ML20207N377
| ML20207N377 | |
| Person / Time | |
|---|---|
| Issue date: | 01/08/1987 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8701140176 | |
| Download: ML20207N377 (107) | |
Text
?
ORIGINAL
~
UNITED STATES OF AMERICA
(-
NUCLEAR REGULATORY COMMISSION s
In the matter of:
COMMISSION MEETING
' Briefing on Status of Safety Goal Implementation (Public Meeting)
Docket No.
~(
I Location: Washington, D.
C.
Date: Thursday, January 8, 1987 Pages:
1 - 87 hDkIlf0hpfB70108 PT9.7 pgg
--ANN RILCY f. ASSOCIATES Court Reporters
(.
1625 I St., N.W.
Suite 921 Wachington, D.C.
20006 (202) 293-3950 J
's P
Os D I'S C L A 1 MER L
1
+
2 3
4 5
6 This is an unofficial transcript of a meeting of the 7
Un'ited States-Nuclear Regulatory Commission held on l
e 1/08/87 In the Commission's office at 1717 H Street, l
9
'N.W.,
LJa sh i ng t on,
D.C.
The meeting was open to public I
10 attendance and observation.
This transcript has not been 11 reviewed, corrected, or edited, and it may contain
[
(;
12 Inaccuracles.
I 13 The transcript is Intended solely for general l
l 14 I nf orma t i ona l, purposes.
As provided by 10 CFR 9.103, it is i
l 15 not part of the formal or informal record of decision of the i
16 matters discussed.
Expressions of opinion in this transcript 17 do not necessarily reflect final determination or beliefs.
No l
I l
18 pleading or other paper may be filed with t he Cona i s s i on in 19 any procanding as the result of or addressed to any statement i
I 20 or argumont contained herein, except as the Cemmission may 01 authorize.
20 C3 24 05
l A'
a :.
1 1-UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
'4 BRIEFING ON STATUS OF SAFETY 5
GOAL IMPLEMENTATION 6
7 (PUBLIC MEETING) 8 9
Nuclear Regulatory Commission l
10 Room 1130 l
11 1717 H Street, Northwest 12 Washington, D.C.
13 g
14 Thursday, January 8, 1987 15 16 The Commission met in open session, pursuant to 17 notico, at 10:00 a.m., the Honorable LA!!DO W. ZECH, JR.,
18 Chairman of the Commission, prociding.
l 19 COMMISSIONERS PRESENT:
1
(
20 LANDO W.
ZECII, JR.,
Chairman of the Commincion l
l 21 T!!OMAS M. RODERTS, Momber of the Commission 22 JAMES K. ASSELSTINE, Member of tho Commission 23 FREDERICK M. BERNT!!AL, Member of the Commission l
24 KENNETl! M. CARR, Mombor of the Commicolon 25 I
2 o
1 STAFF AND PRESENTERS SEATED AT THE COMMISSION TABLE:
2~
WILLIAM C. PARLER 3
SAMUEL J. CHILK 4
VICTOR STELLO 5
MATTHEW TAYLOR 7
JAMES SNIEZEK 8
JAMES TAYLOR 9
ERIC BECKJORD 10 AUDIENCE SPEAKERS:
11 GARY BURDICK 12 ZOLTAN ROSZTOCZY 13 14 15 16 17 18 19 20 21 22 23 24 25
I o-3 l. 0 ;*
1 PROCEED'INGS 2-CHAIRMAN ZECH:
Good morning, ladies and gentlemen.
p 3
Commissioner Bernthal will be joining us shortly.
4 The commission is being briefed today by the Staff 5
on the status of its work with the Nuclear Regulatory 6
Commission's safety goals.
The Commission approved its safety-7 goal policy statement on July 30th, 1986.
In approving the l
8 policy statement the commission recognized that the Staff 9
would require specific guidelines for determining whether a 10 level of plant safety is consistent with the Commission's-11 safety goal policy.
l 12 This guidance was to address matters such as plant 13 performanco guidelines, indicators for operational 14 performance, and the guidelines for the conduct of I
15 cost-benefit analysis.
In addition, the commission asked for 16 further Staff evaluation of a general performance guideline 17 that the overall probability of a large release of radioactivo l
18 materials to the environment from a major reactor accident 19 should be less than one in a million per year of reactor l
20 operation.
I i
21 This is an information briefing today and no 22 Commission decision is required this morning.
23 The EDO memo of January 2nd, 1987 entitled Safoty 24 Goal Implomontation Status says that the developmont of l
25 implomontation guidance will bo taking place during thic
o 4
1 calendar year and that commission approval will be sought 2
prior to formal Staff adoption.
In that memo the EDO states 3
that he has three enclosures dealing with regulatory framework 4
issues and program areas regarding safety goal implementation.
5 In the memo the EDO asked three questions.
The 6
first question concerns averted on-site cost.
The second, 7
large scale core melt.
And the third concerns a definition of 8
a large release similar to Chernobyl.
The EDO memo further 9
states that he intends to request further commission briefings 10 as progress is made towards eventually seeking Commission l
11 approval prior to publishing final Staff guidance concerning 12 cafety goal implementation.
13 In order to assist the Staff continuing efforts to l
14 develop implementation guidance that might ba acceptable to i
15 the commission, after our discussion today I believe that it 16 should be helpful if I put together a paper addressing the 17 issues that you've discussed in your memo of 2 January, and 18 perhaps other issues that we may discuss here this morning.
I 19 will then ask my follow commissioners to provido comments on 20 my paper and add any additional conments that they wish to 21 make.
And hopefully we could got you such a paper in several 22 weeks.
In this way I believe the commission can contribute 23 guidance and direction to the Staff as the package is being 24 generated.
25 All of un look forward to your presentation thin I
l
.a.
5 1
morning and to what I believe will be and should be a joint 2
effort to develop the important implementation guidance to our 3
safety goal 4
Are there any opening comments by my fellow 5
commissioners?
Commissioner Roberts?
6 COMMISSIONER ROBERTS:
No.
7 CHAIRMAN ZECH:
Commissioner Asselstine?
8 COMMISSIONER ASSELSTINE:
Lando, I agree with your 9
suggestion that we perhaps put together some guidance to the I
10 Staff on this.
I would suggest that because there are a 11 number of fairly fundamental issues that I think are resolved 12 at least on an interim basis by the Staff's proposed approach 13 that we address oursolves to that approach as well before the 14 Staff goes ahead even on a trial basis with this package.
15 Because it seems to me that there are a number of fairly 16 fundamental decisions that are either made or left entirely to 17 the Staff as a result of this package.
18 CHAIRMAN ZECH:
I agree.
This is exactly why I 19 think putting a paper together and putting it down in writing 20 by us so we'll really, perhaps be able to agroo to some of 21 those fundamental issues.
What are fundamental, what has been 22 decided and what hasn't been decided.
23 But as I road over the Staff paper it soomed 24 important to no that wo don't just give the Staff permission 25 to go off and do thic on a trial basis.
I think it's 1
a s.-
6 1
important that they perhaps use the guidance they've 2
presented, but not in execution without coming to the 3
-Commission, or at least telling us, this is a trial effort and 4
flagging for us what they want to do.
5 But it seemed-to me that -- I think I understand 6
what you're saying, and it does seem to me it's important-that 7
we the Commission put down what we think and what we 8
understand right now are the fundamental issues.
What's been 9
decided, what hasn't been decided, so that the Staff can 10 better pursue this without feeling that they're not getting 11 the guidance that they're asking for.
12 They're asking for guidance, as I understand their 13 paper.
I think we have a responsibility to give it to them.
14 I believe in going back to them in writing in some way saying, 15 here's what we understand the issues right now.
Here's what 16 We think is settled, here's what's not settled.
And that way 17 we can all participate in their development of this guidance, 18 which I think should be helpful to the Staff.
It should givo 19 them at least some guidance and allow us to participato as we 20 go along.
That's kind of my view.
21 COMMISSIONER ASSELSTINE:
I agrce with that.
22 (Commiccioner Bornthal entered the room.]
23 COMMISSIONER ASSELSTINE:
And I think for myself I'm 24 still at tho stage of trying to understand what all of the 25 implications of the various proposals and decisions that would
's o.;
7 1
be made in this document.
4 2
CHAIRMAN ZECH:
I think we all feel that way, and P
3
.that's kind of.why I thought we'd better step back and try to 4
help them, but not to get too far out in front of it.
5 COMMISSIONER ASSELSTINE:
Yes, good.
6-CHAIRMAN ZECH:
Commissioner carr?
7 COMMISSIONER CARR:
Nothing.
8 CHAIRMAN ZECH:
Commissioner Bernthal, I've just 9
given my opening remarks.
If I may, I'm going to give them to 10 you to read while we proceed.
11 COMMISSIONER BERNTHAL:
Good.
12
' CHAIRMAN ZECH:
Mr. Stello, then will you proccod.
13 MR. STELLO:
Thank you.
There is obviously a very 14 long history associated with a safety goal policy for the 15 Commission, and I don't believe it's necessary to rocap that 16 history.
If there's a need to get back in the history as to 17 why we are whero we are we'll do that if that nood arises.
18 But other than that, I think we'll just skip that for the 19 moment.
I think everyone is at least avaro of the long 20 history.
21 But an important part of that long hictory in --
22 what la clear is this is obviously a very, very complex 23 subject.
It is not one in which you can start to devolop very 24 clear, tight guidelinen and critoria to move forward, becauco 25 if you do without the honofit of the exportonco you really
i 9*
8
\\
1 don't have the insights of what the implication of drawing up 2
very stringent criteria might be in the future.
3 And that's led us to the conclusion that we can't 4
come and tell you that we're ready to have the Commission 5
approve us just en masse going forward with this document, 6
aven though the document itself has got an awful lot of 7
caveats and open ends to it.
8 The reason for that is very simplo.
This is a very 9
controversial subject.
One of which the Commission has had 10 considerable difficulty with various parts of it, as we in the 11 Staff have had.
And if you look at the ACRS briefings, I 12 think we're coming closer and closer to an understanding of 13 uhore to take the next step, but thero's still a great deal of 14 strongly held views about how you ought to go one way or tho 15 other.
16 I think it would be a big mistake today to try to 17 decide on any one of thcoe issues a rigid guideline for moving 18 forward.
I think we need to movo very, very slowly and 19 cautiously in applying safety goal policy within our 20 regulatory business.
And I think.the reason for that in tied 21 directly to the application of PRA.
22 In cimplo torma, that'n what I think a safety goal 23 policy is.
It is, in my view, a templato for applying the 24 results of PRA to decisionmaking in the regulatory prococc.
I 25 ntrongly nupport it.
I think the PRA technology han viven un
i t
t.
9 l
1 enormous insights about safety and we need to continue to take 2
the benefit of those insights and tell us where to go.
3 It also starts to develop bounds in some sense of 4
how we ought-to regulate and we need to tell the industry 5
that.
To me that means that both the industry has got to have j
6 an opportunity to try to use this kind of thinking as they 7
approach safety problems as well as us.
And we need to get 8
some experience in doing it.
9 Until we do, we're not going to be prepared to come 10 to the commission and say, we're ready to ask your epproval.
11 To the extent you can help and provide the comments as wo 12 start to try to develop that guidance over the next few years 13
-- and it is a few years.
I don't think it's even a year.
I 14 think it will evolve, perhaps over several years before we 15 really have the insights wo need to make those very difficult 16 decisions.
17 COMMISSIONER DERNTHAL:
Well, it may be, Vic, that 10 it will taka several yearn for the Staff to learn how to --
19 and for all of us to learn how to implement a policy.
But it 20 does not need to tako cavoral years -- in fact, I think wo 21 could and should have dono it by now -- for the commionion to 22 mako nono fundamental policy docinions.
And thoso decisions, 23 it sooms to me today you're right back whoro wo woro last 24 nunmar on them an nearly ac I can toll.
25 And in fact, what I would lika you to do in the
+.
10 1
briefing today, as best you can, is explain in detail exactly 2
what the difference is between this paper today and the paper 3
we looked at and discussed last spring.
I would like to have 4
outlined where the progress is; what's new in this paper l
5 today.
And I guess that's enough said for now, because I see 6
nuances but I don't see any significant departure from where 7
we were last time around on this.
8 And I have to say, it's probably the fault of the 9
people on this side of the table because we didn't really givo lo you clear guidance in those three fundamental areas, core 11 melt, containment performance, and how to deal with 12 uncertainties.
We simple didn't give you that, no I'm not 13 sure we could expect-to get it back.
But if you could do that 14 today, I'd appreciate it.
t 1
15 HR. STELLO We will try.
l 16 CHAIRMAN ZECH:
And of course, this in exactly the 1
17 reason I think that wo do own the Staff some of our moro la specific viewn on those areas.
Some decisions, I think wo 19 would all agroo, have been mado; others haven't.
Dut I think 20 if we put this down we will all fool a little bit bottor about l
21 having given the staff the guidanco that they really chould 22 have.
23 And wo'ro probably not going to all agroo on 24 ovarything, but I think by all of contributing wo will 25 cortainly unko como progrono.
And I agroo with you that wo l
f 11 1
owe that to the Staff,.and that's really the fundamental i
l 2
reason for my suggestion that we participate in this as we go I
t l
3 along.-
4 COMMISSIONER BERNTHAL:
Yes, I agree'with that.
My l
5 own views remain pretty much what they were last year.
I'm 6
certainly open to modifying those, but there are key elements 7
here that we've just got to provide the Staff before we're 8
going to got something back.
9 CHAIRMAN ZECH:
Right.
I think that's --
10 COMMISSIONER BERNTHAL:
You know, garbage in, i
11 garbage out, the old saying goes.
12 CHAIRMAN ZECH:
I think that's exactly right.
i 13 That's exactly the reason for my approach.
r 14 COMMISSIONER ASSELSTINE:
Frod, I very much agree 15 with you.
I thin that there were some gaps left open with the 16 safety goal.
Although I also think that it's fair to say that 17 at least in a couple of instances the Commission took oither 18 some tentative steps, or at loaot some exploratory stopo 19 towards identifying some of thoso elements that you talked 20 about.
21 We did any that wo wanted the regulatory program to l
22 function in a way that would provent any novoro coro damago J
(
23 accident at a U.S. plant.
That'o a ntop towardo, I think, at i
l 24 loant a coro damago or a coro molt critorien.
It wasn't 25 quantitativo, but at loant it una a ctop towardn it.
And I
c.
12 1
think one of the things I'm real interested in hearing from 2
the Staff is how they're interpreting that statement which was 3
a unanimous statement on the part of the Commission.
4 At least for discussion or exploration purposes wo 5
also agreed to the 10 to the minus six limit for a largo 6
releaso.
And that's another one whero I think it's going to 7
be useful to hear how the Staff is trying to interpret that 8
element, at least for discussion purpocos.
9 I agree with you, I was preparod a year ago to go 10 farthor in both of thoso areas, but at least there are como 11 steps, and how the Staff is interpreting those should give us 12 como indication of whethor we'ro really making progross or 13 not.
But the final olomont, I think, has to como from this
(
14 sido of the table where wo just simply mako como hard 15 docinions and any what it in wa're really looking for in terms 16 of the goals thomnolven, and than hold the Staff accountablo 17 for carrying those out in a fair way.
18 11R. STELLO:
You havo given mo an opportunity to 19 nay, I agroo, great, you solvo the problem.
Except I just 20 can't do that becauco I just don't think it'a going to bo that 21 onny.
I, again, urgo that you liston carefully and wo'ro 22 going to try to ancwor theco two quantions and othorn -- tho 23 difficulty that you havo in trying to atart to draw come very rigid critoria to deal with thono innuon without tho bonofit 24 25 of exporlonco.
0 13 1
Now remember, all of the major issues and rules that t
2 are going to be promulgated by this Commission, this 3
Commission is going to pass judgment on them.
