.'f&

Marilynn M. Nations 20 21 22 Ann Riley & Associates, Ltd.

23 24 25

I I

UNITED STATES j'

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^g NUCLEAR REGULATORY COMMISSION

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s ADVISORY COMMITTEE ON REACTOR SAFEGUARDS

., tg / W A$iHNGTON, D. C 206SS g, . .v. .. /

January 14, 1986 Honorable Nunzio J. Palladino Chairman U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Dr. Palladico:

S E'ECT: ACRS REPORT RELATED TO THE FINAL DESIGN APPROVAL OF THE GESSAR II BWR/6_ NUCLEAR ISLAND DESIGN APPLICABLE TO FUT PLANTS .

During its 3C9th meeting, January 9-11, 1986, the Advisory Committee on Reactor Safeguards completed a review of the reference design described in the General Electric Standard Safety Analysis Report (GESSAR safety II) for Cesign Approval (FDA). GESSAR II provides the a Final infcrmation fcr a reference system consisting of a single BWR/6 Mark III nuclear stea , supply system, with a design power level of 3730 MWt,(and the associated systems and structures, including the reactor building shield building and containment), fuel butiding, diesel generator buildings, control building, auxiliary' building, and radwaste building.

Subco mittee meetings were held with representatives of the General Electric Company (the Applicant) and the Nuclear Regulatory Comission (MC) Staff on October 18-19, December 4-5, 1984, and February 14-15, 1985 in Los Angeles, Calif.; on March 27-29, 1985, in Albuquerque, New The Perico; and on August 7 and September 11, 1985 in Washington, D. C.

full Committee considered this matter during its 299th through 309th meetings held monthly from March 1985 through January 1986.

We telieve that the GESSAR II design includes features that provide If this a

significant im;;rovement in safety over current BWR designs.

were an application for a construction permit for one er more plants of this design, we would have no hesitation in recommending its approval.

However, we are unable to agree with the Staff, for reasons discussed below, that the design satisfactorily or completely addresses all of the concerns described in the Comnission's Severe Accident Policy.

While there is no doubt that, in the future, new plants should be consistent with the Severe Accident Policy, we see no harm in the approval of the GESSAR II design, provided that this approval is for a limited time (say five years), and provided that this procedure not be viewed in any way as a precedent for the handling of future applica-tions. In particular, the information provided to us in connection with GESSAR II would not be suffici.ent to support an application for a one-step license.

Our concerns about the review and the review process are elaborated in the following paragraphs.

kh( hk  :

I January 14, 1986

, ,0 Honorable Nunzio J. Palladino

~

We believe that reviewing tne GESSAR II design under the Severe Accident Policy was premature and incceplete. We do not see how the Severe Accident Policy can be implemented for an FDA while the policy on safety goals is still in the process of being developed. The NRC Staff's severe accident review of the GESSAR II design was based on the accept-ance of values of core-damage prcbability and the use of cost / benefit analyses that may turn out to be quite different from those adopted by the Cnmmission for implementation of the safety goals. These and other concerns are discussed in the following items:

In its policy statement on severe accidents, the Commission did not provide detailed guidance to the Staff concerningThe therequire-safety philosophy the Commission desires for future plants.

ment for completion of a PRA and of a Staff conclusion of safety acceptability leaves the matter of desired safety level undefined and emething to be decided ad hoc for each future plant or stan-dard plant design application.

The Applicant and the Staff both evaluated the cost / benefit However, ratio the of a large number of potential safety improvements.

approach used by the Staff is that which has been used in the past and may or may not be that which the Commission will adopt in its continuing consideration of its Safety Goal Policy.

We believe that further evaluation is needed regarding the likeli-hcod of loss of centainrent integrity, given an accident leading to melt-through of the reactor pressure vessel. Should this likeli-hoed be large, as the Staff says it is, the acceptability of such a characteristic of centainment behavior for a future plant should have the benefit of a deliberate evaluation, even if the Tailure is delayed.

The Staff preposes to leave the question of seismic risk, including the fragility of equipment within the GESSAR II scope, to the censtruction permit stage. The Staff is confident that some, as yet unspecified, criteria for the seismic contribution to risk of

, severe accidents can be met at that stage without significant changes in the approved design. We do not share that confidence in the absence of a decision on a safety goal.

The Staff consultants were provided only limitedBecause resources to of the review the internal fleeding portion of the PRA.

limited effort and the unavailability of design details vital to an evaluation of various flooding scenarios, the consultants were not able to estimate adequately the fleeding contribution towhile Thus, core some melt, which the Applicant calculates to be small.

effort was made, the Staff's evaluation of the PRA was limited in this respect.

(1) the Our concerns about the FDA process include chiefly two are amount of detail

. 1 i

..

