ML20207P853
| ML20207P853 | |
| Person / Time | |
|---|---|
| Issue date: | 01/09/1987 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1569, NUDOCS 8701200327 | |
| Download: ML20207P853 (101) | |
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U UN11ED STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: DOCKET NO:
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 3?lST GENERAL MEETING p
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DATE: FRIDAY, JANUARY 9, 1987 AnPoR pri3 r e h a w awee s? :R P T V o der.otl.emov.e from ACRS Tfice ACE-FEDERAL REPORTERS, INC.
OfficialReporters 444 North Capitol Street Washington, D.C. 20001 -
87o1:00327 870109 (202) 347-3700 PDP ACRS T-1569 PDR NATIONWIDE COVERACE
PUBLIC NOTICE BY THE UNITED STATES NUCLEAR REGULATORY COMMISSIONERS' ADVISORY COMMITTEE ON REACTOR SAFEGUARDS FRIDAY, JANUARY 9, 1987 The contents of this stenographic transcript of the proceedings of the United States Nuclear Regulatory Commission's Advisory Committee on Reactor Safeguards (ACRS), as reported herein, is an uncorrected record of the discussions recorded at the meeting held on the above date.
No member of the ACRS Staff and no participant at
() this meeting accepts any responsibility for errors or inaccuracies of statement or data contained in this transcript.
i l
CR29410.0 DAV/cjg l' f' ) 1 - UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4 321ST GENERAL MEETING 5
Nuclear Regulatory Commission Room 1046 0 1717 H Street, N.W.
Washington, D. C.
.8 Friday, January 9, 1987 9
The 321st General Meeting reconvened at 8:30 a.m.
10 yy ACRS MEMBERS PRESENT:
12 DR. WILLIAM KERR, Presiding as MR. DAVID A. WARD 13 MR. JESSE C. EBERSOLE MR. HAROLD ETHERINGTON 14 DR. MAX W. CARBON DR. HAROLD W. LEWIS 15 DR. J. CARSON MARK MR. CARLYLE MICHELSON 16 DR. DADE W. MOELLER DR. DAVID OKRENT
-77 MR. GLENN A. REED DR. FORREST J. REMICK gg DR. PAUL G. SHEWMON DR. CHESTER P. SIESS MR. CHARLES J. WYLIE 19 20 21 22 23
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S- DAVbur. lL PROCEEDINGS 2 .DR. KERR: (presiding) The meeting will come to
-3 order.
4 This is the second day of the 321st meeting of' 5 the Advisory Committee on Reactor Safeguards.
6 Today's meeting will involve discussion and 7 reports on the following:
8 The meeting with the Executive Director for 9 Operations.
10 Discussion of systems interactions.
- 11. Discussions of the proposed report on the
-12 implications of the Chernobyl accident.
/~T k/ 13 And consideration of the appointment of a new
'l-4 member.
15 Consideration of reports on-the NRC Safety 16 Research Program.
17 And a discussion of a proposed report on improved 18 light water reactors.
19 Portions of the meeting will be closed perhaps, 20 if necessary to protect privileged information.
21 The meeting is being conducted in accordance with 22 the provisions of the Federal Advisory Committee Act and the 23 Government in the Sunshine Act.
24 Mr. Raymond Fraley is the designated federal o 25 official.
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'4100 01:02 -3 i ) DAVbur-s 1 A transcript of portions of the meeting is being 2 kept. I ask that each speaker identify himself or herself 3 .and use a microphone.
4 We have not received any written statements, nor 5 have we had requests for oral statements.
6 The first item on today's schedule is a meeting 7 with the Executive Director for Operations, Mr. Stello, who 8 will describe some.of the facets of the NRC Staff 9 reorganization.
10 Mr. Stello?
11 MR. STELLO: Thank you. It is a pleasure to be 12 here.
('
13 I perhaps thought maybe we ought to broaden the 14 topic and perhaps we ought to key it to something other than 15 reorganization. If there is anything else somebody wants to 16 mention, I will be certainly happy to listen.
17 The reorganization that we have underway -- what 18 I thought I would do is describe it to you in broad terms, 19 where we are and what the next steps will be, and give you a 20 rough feel for how long it will be before the reorganization 21 will be in place, the basic changes associated with the 22 reorganization.
23 Perhaps the most visible one at the office 24 level reporting to the Commission is dividing the Office of 25 Congressional Affairs and Public Affairs, State Programs ACE-FEDERAL REPORTERS, INC.
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\/s DAVbur 1 and International-Programs, two offices reporting up at the 2 division. level.
3 The reasoning and the recognition for the need to 4 do that is it is clear.there are increased policy questions 5 that are being raised with respect to certainly state 6 issues. As I am sure all of you are aware, the states are 7 becoming more and more involved in activities that we 8 regulate.
9 Since Chernobyl there has been very, very intense 10 involvement on the international front. Coordination of 11 Congressional and Public Affairs Offices is clearly 12 desirable. Those activities have been combined now, and
- -13 Mr. Denton has been chosen to head up that particular 14 office.
15 The workload for the agency is clearly changing 16 to where we are going to be regulating essentially an 17 operating industry. In recognition of that need, we took a 18 hard look at some of the ways in which we are doing things 19 to be sure we have unambiguous and clear accountability for 20- the activities that we are regulating.
21 We have felt the need for this for a long time.
22 We took a hard look. It was my recommendation, 23 incidentally, back in 1980 that as that workload was 24 changing there*was a real need to combine those twc l
) 25 activities to make sure that the inspection and licensing l
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-kj' DAVbur 1 activity would be brought together.
2 This organization literally brings them 3 together. There will be one office now responsible for 4 every aspect of reactors. If it is a reactor problem, there 5 is one office that is going to be held directly accountable.
6 and that understands they are accountable for the regulation 7 of that activity, NRR.