To the extent 4
you give us guidance wo will include in those kind of 5
development of rules the implication of safety goals so you'll 6
soo it as it unfolds; you'll see it often.
And that will 7
provide both the Commission with a great deal more experience 8
to help make those judgments as well as the Staff.
And that's 9
basically what I wanted to do.
10 I don't want to tako up a great deal more timo with introductions and we won't got to the briefing.
Lot no just 11 12 introduco, at the table wo havo Eric Dockjord to my far right; 13 Jim Taylor; Jim Sniczekt Matt Taylor who will do a l
14 considorablo amount of the briefing; and Harold Donton.
l 15 Unless thoro's someone who fools the nood to extend this 16 introduction I'll got Jim Sniczek to start.
17 Cl!AIRItAN ZECll:
Proceed, thank you.
la MR. SMIEZEK:
Good morning, Mr. Chairman, l
19 Commiusioners.
20 CIIAIRMAli ZECll:
Good morning.
21 MR. SNIEZEK:
What wo're horo today -- put up slido 22 ono, planso.
23 t lido.)
24 MR. SMIEZE1; The first thing I want to cover is the 25 basic outlino of the prosantation.
I will very briefly l
l
9+
14 1
1-present a brief review of the August 4 Commission policy 2
statement and the current status of the Staff in implementing 3
that policy.
4 Matt Taylor will'then discuss the interim framework 5
for safety goal implementation and discuss the draft 6
implementation guidelines for use of the safety goal in 7
assessing generic issues.
I believe in that discussion you 8
will find, Commissioner Bernthal and Commissioner Asselstine, 9
the issues you raised.
We're going to try to show you how l
10 we're taking them into account as we're going forward to i
l 11 implement the safety goal policy itself.
l l
12 Slide two, please.
13 (Slide.)
l 14 MR. SNIEZEK:
In the August 4th, 1986 policy l
15 statement which was published in the Federal Register, the 16 Commission established two qualitative safety goals.
And the l
17 stated objective was to establish goals'that broadly define an l
18 accoptable icvol of radiological risk to the public from 19 nuclear power plant operation, i
20 The first goal was that individual members of the 21 public should bo provided a level of protection from the 22 conocquence of nuclear power plant operation auch that 23 individualn boar no oignificant additional rick to lifo and 24 hoalth.
l 25 The nocond was that societal risk to life and health
15 1
from nuclear power plant operation should be comparable to or 2
less than the risks of generating electricity by viable 3
competing technologies and should not be a significant 4
addition to other societal risks.
5 Slide three.
6
[ Slide.)
7 MR. SNIEZEK:
Additionally, the Commission 8
established two quantitative health effects objectives to 9
gauge achievement of the safety goals.
This was to be used as 10 guidance to designers and operators and was not to be used as 11 a substitute for existing regulations.
12 The first addressed prompt fatalities.
And that was 13 that the risk to an average individual in the vicinity of a 14 nuclear power plant of prompt fatalities that might result 15 from reactor accidents should not exceed 1/10th of 1 percent 16 of the sum of prompt fatality risks resulting from other 17 accidents to which members of the U.S. population are 18 generally exposed.
19 The second one was the latent cancer fatality health 20 effects objective.
And that was that the risk to the 21 population in the area near a nuclear power plant of cancer 22 fatalities that night result from nuclear power plant 23 operation should not exceed 1/10th of 1 percent of the sum of 24 cancer fatality risks resulting from all other causes.
25 Slide four, please.
4 16 1-(Slide.)
2 MR. SNIEZEK:
In addition,-the Commission commented i
3 on'the need for additional guidelines for regulatory-4 implementation.
Specifically, the commission stated that 5
additional implementation guidelines were needed in the area 6
of plant performance, such as core melt, containment 7
performance area; indicators for operational performance, such 8
-as management, maintenance, et cetera; and guidelines in the 9
-cost-benefit analysis area.
10 COMMISSIONER BERNTHAL:
Let me just make a comment 11 here to try and put these words in context.
We now have a 4
12 context that we didn't have a year ago when the commission 13 first started considering these issues.
And I would point out
- 14 that, Harold, those of you that worked closely in assessing 15 the Chernobyl event can correct me if I'm wrong, but arguably 16 there were no off-site prompt fatalities as a consequence of 17 the Chernobyl event.
18 So I just point that out to lay some context beside point number one that the risk to the average individual
~ 19 20 should not exceed 1/10th of 1 percent of the sum of the prompt 21 fatality risk results from other accidents.
Clearly, the 22 Chernobyl event would have met that criterion because there t
23 were no -- arguably were no prompt fatalities off-site.
24 And secondly, the latent cancer fatality risk.
25
_Again, we have the context there that, as I recall -- and l
L L
t
- -m-r-ve
-w
mw-
--e+-m
-- - = - - + r
- -ar r'*-
'---n~
-r
17 1
numbers are a little fuzzy here.
It's been a long holiday.
/
2 But the latent cancer risk as a result -- to the general 3
population as a result of the Chernobyl event was something 4
well under 1 percent of what you would expect for the general 5
population as a consequence of exposure to natural background 6
radiation.
I believe that that is the benchmark there.
7 So once again, if you compare the goals that we've 8
met here, I would just suggest that those two particular 9
criteria are not terribly stringent.
10 MR. STELLO:
You need -- if I can ask you to just 11 hold back, and we get into that.
You need to hear some more 12 about how that --
13 COMMISSIONER BERNTHAL:
I understand.
I'm just -- I 14 think I've accurately supplied some context here though that 15 indicates the nature of those criteria.
16 COMMISSIONER ASSELSTINE:
I think that's a valid 17 point, Fred.
The fact that the Chernobyl accident would pass 18 our safety goals is worth noting.
[
19 MR. STELLO:
Let me just say for the moment for the 20 record, it would not.
And you need to hear how we're going to
-21 do it.
It's explained in the paper, but maybe it wasn't clear 22 enough.
But let us explain it so that it is clear Chernobyl 23 would not pass our safety goal.
24 COMMISSIONER BERNTHAL:
Some aspects of it.
I was 25 specifically referring to --
L.
18 1
COMMISSIONER ASSELSTINE:
To the health effects 2
criteria.
3 MR. STELLO:
So was I.
We'll get to it.
4 CHAIRMAN ZECH:
Let's go.
5 MR. SNIEZEK:
The Commission also stated that they 6
wanted to review and approve any final guidelines to be used 7
by the Staff in these areas.
8 The Commission further stated that guidance to be 9
developed in these areas should be based on a proposed general 10 performance guideline which is to be further evaluated by the 11 Staff.
And that is the guideline that, I believe it was 12 Commissioner Asselstine mentioned, consistent with the
(.
13 traditional defense-in-depth approach and the accident 14 mitigation philosophy requiring reliable performance of 15-containment systems, the overall mean frequency of a large 16 release of radioactive materials to the environment from a 17 reactor accident should be less than one in one million per 18 year of reactor operation.
19 And one of the things we're doing is trying to i
20 define now what will be a large release of radioactive 21 material.
That's one of the issues that we are wrestling 22 with.
23 Slide five.
24
[Slidc.]
25 MR. SNIEZEK:
The Staff has developed an interim
19 1
quantitative and integrated interpretation of the safety goal 2
policy and the general performance guideline as a framework 3
for development of. specific Staff guidance in the various 4
areas of NRC's regulatory activities.
We're presenting today 5
our trial approach in this area.
6 COMMISSIONER BERNTHAL:
Let me just make one other 7
comment here for the sake of context again.
I would just 8
comment that this less than one in a million per year of 9
reactor operation, I'm sure you would agree, that is a 10 stringent criterion.
11 MR. STELLO:
Yes, that is a most stringent --
12 COMMISSIONER BERNTHAL:
As opposed to the tenth of a 13 percent health effects thing that I just commented on.
And 14 I'm very interested in hearing how we intend to interpret and 15-meet that exploration one per million reactor years of 16 operation -- if I've said it right.
But go ahead.
17 MR. SHIEZEK:
And we do not have a final answer in 18 that area yet.
We're just going to show you an approach that 19 vo're taking.
20 COMMISSIONER ASSELSTINE:
I agree with that, Fred, 21 although there are some variables there, one of which is how 22 you define a large release.
23 COMMISSIONER BERNTHAL:
Exactly, and I have my own 24 definition for that, but let's hear what --
25 COMMISSIONER ASSELSTINE:
Well, the Staff's got one,
l 20 l
1 too, that's kind of interesting.
(..
2 MR. SNIEZEK:
I'd mention also that we met with the s
3 ACRS on our approach on December 10th and also yesterday --
4 ACRS subcommittee.
And this afternoon we'll be meeting with 5
the full committee -- ACRS full committee on our approach 6
again.
7 At this time I'd like to turn it over to Matt 8
Taylor who will discuss the interim framework the EDO intends 9
to provide to the Staff to guide the Staff in its safety goal 10 implementation, and to discuss the draft implementation 11 guidelines for assessing generic issues in light of the safety 12 goal.
13 It should be understood that the guidance in these 14 areas will more than likely change as the Staff starts using 15 them on a trial basis.
Matt?
16 MR. M. TAYLOR:
Thank you, Jim.
Mr. Chairman, 17 fellow commissioners, what I'd like to briefly touch on is the 18 framework that we put together that would cover a nurber of 19 areas in the regulatory decision process.
20 Slide number six, please.
21
[ Slide.]
22 MR. M. TAYLOR:
The framework we've put together 23 envisions une of the NUREG 1150 results as an inportant first 24 resource to begin to build our tools on.
Basically 1150, as 25 you well know -- you have had briefings, I believe in recent
21 QL.
' months -- is a state-of-the-art of-PRA assessment.
It has f ~,
2 many attributes.
It has new source terms included.
It will 3'
have safety goal comparisons included, and it will include 4
improved uncertainty treatments.
5 As part of the work to commence implementation of 6
the safety goal, we have under development some tools that 7'
would assist the Staff in making assessments.
These would be 8
founded initially on NUREG 1150 plants, and can accommodate 9
other PRAs.
Basically these are the system analysis and risk 10
. assessment tools, and the IRRAS, or integrated reliability and 11 risk assessment tools.
12 Basically these tools would accommodate feedback 13 from new data or experience.
And we do expect to take a hard U
14 look at the Chernobyl impacts as part of our work here-to make 15 sure that we do cover the health effects, the large release 16 definition, and the economic impacts.
We want to-make sure 17-our models are d.oing a reasonable job in that regard.
We 18 believe they are, fairly accurate at this point.
19 With regard to specific guidelines, in our paper we 20 have attempted to cet forth an integrated framework that the 21 Staff might use as a template to guide their generic issue o22 resolutions primarily; to guide decisions with regard to plant f.
i
- 13 specific PRA results.
24 We have set forth some general ground rules in 25 implementation guidance to help craft detailed guidelines in
.--a
- m
22 1
the various regulatory decision areas.
We have set forth some b
2, plant. performance guidelines, and we have started one-3 definition for.the large release.
I will get to that in a few moments.
5 COMMISSIONER BERNTHAL:
One other thing that I would 6
like you to detail for us here is the question of population 7
density and where that is folded into your criteria here.
As 8
you know from last time around on this, all of our tenth of 9
a percent criteria, health effects criteria are -- as nearly 10 as I can tell, were from the beginning independent of 11 population density.
12 MR. M. TAYLOR:
That's correct.
13 COMMISSIONER BERNTHAL:
In other words, you could 14 have put a plant in Central Park and still met the criteria 15 because they dealt with hypothetical people.
I'd like to know 16 how we're dealing with the population density question.
17 MR. M. TAYLOR:
I believe I would just say -- I'll 18 try to get into that a little bit more, but I believe in two 19 respects.
Number one, if you look at the personrem aspects, 20 that is sensitive to population density.
21 COMMISSIONER BERNTHAL:
Right, okay.
22 MR. M. TAYLOR:
The other aspect is by use of the 23 large release definition we have here we constrain the 24 population -- different population sites to certain health 25 effects independent of the individual risk.
In other words,
23 1
it does. constrain'the integrated risk across all sites.
2 COMMISSIONER BERNTHAL:
Okay, go ahead.
3 MR. M. TAYLOR:
In developing the framework or the 4
. proposed framework for. safety goal implementation we looked 5
across a number of regulatory areas where the safety goal.
6 might be a useful factor to help as part of the decisionmaking 7
process.
We identified a number of areas and there are a 8
number of subareas that are in the paper.
But basically these 9
are with respect to generic issues --
10 I'm scrry, slide seven, please.
11 (Slide.]
12 MR. M. TAYLOR:
These are generic issues; severe 13 accident decisions; decisions with regard to source term 14 related changes; plant specific requirements as these evolve 15 perhaps through severe accident policy implementation.
If 16' outliers are found the safety goals could be used here as a 17 helpful decision factor.
In assessing regulatory priorities 18 for perhaps research, inspection resources.
19 We believe it is useful for helping gauge the risk 20 significance of operational events.
And ultimately we see an 21 opportunity perhaps to address the safety goal in the final 22 environmental statements since we do display the Class 9 23 accident, or severe accident risk through that vehicle in the 24 regulatory process today.
25 We are looking forward to completing most of the
- .1 24 1-detail implementing: procedures in a period of about one year.
2 And we would look forward al'so to periodically briefing the 3
Commission on our progress.
After.that time we would look
.4' forward to formal. commission approval to go forward with this 5
' implementation plan in hand.
6 Slide eigh't, please.
7
[ Slide.~]
8 MR. M. TAYLOR:
What I have just touched on is
'9 briefly shown in a very-busy slide here.
This shows how the 1
10 pieces fit together.
As I mentioned, there are a number of 11 attributes in the NUREG 1150 work.
We have other insights 12 that we can use from other plant specific PRAs.
And we can 13 fold this into-the decision process in the regulatory.
14 implementation areas shown by this' figure.
15 As I pointed out, we have developed some specific 16 guidelines that we would hope to use to craft the detail 4
17 implementing procedures.
i 18 I'll move on from this one.
Number nine, please.
19
[ Slide.)
20 MR. M. TAYLOR:
We have set forth some general 21 ground rules for the Staff to use in implementing and 22 developing the implementation of detail implementing 23 procedures.
We would expect the safety goals to be used in t
24 conjunction with traditional review methods.
We fully l.
25 acknowledge that there are issues of plant management that i
. ~.
e 25 1
still remain.
We look towards the plant performance indicator 2
program to perhaps detect trends in this regard.
3 The books are still not closed with regard to the 4
treatment of uncertainty, and Research is doing considerable 5
amount of -- the Office of Research -- considerable amount of 6
work in this effort, and we would hope NUREG 1150 would 7
provide further enlightenment in this regard.
8 In terms of the use of the PRAs, those that might be 9
brought to bear beyond 1150 we would -- NUREG 1150 data and 10 results -- we would expect peer review to take place before we
.11 would enter those into the process.
We intend to assure that 12 the safety goal decisions include both external event and 13 internal event initiators.
And consistent with the policy 14 statement, we would not use the safety goals for the security 15 and sabotage issues.
16 COMMISSIONER ASSELSTINE:
When you say internal and 17 external event initiators, does that include sabotage?
18 MR.
M. TAYLOR:
No, it does not.
19 COMMISSIONER ASSELSTINE:
Okay.
20 MR. M. TAYLOR:
That largely addresses seismic 21 events.
22 We believe the safety goals can be very useful and 23 an authoritative factor in arriving at regulatory safety 24 decisions.
And as Mr. Stello pointed out, we would expect to 25 begin addressing that in connection with rules and regulatory
=.
26 1
guides or other decision vehicles.
2 I think it's important for the Staff to keep in mind 3
that licensees must still meet the NRC's regulations.
We 4
would intend the implementation guidelines to address both 5
future plants and existing plants and also resolution of a 6
number of outstanding generic issues that are presently on the 7
books.