  • Honorable Nunzio J. Palladino January 14, 1986 desig6" and (2) the nature and definition of the interfaces between the nuclear island and the balance of plant, especially those that must be expressed in terms of reliability to meet the intent of the Severe '

Accident Policy. These concerns are generic to the standard plant concept and have arisen in our deeper examination of GESSAR II in terms of the Severe Accident Policy. Their resolution necessarily will be evolutionary; but, in our opinion they have not been adequately resolved in the GESSAR II application and review. Some of our concerns are described more fully in the following:

. The Applicant has committed to incorporate an ultimate plant l protection system (UPPS) in the GESSAR II design, which could reduce the incidence of core melt accidents. However, the detailed design of this system has not been provided; it is to be provided at the time of a specific plant application. As a result, the Staff has not been able to evaluate thi; proposed system, nor have we.

We are concerned that the scope of the FDA is not defined and ,

doct ?e nted with sufficient comprehensiveness and detail.

We believe that this is necessary in order to make clear what changes in 19e design or in the plant can subsequently be required by the Staff without their being justified under the backfitting rule.

The interface requirements are not sufficiently well specified in l terms of minimum, quantitative performance requirements for systems and components of importance to an evaluation of core melt frequen- l cy and risk. Hence, there is no real assurance that a plant built in accordance with the GESSAR II design will meet or better the Sta'f's estimates of accident frequency and consequences. Also, there is no interface requirement aimed at limiting the number of challenges arising from the balance of plant to those assumed in the PRA.

Over and above the questions relating to the severe accident review and adequacy of the FSAR for an operating license stage document, the ACRS thinks that the fcllowing matters warrant consideration for the GESSAR II. #

We believe that the design of the scram discharge systen has basic deficiencies in concept in the form of a preclosed dump volume.

Consideration should be given to means, which may be relatively simple, to avoid continuing problems with this design.

We believe that there should be requirements for a study of the effects of seismically induced failures of nonseismically designed components and structures on systems important to safety, for both GESSAR 11 and the balance of plant.

January 14, 1986

.. Honorable Nunzio J. Palladino

. General Electric maintains that with their choice of materials and proper attention to water quality, GESSAR II should be essentially free of stress corrosion tracking. We do not believe that this can be assured in view of the long prior history of surprises in regard to stress corrosion cracking. We recommend that any FDA should include provisions for monitoring and for replacement of deficient material.

Our findings and recommendations are as follows:

We believe that the GESSAR II design includes features that have the pctential to provide a significant improvement in safety over current BWR designs.

We are unable to agree with the Staff, for reasons discussed previcusly, that the design satisfactorily or completely addresses all of the concerns described in the Commission's Severe Acci Policy Statement.

We see no harm in the approval of the GESSAR II design, provided that this approval is for a limited time (say five years), and provided that this procedure not be viewed in any way as a prece-In p dent for the handling of future applications.

infor atien provided to us in connection with GESSAR !! would not be sufficient to su; port an application for a one-step license.

Additi ral cc- ents by ACRS members Max W. Carbon and Charles J. Wylie ard by ACRS Perber David Okrent are presented below.

Sincerely, .

David A. Ward c

Chairnan I

Additieral Co-ents by AC:ts Pe-bers Max W. Carbon and Charles J. Wylie It is our belief that the GESSAR II design represents an improvement in safety over SWR designs approved in the past and that the Applicant has met all NRC require ents. Many items remain cpen to final resolution, but considerable additienal review will be performed by both the Staff Therefore, we I and the ACRS for either one- or two-step licensing.

support the Staff's plan to issue an FCA applicable to one-step licens-l ing.

I J

. Fonorable Nunzio J. Palladino January 14, 1986 Additional Corrents by ACPS Member David Okrent I agree with the ACRS that the GESSAR II design (and NRC Staff review) '

does not satisfactorily or completely address all of the concerns described in the Commission's Severe Accident Policy Statement. I also agree with those specific ccncerns about the review and review process described in the ACRS report.

I do not concur with the Staff that the design and review are adequate for issuance of an FDA that has met the Severe Accident Policy State-ment, one which, according to the EDO recommended position, would be eligible for a five-year extension after a five-year initial award (and one for which the AIF proposes a ten-year approval period). I would have preferred rather that this be an interim report and that the entire matter, including the status of the GESSAR II review, be discussed by the ACRS with the Commissioners prior to further action on the GESSAR II FDA. In view of th? multiple problems of inadequate design detail, ircerplete Staff review, and potential conflicts with safety goal policy, among others, I do not think that GESSAR II should receive the

" qualified" FDA recorrended by the ACRS at this time.