8 By the same token, there is now going to be one 9 office for regulating materials, programs, recycle 10 facilities.
11 Those two particular changes are probably the 12 most significant in terms of operating.
13 The changes obviously are essentially restricted 14 to changes within our headquarters operations, the field 15 operations remaining essentially the same.
16 The individuals who have been chosen for the rest 17 of these jobs -- I understand that the ACRS members were 18 passed out the recent announcement that-was made of what 19 individuals are reportir to what jobs.
- . 20 One other imp ant element of the new 21 organization is the issu f dealing with unresolved safety 22 questions, generic issue _, and what ,have you, that have been 23 kicking around for a long, long time. The resources 24 sometimes get applied and sometimes get pulled off, and they
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25 don't go very smoothly. Recognizing that, we have gotten ACE-FEDERAL REPORTERS, INC.
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2 We have also provided impetus to make sure that-3 the research activity is closely coupled to the questions 4 that need to be answered, safety questions, and that need to 5 be answered for licensing.
6 Research will now be responsible'for doing the 7 work to resolve all of those generic issues. The resources 8 from NRR that were assigned to work on that have been 9 reassigned over to Research.
10 There are a variety of other administrative 11 things that have been sorely needed for some years, 12 providing some of the administrative activities of
-(~'s s_) 13 information systems, budget personnel, consolidated and put 14 into an office except for personnel, separate offices 15 reporting directly to me. All the other activities are 16 combined into one large administrative office rather than 17 into satellite offices.
18 Yes?
19 DR. MARK: To what extent and by what means is it 20 assured that the decisions of the regions concerning the 21 question as to whether something or other need be done or 22 need not be done are coordinated and made consistent?
l 23 MR. STELLO: Are you talking about -- there are i
24 two aspects of it. Let me see if I captured it.
) 25 Consistency among regions is one issue we have ACE-FEDERAL REPORTERS, INC.
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L4100 01:06 7 k DAVbur 1 talked about, and the other is the flow of information 2 identifying problems from any particular region.
3 Right now the way it is set up is that 4 information has to flow and be coordinated among at least 5 three different elements -- NRR, I&E, and the regions. In-6 the reorganization it will be NRR and the regions, just two, 7 and NRR will be accountable and responsible for making sure 8 that the problem is resolved -- NRR. That is diffused in 9 the current setup that we have.
10 Consistency among the regions, that problem is 11 hopefully going to be significantly less. There is going to 12 be now one office charged with the overall responsibility.
13 Prior-to this time there were two, but I assure you, the 14 idea of_ consistency among regional offices is never going to 15 be an issue.that escapes us. It is going to be something we 16 will have to pay attention to all the time and make sure 17 that we don't let that get away from us.
18 DR. MARK: That is my concern. You will be sure 19 that it is made sure?
20 MR. STELLO: Yes. It will be easier, but it is 21 something that will continue to need attention.
22 MR. MICHELSON: Along the same lines, Vic, I&E 23 used to prepare some kind of overview standards and 24 guidances to get out to the regions.
O 25 Who will now prepare these overview standards, ACE-FEDERAL REPORTERS, INC.
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2 MR. STELLO: That happens-to.be an area that.I-3- :had particularly sensitivity to for-a lot of years because
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-4 .I&E had an office when I was there.' We used to develop-5 inspection modules and send them out.to the field. Butfwere-
-6 'they the right things to inspect? Were they really-7 coordinated with the licensing activity?
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8 At'best, I think I would describe that as hit and 9 miss.
10 The new office is going to. combine the activities 11 of developing new modules, new inspection modules for the i
12 regions in the.same unit that.is also responsible for-13 licensing to make sure this time they are really hand in d
14 glove.
15- MR. MICHELSON: I guess the answer is it is in 16 NRR now, or will be?
17- MR. STELLO: But it is pulled out as a separate 18' unit, not distilled, reporting up through Murley separate 19 from the day-to-day activities.
20 The reason for that is to make sure this time we 21 have asked and answered the question: is this a better 22 activity accomplished by asking questions during the 23 licensing process in Washington when you-really need to go 24 out and see it and make sure it is okay via inspection?
O 25 In other words, to get the real hand in glove ACE-FEDERAL REPORTERS, INC.
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4100 01 08 9 th kw [ DAVbur 1 operation of inspection and licensing, recognize what the 2 strengths and weaknesses of both are and take advantage of 3 it.
4 There will be a separate organization now that 5- will do that. That will be essentially for the first time.
6 That has been sorely needed, as you are well aware.
7 MR. EBERSOLE:- Vic, in all this vast 8 organization, I like to think that each plant has some sort 9 of NRC parental type overview; that is, you have got some 10 NRC person who looks upon it as a child of some sort.
11 MR. STELLO: The project manager is going to be 12 that end of the duo.
s/ 13 MR. EBERSOLE: Is he offering that intimate 14 contact?
15 DR. KERR: Mr. Ebersole, I know Mr. Stello can 16 hear you better that way.
17 MR. EBERSOLE: Can everybody hear what I said?
18 I would like to see an identification of the
< 19 individual for NRC who takes a direct, primary interest in I
i 20 each individual plant, somebody I can go to and say, is your l:
21 plant in good shape. I would like to know those folks. For 22 all these 104 plants.
! 23 MR. STELLO: I heard the question. The answer is
_ 24 the project manager -- he or she -- is going to need to l
%-) 25 know. They are going to be asked that question, and they 1
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^(ol DAVbur 1 are going.to literally have to know everything about the 2 plant, what is going on in inspection, what are the 3 outstanding licensing issues, and they are going to have to 4 be responsible for having complete knowledge of all aspects 5 of the plant. They are going to be out there a lot more 6 often, too.