8 CHAIRMAN ZECH:
Before you move off that one, let me 9
just say here -- and I notice on the previous busy slide that 10 you do mention the severe accident policy -- but it seems to 11 me that in your ground rules for implementation it's important 12 to recognize that the Commission has made some rather 13 significant decisions in other areas than the safety goal over 14 the past year or so.
We've made decisions regarding severe 15 accident policy, the backfitting rule, hydrogen rule, and 16 perhaps others that should be looked at in total.
17 I think, if I recall, a month or so ago I made the 18 suggestion that we have some kind of a staff review of all of 19 those policy to ensure we have consistency in what we're 20 doing.
And it seems to me that that's still an appropriate 21 thing to do.
I hope we're doing that.
Are we?
22 MR. STELLO:
We have that paper under preparation, 23 and I hope to have it down in several weeks.
24 CHAIRMAN ZECH:
Fine.
Okay, it is important that we 25 review the decisions that we have made and when you get
27 1
Friday --
2
[ Laughter.]
3 CHAIRMAN ZECH:
-- take a little bit more time to 4
review it.
I think that's appropriate.
But it's important 5
that this gets factored into -- as I think Commissioner 6
Asselstine and Commissioner Bernthal, too, have alluded to 7
earlier, we have made some decisions and they should be stated 8
and recognized.
And we want to have a consistency.
9 Now if you get different guidance from the 10 Commission, that's fine.
But we've done those things.
They 11 should be consistent and you should look for a thread of 12 consistency throughout what we're doing.
13 MR. STELLO:
I know it was a light moment, but we're 14 going to answer that question.
But again, that's because it's 15 such a complex issue.
16 CHAIRMAN ZECH:
I understand.
The whole issue is 17 complex, but it's important that we not make these very 18 important decisions in isolation.
And I'm just trying to say 19 from a management standpoint, from a good business standpoint i
l 20 we should keep those integrated.
4 21 MR. STELLO:
Absolutely.
22 CHAIRMAN ZECH:
And because we -- and it may show 23 that we've gone a different way in one aren than another.
If 24 that's it, then we should be aware of that.
But it's 25 important that we review the total package and all the i
i
.i 28 1
decisions that we've made in these rather complex areas.
2 MR. STELLO:. And the paper makes clear that those 3
are also constraints that the Commission has already imposed 4
on us.
5 CHAIRMAN ZECH:
Good.
6 MR. STELLO:
And we said that in the paper, we 7
intend to live with that.
8 CHAIRMAN ZECH:
I'll look forward to your paper.
9 Proceed.
10 MR. M. TAYLOR:
Slide number ten, please.
11 (Slide.)
12 MR. M. TAYLOR:
With regard to the general 13 performance guideline that the Commission offered in its 14 safety goal policy statement we have offered some thoughts 15 here on one approach.
We would intend to apply this to both 16 existing and future plants.
We believe that whatever the 17 particular large release definition would be or the risk of 18 exposure, it should be reasonably consonant with the mortality 19 risk objectives that the Commission has used to gauge the 20 achievement of the safety goals.
21 We would hope to capture acceptably the accident 22 uncertainties and the risk dominant releases by our 23 definition.
And we would also include in our further study of 24 this matter include any insights from Chernobyl that would 25 indicate we perhaps should adjust factors in our codes and so
29 1
forth.
2 We believe that the mean frequency for large 3
releases should capture the more serious early containment 4
failures, large magnitude releases, and even the bypass 5
possibilities.
We have offered one approach here.
This may 6
not be the final approach that further study shows is 7
appropriate, but we have elected to constrain to a limit line 8
approach at less than 10 to the minus six for one early 9
fatality at'all distances and affected population beyond the 10 site boundary by the use of the CCDF.
11 Now I would say this is -- and CCDF is a 12 complementary cumulative distribution funct!.on.
I'm sorry, I 13 did not spell that out here.
This is a display of the
,r 14 probability versus a particular risk outcome of the chance of 15 having a risk outcome greater than a certain value.
This is 16 customarily presented in most PRAs and it has been used in, I 17 believe, somewhere around 30 final environmental statements 18 sont before the public, this risk display.
19 At present NUREG 1150 is displaying the effects 20 of this particular CCDF approach for large releases versus the 21 uncertainties involved.
And I believe you have been shown 22 that in the recent months.
We believe it is capable of being 23 used as a surrogate as was suggested by the Advisory Committee 24 on Reactor Safeguards to assure a reasonably high confidence 25 that safety goals have been achieved.
That is the 0.1 percent i
30 1
individual risk objectives.
2 As I would note this final bullet, we have not 3
foreclosed on other large release definitions and would plan 4
to look at this further and hopefully get back,to you at some 5
future date.
6 COMMISSIONER BERNTHAL:
Why are we struggling so 7
much with this definition for a large release?
We have a 8
legal definition that is woven through Price-Anderson that 9
this organization has applied over the years to serve as a 10 threshold, and that's the extraordinary nuclear occurrence 11 threshold.
12 Why it is such a struggle to come up with a 13 definition for large off-site release when I would have 14 thought that the extraordinary nuclear occurrence threshold, 15 however we end up defining it -- we're in the process of 16 redefining it, I guess -- would be the logical criteria?
17 MR. STELLO:
Let me see, as I remember those numbers 18 they are less than Part 100.
19 COMMISSIONER ASSELSTINE:
That's right.
20 MR. STELLO:
Then you would be suggesting that Class 21 9 accidents have to meet more stringent criteria than the 22 Commission has promulgated in its regulations as the 23 requirements that dictate the design basis accidents through 24 Class 8.
I'm not sure I understand --
25 COMMISSIONER BERNTHAL:
Maybe you ought to say that
31
-I in plain English.
2' MR. STELLO:
The Commission's regulations require 3
the design envelope to be analyzed so that you do not --
4 throughout the Class 1 through Class 8 accidents exceed the 5
doses set forth in-10 CFR Part 100.
The definition that's 6
included in extraordinary nuclear occurrence set dose criteria 7
which are significantly lower than those that are in Part 100.
8 That would be tantamount then to saying that the 9
Commission has taken a position which would require more 10 stringent criteria for Class 9' accidents than Class 8.
And I 11 cannot understand --
12 COMMISSIONER.BERNTHAL:
It's easily dealt with, 13 Victor.
I mean, if you don't like that criterion, then at
(
14 least you peg it to the extraordinary nuclear occurrence 15 criterion.which seems to me to be a logical thing to do.-
And 16 by the way, we, I think have not reached a final decision yet 17 on what the definition of ENO is going to be.
That's still 18 before the Commission, so I think you're statement is a little 19 premature on what it may or may not be.
20 But even if what you say -- and I gather what you 21 say now certainly is true under the current ENO definition --
22 you know, pick your quantitative factor if you wish for Class 23 9 accident.
But still there's a benchmark there that's 24 quantitative, it seems to me, and I would hope gets simplified 25 in the final definition for ENO.
32 1
Why not apply that to this case?
It's a suggestion 2
that I've made many times, and again, I don't understand why
~3 this is such a struggle.
If what you say is the case, and it 4
may well be that that's an inappropriate level, then we can 5
still use that as a benchmark and decide what the appropriate 6
level is, it seems to me.
7 MR. STELLO:
I think you need approach that very 8
carefully and very cautiously in terms of options that could 9
significantly improve safety that could be precluded by 10 incorporating those kinds of definitions.
Let me give you one 11 example.
12 You heard a proposal several months ago on Mark I 13 containment which would suggest that we go through filtering 14 systems through the pool and, hence, release only the noble 15 gases.
I haven't done the calculations.
My expectation is 1G the 50 million curies being released through the pool you 17 would be nowhere near meeting the criteria for the ENO.
And 18 hence, you're precluding having important safety features that 19 could significantly enhance safety by taking that kind of an 20 approach.
That's what I mean about saying, go slow, go 21 carefully.
22 What we have done is try to frame -- and if you let 23 us get through it -- a proposal on how to define this that 24 gets to the real safety issue, hurting people.
That's what 25 we're all about.
Our mission, our charter is to prevent
,e
.rm w
---e
33 1
people from being hurt.
That's what we have tried to describe 2
to encompass the entire spectrum of the Class 9 accidents.
3 What we have taken as a given is that all of the 4
accidents up through class 8 are governed by existing 5
regulations now.
Since we're talking about accidents clearly 6
more severe than those, it would seem at least logical the.
7 the criteria, in terms of consequences to the public would be 8
something above those specified in the current regulations.
9 That is, bigger than 25 rem whole body or 300 rem 10 thyroid.
That the consequence for class 9 accidents are 11 clearly expected to exceed those.
It would seem incongruous 12 to have the Commission suggest that we would have criteria 13 that for an accident more severe than we're designing for that 14 we have set dose criteria more stringent.
That doesn't make 15 any sense to me.
Have I made my point?
16 COMMISSIONER BERNTHAL:
I'm not sure I understand 17 what you're saying.
18 CHAIRMAN ZECH:
I think we've got a different 19 discunsion perhaps, and maybe we ought to just let them finish 20 what we have here today and leave that for some other time.
21 COMMISSIONER ASSELSTINE:
I think that's a fairly 22 important part of what they're doing, Lando.
But let me ask a 23 question if I could.
I thought I saw something in the paper 24 that indicated that your definition of a large release was 25 basically an SST-1 release.
Am I right about that?
34 1
MR. M. TAYLOR:
No, that's not correct.
I pointed 2
out an SST-1 release at a certain frequency level would
~
achieve the Commission's safety goals.
I pointed out that we 3
4 are more stringent --
5 COMMISSIONER ASSELSTINE:
That's somewhat 6
frightening in itself as well.
7 MR. M. TAYLOR:
Well, at a certain frequency level.
8 It was very low frequency.
9 MR. STELLO:
Excuse me, we're getting confused.
10 Risk has two elements to it.
It has an element of a 11 probability of occurrence --
12 COMMISSIONER ASSELSTINE:
And consequence, that's 13 right.
14 MR. STELLO:
It is clear that you could always apply 15 one more what-if in terms of probabilities to reduce a 16 question to what's the chances of an accident one in 100 17 billion.
That will be an SST-1, I assure.
18 So if you're going to say, all SST-1s have to be 19 precluded, then let's shut down this business because that i
20 clearly is impossible.
You can't make the risk zero.
21 COMMISSIONER ASSELSTINE:
That's right.
22 COMMISSIONER BERNTHAL:
That's a straw man.
23 Nobody's arguing that, Vic.
I mean, it's cicar you can't -- I 24 don't even know what reasonable assulance of no core melt 25 means, which is the wording the Ccmmission used in the safety
i 35 1
goal.
2 But I would also make one other point.
You said 3
-that our business is make sure people don't get hurt.
4 MR. STELLO:
Right.
5 COMMISSIONER BERNTHAL:
That's the first order of 6
business.
The law also requires that we protect property.
7 That's also a requirement of the Commission, so let's not 8
leave that element out.
9 MR. STELLO:
What I eculd suggest'is, could we 10 explain at least the proposal.
I think there are questions 11 that are answered if we could get to explain it.
I was 12 dealing with a very specific question.
13 An SST-1 release, by definition, if that's low 14 enough in probability it must be acceptable, yes?
15 COMMISSIONER ASSELSTINE:
Yes.
But you're talking 16 about in the context here of a performance guideline that says 17 we want to keep a large release at a frequency of less than 10 18 to the minus six per reactor year.
What I want to know is, 19 how large are you defining a large releane?
20 Now Fred says, all right, maybe you can set it at an 21 ENO.
You say, all right, that's below Part 100.
One option 22 is setting it at Part 100 -- what we thought we were designing 23 these plants for to start with.
But what I'm trying to do is 24 get a point of reference for how are you defining large 25 release?
Are you defining it as something so big that it has
36 1
to be an'SST-1, which was above Chernobyl, or are you defining
,s.
2 it somewhat lower than that?
3 MR. STELLO:
Let us explain.
4 CHAIRMAN ZECH:
Go ahead.
5 MR. M. TAYLOR:
The next slide, please.
6
[ Slide.]
7 COMMISSIONER ASSELSTINE:
And if you could also 8
relate that to how it relates to Part 100 release levels.
9 That way we know how you're benchmarking it against what we 10 thought we were designing these plants for in terms of class 1 11 through 8 accidents.
12 MR. M. TAYLOR:
I'm not sure I can benchmark this
(
13 precisely against Part 100 at this point in time.
I would 14 expect we would try to make that a consideration for further 15 study.
16 COMMISSIONER ASSELSTINE:
It strikes me that that's 17 a fairly relevant inquiry here.
18 MR. M. TAYLOR:
Sure.
19 COMMISSIONER ASSELSTINE:
We thought we were 20 designing these plants to limit releases to a certain level 21 for Classes 1 through 8 accidents, the design basis for the 22 plant.
And it would be interesting to know what you're 23 talking about here in terms of beyond design basis accidents, 24 how far above those releases you'd be pretty to accept.
25 MR. M. TAYLOR:
Fine.
This viewgraph illustrates
- s.
37 1
the approach that is being taken at this point in time in s
2 1150.
It's.one conceptual approach that is available for 3
examination.
It is a traditional, as I pointed out, PRA 4
display for risk.
Basically, the area under this 5
complementary cumulative distribution function represents the 6
mean value of the risk.
7 In this case we have elected to propose a limit of 8
less than or equivalent to 10 to the minus six at one early 9
fatality at all distances, all points beyond the site 10 boundary.
This is basically the fundamental input that would 11 go into the calculation of the safety goal.
This approach --
12 of the safety goal individual risk objectives.
13 This approach, we believe, should provide us around 14 95 percent confidence if this is achieved, that the safety 15 goals are -- individual risk objectives of the safety goals 1.6 are also achieved -- very high confidence.
17 COMMISSIONER ASSELSTINE:
Does that mean that what 18 you're doing is defining the large release as a release 19 sufficient to cause at least one prompt fatality?
20 MR. M. TAYLOR:
That's correct.
21 COMMISSIONER ASSELSTINE:
So Chernobyl would not be 22 a large release; is that right?
23 MR. M. TAYLOR:
If it was at high enough frequency, 24 yes, Chernobyl would be folded in here.
25 COMMISSIONER ASSELSTINE:
Why does the frequency
38 1
come in?
It seems to me the frequency of the criterion is the 2
10 to the minus six.
It's not?
3 MR. M. TAYLOR:
This is used as a constraint.
Ten 4
to the minus six is used as a constraint for all large 5
releases that would threaten the safety goals; all large 6
releases.
It would include small releases with high 7
frequencies, large releases with low frequencies, all release 8
paths from the plant.
9 MR. STELLO:
Let me see if I can help.
You've got 10 to think in terms of the results of the PRA, which is a 11 spectrum of releases with a variety of frequencies.
And if 12 you're going to do this task in defining the consequences of 13 the Class 9 accidents, don't you really feel an obligation to 14 integrate over the entire spectrum so that even if you had 15 accidents whose consequences might be, in terms of magnitude 16 of release, fairly sma11 but have high frequency -- high 17 frequency of core melt that lead to these kind of things, but 18 never have an SST-1.
19 I mean, you never get containment failure in that 20 context, of a very early large release of those kind.
Then 21 you clearly want to take those into account, too.
So what 22 you're trying to accomplish is a way in which to do the full 23 integration over the entire spectrum of possible accident 24 consequences.
If you got a large number of people exposed 25 oven to modest amounts of radiation, when you calculate in
39
'l terms of probability and integrate them you get one.
You 2
would have maybe one fatality, two, three, as you integrate 3
them.
4 And we said, when you're finished with the 5
integration, it's no more than one.
But clearly, as you have 6
less or lower and lower frequency kind of events, 10 to the --
7 you remember the Sandia studies that went down into the 8
conditional probabilities of 10 to the minus 11 you had 9
calculated large numbers of fatalities at the 10 to the minus 10 11 numbers.
So it's bringing the entire integration over the 11 entire spectrum of accident consequences and frequencies.
So 12 you have to have both.
13 COMMISSIONER BERNTHAL:
Is this intended to be 14 carried out then on a plant specific basis, Vic?