I would like to elaborate on some of the concerns raised in the ACRS letter and introduce others that are not mentioned in the ACRS letter, as follows:

1. The seismic cesign and seismic FRA are inadequately defined. In SSER No. 3, the Staff determined that the GESSAR II seismic risk study did not eccel well the risk likely to be contributed by seismic initiators for an actual GESSAR Il plant at a typical site.

The Staff now reports that the point estimate seismic-induced core melt frequency nicht be as high as one-in-a-thousand per year for

" worst case" fragility values and un'avorable siting locations.

The Staff gives a point estimate of about 4-5 x 10-5 per year as the seismic contribution to core melt frequency, perhaps half of which is attributed to seismically induced relay chatter. The l

Staff's esticate of the seismic contribution to core melt frequency is not a mean value, and it is not practical to ascertain a mean l

[fromtheirreportedresults.

I am currently not able to ascribe a numerical value to the seismic contribution to10-3 However, I believe that the Staff estimate ritk . is too of about 4-5 x large to be accepted for the contribu-tion to core melt frequency from a single source or kind of acci-dent initiator. I believe this value is too large an overall core melt frequency to be accepted for a future plant or FDA. I recom-rnend that an overall total large-scale core melt frequency with a i

mean value of 10-5 per year be taken as the objective for future plants, and that about one-fifth of this objective should be a f

somewhat flexible objective for any principal contributor, such as i

an earthquake. Limitations on the contribution from individual sources will help reduce the impact of large uncertainties.

l i

Honorable Nunzio J. Palladino January 14, 1986 The Staff proposes to leave the question of seismic risk, including the fragility of components and equipment within the GESSAR II scope, to the construction permit stage. The Staff lists condi-tions to be met which could be interpreted as accepting a seismic core melt frequency such as the Staff estimates. The Staff further concludes that, if these conditions are not met, the utility applicant must demonstrate that this does not result in any significant increment in risk. But what is significant for a PRA?

Is it a factor of two? A factor of ten? The Staff provides no basis for judging what might be acceptable in this regard. The Staff also states that the site hazard curve must be bounded by the GESSAR II hazard curve, without explaining how uncertainties are to enter into such a bounding exercise.

Althcugh GESSAR II is well into the design stage. I believe that the merits of probabilistic seismic design bases should receive consideration in trying to achieve a smaller contribution to overall risk.

2. I believe that the FDA should not be approved with such incomplete and sketchy informatica available for the proposed ultimate plant protection systen (UPPS).
3. For future plants. I believe that a dedicated, sa fe ty-grade, independert system for removal of decay heat from the core and containment should be included, in consequence of the matters entering into the resolution of USI A-45, Shutdown Decay Heat Removal, unless a case can be made that all of its merits have been net in other ways. I favor hardening this system. This issue is discussed further in the next item.

4 In its review of GESSAR II, the Staff did not look beyond the current requirements for sabotage protection. In a letter to you dated July 17, 1985 concerning sabotage protection, the ACRS reco= ended that the Ccemission reconsider its design basis threat definition for sabotage protection and decide if the present

-definition shculd be recenfirmed or modified. The Comittee also

- reco= ended that the Comission consider whether the NRC Staff, in l the course of reviews of new designs, should take account of design options, and possible combinations of measures, which might have the effect of reducing or inhibiting sabotage or terrorist threats.

This matter should be dealt with before issuance of future FDAs, rather than as a possible backfit item. Specifically, I recomend that the following be factored into the design of GESSAR II (and its balance of plant):

a protected, independent, safety-grade shutdown heat removal systen

Honorable Nunzio J. Palladino -

January 14, 1986

., protection of the control rocm and other vital areas or functions against a vehicle bomb at the edge of the guarded site periphery by proper location, building strength, or other measures

. geographical separation of redundant systems, including the ultimate heat removal system

, special menitoring and access control of especially sensitive protection systems

. roof design to limit helicopter landing access In surrary, I believe that neither the state of the design nor the Staff's review process is adequate for issuance of a forward-looking FDA which has taken Severe Accident and Safety Goal Policy properly into acccunt. This is particularly so in view of the Comnission's own test in applying backfitting policy.

Refererces:

l. General Electric Company Standard Safety Analysis Report, "GESSAR

!!, BWR/6 Nuclear Island Design," with Amendments 1 through 20

2. LI . S. Nuclear Regulatory Commission, " Safety Evaluation Report Pelated to the Final Design Approval of the GESSAR II BWR/6 Nuclear Island Cesign" NUREG-0979, dated April 1983
3. Supplement 1 to the Safety Evaluation Report, dated July 1983 4 Supplement 2 to the Safety Evaluation Report, dated November 1984
5. Supplerent 3 to the Safety Evaluation Report, dated January 1985
6. Supplement 4 to the Safety Evaluation Report, dated July 1985 P

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