7 MR. MICHELSON: Is that approximately one on one, 8 - or does one project manager cover several plants?
9 MR. STELLO: I would like it to be one on one if 10 we can manage it, 11 MR. MICHELSON: Right now it is a little more 12 than one per manager?
13 MR. STELLO: It is close to one on one. Close.
14 We are going to shoot to try to do that.
15 DR. SIESS: Vic, does the project manager have 16 any more authority to go along with this additional 17 responsibility, or is he still going to be somebody 18 transmitting stuff?
19 MR. STELLO: My desire is for him to have 20 increased responsibility and authority.
21 MR. EBERSOLE: That is my problem. I have 22 identified more or less that most of the time he is just a 23 transmittal agent, like a transmittal letter, and you are 24 telling me he is going to have an increased level of direct O
'd 25 responsibility?
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1 14100 01 10' 11 IY a_/ DAVbur MR. STELLO:
l- That is correct.
2 MR. EBERSOLE: I guess you will have a composite 3 list of all the names of these fine individuals that we can
- 4. find, that you-have got someplace?
1- 5 MR. STELLO: Will have, yes.
6 MR. HERNAN: We do have that list now, Jesse.
7 MR. STELLO: You have the current list. He is 8 talking about the new organization, the future.
9 The answer is yes. We don't have it yet.
10 MR. EBERSOLE: The new character of these people 11 is that they do'have responsibility, not merely to transmit 12 problems but to have a heavy hand in the decisionmaking of
('3
(> 13 what is to be done.
14 MR. STELLO: That is correct.
15 DR. KERR: Please continue, Mr. Stello.
16 MR. STELLO: I think really I have captured the 17 basic reasoning and philosophy behind coming up with the 18 reorganization.
19 Obviously, the next step is when. The Commission 20 desired to become very, very much involved in this
! 21 organization question and has been taking it a step at a f 22 time. You have seen the announcements about a step at a 23 time.
, 24 The major office levels were agreed on, and j
O. 25 finally the instruction was taken down to the next step to t
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_ 1 the division levels, and they agreed on that structure, and-2 who those individuals ought to be, and that was published.
3 The step following that now is obviously the rest 4 of the organizations, and the Commission has indicated a 5 desire to look at the entire organization in detail. We 6 have prepared that and hope to have that in a month or so.
7 for the Commission to look at and finally approve.
8 When they finally approve that structure -- and 9 we have all the usual things to go through, preparing the 10 package and letting the union become involved in it before 11 final implementation -- I guess we are hoping to be in a 12 position to have that done in the next couple of months. It
! rm
(-) 13 may turn out to be coincidental with consolidation, which 14 would be very nice if it is but it is not mandatory that it
- 15. is that way.
16 But the coincidence -- I hope it is going to be 17 Very close. I don't know which one is going to control, l
18 consolidation or reorganization.
19 MR. EBERSOLE: Are these people with this focused 20 responnibility of the individual plants yet named for the 21 TVA projects?
22 MR. 3TELLO: Oh, I missed something. Thank you.
23 The answer to that question is no. In the I 24 process of going to the Commission between these two
' 25 organizations, it became apparent to me that there were two l
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(_/ 'DAVbur 1 particular projects for which there is very, very intense 2 involvement'and it did not seem appropriate to have those 3 handled in the usual way by line management.
4 I proposed and the Commission agreed to set up 5 separate project offices, putting all the resources in 6 separate project offices for TVA and Comanche Peak. Those 7 decisions have not yet been made.
8 I think TVA and Comanche Peak in respect to 9 organizational , structure are unique and we need something 10 special for those. There is just too much going on to rely 11 on the usual structure.
12 MR. MICHELSON: I have a couple of questions, 13 Vic.
, 14 The first is where does CRGR now fit into the 15 structure?
17 MR. MICHELSON: But they are the administrative 18 custodian? How is the CRGR going to be made up, the same as 19 it has?
20 MR. STELLO: The staff will be transferred over 21 into AEOD. The reason for that is that is the office, I 22 think, that is at least neutral in terms of being an 23 advocate of any rule, regulation, or order. The other 24 offices very well will be. So they have responsibility.
O i
25 That will be separate from them. The chair of the office l
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\-,/ DAVbur 1 will be AEOD as well.
2 MR. MICHELSON: My comment on that of course is 3 that AEOD is of ten the office that originates the problem 4 that CRGR is then resolving. It originates the concern, and 5 now the judge and the jury are going to be in the same 6 place?
4 7 DR. OKRENT: Not the whole jury.
8 MR. MICHELSON: Not the whole jury, admittedly.
9 It is hard to see --
10 MR. STELLO: There is a reason for that, though.
11 You are right. They identify the concerns. When that gets 12 translated into requirements, that is done somewhere else, f'/
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13 not by them.
14 MR. MICHELSON: But now, in appearance at least, 15 it looks like they are setting down to pass final judgment 16 on it. That is why I asked whether CRGR was just being 17 administered by AEOD or just how closely it would be 18 associated.
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- ) DAVbur 1 MR. STELLO: The perspective of' the CRGR members 2 would be about where they are today.
~
3 MR. MICHELSON: Presently, CRGR is in the EDO's 4 office, and my question is why doesn't it remain in the
- 5 EDO's office just to keep things clean? -
6 MR. STELLO: You could do that, and for 7 appearance it would probably appear to be cleaner, but the 8 staff that has to work on the problems, in getting a little 9 bit closer to it, I think it has an advantage to it. I 10 don' t 'really worry too much about the problem, though the 11 perception is there. But in reality it is not because the 12 AEOD prepares the reports.
f's N/ 13 Here is the concern, here is what is understood .
14 about it, and we think you look at it.
15 Another office translates that concern into 16 specific, detailed requirements and proposes the 17 requirements that the committee passes judgment on, and 18 there is enough independence in the committee that I have 19 absolutely no concern about it.
20 HR. MICHELSON: The other question is, #
the 21 training center still in AEOD?