Is this 15 where the population density gets folded in?
16 MR. STELLO:
It would come in here, yes.
17 MR..M. TAYLOR:
It would come in here, yes.
And 18 also the personrem aspects.
19 MR. STELLO:
Excuse me, that answers part of the 20 question that you raised.
When you do this integration, if 21 you had a site which had a close in population you're going to 22 have considerably more difficulty in meeting this kind of an 23 approach than one obviously with very little population 24 involved in it.
So this starts to take that kind of thing 25 into account.
Y 1
s 4
40 1
MR. M. TAYLOR:
Well, I will not dwell further
,.~
2 unless there are questions on this particular slide.
3 CHAIRMAN ZECH:
Let's go, proceed.
4 MR. M. TAYLOR:
Number 12, please.
5 (Slide.]
6 MR. M. TAYLOR:
In considering the total integration 7
of the elements in the safety goal policy, including core 8
melt, off-site health effects, and the 10 to the minus six 9
large release criteria, we tried to put together a cost 10 benefit approach that reflected a sliding scale of incentives 11 to improve the core melt frequency primarily.
And 12 particularly, the incentives get much higher if the principal 13 safety goals, off-site health effects, are not achieved.
14 Where the safety goals are achieved we have a 15 sliding scale that is commensurate with the core melt 16 frequency.
And where we have very high core melt frequencies, 17 if those are found to exist, of course, the issue of cost is 18 mooted.
We would propose to fix those.
19 We have used $1,000 per personrem as a surrogate for 20 the societal health effects and property damage costs 21 off-site.
And also, we would include in the cost benefit 22 analysis the effccts of on-site occupational health effects 23 whether these be associated with an accident or associated 24 with safety improvements that we might require at the plant.
25 Thece are also to be valued at $1,000 per personren.
41 1
We would note also that in NUREG 1150 the full 2
spectrum of cost benefit results, with and without the use of 3
averted on-site costs will also be displ'ayed so that the 4
Commission can see the effect of inclusion or non-inclusion of 5
this factor.
6 Thirteen, please.
7 (Slide.]
8 MR. M. TAYLOR:
Now this is a rather busy slide that 9
I apologize for.
I will not dwell on this extensively, but 10 this display the matrix proposal that reflects a sliding scale 11 for cost benefit that is tied to the large scale core melt 12 frequency.
The top of the slide, the first horizontal row at 13 the top of the slide would be aiming points that we would hope 14 to encourage for future plants.
15 COMMISSIONER ASSELSTINE:
How does this matrix 16 diffor from the matrix that you presented to us the last time 17 around and the Commission said no to?
18 MR. M. TAYLOR:
I was unaware the Commission said 19 no.
20 COMMISSIONER RODERTS:
That was my impression.
21 COMMISSIONER BERNTHAL:
That answer is, not at all.
22 COMMISSIONER ASSELSTINE:
That's my impression is 23 it's exactly the same.
24 COMMISSIONER BERNTHAL:
I have the previous one in 25 front of me.
42 1
COMMISSIONER ASSELSTINE:
This one is smaller.
It's 2
harder to read.
3
[ Laughter.)
4 MR. M. TAYLOR:
It is harder to read, sir, but there 5
is a change.
We have built in the large release frequency as 6
a surrogate.
So this does not differ appreciably with that 7
exception.
8 MR. STELLO:
This issue is so complex that I brought 9
everything the Commission has sent me.
And I don't know when 10 the Commission said no to this table.
It said no with respect 11 to putting it in your policy in August.
12 COMMISSIONER BERNTHAL:
That's right.
13 MR. STELLO:
But also told the Staff, take that i
14 table and start to look at how you would use that in 15 implementation.
Does I understand it correctly?
16 COMMISSIONER BERNTHAL:
That's right, the commission 17 basically said, don't give us that for safety goal because we 18 can't understand it and the public isn't going to understand 19 it.
But if you feel that that's the sort of thing you want to 20 use as an implementation guideline, then that I think --
21 CHAIRMAN ZECH:
That's right.
22 MR. STELLO:
That's what we're telling you about.
23 COMMISSIONER ASSELSTINE:
But make us understand --
24 CHAIRMAN ZECH:
What we said was, we weren't 25 enamored with the table.
We wanted you to look at it
43 1
further.
And none of us, I don't think, were ready to buy off 2
on it at all.
We needed you to look at it more and to 3
convince yourselves and convince us that this was the right 4
approach to take.
5 We certainly didn't say no outright, but we did 6
voice concern, and certainly no approval at that stage.
7 But we didn't tell you to throw it out completely.
We said 8
you need to convince us with further evaluation and analysis 9
that it was sensible.
So I think we're kind of where we 10 started last time.
11 COMMISSIONER ASSELSTINE:
Fair characterization.
12 MR. STELLO:
And quite frankly, these have all of 13 the controversial issues wrapped up in this table as well, for 14 which there are strongly held views, such as averted on-site 15 cost.
I don't think it's worth even trying to go through 16 that, but all of these issues we're going to have to get some 17 experience in deciding where to go.
18 COMMISSIONER ROBERTS:
Can you get me a copy of this 19 that's legible?
20 MR. M. TAYLOR:
Yes, sir.
21 CHAIRMAN ZECH:
I think we'd all appreciate that.
22 None of them are very legible, I don't think.
23 MR. M. TAYLOR:
Moving on to the next viewgraph.
24
[ Slide.]
25 MR. M. TAYLOR:
This viewgraph is a simple
w 44 1
illustration of how the personrem is coupled to population 2
density, as Commissioner Bernthal inquired, as a function of 3
core melt.
It's a simple display, or an illustrative display 4
of what the cost benefit algorithm would provide you across a 5
spectrum of core melts.
And I would not on the vertical that 6
the cost would be the justifiable cost for safety expenditures 7
as a function of the core melt.
8 Note that the black bar is -- at the top of the 9
black bar represents high population sites.
At the bottom 10 would be reflective of low population sites.
And the 11 horizontal bar in the white or black horizontal mark is where 12 the average population site would lie.
13 I think it's important to note that when one 14 disapp, ears below core melt levels of, say, less than 10 to 15 the rinus four there simply is not a very high justifiable 16 cost for safety expenditures through most of the cost benefit 17 algorithms that we've considered.
18 MR. STELLO:
I would say that we would use that as a 19 relative term.
I'm sure some in the industry would look at 20 these numbers in the millions of dollars as still being 21 substantial.
Everything is relative.
22 CHAIRMAN ZECH:
Right.
23
[ Slide.]
24 MR. M. TAYLOR:
One other part of the package that 25 we provided you, there were some example interim procedures
'r 45 1
that we developed as sort of a benchmark for-the Staff perhaps 2
to use for guidelines and coming up.with their detail 3
implementation procedures in the other decision areas.
This 4
particular -- this is enclosure two in your package.
5 Basically we completed that this month.
We would 6
hope this would serve as a benchmark for other implementing' 7
procedures.
We would propose to try this out for one year, 8
subject to revision as experience may dictate.
We would seek 9
final Commission approval after its trial use.
10 This is a possible candidate for updating eventually 11 the CRGR. charter.
Safety goals would be specifically 12 addressed in the regulatory impact analyses that would be-13 conducted on each new proposed generic requirement.
14 We have in this procedure included some general 15 ground rules for the Staff to perhaps argue in terms of what 16 might constitute a substantial increase in overall protection 17 of the public health and safety.
We have done this in view of 18 the uncertainties as we see them projected.
We have done this 19 in terms of core melt, and in terms of other issues that might 20 bear on containment, plus core melt, plus source terms.
21 We have also proposed to initiate a cumulative 22 process for tracking the individual generic issues so that we 23 could look at the continuing risk reduction potentials that 24 are being predicted, as well as the continuing costs that are 25 being predicted for these risk reduction potentials.
i l
l-t
46 1-We would also propose to use the integrated safety 2'
goal matrix as sort of a template whereby the Staff could 3
display the proposed effects of its proposed change in 2
4 requirements.
5 With that, that concludes my portion of the 6
briefing.
If there are any questions?
7 MR. STELLO:
Yes, I have one for-you, Matt.
8 MR. M. TAYLOR:
Sure.
9 MR. STELLO:
One of the questions that was raised 10 earlier was, Commissioner Asselstine asked, is the criterion 11 associated with the frequency of one in a million for large 12 release in all cases going to be controlling?
13 MR. M. TAYLOR:
I believe this is -- to the best of 14 my knowledge right now, this is the controlling as NUREG 1150 15 results are showing, yes.
16 MR. STELLO:
As I thought about it when he asked the 17 question I would say except for when we calculate frequencies 18 that are down in -- certainly anything down around, below 10 19 to the minus three by definition in the matrix would say cost 20 is no longer even a criterion, you've got to fix.
So until 21 you operate on that table this doesn't even come into being.
22 Once you get beyond that then this could very well drive the 23 system, which was your question.
24 Of all of the criteria in the Commission's policy 25 statement, does this turn out, with our definition, turn out
47 1
to be the most stringent.
I think the answer based on -- and 2
please understand caveating because we haven't'done enough to 3
get the experience -- but I think the answer is yes with the 4
' definition that we now have.
5 I say that because if you choose now to modify that 6
in any way beyond the definition we have -- here's why I say, 7
let's go very, very slow -- we have no idea the degree to 8
which you would impact in terms of that policy, the plants in 9
order to meet that criteria.
You may wind up setting one 10 which becomes very, very difficult and very, very expensive to 11 achieve by arbitrarily picking some of these numbers.
12 I know if we down to ENO criteria for sure wo 13 would.
I'm not so sure, quite frankly -- maybe I can say it 14 stronger than that.
You would never be able to license any 15 plant because Part 100 calculations that we have today are all 16 in excess of that.
17 COMMISSIONER BERNTHAL:
What about Part 100?
18 MR. STELLO:
By definition all the plants meet Part 19 100.
But it would mean that the risk of a Class 9 accident 20 would have to be zero.
21 COMMISSIONER ASSELSTINE:
If you wanted to say that 22 we wanted to ensure that existing plants would not result or 23 have releases exceeding Part 100 from severe accidents as well 24 as from design basis accidents --
25 MR. STELLO:
By definition all of the design basis r
I
48 1
accidents are evaluated and shown by licensee and reconfirmed 2
by our' calculations.
3 COMMISSIONER ASSELSTINE:
Sure, so 1 through 8 4
'they're okay.
5 MR. STELLO:
Yes.
So, by definition --
6 COMMISSIONER.ASSELSTINE:
Assuming they meet our 7
regulations.
4
-8 MR. STELLO:
If you set as that criterion, by 9
definition you'd have to get -- you'd.have to eliminate Class 10 9 accidents.
And another way to say it is you just made a 11 Class 9 accident --
12 COMMISSIONER ASSELSTINE:
A design basis accident.
13 MR. STELLO:
-- a design basis accident.
And now l
14 said, instead of our design basis being 1 through 8, it's 1 15 through 9.
{
16 COMMISSIONER ASSELSTINE:
Right.
I 17 MR. STELLO:
And I assure you the implications of 18 that are extremely enormous.
4 19 COMMISSIONER ASSELSTINE:
You either prevent them or 20 mitigate their consequences.
21 MR. STELLO:
No, no, no.
No, not mitigate.
22 COMMISSIONER ASSELSTINE:
Sure, ensure the 23 containments prevent a release.
24 MR. STELLO:
Well, mitigate to the extent of Part 25 100.
You'd have to have a containment system which means no
49 1~
containment failure ever could not occur.
You could only have 1
2 leakage because --
3 COMMISSIONER ASSELSTINE:
Depends on how you
.4~
Linterpret reasonable assurance.
5 MR. STELLO:
No, you calculate Part 100 on the basis 6
of a tenth of_a percent per day leakage, so you couldn't.
7 exceed it.
8 Well, we're finished, Mr. Chairman, and I think 9
we've again demonstrated this is a very controversial issue, a 10 very difficult issue.
I reiterate what I said at the ll-beginning, if we don't start to get some experience using the 12 kinds of things that we've had now at least enough time and f
13 devote enough energy to at least sorting out that says, here's 14 at least a way in which to proceed and gain some experience, I 15 don't think we're going to be better prepared ever to help the 16 Commission in dealing with this very complex subject without
'17 the benefit of some kind of experience and going forward.
18 Any of these changes that we've talked about here 19 are very profound and can have enormous implication and need 20 very, very careful study before we can -- and not just study, 21 I think you need experience.
So if we're ever going to move 22 forward in the safety goal arena I think we're going to have 23 to start actually getting some sort of experience.
24 Whatever the further guidance the commission can 25 give us as you outlined would be extremely helpful.
We can
50 1
take that and combine that with what we've got and then we.
2 will be back from time to time with the Commission as we 3.
incorporate that kind of thinking into formulation for the 4
basis for a rule proposed for the commission consideration.
5 CHAIRMAN ZECH:
All right, fine.
Thank you very I
6 much.
Comments, questions of my fellow commissioners?
1
.7 Commissioner Roberts?
8 COMMISSIONER ROBERTS:- No.
9 CHAIRMAN ZECH:
Commissioner Asselstine?
10 COMMISSIONER ASSELSTINE:
Just a couple.
One of the 11 things that the Commission added to the safety goal was the 12 statement that we wanted to pursue a regulatory program that i
13 has as its objective providing reasonable assurance while 14 giving appropriate consideration to the uncertainties involved 15 that a severe core damage accident will not occur at a 16 U.S.
nuclear power plant.
17 How have you translated that into, or how have you 18 tried to define that standard?
Is that the 10 to the minus 19 four for core melt or for severe core damage accident?
l 20 MR. STELLO:
And 10 to the minus five for --
21 COMMISSIONER CARR:
Let me clarify something before 22 you answer that.
My piece of paper -- and I wasn't here for i
23 that meeting, but this is the Staff requirements paper says i
24 that the majority of the Commission disagreed with the 1
25 addition of that statement.
t 4
.A 51 1
COMMISSIONER.ASSELSTINE:
No, I don't think that's 2
true.
That statement, the one I just read, was added 3
unanimously.
4.
COMMISSIONER BERNTHAL:
The question was whether 5
that was going to be added, I believe I remember right, to the 6
safety goal policy itself.
7 COMMISSIONER CARR:
It was not.
8 COMMISSIONER BERNTHAL:
It was not.
9 CHAIRMAN ZECH:
Not to the policy.
10 COMMISSIONER BERNTHAL:
As opposed to being in the 11 explanatory material.
I think that was the decision.
12 COMMISSIONER ROBERTS:
That's entirely correct.
13 CHAIRMAN ZECH:
Yes, I think that's correct.
6 14 COMMISSIONER ASSELSTINE:
Okay.
But you addressed f
15 that statement in your paper.
j 16 MR. STELLO:
I think what we did was what the 17 Commission asked us to do.
18 COMMISSIONER ASSELSTINE:
What you think it means, 19 yes.
20 MR. STELLO:
And I said for the future plants we've 21 set -- and I think there's general -- at least'I felt a 22 general consensus both at the several Commission meetings we 23 had that for the new, the future that we ought to have 24 something on that order of 10 to the minus five and let that 25 signal be out.
3
52 1
Now for plants that are lesser than that than we
(.
2 ought to evolve a criteria consistent with our backfit rule 3
and backfit guidance to implement safety goal policy as 4
outlined in that table nobody likes and use it as a template 5
for making that judgment to move plants to further and further 6
reduce the risk.
You can see that there's clearly an emphasis 7
in the table as you have lower frequency, hence, a greater 8
incentive to cause that frequency to be -- excuse me, higher 9
frequency, to cause it to become lower and lower.
10 That's the policy that we would use to reduce the 11 frequency of risks consistent with it.
But we have not 12 crystallized any particular number as neither did the 13 Commission.
14 COMMISSIONER BERNTHAL:
Jim, excuse me.
Let me-15 clarify again, the Staff has just reminded me of what the 16 Commission did last year on this; what we all did.
17 The statement that you read is in the policy 18 statement.
The decision was not to put it in the summary 19 statement.
I think that is the correct status of that 20 language.
21 COMMISSIONER ASSELSTINE:
I' haven't looked + the 22 Staff's requirements memo in a while, but --
23 CHAIRMAN ZECH:
I'd have to review it, too.
I know 24 we discussed it.
25 COMMISSIONER ASSELSTINE:
If you've got it I'd like
53 1
to look at it.
2 COMMISSIONER BERNTHAL:
So it is in.the Commission's 3
policy?
4 MR. STELLO:
Yes, it is.
5 COMMISSIONER BERNTHAL:
It was not put in the 6
summary statement.
I think that's the correct --
7 COMMISSIONER CARR:
You're correct.
8 COMMISSIONER ASSELSTINE:
So it's operative.
9 COMMISSIONER BERNTHAL:
Yes, supposedly.
10 COMMISSIONER CARR:
I'll have to reread the policy 11 statement.
12 COMMISSIONER BERNTHAL:
The Staff requirements --
13 MR. STELLO:
Whether it's there or not, I've 14 answered the question as to how we're doing it.
15 COMMISSIONER ASSELSTINE:
So you're doing it by the 16 matrix.
17 MR. STELLO:
Yes 18 COMMISSIONER ASSELSTINE:
Okay.
What would the 19 number be?
We've got 100 or so plants, we'll have 125 in all 20 likelihood in a few years.
Assuming that we didn't have any 21 more plants beyond the ones-we have now, and assuming that 22 they run for another -- what, 40 years; a fairly conservative 23 assumption -- what would a core melt frequency come down to to 24 ensure that we don't have one over that period of time for 25 those plants?
- s 54 1
MR. STELLO:
Don't know the answer.
All we know is
/
2 the beginning of the answer.
The beginning of the answer is 3
out of the plants that are being reassessed as part of looking 4
at all of the things that we've done since TMI and what are 5
the newly calculated frequencies in corn melt -- Mr. Burdick, 6
do you happen to know what those are for all the plants?
7 MR. BURDICK:
No.
8 MR. STELLO:
Let me see, as I remember Grand Gulf 9
was something like six times -- I think seven times 10 to the 10 minus six.
Does anybody know what they are?
11 MR. ROSZTOCZY:
Yes, they --
12 CHAIRMAN ZECH:
Come up to the microphone please and 13 identify yourself.
t 14 MR. STELLO:
Use the microphone, give your name and 15 recite the numbers.
16 MR. ROSZTOCZY:
Zoltan Rosztoczy, regulatory staff.
17 NRC has calculated frequencies for five reference plants and 18 they vary from eight times 10 to the minus six, to eight times 19 10 to the minus four, with one exception.
One of the plants, 20 Zion, has been calculated twice.
We had two subcontractors.
21 One of them calculated it as 3.5 times 10 to the minus five.
22 The other one calculated it as 1.5 times 10 to the minus four.
23 CHAIRMAN ZECH:
All right, thank you.
24 COMMISSIONER ASSELSTINE:
If you accept 10 to the 25 minus four though, isn't it -- as an acceptable core melt
55 1
frequency for those 125 existing plants, isn't it clear that 2
you won't meet this standard over the next 40 or 50 years?
3 That's assuming you don't even add any new plants.
4 MR. STELLO:
But at least the matrix would say, if 5
you came in at that range you'd be looking at ways in which to 6
modify it to reduce the likelihood or frequency of core melt.
7 COMMISSIONER ASSELSTINE:
To some extent.
8 MR. STELLO:
To some extent.
9 COMMISSIONER ASSELSTINE:
Is the use of the $1,000 10 per manrem standard consistent with this statement, achieving 11 that objective of no core melt for,any existing, any 12 U.S. plant?
13 MR. STELLO:
I don't understand the question.
14 COMMISSIONER ASSELSTINE:
Is that a restraining 15 factor on achieving that objective, the way you've built it 16 into the matrix?
17 MR. STELLO:
Well, we have both averted on-site 18 costs as well as the personrem.
And the personrom obviously 19 varies with sites.
The larger the personrem number, clearly 20 the bigger the dollar value.
And the averted on-site cost is 21 a relatively fixed number.
22 MR. SNIEZEK:
Vic, there's really a different 23 question on the table.
The question that's being asked is, 24 what is the Commission's most restraining objective?
Do you 25 want it to be core melt?
Do you want it to be the 10 to the
56 r
1 minus six for large release?
You can pick any one and make it 2
a most constraining.
And that's what you'd probably be doing' 3
if you --
4 MR. STELLO:
But again we've answered, the most 5
constraining one is going to be this one.
That's why I don't 6
know what the answer is.
7 COMMISSIONER ASSELSTINE:
But what is the most 8
constraining also depends on how you interpret that 9
restriction.
6 10 MR. STELLO:
No.
11 COMMISSIONER ASSELSTINE:
No?
~
12 MR. STELLO:
No, because this one is right now the g^
13 most constraining.
14 MR. SNIEZEK:
But if the other statement was meant 15 to be the most -- to be taken literally that no core melt --
i 16 you know, the thing about reasonable assurance is, that could 17 and up being the most restrictivo also.
r 18 COMMISSIONER ASSELSTINE:
That's right.
j 19 MR. STELLO:
Excuse me, Jim.
I'm assuming that you i
20 apply 10 to the minus four.
Question, is a plant at 10 to the i
l 21 minus four going to moet this?
Not necessarily.
That was the 22 reason I said it.
i 23
-I think even -- and I was granting the assumption you met 10 to the minus four -- then will this bo 24 J
1 25 constraining?
And based on those numbers you could soo tho 4
-w-?
w-ww y--
-.-_.+-,,,w-w m i..m.ireeg~-r-.-
. + nes i e-~
w sm wi y-
--rwe.--y-w w-ww
--m wwwe ve-w ' '
re ~= y w -, -
57 1
range.
Here's the criterion (indicating).
It s'.ill appears 2
that -- you don't have this.
It's a back-up slide.
Put 3
back-up slide number two on, maybe it will help make the point 4
I'm making.
5 (Slide.)
6 MR. STELLO:
It isn't clear that you get away from 7
-- even when you meet 10 to the minus four -- that you get 8
away from this objective.
That's your question, right?
Is 9
that going to be more restrictive?
10 COMMISSIONER ASSELSTINE:
Yes.
11 MR. STELLO:
There's the criterion (indicating) and, 12 let's see, which plant was it that had the highest calculated 13 frequency, Zoltan?
14 MR. ROSZTOCZY:
Sequoyah.
15 MR. STELLO:
Okay, there's Sequoyah (indicating].
16 MR. ROSZTOCZY:
I'm sorry, on this slide Sequoyah is 17 the highest.
18 MR. STELLO:
Okay, you can see Sequoyah on this 19 one.
And Sequoyah was what?
What was the frequency of core 20 melt?
21 MR. ROSZTOCZY:
For Sequoyah it's --
22 COMMISSIONER ASSELSTINE:
Eight times 10 to the 23 minus four?
24 MR. ROSZTOCZY:
No, it's lower than that.
25
!!R. SNIEZEK:
It's right about 10 to the minus four.
58 1
MR. STELLO:
It's about 10 to'the minus four?
2 MR. ROSZTOCZY:
It's five.
Five times 10 to the 3
minus five.
4 MR. STELLO:
It's even lower.
There's a good 5
example.
Five times 10 to the minus five, and you can see on 6
that one, that criterion is probably controlling.
So even 7
when you were at a frequency lower than 10 to the minus four 8
on that plant the criterion of one chance in a million is 9
controlling.
10 MR. SNIEZEK:
And that population is still in there, 11 too.
'12 MR. STELLO:
Yes, when you operate with that 13 criterion and decide where you're going to go with it is then 14 going to determine what further action you have.
Again, all 15 I'm reminding you is what I said at the beginning.
This is 16 extremely complicated.
It's a hard thing to deal with and 17 we've got to get some experience because you intuitively start 18 thinking that you know the answers to questions and then when 19 you look at it it doesn't turn out that way.
20 COMMISSIONER BERNTHAL:
You know, we can't let this 21 get extremely complicated in terms of the fundamental 22 underlying policy that the public needs to understand here.
23 It may be very complicated for implementation, but one way or 24 another this commission has to come up with safety goals that 25 somebody besides a Ph.D. engineer can understand.
59 1
MR. STELLO:
You have them.
2 COMMISSIONER BERNTHAL:
We've got to figure out how 3
to do that.
4 MR. STELLO:
You published those in August of 1986.
5 What we're talking about now is --
6 COMMISSIONER BERNTHAL:
We're not finished yet.
7' MR. STELLO:
But what we're talking about is Staff 8
guidance for implementing.
This has nothing to do with 9
changing your August statement.
All this deals with is how to 10 develop a process for which the Staff can move ahead with it.
11 And all we're talking about is implementation, and it is --
12 unfortunately, it's going to be very complex.
/
13 CHAIRMAN ZECH:
Yes, I think the safety goal itself k.
14 is in very plain language most everybody can understand.
But 15 we're talking implementation and it does get more 16 complicated.
And I think we're trying to make it as simple as 17 we can but it's a challenge, no question about it.
The 18 implementation part is, I think, very complex.
We're trying 19 to simplify it and we should.
20 COMMISSIONER BERNTHAL:
Well, I don't think it is 21 understandable.
22 CHAIRMAN ZECH:
The safety goal, I believe, is 23 understandable.
24 COMMISSIONER BERNTHAL:
I don't agrec with that.
It 25 appears to be understandable.
,s..
tc 60
?l-CHAIRMAN ZECH:
I think it is.
2 COMMISSIONER BERNTHAL:
But a statement like 3
reasonable assurance of a number being zero is illusive.
I.
4 mean, it appears to be understandable but-nobody knows what 5
that means.
What is reasonable assurance of zero?
Nobody 6
that.I've talked to --
7 ER. STELLO:
It's not achievable.
8-COMMISSIONER BERNTHAL:
It's not achievable, that's 9
clear.
-10 MR. STELLO:
But our implementation --
11 COMMISSIONER BERNTHAL:
And I realize that you've 12 struggled to deal with that lack of clarity in our policy 13 statement.
It's things like that we've got to straighten out.
14 MR. STELLO:
But we have told you how we're going to 15 implement it, which answers that question.
16 COMMISSIONER BERNTHAL:
I understand that.
Which is 17 very complicated.
18.
MR. STELLO:
Yes.
19 CHAIRMAN ZECH:
What we're saying is that there is 20 some risk.
The risk is not zero.
And when it's not zero, 21 then it is complicated to discuss very, very small, tiny risks 22 and how do you achieve them.
I think it is a complicated 23 subject.
There are uncertainties involved.
But in order to 24 try to clarify those and to articulate the small risks 25 involved when risk is not zero is simply a difficult
,-n.
--n.
+.
61 1
challenge.-
2 I think the safety goal itself is clear.
As clear
'3 as we can possibly'make it.
I do think: implementation 4
guidelines are going to be more complex.
That's our job to
-5 simplify them and make them as clear as we can.
6 COMMISSIONER ASSELSTINE:
I guess part of the 7
difficulty I'm having is that I think while it may be complex 8
and difficult to understand, we did agree on certain things 9
and I think it's important for us, and for that matter, for 10 the public to understand what that really translates into and 11 what we're doing.
12 We said we want reasonable assurance that there 13 won't be a core melt at any U.S. plant, -And I guess I'm 14 still struggling a little bit to understand in practical terms 15 what that means in terms of what we're going to do.
16 What I read in the paper, the paper says there's a 17 three-pronged approach.
One is the search for outliers, which 18 sounds like the IDCOR surrogate program.
19 The second is the performance indicators program 20 which may help our ability to understand or identify problem 21 cases earlier.
I'm all for performance indicators.
22 A third is the tech spec program.
For the life of 23 me I don't understand how that's going to dramatically reduco 24 the core melt frequency question.
25 That's what's in the paper.
And I guess what I'm
62 l'
trying to understand is, first, what does that translate into r
-2 in' terms of what we're looking for on core melt frequency?
3 And are those the only three elements that the Staff is really 4'
. pointing to in terms of being able to achieve that?
That's 5
what the paper seems to be saying, and-I guess I'm sort of 6
left at a loss with understanding how you're really proposing 7
to translate that element of what the Commission agreed to.
8 MR. STELLO:
Via that matrix that no one is enamored 9
of.
10 COMMISSIONER ASSELSTINE:
So it's really back to the 11 matrix?
12 MR. STELLO:
That's it.
And the most restrictive 13 part of that matrix, based on the most recent calculations, 14 suggests that what will in fact drive the system is the 15 criterion of one in a million.
16 Now I would suggest that the Commission recognize 17 that the policy statement that it issued said that the risk of 18 operating a nuclear plant should be comparable to or less than 19 risks of generating electricity by viable competing 20 technologies.
That criterion may in fact get rid of 21 comparable to and may drive it to be less, and maybe even 22 significantly less than any viable alternative to.
23 COMMISSIOMER BERNTHAL:
Sorry, what's -- say the 24 statement again.
25 MR. STELLO:
It could be that in driving the
63 1
criterion of one in a million of a significant release may 2
very well cause us to reduce the risk from nuclear to where 3
they are significantly less, not just comparable to but 4
significantly less than the other viable one.
It might be 5
inconsistent'with the promulgated words of the commission what 6
its target was, too.
7 COMMISSIONER BERNTHAL:
I entirely agree.
I think 8
underlying all of this discussion is the fact that one of the 9
easiest criteria for us to meet is that the risk from nuclear 10 power plant operations be less than the risk from, I guess, 11 any other power generation source of which I'm aware.
That's 12 very easy for i.s to meet.
It's not generally recogni cd by.
13 the public, but that's duck soup.
14 CHAIRMAN ZECH:
But it's important we meet that.
15 You don't want to exceed it, I don't imagine.
16 COMMISSIONER BERNTHAL:
I think what Vic is saying 17 is we could exceed it by a very large margin if we meet this 18 10 to the minus six, 000 fatality.
19 MR. STELLO:
In other words, it is no longer 20 comparable, it's significantly less than other risks.
21 COMMISSIONER BERNTHAL:
Yes, I agroo.
22 MR. STELLO:
By other viable technology.
It at 23 least appears that this may drive it jn that direction, but wo 24 don't know.
We need that experience.
25 CHAIRMAN ZECH:
Well, we want to get -- we want to
. _ _,... _ _ _, _ _ ~,.., _.,. _. -.. _..,,.
,m
64 1
have the safest technology we can have.
That's exactly what 2
we're trying to do, and that's what our policy states.
And it 3
looks like that's the direction we're going which I think is 4
appropriate.
5 MR. STELLO:
Well, you've got to be careful because 6
that could also mean risk aversion -- zero risk.
7 CHAIRMAN ZECH:
I know that, but we're not talking 8
zero risk.
As I said earlier, there's always a risk.
We 9
recognize that.
10 MR. STELLO:
In a responsible way.
11 CHAIRMAN ZECH:
Yes.
12 MR. STELLO:
That's what we're trying to do.
13 CHAIRMAN ZECH:
That's what we're trying to do,
,\\
14 exactly.
15 MR. STELLO:
That's what we've tried to outline for 16 the Commission.
17 COMMISSIONER BERNTHAL:
I don't want to interject 18 here much longer since Jim has the floor, so to speak.
But 19 where is Zion on here, and Indian Point and some of these 20 others where populatio.t density does become a primary 21 constraint.
22 MR. STELLO:
I assume those aren't finished.
23 COMMISSIONER BERNTHAL:
Zion is there, but it's a 24 blank.
Does that mean it's off th7 chart?
25 MR. M. TAYLOR:
No, the results are not ready yet.
65 1
This is from NUREG 1150.
2 COMMISSIONER BERNTHAL:
Do you have any preliminary 3
analysis on that?