22 MR. STELLO: Yes.
23 MR. MICHELSON: Is there some logic for that?
24 MR. STELLO: Yes. The training center that we V 25 have is really, as you are aware, of a highly technical i
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2' One of the things we are trying to do with the t-
-3 training . center is make it more responsive to what we are
.4 . learning from experience and feedback from the plants so-5 that we can'put that kind.of thinking into-the. training I
6 center in order to keep it very'much in the technical arena-7 -rather than put it with the' rest of the training in the 8 agency.
9 The ideal office to do that in terms-of where 4 i 10 that knowledge.is going to be to do things isLAEOD. They 11 are responsible for looking into trends and making that kind.
12 of understanding and would be, I think, best prepared to 1
13 pass that kind of knowledge into the training center.
! 14 MR. MICHELSON: Thank you.
15- DR. KERR: Mr. Ward is next, I believe.
16 MR. WARD: Vic, in the present organization there 17 is a Division of Human Factors Technology in NRR.- That t
l 18 seems to have disappeared in the proposed orgar.ization.
- 19 MR. STELLO
- We are still working out the details
[ 20 on how that is all set up. We will be meeting on that this 21 afternoon at 4:00 o' clock on how to accommodate all this.
22 MR. WARD: Do you expect there would still be a i 23 division devoted to that activity?
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l 24 MR. STELLO: Not only a division. I think that
- 25 the whole concept of people problems is going to be l.
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M.DAVbur 1 : basically on NRR.
2: If you look very carefully at one.of the-3 proposals that we are looking real hard at now, it is how to 4 ' align the activities of NRR, and if you look at how do you 5 sat up project management functio'ns, one of the th'ings-that-6 we are going to de is to align the project management-7 activities by regions rather than reactor type.-
8 That has-been very difficult to call. The thing 1
9 that persuaded me, that said do you want to do it that way, 10 is that on one issue it is clear that where you get-the
. : 1- 11 1 largest change in the facility is where you'have management 12 problems. The regions, by definition, handle utilities, the' 13 management of them, rather than reactor types. So you have 14 a very concentrated effort on dealing wich management 4'
15 problems by aligning the project managers and regions to 16 work on the management problem.
17 So we are thinking about it from the' top'down, ,
18 and that'is a very, very big change.
!~ 19 MR. WARD: That sounds like it is, i-
! 20 MR. STELLO: The thing that pe .Suaded me that it 21 was important to go that way was if you look at mome of the 22 sites you can pick sites with a BWR, a CE design and a 23 Westinghouse design, all with the same utility, who are 4
24 split among different directorates and different O 25 organizations within NRR, and you don't really get the real i
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- 4100u02 04' 18 A) DAVbu r m 1 feel for how well that organization, that management system 2 works, and that is the people problem.
3 So that kind of thinking, although, as I said, it
-4 is from the top down, is coming into the decision.
5 DR. KERR: Does that complete your questions?
6 MR. WARD: Yes.
7 DR. KERR: Mr. Okrent.
8 DR. OKRENT: Vic, I have some complicated 9 questions that I would like to lead into with just a little 10 bit of background.
11 I don' t know if you recall, but some of us recall 12 the era of Milton Shaw, when he was the head of the Division 7s ,
T) s 13 of-Reactor Development and Technology, when he was 14 , ill-inclined to brook opinions which went counter to what I ss 15 will call the official line coming from Germantown.
16 This inclination of his was sufficiently strong-17 that in fact people were fired in various contractor A
i
/ 18 organizations, and I know for a fact that that is the case 19 because I belonged to one in which that-occurred.
20 s You may or may not recall that there were a 21 series of articles that reviewed this in Science Magazine in 12 2 the early '70s, which I suspect helped Commissioner Ray in 23 her decision to change some of the organizational matters in 24 the then AEC, taking Research away from Shaw for example.
~
25 Other kinds of background, I think we have a ACE-FEDERAL REPORTERS, INC.
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4100 02 05 19 p(_/ - DAVbur 1 couple of members on the ACRS who worked for an organization 2 where it was their job to try to find out things that>were 3 going wrong and had trouble being. listened to. It was a ,
4 curious situation where the organization in fact set up a 5 devil's advocate, if you want to call it that, but they didn' t like what they heard.
7 It was interesting that when we had the Christmas L 8 party I sort of alluded to the importance, I thought, ,to any 9 CEO or General Director of Operations to have somebody who 10 would be willing to tell it to him straight, even if it was 11 something he thcught the boss didn't want to hear.
12 Commissioner Zech was reminded of the fact that 13 in one of his Naval positions he found himself in exactly 14 that position and in fact had to tell his immediate 15 commanding officer that what they were doing was just not 16 the way to go. That is all by way of background.
17 I am wondering if in the new organization, first, 18 there is a conscious effort to build in either a group, or 19 something equivalent to this, who are looking at what is the 20 proposed staff policy emerging from EDO and who have the 21 responsibility for questioning it if there are any -- if 22 they see any major flaws.
23 I am not talking about trivia in this, 24 obviously. In fact, in effect, it is their job. If
'O 25 something bad gets by, in effect, they ought to be fired, as ACE-FEDERAL REPORTERS, INC.
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H k)l DAV/bc m il: DR..KERR: Is this leading up to a question, or-
- 2. areLyou still in the comment mode?
3 DR.lOKRENT:- 'I'll1probably not end up'with a E 4 . specific question, and I'll probably end the comment-very 5: . shortly.
7
-6 It's an observation,<a' caution...I'll.make one l
,- l '7- last. observation.- I heard ' a TV program, -McNeil-Lehrer,
.. 8 :where-you and' Ellen ~ Weiss were on with a discussion on r
9 Chernobyl.
, 11 0 There's been a lot of discussion about how the-t c 11 LWRs~were different. And even though she's a lawyer and,-
12 presumably, not technically with such as deep insight 1as
{. 13 engineers, she raised' the point that U.S. reactors, by 1 14 different' accidents, can have releases not unlike those.at l
[ -15 ' Chernobyl.