4 MR. STELLO:
It's not finished.
This is a 5
preliminary slide from the NUREG 1150 results.
6 COMMISSIONER BERNTHAL:
Yes, I understand.
7 MR. STELLO:
Those calculations aren't finished.
8 COMMISSIONER BERNTHAL:
But because this -- if I 9
understand this right, folding in this one fatality business 10 now and integrating curves makes it something quantitative 11 that you can benchmark things to, folds in the population 12 density.
And I'm particularly curious to know -- if you can't
(
answer it at all or even give a guesstimate today -- I think 13 14 it's very important to see where our three high population 15 density plants come cut on this.
16 MR. STELLO:
We're get it to you as soon as we have 17 it, as soon as they're finished.
18 COMMISSIONER BERNTHAL:
Okay.
19 CHAIRMAN ZECH:
Anything else?
Commissioner 20 Asselstinc?
21 COMMISSIONER ASSELSTINE:
Let me explore one other 22 area, too, and Lando, it goes back to something you raised 23 earlier.
I'm trying to understand how all of this fits 24 together with some of the other things that already exist, 25 namely the backfit rule.
00 66 1
When I look at pages eight and nine of enclosure 2
two, I'll tell you what that seems to be saying to me.
Tell 3
me if I'm right or wrong, or if I'm wrong where I'm wrong.
4 This seems to be saying that you're going to start with NUREG 5
1150 and you're going to start with the 10 to the minus four 6
in terms of safety improvements for an existing plant.
7 Then what you're going to do is take a look at the 8
safety improvement that might result from a backfit.
You seem 9
to be saying that unless it's going to provide a factor of 10 three or more reduction it's not a substantial increase in the 11 protection of the public health and safety.
12 So that seems to be saying, what we're going to 13 do is rely on 1150 as the risk baseline.
Then we're going to 14 say, let's look at a proposed backfit.
If it doesn't provide 15 a factor of three or more reduction it doesn't fly under the 16 backfit rule.
And what's more, once we had, say two or three 17 of these factor of three reductions then that's it.
Then 18 you'd moet the -- you'd hit 10 to the minus five and you'd 19 never over do anything else again for the plant.
20 Am I reading that wrong?
Isn't that the way that 21 analysis flows?
And how do you facter in uncertainty?
22 MR. SNIEZEK:
Let me address part of that and, Matt, 23 I'm going to ask you to talk the uncertainty end.
24 As far as the backfit rule, this is only meant for 25 generic issues, not plant specific issues -- consideration of
N 67 1
generic issues.
And it says because of --
2 COMMISSIONER ASSELSTINE:
But the same rule applies 3
to both.
4 MR. SNIEZEK:
Well, we don't.have anything written 5
for plant specific yet as what's a substantial safety 6
improvement.
7 But in judging the merits of a generic issue we'd 8
say, if the Staff shows that there is a factor of three 9
improvement in coro melt -- and we don't peg it at 10 to the 10 minus four -- we say that factor of three improvement in core 11 melt would be valid around a fairly wide range around 10 to 12 the minus four in treatment cf uncertainties.
If it's a 13 factor of three improvement that Staff with very little s
14 argument can say, there is a substantial increase.
15 That does not mean that if there's something less 1G than a factor of three improvement in core melt that it could 17 not be shown to be a substantini increase.
Wo say with very 18 little argument the Staff could say that would be a 19 substantial increase.
20 COMMISSIONER ASSELSTINE:
So I shouldn't road that 21 as saying, if it doesn't pass the factor of throo test the 22 Staff is going to have a real uphill battle in convincing CRGR 23 that this is --
24 MR. SNIEZEK No, but what we're saying is, if you 25 can show that's a factor of three you'ro not going to have
68 1
much battle to show.
2 MR. STELLO:
What is was trying to do is to avoid 3
the point at which you should be arguing.
If it's that much, 4
there ought not to be any argument.
There ought to be 5
consensus agreement when it's that much, let's move forward.
6 As you move from zero to three space, then you ought to bo 7
exercising that judgment.
8 MR. SNIEZEK:
Matt, why don't you talk about why the 9
factor of throo was picked?
10 MR. M. TAYLOR:
Basically that factor of three comeo 11 from consideration of the uncertaintion.
If one looks at the 12 apread, the 95 percent confidence on the mean and the mean 13 value as being done in NUREG 1150 you'll find the 14 uncertaintiou is about a factor of two to three.
Clearly, a 15 factor of throo would arguo that you are fairly confident that 16 you havo overcomo that range of uncertainty it is indcod an 17 improvement.
18 Soo, the uncortnintion do cut two ways.
In trying 19 to specify whero the absoluto rick 10, as wall ao to specify 20 how much you're inproving that risk state.
Ono han to 21 conaldor the uncertaintion in both canon.
22 COMMISSIONER ASSELSTINE:
So it ronlly would bo 23 unfair to any that what thin really doon in put you on the 24 horno of a dilomma.
On the ono hand you'vo got to go for the 25 big chango.
But on tho other hand, tho big chango in probably
h 69 i
1 what's going to be most difficult to justify in the cost l
2 benefit basis, particularly given some of the things that are l
3 in 1150.
That's wrong?
4 MR. STELLO:
Yes.
I 5
COMMISSIONER ASSELSTINE:
It doesn't drive you that 6
way.
j 7
MR. STELLO:
No, I don't think so.
l 8
CHAIRMAN ZECH:
Anything else?
9 COMMISSIONER ASSELSTINE:
How much of this depends 10 upon the validity of 11507 How much is 1150 an integral part 11 of this whole effort to implement the goal?
12 MR. STELLO:
We're going to use it to the extent it l
l 13 helps us to make the judgment.
It clearly should be the best
\\
14 state-of-the-art PRA.
But remember there are like -- how
[
15 many, 26, 27 other PRAs also to start helping, as well as many 16 of the other things that are in very busy slido which is slide 17 number --
[
10 And the answer to the question, the full and 10 complete answer is the one that's in the slide -- clido number
(
20 eight.
I 21 MR. M. TAYLOR:
Slido number eight, ploaco.
l 22 (Slido.)
23 MR. STELLO:
I think the purposo of that slido in to 24 chow you all of the things that are parts of it, and NUREG 25 1150 in ono of them.
l l
70 1
COMMISSIONER ASSELSTINE:
So it's really the 2
starting point for the analysis.
3 MR. STELLO:
There are a lot of others.
4 COMMISSIONER ASSELSTINE:
So if it's good, great, 5
you've got a valid starting point.
If it's not, you've got 6
problems.
7 MR. SNIEZEK:
Thore may be other studies that show 8
that for a specific issue 1150 isn't the right thing to use, 9
you use something also.
10 MR. STELLO:
You're not constrained to it though.
11 To the extent it is a state-of-tho-art, wo believe it's the 12 best we've got available we'd like to uso it.
13 COMMISSIONER ASSELSTINE:
Ono last question then
\\.
14 I'll stop and lot others --
15 Thoro's a lot of talk in here about flexibility and 16 provention versus mitigation.
But I don't soo a lot in hero 17 at all in terms of how the Staff is going to go about making 18 thoco kinds of judgmento.
How you striko the balance on 19 dofonso-in-dopth that we've always tried to strive for.
20 Why don't wo nood como fairly definitive judgmente 21 on how you make that balanco, how you otriko the balanco?
I 22 moan, 10 it possible that you could put overything on the 23 provention oldo and bacically ignore tho mitigation sido for 24 existing ac wall ao futuro planto?
25 MR. STELLO:
It'a pensible.
Using the word
71
-1 possible, yes, everything's possible.
But that clearly isn't 2.
the intent at all.
We've done the best we could to try to 3
tell you how we're going to go forward with the judgment, but 4
I don't think --
5 COMMISSIONER CARR:
Well, there's certainly more 6
payoff on the prevention side.
7 COMMISSIONER ASSELSTINE:
If you're right.
There's 8
a lot of pain if you're wrong.
9 MR. STELLO:
Let me remind the Commission as I told 10 you when we were here with the Mark I containment issue.
11 We're going to have to face it very squarely because I think 12 that there are data now available that says, perhaps for the 13 same sort of expenditures, cost, you may be able to get on the
.k 14 order of a factor of 10 improvement in reduction in core melt 15 frequency.
16 And if we look at the way we're dealing with the 17 mitigation side on the Mark I you might get maybe a factor of 18 two or three.
It's going to raise that question, which of 19 them should you do, and how should you go about them.
I don't 20 know the answer.
There's not an easy answer.
21 I instinctively think that if it's reasonable and 22 achievable to prevent accidents that's the one you devote more 23 energy to than having to mitigate them.
Don't want to release 24 fission products if we don't have to.
25 COMMISSIONER ASSELSTINE:
I would suggest as part of
u 72 1
this exercise that we take a look at the containment 2
performance question.
I mean, that that is not yet addressed 3
in this package.
It's something that I think at least 4
several of us said we were interested in pursuing.
And I 5
gather that the Staff put together a workshop of people to 6
look at the containment performance objective question.
7 And I'd suggest we have a meeting and bring those 8
folks in and talk to them about the issue as part of this 9
overall exercise, because it seems to me that one fundamental 10 issue is whether we want to have some specific objectives on 11 containment performance on the mitigation side, or whether 12 we're prepared to allow this free and easy trade-off without a
~
13 lot of guidance.
14 MR. SNIEZEK:
That is one of the things that's being 15 looked at.
And in Table 1 of enclosure one in the list of 16 tasks going on it shows that research and coordination with 17 NRR, I think, it's around April or so of this year expects to 18 have that report out on containment performance.
19 COMMISSIONER ASSELSTINE:
All right.
I'd suggest we 20 have a meeting with those folks as soon as the report is 21 available to look at it.
22 MR. STELLO:
We'll be happy to do that.
But again, 23 if we tie too many strings as conditions before we can move 24 forward -- I'll make a prediction -- we'll be sitting at this 25 same table, same conversation a year from now.
73 t
1 CHAIRMAN ZECH:
I think we should look at your I
2 report when it comes out and decide at that time.if we ---
3 COMMISSIONER ASSELSTINE:
I'll stop with that.
4 CHAIRMAN ZECH: 'All right.
Commissioner Bernthal?
5 COMMISSIONER BERNTHAL:
I'd just add the emphasis on 6
containment performance because that was the key missing 7
element of the commission's policy statement and I don't 8
understand how we can implement a BWR Mark I program, for 9
example -- well, I'm sure we can do it -- but if the 10 Commission doesn't speak to what we expect containment 11 performance and mitigation features to be, then Staff will 12 come up with another matrix or something.
So I think we ought 13 to do that.
14 I have a question or two here, and I'll try to 15 encapsulate this as best I can.
I guess if I walked out of 16 this mee.ng today and asked myself what is the new element 17 that I learned since a year ago, it's the key element here is 18 what you've decided to do with the 10 to the minus six 19 criterion and adding that prompt fatality element there.
20 Is that a fair statement?
I mean, isn't that --
21 you've said, and I think it's correct, that is the most 22 stringent element in our safety goal criteria.
And I scens to 23 me that that's the principal new element here, isn't it?
24 MR. STELLO:
In terms of --
25 COMMISSIONER BERNTHAL:
In terms o'.
implementation.
74-1 MR. STELLO:
-- most significant.
But the whole 4
2 implementing framework that.we've put together is all brand 3
new.
4 COMMISSIONER BERNTHAL:
I understand that, but what 5
I'm trying to get a clear-cut sense of31s what is going to 6
drive ~the Commission's safety goal policy.
And'it seems to me 7
that that is the criterion, is it not?
8 MR. STELLO:
That appears to be the most stringent 9
part of the policy.
10 COMMISSIONER BERNTHAL:
Okay, I just wanted to 11 emphasize that point.
12 I share a' concern that I think some others at the i
13 table here'do about the way you're dealing with averted i
14 on-site costs.
And I'm not going to initiate a big discussion 15 of that here.
We could talk another hour, I suppose, on that 16 issue.
But you've sort of -- if I understand what you've 17-done here -- you sort of fuzzed that issue out a bit and it's 18 a kind of.a sliding scale of treating averted on-site costs.
i 19 I have a comment that you don't need to respond to.
20 And that's that it seems to me that the uncertainties in this 21 business being what they are -- a factor of 10 at best -- are 22 eufficiently fuzzy already.
I'm not sure that the commission
- 23 wants to further fuzz up an issue like averted on-site costs.
j.
24 That's our fault and our responsibility, again, I realize.
25 But maybe the Commission needs to deal frontally and directly
75 1
with that averted on-site cost issue.
2 My policy concern on that is that by including the 3
averted on-site cost considerations -- and I don't have any 4
answers here -- but by including those considerations, don't 5
you drive things very much toward accident prevention and tend 6
to drive things away from accident mitigation?
In other 7
words, avoid the core melt, don't worry so much about 8
containment performance.
Isn't that kind of where you end up 9
if you heavily emphasize averted on-site cost?
10 MR. STELLO:
I don't really know because there's two 11 parts of it.
If you don't meet health effects then you're 12 averted on-site cost jumps up to 100 percent.
J 13 COMMISSIONER BERNTHAL:
But it gets back to the 14 defense-in-depth idea.
You might calculate that you meet 15 everything, but if the averted on-site cost is the driving 16 force here, then if you can calculate that your core melt is 17 low, to the extent that averted on-site cost is a major 18 consideration, the containment performance becones something 19 that you are less likely to pay a lot of attention to it seems 20 to me.
21 CHAIRMAN ZECH:
But wouldn't containment 22 modifications be also in the category of on-site costs?
They 23 could be, I think.
6 24 MR. STELLO:
Yes.
25 COMMISSIONER BERNTHAL:
Well, they would be, sure.
76 1:
COMMISSIONER ASSELSTINE:
They're certainly on-site 2
costs on the cost side.
The question is on the benefit side 3
protecting the value of the asset, the plant basically.
4 COMMISSIONER BERNTHAL:
As I say, I'm not sure we 5
need to try and deal with that, but I think it bears some 6
looking at.
If you're 10 to the minus six one early fatality 7
is clearly the driving force here, then the averted on-site 8
cost may retreat to a more reasonable position and reasonable 9
influence.
But I think we want to be careful about how 10 influential that issue becomes.
Some others here are 11 concerned about that.
12 MR. STELLO:
I really don't know.
Without some 13 experience I think you really can't answer it because you're 14 really driving three elements of an equation here.
Obviously lL5 you're driving with the frequency of it, you're driving with 16 the off-site health effects, and then you have this --
l 17 COMMISSIONER BERNTHAL:
On-site costs.
18 MR. STELLO:
And the new element, the new criterion 19 of one in a million.
And you know, what forces each of those 20 might have and how you get the answer.
I really don't -- and 21 if anybody else thinks they can take a shot at that, go ahead.
22 MR. SNIEZEK:
The sliding scale on averted on-site 23 cost was meant to try to drive core melt frequency to a lower 24 value.
That's why the sliding scale.
i 25 COMMISSIONER BERNTHAL:
I see.
Well, let me ask
77 1
what I hope will be a more transparent question.
s 2
I'd like to clarify in my own mind here what you 3
mean when you use the term large scale core melt.
What was 4
TMI?
5-MR. STELLO:
By the definition we're using?
6 COMMISSIONER BERNTHAL:
Yes.
Was that a large scale 7
core melt?
8 MR. STELLO:
TMI would not be a large scale core 9
melt when you calculate that individual accident itself.
10 Whether the TMI facility when you calculate and integrate over 11 the entire spectrum, whether it would or wouldn't meet the 12 criterion that's promulgated is a different question.
13 See, you can't ask a question, is any individual 14 accident -- in terms of definition we're incorporating -- a 15 significant release.
You have to integrate them all.
16 COMMISSIONER BERNTHAL:
No, I'm purely -- I'm really 17 talking only about the terminology you're using here because 18 your term large scale core melt is rather different from the 19 one that I think the Commission used in the policy statement.
20 COMMISSIONER ASSELSTINE:
Severe core damage.
21 COMMISSIONER BERNTHAL:
Severe core damage.
TMI was 22 clearly severe core damage.
E23 MR. STELLO:
Clearly.
TMI would have been either 24 core melt or -- cither one.
Because we've said, until someone 25 can do more, they're synonymous.
78 1
COMMISSIONER BERNTHAL:
Okay.
2 MR. STELLO:
Until someone does something else, 3
those two terms are synonymous terms.
4 COMMISSIONER BERNTHAL:
Okay, so that answers my 5
question there.
6 COMMISSIONER ASSELSTINE:
That's essentially total 7
loss of failure of cooling to the core, right?
8 MR. STELLO:
It's a PRA calculation.
It's a result.
9 COMMISSIONER CARR:
Loss of cooling with cladding 10 failure.
11 MR. STELLO:
No.
12 COMMISSIONER CARR:
You can have loss of cooling and 13 not have plant failure.
14 MR. STELLO:
You don't even have to calculate 15 cladding failure.
16 COMMISSIONER CARR:
You've got to have some kind of 17 18 MR. STELLO:
We just assume it.
And we said, until 19 we know how to do it better, we're going to assume they're one 20 and the same.
And that's why we wanted to provide some 21 incentive.
We have this conversation last time to try to see 22 if they can't sharpen that up.
We think it would be important 23 if they could.
24 COMMISSIONER BERUTHAL:
I just want to emphasize, I 25 guess, that severe core damage, I think should be the operable
^
79 1-phrase here so that we don't get into arguments over whether 2
you really had a core melt or not at TMI.
It was pretty badly 3
damaged.
4 If possible, I'd like to have the Staff consider, 5
despite the comments here earlier today, how you might 6
benchmark the definition of large off-site release to 7
extraordinary nuclear occurrence.
Is 10 times the NO 8
threshold appropriate?
Is 100 times the NO threshold 9
appropriate?
Is there some way you can benchmark it to what 10 is en operating legal definition that now exists in the 11 Commission's regulations?
And I realize that we're about to 12 change the NO definition.
13 But I'd like to know where you think an appropriate 1
14 definition of large off-site release for purposes of the 15 safety goal policy would fall if you benchmarked it to the NO 16 definition.
If somebody could work that up for me I'd 17 appreciate it.
18 I guess that's maybe where I'll stop for now.
19 Again, I just want to make the comment that I would hope that 20 especially on the containment performance issue, perhaps on 21 the treatment of uncertainties as well, that the commission 2
22 come up with something that's clear and comprehensible to the 23 public, to the technical community, the people that have to 24 implement _this in the field, the utilities and the engineers, i
25 and to our own Staff as the fundamental policy statement.
- _,, ~
80 I realize the implementation has to be complex, but
.1 2
I think'it's vitally important that we have a set of safety 3
goals that the public at large can understand.
I'm not sure 4
that all elements of our safety goal policy right now are 5
understandable.
They're not understandable to me at least.
6 And again, I would like to stress that in my mind 7
safety here relative to other power generation sources isn't 8
the issue.
It seems to me that all throughout, with emphasis 9-based on what's happened in this last year, the issue really 10 is what is the public going to accept here.
11 And we've got to come up with understandable safety i
12 goal language that in effect says that you can't have a TMI 13
[
very often, because I think everyone agrees that that is not 14 acceptable to the public.
And that you probably can't have a i
15 Chernobyl more than about once in a lifetime on the average, 16 because that would not be acceptable to the public.
17 Those are very crude and seat-of-the-pants guesses, 18 but that really is a key issue it seems to me that has to 19 drive our safety goal considerations.
And whether that means 20 that this has got to be a lot safer technology than coal power 21 generation or any of the others, it seems to me is almost not
.22 an issue.
23 That's all I've got to say right now.
24 CHAIRMAN ZECH:
Thank you.
Commissioner Carr?
25 COMMISSIONER CARR:
Yes, when you're talking about
81 1.
the technology I think you overlook the fact that the two 2
accident we've had have been personnel related and operator 3
error.
Technology can only go so far and I think the whole 4
paper leaves out too much of the operator problem in the whole 5-thing.
6 I come from a bapkground where there is no 7
mitigation, if you have an accident you've had it.
8
[ Laughter.)
9 COMMISSIONER CARR:
So prevention is the only thing 10 that I think -- I think it's the area right now that we can 11 make the most progress at.
So I think you have to have some 12 area in here -- I don't know how to put it in -- where you've 13 got to take into effect that, can we improve the operator 14 performance so that we don't have those kinds of accidents
.15 which we've already have.
16 Technology is not going to solve the problem if the 17 guy is going to bypass the interlocks.
And we just had 18 another case of bypassing safety in the railroad accident, so 19 operators do do those things.
20 Having said that, I would say also that as you 21 proceed with whatever system you come up with, I would suggest 4
.22 that you try it out on a decision we've already made and see 23 if it correlates.
Would it have worked in one we've already 1
r 24 made on some other fashion?
And you might ---at least you can 25 be able to try out your system and see if some of it works.
J y_
..y
,.___..m_,
y
s 82 1
Having said that, I would like somebody to tell me 2
how many reactor years of operation we've already got in the 3
U.S.
4 COMMISSIONER BERNTHAL:
It's 3,000 worldwide.
5 COMMISSIONER CARR:
Yes, but we're not discussing 6
worldwide years here, are we?
These are only U.S. years we're 7
looking at.
8 COMMISSIONER BERNTHAL:
I think ours is about 1,000.
9 MR. M. TAYLOR:
Around 1,000.
10 COMMISSIONER CARR:
We're not doing too bad.
11 CHAIRMAN ZECH:
All right.
Let me ask, what do you 12 mean by one-year trial usage?
How does that -- can you define g.
13 what you mean by that, in light of the fact that Commission s
14 approval has not been granted this program yet?
15 MR. SNIEZEK:
What was meant by that, Mr. Chairman, 16 is that -- and this is for the generic enclosure, too, I 17 believe you're talking about -- we wanted to use a one-year 18 trial.
We don't know if it's the right answer yet, but what 19 we wanted to do is for CRGR packages, when Staff reviewed 20 generic issues that they'd address how -- compare it to what 21 we had here as they come forward for Mr. Stello's approval on 22 the packages and to see how it fits.
23 And then based on that experience, if it looks like 24 it fits good in the decisionmaking process, we would then 25 formally propose to the Commission that we adopt it as formal
.e-83 1
' Staff guidance for the future for generic issue resolution.
2 If it didn't look good as we start using it, we'd be going-in-3 and modifying this approach as we went along to try to get an 4
approach that would be suitable for presentation to the 5
Commission for final' approval.
6' CHAIRMAN ZECH:
Okay, fine.
Well, my concern is 7
that if you decide to use it on a trial basis before 8
Commission approval I'd hope you'd point that out to the 9
Commission and come to us before you actually-make any 10 execution.
I presume that's what you're saying.
11 MR. SNIEZEK:
.On the issues, implementation of the 12 issues.
13 CHAIRMAN ZECH:
Yes.
(
14 MR. SNIEZEK:
Yes, sir, that would be done.
15 CHAIRMAN ZECH:
All right.
16 MR. STELLO:
The whole idea is that all of those 17 issues one way or another get before the Commission.
j 18 CHAIRMAN ZECH:
That's my point, especially-before 19 we've approved the program.
20 MR. STELLO:
Yes.
21 CHAIRMAN ZECH:
Let me just thank the Staff for 22 their presentation.
I do think it's a very important and very 23 complex subject, and it certainly merits the time we've spent 24 this morning and a lot more.
I'm even more convinced now that t
25 my suggestion in my opening remarks that I put together a
9" 84 1
paper that addresses the subject and brings up the points that 2
you've addressed in your January 2nd memorandum, and perhaps 3
some of the other points we've addressed here today, and allow 4
my fellow commissioners then to add whatever comments they 5
want and get that to you perhaps would ass'ist the Staff in 6
~ proceeding.
7 And I think that's a responsibility we have.
And 8
unless my fellow commissioners object to that approach, I'll 9
go_ ahead and initiate that and try to get something to them 1.0 soon, and perhaps we could get it to you in the next few 11 weeks.
12 Are there any other comments by my fellow c
13 commissioners this morning before we close?
14 COMMISSIONER ASSELSTINE:
One last quick question, 15 if I could, Lando.
16 CHAIRMAN ZECH:
Sure.
17 COMMISSIONER ASSELSTINE:
It occurred to me after --
18 when Fred was raising the question about the averted on-site 19 costs, I didn't see any mention of averted off-site costs.
I f
l 20 take it those are still not considered.
21 MR. SNIEZEK:
No, that's $1,000 per personrem is a 22 surrogate for the off-site costs.
-23 COMMISSIONER ASSELSTINE:
I seriously doubt whether 1
24 it's an accurato surrogate for the off-site costs.
And it 25 seems to me if we're going to address the on-site costs, why i
85 1
don't we address whether those issues -- those costs should be 2
included as well.
3 COMMISSIONER ROBERTS:
We went through that once.
4 COMMISSIONER ASSELSTINE:
Well, we've talked about
'5 it from time -- but it seems to me if you're going to talk 6
about including on-site costs, the Commission ought to at 7
least make the decision on whether we want to see the off-site 8
costs included as well.
9 COMMISSIONER ROBERTS:
We nade that decision.
10 COMMISSIONER BERNTHAL:
We have discussed that 11 issue.
12 CHAIRMAN ZECH:
I thought we had.
I know we have.
13 COMMISSIONER BERNTHAL:
But I think that -- my guess 14 is -- and I'm not sure we agree on this, Jim -- but my guess 15 is that for the vast majority of plants at least that this 16
$1,000 personrem is by far the more stringent criterion.
But 17 it could be that in certain areas with lots of destruction --
18 CHAIRMAN ZECH:
Well, perhaps that's one of the 19 things we can bring up in our comments to the Staff.
20 COMMISSIONER BERNTHAL:
Could I just ask if there's 21 someone from the ACRS here?
Once again, I think this is an' 22 area that the advice and counsel of the ACRS is especially 23 useful to the Commission.
And I would like to suggest that at 24 some point here, whether before or after we have a position 25 paper or whatever it is that you're planning to work on,
86 1
Lando, that we have another discussion with the ACRS on these 2
' broad issues.
3 I'm sitting here a little bit at a loss knowing 4
where to grab on now with this thing.
Where do we go from 5
here?
It's just not clear to me at all.
6 MR. STELLO:
The ACRS, we're having a meeting with 7
them this afternoon.
We've already had the subcommittee 8
meetings.
So if it's their usual practice, I suspect they'll 9
be comnunicating it to you.
10 COMMISSIONER BERNTHAL:
Good, I think we need to --
11 COMMISSIONER ASSELSTINE:
I think a follow-up 12 meeting is good idea with them, Fred.
13 MR. STELLO:
Well, I'd suggest you wait and see
(
14 their letter.
I mean if they agree with us, you might not 15 want to meet with them.
16 COMMISSIONER BERNTHAL:
They may not.
17 MR. STELLO:
You'd just go through the same 18 discussion.
19 CHAIRMAN ZECH:
It's certainly appropriate to hear 20 from the ACRS, and we'll figure out how to do that, one way or 21 another.
22 COMMISSIONER BERNTHAL:
We should be so lucky.
23
[ Laughter.]
24 MR. STELLO:
Don't give up.
We get them a little 25 closer each time.
.. ~
~ -. - -
-... =
87 1
CHAIRMAN ZECH:
Any other comments?
All right,'
2 thank you very much.
3
[Whereupon, at 11:54 a.m., the commission meeting 4
was concluded.]
5 6
7 8
9 10 l
11 a
12 13
(
14 15 16 17 18 19 i
20 21 22 23 24 25 1
d
1~
2 REPORTER'S CERTIFICATE 3
4 This is to certify that the attached events of a 5
meeting of the U.S. Nuclear Regulstory Commission entitled:
'6 7
TITLE OF MEETING:
Briefing on Status of Safety Goal Implementation 8
PLACE OF MEETING:
Washington, D.C.
9 DATE OF MEETING:
Thursday, January 8, 1987 10 11 were held as herein appears, and that this is the original-12 transcript thereof for the file of the Consission 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 18 Pamela B it le 19 20 21 22 Ann Riley & Associates, Ltd.
23 24 25
b COMMISSION BRIEFING ON
. STATUS OF SAFETY GOAL IMPLEMEPTATION DEDR0GR JANUARY 8, 1987 r
... _ ~
4 1
PRESENTATION OUTLINE e
BRIEF REVIEW 0F AUGUST I4,1986 POLICY STATEMENT AND CURRENT STATUS e
DISCUSS INTERIM FRAMEWORK FOR SAFETY GOAL IMPLEMENTATION e
DISCUSS DRAFT IMPLEMENTATION GUIDELINES FOR ASSESSING GENERIC ISSUES
- ee 4
.i
4 2.
AUGilST 11, 1986 POLICY STATEMENT COMMISSION ESTABLTSHED TWO OUALITATIVE SAFETY G0ALS e
FIRST SAFETY G0AL - INDIVIDUAL MEMBERS OF THE PUBLIC SHOULD BE PROVIDED A LEVEL OF PROTECTION FROM THE CONSEQUENCES OF NUCLEAR POWER PLANT OPEPATION SUCH THAT INDIVIDUALS BEAR NO SIGNIFICANT ADDITIONAL RISK TO LIFE AND HEALTH 4
e SECOND SAFETY G0AL - SOCIETAL PISK TO LIFE Ah'D HEALTH FROM NUCLEAR POWER PLANT OPERATION SHOULD BE COMPAPABLE TO OR LESS THAN THE PISKS OF GENERATING ELECTRICITY BY VIABLE COMPETING TECHNOLOGIES AND SHOULD NOT BE A SIGNIFICANT ADDITION TO OTHER SOCIETAL RISKS,
.,,,,._.__.,-,---.,,,_-,,,,,,.,,,nr-,...
, a.
s
?
COMMISSION ESTABLISHED TWO OUANTITATIVE HEALTH EFFECTS OBJECTTVES TO GAUGE ACHIEVEMENT OF THE SAFFTY GOAL PROMPT FATALITY - THE RISK TO AN AVERAGE INDIVIDUAL IN THE o
VICINITY OF A NUCLEAR POWER PLANT OF PROMPT FATALITIES THAT MIGHT RESULT F90M REACTOR ACCIDENTS SHollLD NOT EXCEED ONE-TENTH OF ONE PEPCENT (0.1 ",) 0F THE SUM OF PROMPT FATALITY PISKS RESULTING FROM OTHER ACCIDENTS TO WHICH MEMBERS OF T U.S. POPULATION ARE. GENERALLY EXPOSED, LATENT CANCER FATALITY - THE PiSK TO THE POPULATION IN THE o
AREA NEAR A NUCLEAR POWER PLANT OF CANCEP FATALITIES THAT MIGHT PESl1LT FPOM NllCLEAP PDFER PLANT nPERATION SH0lllD F EXCEED ONE-TEFTH OF OME PERCENT (0,1") 0F THE SUM OF cat'CEP FATALITY RISKS PESilLTING FPOM ALL OTHEP CAUSES,
(
..,_y...-__
n c
.,,.. - - - ~.. - -.