16 And then, instead of acknowledging that.this was L
17- 'the case, what I heard you say.was, you kind of said a-18 reassuring word that deflected the question, which would
- j. 19 leave, at least in part, it perhaps with the impression that I- 20 the NRC -- certainly the AIF -- was saying i
i 21 There's a one in a hundred chance. Or felt that- .
there was little chance that a U.S. containment would fail.
22~ :
g 23 And what bothers me somewhat, and this comes back 24' to the Bernero initiative, is I can't tell whether in the j
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25 EDO there sits more confidence in containments, more ACE-FEDERAL REPORTERS, INC.
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(.) DAV/bc 'l confidence in what-the mean core melt frequency over the 2' full span of reactors, more' confidence over good. containment 3 and low frequency than-I think is-justified.
4 MR. STELLO: I definitely would like to respond, 5 although there isn't a question, if I may.
6 DR..KERR: I think you should. I don't think 7 this had anything to'do with the reorganization..
8 MR. STELLO: That's okay. I invited any.other 9 questions that might be raised. So, if I brought this on 10 myself, I'm glad for the opportunity.
11 I have a copy of that tape. Maybe you and I 12 ought to sit down and listen to it again.
) 13 DR. OKRENT: I'd love to.
14 MR. STELLO: Because you seem to characterize it 15- in a way differently than I recall the issue was.
16 Can a Chernobyl type accident happen in a light 17 water reactor?
18 Knowing what I knew then, I said no. Knowing i 19 what I know now, hell, no. A reactor accident like you had 20 at Chernobyl, with positive feedback you have that could 21 literally disintegrate the core and destroy the entire 22 confinement containment systems, spread radioactivity, in 23 fact, the calculations indicate that approximately on the 24 order of something like 10 tons of fuel were ejected from f~/h
'- 25 the reactor, about half of that beyond 20 kilometers, l
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~4100 03 03 29 r-1)) DAV/bc 1 physically cannot happen _in a U.S. olant.
2 We have at nauseum advertised what the 3 radiological consequences are from the complete and total 4 spectrum of accidents in U.S. plants.
5 If I need to, I'll remind you of the Sandia 6 reports for which we have calculated ~ conditional 7 probabilities down to 10 to the minus 11, where you have had 8 the numbers of deaths up into the thousands.
9 For every site in the country, we have not 10 hesitated, in fact, we probably have flooded the market with 11 calculations of the severity of accidents that.can happen in 12 U.S. plants. Tne r -lete and total spectrum of them.-
13 There are literally thousands of such reports on 14 reactors in the United States that can have accidents and 15 what their consequences are.
16 There is no way a Chernobyl accident can happen 17 in a light water reactor in the United States, period. I 18 said it with some reservation then, I say it now with, based 19 on the calculations that we have made and they have made, 20 l with far more vigor than I did then.
21 It cannot happen, period. Scientifically 22 impossible.
23 Now, let me go on to respond to the confidence in
- 24 containment. I believe you're talking about the Mach I I told the Commission when we were briefing the 25 issue.
ACE-FEDERAL REPORTERS, INC.
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/* - i L(>y.- DAV/bc' 1 -Commission on this issue, that the results that I believe
, 2 were being calculated as part of ll50 for the two BWRs, and~
I,~ 3 now. I'm going -to have to rely somewhat on memory since _ ,
4 there's some distance, that, in one case, the' controlling 5- sequence, which was, as I recall, in one case 99' percent of g
- . 6 the~ risk-of station blackout.
l t 7 And as I recall, in the 'other BWR,.90 percent of-l 8 the risk from' station blackout. I said I do not believe 9 that we ought to be pursuing'this question of what to do on t-F .10 the Mach I's withou't' recognizing whether or -not there was c
11 more to be done.on the prevention side, since,.if I can ~t 12 improve overfall safety, if, indeed, those numbers are 13 correct, an order of magnitude by dealing with preventionk
! 14 that I would certainly want to weigh that very heavy in
? 1 1 15 trying to decide what to do.
? -
16 Furthermore then, it is not clear that the kinds ,
17 of fixes that you're talking about on the Mach I 4
1 18 containments are the same kind of fixes if you eliminate .
4 19 those scenarios, whether there are other and more demanding r F
1 20 or different scenarios that you want to worry about.
- 21 To say it simply, I didn't think that we had a
22 considered the problem enough and decided, especially when
{i
{ 23 we saw the results coming out of 1150, you also recognize
- 24 that those results also suggest that the frequency of core i <
l 25 melt is in fact much lower, it brings us enormous policy and i
t i f
i ACE-FEDERAL REPORTERS, INC.
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- s. .DAV/bc 1 philosophical questions for this agency in how to balance 2 prevention and mitigation and how far are you trying to drag 3 down the risk.
ll It is my risk that that needed to be ventilated.
5 In fact, I read a little bit of that~into the response of 6 the ACRS when they looked at this issue themselves.
7 I firmly believe that. I think we ought to keep
- 8. our eye-on safety all.of the time. And I think the recent 9 results we have suggested that we have not done that yet.
10 And I felt it needed to be done before we went back to the 11 Commission.
12 And I told the Commission that at least on two
,r '
'() 13 occasions. And I stand by what I've said.
14 DR. OKRENT: I'm sorry to hear you putting so
, 15 much reliance on the results of 1150. I think it 16 ill-founded, is my first comment. And I don't think-it's 17 representative of the bulk of the reactors in the U.S. and, 18 in fact, the Sandia people themselves have made that point 19 in conversation, if not in their reports.
20 I think, if there is a containment that is weak 21 in its capability to withstand a considerable range of core 22 melts, that is a factor that should be looked at in the 23 defense in depth policy, even though you may try also to 24 prevent the thing from occurring.
25 And I find some tendency to forget that defense ACE-FEDERAL REPORTERS, INC.
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- (_/ DAV/bc 1- indepth policy, I must say, unfortunately, although what we 2 heard yesterday was that the most common, the' majority --
3 .the. overwhelming response -- that Denton got f rom the people 4 he talked to in various states, and so forth, is they don't 5 want to see a large release.
6 I'll just leave.it with you at that.
7 MR. STELLO: Again, I've got to respond. You 8 know, you are characterizing things in a way I didn' t say 9 them. I said the results of 1150 ought to be considered.
10 Now, let me give you an example of what that 11 might mean. If, in solving the station blackout, the 12 easiest way to do it is to bring an independent power supply 13 in, you would have the capability to prevent core damage.
14 But, in addition, by having that extra power 15 source, you could have enormous core spray potential and 16 significantly reduce the poten'tial for overpressure failure 17 because of the availability of the spray, which is one of 18 the elements that, if you recall, are in that particular 19 program.
20 It doesn' t appear that the concept of balancing 21 the prevention, the mitigation and the mix that one ought to 22 censider is there. That is the kind of thing that's got to 23 go on.
24 I'm not putting any more or less confidence in 25 1150 than you are. It's a question, it's a result. Should ACE-FEDERAL REPORTERS, INC.
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14100f03-07 . 33 DAV/bc l 'I ignore it or should I look behind it,.: consider it and look g 2; 'at what'it.is that it tells me? .
- 3- That's - the one thing that we've all ?said' we ;ought ;
4' to do with'PRAs, try.to. understand if.it's telling us 5 .something.
6 When-it says that-the controlling risk,-99 7 percentaof it,Iis> station blackout, it has piqued my 8- interest. .I think:it needs'a look.
9 If you don't--share that, we disagree with each
~10 -other. I feel'strongly, and I suspect that there's a fairly;
- 11. wide concensus that that's the recognized way~in which you-12 ought'to be using PRA results: Look behind it'.-
! ) 13 DR. KERR: Mr. Remick is next.-
14 DR. REMICK: Vic, I have two questions,~one of p
[ 15 them a follow-on to Dave Ward's question. ;
'16 The human factors. .In Inside NRC, it. indicates t :
. 17 that . Bill Ru'ssell, the Director of Licensing Performance and '
i 18 Quality Evaluation, I assume Human Factors is not in that. i
(. 19 So Bill has been changed out of Human Factors. Is that 20 correct? Or will Human Factors be a part of that?
L l
l 21 MR. STELLO: I don' t have the organization chart f
22 with me, unfortunately. My glasses broke this morning and I ;
[
f' 23 was unable to bring anything that I brought with me. I've 24 looked to see if it's in the book you have, which it's not.
I i 'r .
o
[ -
25 And that's the new spread of the organization.
! ACE-FEDERAL REPORTERS, INC. l f- 202-347-3700 Nationwide Coverage 800-336-6M6
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- 4100'03 108 34
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' C)l'DAV/bc- ' l- MR. WARD: I don't'think we've even seen that.
2 All we have is this Inside NRC thing.
3 MR. STELLO: No. I-have the. book that you have.
4 MR. WARD: Do you mean we have to look at our 5 book?
6 DR. REMICK: Could you tell us what tab?
7c MR. STELLO: Tab D.
8 (Laughter.)
9 MR. STELLO: There's an employee announcement 10 that came out that gave a further breakdown of this most 11 recent one. I notice that is not in here. I don' t know 12 why.
13 .Does anybody know why it's not there? That one 14 breaks it down for you in much more detail. If you don't 15 have it, there's a copy upstairs, if you make sure they get l
16 it.
j 17 MR. FRALEY: Yes.
18 DR. REMICK: My question is, Human Factors is not 19 ~in that division?
20 MR. STELLO: As I recall, it is not in the I
21 division.
d 22 DR. REMICK: The other question I have, if I 23 recall from one of the early announcements, one of the 24 criticisms I've had as an outsider -- I still see it as an 25 ACRS member -- is when rulemaking comes up through the staff i
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4100 03 09 35 k DAV/bc -1 in different offices, it appears uncoordinated. I guess 2 I'll have to give you a couple of examples just to 3 demonstrate what I mean.
4 We recently, in the High Level Waste area, talked 5 about' activities for the MRS and we find in.that, in reading 6 the words and talking to the NMSS staff, they're not 7 familiar with what's going on, the new Part 55. A 8- discussion on the. licensing basis agreement with JD ABWR, 9 there's language in there that's not consistent with the 10 language in Part 55.
11 You run across these inconsistencies in the 12 staff, and sometimes these get out in the rules. They come p
\ 13 out from one office. They language is different. There's 14 inconsistency with what other people are doing.
15 Are you giving any thought -- and I thought CRGR 16 would solve some of this, and they perhaps are solving some 17 of it -- are you doing anything specifically to make sure 18 that it's one agency when it comes to things like rulemaking 19 that are affecting licensees out there?
20 MR. STELLO: That's the reason for putting it in 21 Research.
22 DR. REMICK: I'm hoping that will be the case.
23 MR. STELLO: Because it's been spread out with
, 24 individual offices doing it. By putting it in Research, we 1
l
('/)
' 25 hope to have it now really and truly represent the agencies.
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()~DAV/bc- 1- DR. REMICK: Do I understand that that's'their 2 charter? I hesitate to call it OA, but there needs to be 3 some consistency.
4 MR. STELLO: They clearly understand that that is 5 their responsibility.
6 Now, execution is important. You have to 7 recognize that you have a culture that you have to change; 8 it's going to take time. Nothing is going to happen 9 quickly, but I think everyone understands that that's the 10 direction to go in. And, in time, I expect we'll see 11 significant improvement.