.c
.e 4
COMMISSI0tl COMMENTED Of! ffEED FOR ADDITI0tlAL GlIIDELINES FOR REGIILATORY IMPI_EMErlTATION e
ADDITI0tlAL IMPLEMEtiTATI0il GUIDELINES ?!EEDED PLAtlT PERFORMAllCE INDICATORS FOR OPERATI0t!AL PERFORMAFCE GUIDELIllES FOR COST-BEllEFIT ANALYSES e
COMMISSI0ll REVIEW AtlD APPROVAL e
GUIDAtlCE TO BE DEVELOPED WOULD BE BASED ON A PROPOSED GENERAL PERFORMAt!CE GUIDELIt!E WHICH IS TO BE FURTHER EVALUATED BY STAFF "C0tlSISTEtlT WITH THE TRADITI0t!AL DEFEllSE-If!-DEPTH APPROACH AtID THE ACCIDEllT MITIGATI0tl PHILOSOPHY REQUIRIllG RELIABLE PERFORMAllCE OF C0tlTAlllMEtiT SYSTEMS, THE OVERALL MEAtl FREQUEt!CY OF A LARGE RELEhSE OF RADIOACTIVE MATERIALS TO THE Ef!VIR0t!-
MEllT FROM A REACTOR ACCIDEt!T SH0llLD BE LESS THAti 1 Ill 1,000,000 PER YEAR OF REACTOR OPERATI0i!
5 Cll R R E rlT S T A T il S e
STAFF HAS. DEVELOPED All IllTERIM 00Af'TITATTVE AtlD IllTEGRATED INTERPRETATIO?I 0F THE SAFETY G3AL POLICY AtID THE GErIERAL PEPFORMAtlCE GUIDELINE AS A FRAMEWORK FOR DEVELOPMEtlT OF SPECIFIC STAFF GUIDAtlCE Ill THE VARIOUS AREAS OF ?!RC'S P.EGULATORY ACTIVITIES.
o THE SPECIFIC GUIDAPCE WILL BE P. RESENTED TO THE COMMISS10tl FOR APPROVAL PRIOR TO ADOPTION AS Filial STAFF GUIDANCE, e
PET WITH ACP.S Sl!BCOMMITTEE OM DECEf1BEP 10,1986, AFD JAfIVARY 7, 1987, e
MEET WITH FULL-ACRS Oil.lAtil.IARY 8, 1987.
- - ~
1 i
6 INTERIM FRAMEWORK F0P. SAFETY G0AL IMPLEMENTATION e
ilVREG-1150 RFSULTS AS IMPORTANT RESOURCE REBASELINED PRAS--STATE OF ART MANY ATTRIBUTES; E.G.,
NEW SOURCE TERM SAFETY GOAL COMPARIS0flS INCLUDED IMPROVED UtlCEPTAINTY TREATMENTS e
INTEGPATING TOOLS TO ASSIST GEMEPIC ISSUE RESOLUTIONS SARA (SYSTEMS ANALYSIS AND RISK ASSESSMENT)
IP.DAS (INTEGPATED RELIABILITY AND RISK ASSESSMENT SYSTEM)
FEEDBACK FOP MEW DATA At!D EXPEPIEPCE CHERNOBYL IMPACTS (T0 BE PRESEfFED LATEP) e SPECIF4C GUIDEL INES, E.G.,
ItITEGPATED SAFETY GOAL MATPIX AS TEMPLATE FOP STAFF USE GENEPAL IMPLEMENTATION GUIDAtlCE PLANT PEPFORMAt1CE GUIDELIt!ES LARGE RELEASE DEFIllITIOi!--DEFEllSE-Iti-DEPTH
I 7
It!TERIM FRAMEWORK FOR SAFETY GOAL IMPLEMEllTATI0tt (CONTINUED) 8 REGULATORY IMPLEMENTATION AREAS GENERIC ISSUES /SEVEPE ACCIDENTS / SOURCE TERM CHANGES PLANT-SPECIFIC REQUIREMENTS REGULATORY PPIOP.ITIES (flRC RESOURCES)
ASSESSING OPEPATIONAL EVENTS ENVIPOMMENTAL STATEMENTS (FES)
IMPLEMENTING PROCEDUPFS MOST AREAS COMPLETED IN ABOUT 1 YEAR PEPIODIC STATUS BRIEFINGS COMMISSION REVIEW AND APPROVAL AMTICIPATED
a e
ATTRIBUTTS New Source Term Technology I,,,,,,,,,,,,,,,.,,,,,,,_l s
Improved Consequence Modeling
(
I l
latest Health Effects Models
(
l l
1r: proved Containnent Fodels
(
Improved lincertainty Treatment
(
l g
Improved Fhenomenological Treatrent (
I site specific Analyses
(
MUREG-115D I
Mainframe Risk Rebaseline l
Assist.
Improved Cearnon Cause Models s
I 6 Plants g
Plant Specific Data
(
Pisk Management Considered
(
j I
I Erergency Procedure Guidelines C
I UX5H-I4Mt Cmparisons
(
Integrating I
I Safety-Cost Tradeoffs
(
I Other Plant s
Tools I
(
l Specific PRAs Risk Importance Measures safety Goal Ccenarlsons i
L- +
(incl. External SARA 1RRAS
(--
Feedback of Post-THI-2 Changes
(
Events)
Lessons and Data frist External Events Not Included
(
Cherv.oby1 Insights Operating Experience I
- % /.
S/
l p_
3 l
Regulatory implementation i
I 8
l Areas l
l i
l '.
Severe Accident Policy implementation g
g Specific Guidelines 2.
Regulatory Use of Pew Source Terms I
I g
3.
Resolution of Generic Issues 1.
Integrated Safety real Matrix I
I 4.
Decisions about Plant-Specific Rqts.
2 General Implementation Guidance
)
I l
5.
Setting Regulatory Priorities 3.
Plant Perfonnance Guidance 1,_ _ _6., M ety h_Operttienal,E_y_en_ts_,,,,,,,, _ ),,,,j Asses _ sing 4.
Defense-In-Depth Guidance C
1 Comparisons in Staff A
Environmental Statements Impleurr* ting S.
Definition of Large Pelease Affecting Procedures Portality Risks X
- 10 /RY P>x f
1.0 x
Figirre 1.
Framework for Safety Goal Implementation 0o s.
O 9
SOME GENERAL GROUND RULES FOR IMPLEMENTATION e
SAFETY GOALS WILL BE USED IN CONJUNCTIOil WITH TRADITIONAL REVIEW METHODS.
o SOUND PLAtli MAtlAGEMENT REMAINS AT ISSUE)
PREDICTED PLANT RISKS MAY IMPROVE OP DETEP.IORATE DEPEilDIllG ON HUMAN PERFORMANCE.
O UNCERTAINTIES TO BE EXAMitlED.
8 APPROPRIATE PEEP PEVIEW OF QUANTITATIVE PISK ANALYSES.
e WILL USE BOTH IllTEPi!AL AND EXTERt'AL EVEllT INITI ATORS e
SAFETY GOALS WILL t!OT BE llSED FOR STAFF EVALUATIONS OF SECURITY AND SABOTAGE ISSUES.
i e
SAFETY GOALS WILL BE USED IN ARRIVING AT REGULATOPY SAFETY DECISIOFS.
e LICEtlSEES MUST STILL MEET PEGULATI0ftS.
9 IMPLEMFitTATION WILL ADDPESS GOALS FOP FXIST!?!G AND FUTURE PLAtlTS AtID PESOLUTI0tt OF OUTSTAtIDItlG GFitEPIC SAFETY ISSUES.
.._.7 10 GENERAL PERFORMANCE GUIDELINE--MEAN FPEQUENCY Fn9 LAPGE RELEASES e
APPLIES.TO EXISTING AND FUTURE PLANTS e
CONSOf1AtlT WITH THE COMMISSION'S POLICY Oil MORTALITY RISK (0.1 PERCEilT INCREMENT) e CAPTURE ACCIDENT UNCERTAINTIES AND RISK DOMINANT RELEASES (INCLUDING CHERNOBYL) e CAPTURE EAPLY CONTAINMENT FAILUPE/ BYPASS POSSIBILITIES.
gy 10-6/RY FOR 1 EAPLY FATALITY FOR ALL DISTAtICES At!D l
e AFFECTED POPULATION BEYOND SITE BOUNDARY (USE OF CCDF) e CCDF HAS BEEN-DISPLAYED ALPEADY Ill ABOUT 30 FES.
e FUREG-1150 WILL DISPLAY EFFECT OF THIS CCFF APPPOACH FOR LAPGE PELEASES VS. UNCEPTAINTIES e
CAPABLE OF BEING USED AS SURROGATE TO ASSUPE HIGH CONFIDENCE OF ACHIEVIt!G COMMISSI0t!'S SAFETY GOALS.
e ALTERNATIVE APPROACHES TO LARGE RELEASE DEFINITI0fl ALSO TO BE CONSIDERED.
s 11 GEP'EPAL PERF0PMAflCE Gil1 Dell?'E--LARGE RELEASE J
, LARGE-SCALE CORE MELT l
10.g,
FPEOUFNCY
-,10-5 f 4 10-6 %
"'W/,
LESS POPULATED SITE MORE POPULATED SITE
> EF 1.0 Ot!E C0tICEPTilAL APPP.0ACH FOR EXAMIllAT10t!:
o USE CCDF--TPADITIOllAL PRA DISPLAY FOP P.ISKS e
ACKfl0HLEDGES EARLY FATALITY PISK IS C0f'TPOLLIMG HEALTH EFFECTS OBJECTIVE e
INTEGPATI0t! 0F CCDF P.EPRESEllTS MEAT' HEALTH PISK PER YEAR AND IS READILY PFLATED TO SAFETY GOAL e
CCDF I.S It'TEtIDED TO CAPTUPF RESULTS OF ALL SEVEPE CORE DAMAGE / COPE-MELT ACCIDENT RELEASE PAGillTUDES, FREQUEtlCIES, PATHWAYS, PPEVENTION Af'D MITIGATI0i!
FEATURES THE LIMIT-lit'E APPROACH (610~6/RY) CAPTUPES e
DEFEFSE-Iff-DEPTH AND SHOULD C0f! STRAIN MEAN HEALTH EFFECTS TO BE WITHIt' THF SAFETY GOALS WITH HIGP i
rot'F I DEt'CE.
o-12 COST-BENEFIT APPROACH USES BENEFITS OF AVERTED OH-SITE COSTS (AOSC) e SLIDING SCALE WHERE SAFETY GOALS ARE ACHIEVED 100 PERCENT AOSC WHERE SAFETY GOALS ARE NOT ACHIEVED TIED TO AND SCALED WITH AVERTING COPE-MELT ACCIDENTS.
COST 0F SAFETY IMPROVEMENTS APE NOT AT ISSUE WHERE VERY HIGH CORE-MELT FREQUENCIES APE INDICATED.
$1,000 PER PERSOH-PEM USED AS SURROGATE FOR THE SOCIETAL e
HEALTH EFFECTS AND PROPERTY DAMAGE COSTS OFFSITE (O OCCUPATIONAL HEALTH EFFECTS ALSO VALUED AT $1,000 PER PERSON-REM)
EFFECT OF VARIOUS COST-BENEFIT ALGORITHMS (WITH AND e
WITHOUT AOSC INCLUDED) WILL BE DISPLAYED IN NUREG-1150 I
e j
j
__(tal!!rJLINE Ft"t CopF-F.tLT. LAPGE RADIDAU3h IEMAR. IULTil FFFtf?S M ODEFIT-CDST)*
i, 1FTEf3ATED SAFETY r.f*L FATRif t
I i
Benefit Cost (11.000/p-r
- Averted Large Radioactive Neelth Effects 90.11/RT_
~ easite costs)****
l l
Release trequency Large-Scale Core-Proset/ Latent ***
Pelt Fisivency (Per RY)_
(Per RT)**
(
Meet both eb.lectives De further safety l
< 10-5
$.10. er inerevement i
Taprove ($1.fm0/p-r)
> 10 ". health effects Don't meet one l
analyses may be regelred l
l j
< 10 5
< 10d cc Hect both objectives laprove(it.000/p-r
{
4
+1
--.]> 01 AOSC) leprove ($1.000/p-e
> 10. health effects Don't meet one
+1005ADSC) analyses Itkely required i
10-3 4 presumed not to meet health fleet both objectives leprove(ll.000/p-r
+ 10 9 11 805C) effects matti detailed l
analyses reveal otherwise leprove(11.000/p-r j
l Don't meet one
+1001A05C)
)
> 10-3 Presumed not to meet health Heet both objectives Ieprove (it.000/p-r
+1001405C) effects untti dctatled analyses reveal otherwise leprove(costnoIlmit)
Dee't meet one i
)
4 All values are taken as mean values per Rf may serve as The overall guideline for the frequency'of a large and life threatenlag release less then 10 "an acceptable surrogate (for health effects analyses) that prevfdes a high degree of asserence that the Comartssion Otherwise. improvement in accident mittgation er prevention may be desirable for added Safety Goals are achieved.
d defense-in-depth.
Prrspt ef fects integrated to 1 mile from site boondary; latent effects to 10 miles.
i (1) A05C = Averted custte costs (See RtRrG/CR-3568, A Handbook for value-1spect Assesssentl
]
(2) p-r =' person-rta, lategrated to 50 miles '
J l
i 1
I
v II4 0
COST CALCULATIONS USING
. SAFETY GOAL INTEGRATED MATRIX (Sensitivity To Site Population)
Health effect goals are not met Health effect goals are met 10' =
High 8
10 I
g l
3p
==
=
Low
- Average 10' Populat!cn
. Sits 8
i i
10 4
3 x 1D*'
3 x 10" 1 x 10 PROB ADILITY OF CORE MELT (Per RY)
,_...-,.,..r
V 15 ItlTERIM PROCEDURES DECIS10FMAKING FOR NEW GENERIC REQUIPEMENTS e
COMPLETED DECEMBER 1986 e
SERVES AS POSSIBLE BENCHMARK FOR OTHER IMPLEMENTING PROCEDUPES e
1-YEAR TRIAL USAGE PLAtlNED e
SUBJECT TO PEVISION FROM EXPEP.IENCE ACQUIRED e
FINAL COMMISSI0t' APPROVAL SOUGHT AFTER TRI AL USE e
POSSIBLE UPDATE OF CRGR CHARTER e
SAFETY GOALS TO BE SPECIFICALLY ADDRESSED IN REGULATORY IMPACT AtlALYSES e
IrlCLUDES SOME GENEPAL PULES OF THUMB FOR STAFF TO USE, E.G.
SUBSTAtlTI AL INCPEASE IN OVERALL PROTECTIOt10F PUBLI,C HEALTH AtID SAFETY ACKt10WLEDGES Ut!CEPTAltlTY PAMGES ESTABLISHES CUPULATIVE PROCESS FOR PISK PEDUCTION BENEFITS, COSTS AND PROPOSALS FOR RELAXATION OF REQUIREPENTS ESTABLISHES COST-TPADEOFFS WITH INTEGRATED SAFETY GOAL MATRIX.
{
iiFWIWVfVWW9VMfVWWWWW9VW9VIVfvWWW9VWWWEVJVgVgVwgvgypt gygygygygygggggggggg TRANSMITTAL TO:
X Document Control Desk, 016 Phillips i
S i ADVANCED COPY TO:
The Public Document Room
/ //L/E7 DATE:
3
/
3 :
3 ""
FROM:
SECY Correspondence & Records Branch 3
33 Attached are copies of a Commission meeting transcript and related meeting s
3 ll document (s). They are being forwarded for entry on the Daily Accession List and j j.
placement in the Public Document Room. No other distribution is requested or required.
a ll 3
j Meeting
Title:
Mbb s o $ N4 ok Sdek bod 3
3 ;
3 :
5 i Meeting Date:
1 & /D Open Y
Closed 3 :
3 :
3 :
3 :
m i Item Description *:
Copies 3 :
Advanced DCS
- 8 S i to POR
- Copy, 9
3 l-3 3 !.
- 1. TRANSCRIPT 1
1 a :,
s i; u d U t b.r o h s g ;
=
3 2.
333 E 33 !
3.
3 :"
3 4.
3 :.
3:;
n i; 3 -:
3 S*
3 3 l; 3
l 3
6.
3 E; 3 -
i 3 l.l 3
- POR is advanced one copy of each document, two of each SECY paper.
"i C&R Branch files the original transcript, with attachments, without SECY 3
D
$ j papers.
3 !
3 =
Y alm l
l l
hl h
i
.