12 DR. KERR: There will be no significant 0)
N_ 13 reorganization for the next year?
14 MR. STELLO: I used to keep track of it. If I 15 remember, for about 10 or 11 or 12 years, it was an average 16 of about 2.3 years, as I recall.
17 I hope this one, because it really is the first 18 time that it affects the future business of the agency, and 19 taking that into account, I hope it lasts for a lot. longer.
20 DR. REMICK: One final comment. I don' t consider 21 that my function is to be a skeptic. I consider my function 22 on the committee is to provide advice to the best of my 23 ability and as unbiased as I can make it, and to be positive 24 as well as negative.
25 And I look at the reorganization as a major ACE-FEDERAL REPORTERS, INC.
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4100.03 11 37 k_./ DAV/bc 1 undertaking, as you are well aware better than I do.
2 But I think ~it's a worthy endeavor and I wish you 3 well and hope it all works out.
4 DR. KERR: We have time for one short question 5 and one short answer.
6 MR. EBERSOLE: Do I get that?
7 DR. KERR: I'm prepared to wait and see.
8 (Laughter.)
9 MR. EBERSOLE: Vic, in this flap about Bernero 10 and the Mach I's, I hope this discussion about venting and 11 restructuring of the Mach I doesn' t preclude a very 12 important consideration in the purely prevent mode, which is (O_/ 13 the.importance of the venting process in the PWRs to cope 14 with this problem of loss of power and suppression pool 15 overheating.
16 I think that vending process is critical. This 17 is predamage. That's another domain entirely. And all our 18 discussions have more or less encompassed venting overall.
19 And the post-damage one is the tough one, of course.
20 The other one is not tough, but I hope you can 21 give heavy consideration to add to considerably to the BWR.
22 MR. STELLO: I agrea.
23 MR. EBERSOLE: You see, it's clouded by the fact 24 that venting was blanketed, under no venting at all.
~/ 25 DR. KERR: Short comments, please?
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DAV/bc 1 MR. STELLO: I can' t give a short answer unless I 2 just say: Yes, I agree with you -- and walk away. But it 3 is an area that needs a_ lot more discussion and it raises 4 the very questions that I was trying to note'.
5 It goes back to the whole concept of preventing 6 the. severe accident when you can. And if you look at the 7' results, you ought to be looking very hard at understanding 8 what they say, and go from there.
9 10 11 12-
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\ / - DAVbur 1 DR. KERR:. .Vic, I want to thank you for providing 2 --us with;a very complete discussion, and we hope this sort of 3 thing will'take place periodically.
4 MR. STELLO: . I promise to be as candid as I know 5 how to be, and if you have any questions about that, why, 6 remind me.
7 DR. KERR: Thank you very much.
8 That ends that session and brings us to the next 9 topic on our agenda, which is systems interaction and the
, 10 briefing by NRC Staff.
11 Is-there a subcommittee. report? Mr. Okrent, are 12 you prepared to make that?
) 13 DR. OKRENT:- Whenever you bang the gavel.
14 DR. KERR: Mr. Okrent, the Subcommittee Chairman, 15 will give his report.
i 16 DR. OKRENT: The topic is systems interaction.
[ 17 You may or may not recall that some months ago 4
^
18 this topic came before the full committee, at which-time the 19 task manager and the supervisor provided before us the l 20 position that they were then proposing to bring to the L 21 CRGR.
. 22 This position differed in certain ways from an l 23 earlier position developed some months before by what I will 1
l .
24 call the working group itself, going through, getting office 25 comments, and so forth, for CRGR. The position was changed ACE-FEDERAL REPORTERS, INC.
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-(,)'DAVbur 1 -from what the task group on USI A-17 had recommended to what 2 was agreed with the CRGR.
3 There was a subcommittee meeting then. There was 4 a full committee meeting, and the full committee letter, 5 which I assume is in the tab, you will see did not support 6 the proposal that the Staf f was going to bring to CRGR.
7 Partly it supported it, but not entirely,.and it had some 8 other additional things that seemed not to be in what was 9 being discussed by the Staff.
10 The Staff has reconsidered this matter. We had a 11 subcommittee meeting yesterday, and we will in a moment hear -
12 what I propose to be an uninterrupted presentation by the 13 Staff in order to let them get through their whole 14 presentation, which is not supposed to take more than 25 15 minutes --
- 16 Right?
17 MR. THATCHER: 15 minutes.
18 DR. OKRENT: Good. That is less than 25.
19 -- after which there will be half an hour or more 20 for discussion.
21- At the end of the meeting today, or sometime this i 22 week, presumably the committee will need to decide, 23 preferably, if it can, at the end of this one hour, whether 24 it wants to send an additional letter -- it might not right
' 25 at this time. It might just send a note -- or whether it ACE-FEDERAL REPORTERS, INC.
202 4 47 3700 Nationwide Coverage Mn3346M6
f4100304 03 41 DAVbur .l~
is' completely satisfied with what the Staff is proposing to~
2 do or whether it decides it will wait until'something' is 4
3 issued for public comment and they get public comments-4 back, and at that point the. committee comes back~with a 5- . review.
6 Whichever of these paths'are followed, then, we 7 should makeLaure that if there is a plant in review in a
! 8 later time that in. fact this is assigned to the subcommittee 9 and the time is set'up, and so forth.
i 10 I am.not going to try to summarize the 11' questions. Many of them are unchanged from the letter that 11 2 we last wrote.
.13 The Staff's thinking on how some of these issues-14 in fact fit or don't~ fit within rules or backfits or not seems to have shifted somewhat.
~
] 15 We will hear about that,
, 16 too.
1 1 17 So'I would propose we go directly to this i
18 uninterrupted Staff presentation and then hear what other l 19 members of the subcommittee have to see and see what 20 questions the ACRS members have.
21 The members present for that particular meeting 22 who were particularly interested in this subject were Wylie, 23 Michelson, and Ebersole.
24 DR. MOELLER: I have a question. In the Staff's 25 presentation, will they address the key points in our May I
ACE-FEDERAL REPORTERS, INC.
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7 4100 04 04 42 i._f DAVbur 1 letter?
2 MR. THATCHSR: That is the second' slide.
- 3 DR. MOELLER: Thank.you.
4 DR. KERR: Okay.
5 (Slide.)
6 MR. THATCHER: I am Dale Thatcher, Task Manager 7 for the USI A-17, systems interaction.
8 Basically, I am going to give an overview of 9 where we are right now on A-17, with some background 10 information, and specifically the ACRS. letter of May 13th.
11 Dr. Okrent summarized a lot of what I have on 12 this slide.
[)
s_, 13 In a sense, I went back to the-resolution package 14 that went to CRGR in March '86. At that particular time we 15 were proposing a number of items, but I will make the 16 comparison when I get to the last slide of what we are doing 17 right now.
18 We had a CRGR meeting on that package back in 19 April '86. We interpreted what CRGR wrote after their
! 20 meeting as saying that they basically agreed with what we 21 were saying but that we did need some rewrites and 22 clarification.
23 It wasn't clear. We stated that we were 24 proposing no new requirements. They said we had a lot of OAl 25 wording in there that sounded like new requirements. We ACE-FEDERAL REPORTERS, INC.
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x mj - DAVbur' 1 have modified some of those things.
2 But.again I will try to cover all that on the 3 last slide.
4 We had the ACRS meeting, which led to the May 5 letter. We had the ACRS meeting back in May of '86. At 6 that meeting, as I recall, we pretty much discussed 7 definition, scope. That was probably the major subject of 8 discussion at the meeting.
9 There was some discussion among the committee, as 10 I recall, about what is one -- do we know what one is? How 11 long would it take us to do more work in this area?
12 I recall specific statements. Some people said
() 13 two years, five years. I think I may have even heard up to 14 10 years.
15 That was again then brought out in the May 13th 16 letter, and as I said, the next slide is specifically on 17 that letter. So let me not talk too much about that.
18 We responded to the May letter on August 1st of 19 1986. We think they had a response that dealt with every 20 point in that letter. We think that the program, the 21 resolution that we have right now is also responsive to that 22 letter, and as I said, I will give you all that.
23 Right now, as far as where we are, the revised 24 package is out for comment. We sent it out on November 24th 25 l and asked for -- I think it was two weeks -- return of ACE-FEDERAL REPORTERS, INC.
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'(,,f ' DAVbur 1 comments and concurrence.
2 We have been unable to get it. That was probably 3 a little bit unreasonable, given the holidays, and so forth, 4 but we are very close to getting the last comments in.
~
5 Two of the offices that we do not have are the 6 Legal Office and the Office of Research, but we think we are-7 pretty close to getting those shortly.
8 (Slide.)
9 The ACRS letter of May 13, 1986.
10 The way we read that letter is what I have 11 summarized on here, and of course if members have different 12 ideas on what was said, I am sure we will. discuss them after l ) 13 this presentation.
14 But let me just go through this. I read the 15 lette r -- Staff read the letter as recommending more 16 walkdown activities for spatial interactions, those physical 17 locations and related commodities -- for lack of a better 18 word -- just more walkdown requirements. Put it that way.
19 That is the way we interpret what ACRS was saying.
20 l That was put in the context of the August '85 l
21 proposal that went out for comment that Dr. Okrent referred 22 to, in which the A-17 program put out to all the offices a 23 package for coinment, and at that time we were proposing '
24 somewhat more, yet limited, but somewhat more walkdown I
- s. 25 ' activities for spatial interactions.
I ACE-FEDERAL REPORTERS, INC.
1 a- , , ~ .- + c- n -
4100 04 07 45 g' DAVbur As stated, that was changed in the package that
(,j 1 2 was brought to CRGR in March of this last year. But I will 3 also speak about -- we have addressed that also in our 4 resolution.
5 Basically, we read the letter that ACRS agreed 6 with the idea and an information letter for functional 7 interactions again was part of the proposal in August of 8 '85. It is basically still in there today, the same idea.
9 The ACRS also recommended a new standard review 10 plan section. Again, that was going back to the '85 draft 11 proposal that circulated for comment. That proposal had a 12 draft standard review plan section in it, but it was removed 4
13 before we went to CRGR, and the basis for removal was the 14 Staff comments which -- summarized basically -- which said 15 that most people felt the SRPs already covered these areas 1
16 sufficiently.
17 The next bullet, I think, is probably the biggest i
18 discussion item. The ACRS basically stated a disagreement 19 with the scope and definition of the issues, in the sense --
20 I believe the terms were -- in the longer term the Staf f 21 should initiate appropriate studies, which we interpreted as 22 leading to a search for a method to deal with all types of f
23 systems interactions.
, 24 I will have more to say about that on the last d
slide as to what we propose to do about that in our 25 f 1 i l
i k ACE-FEDERAL REPORTERS, INC.
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- 4100-04 08 ,
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~DAVbur' ' 1- resolution'as it is right now.-
2 The other item in-the letter of May 13th J
3 recommended'the removal of the single failure guidance. It-
. 4 didn't disagree with it. It just said that there should be 5 .another forum or another mechanism to deal with that aspect i
6 of what we were proposing as added guidance for single i
7 failure.
s
.8 Basically, that is the way the Staff read and I: 9 interpreted the letter, and that is what we responded tc, 10 and we think;that our program today is along the lines of' 11 what we said in our August 1st letter, which.was the 12 response to this, and what is in the package today.
13 (Slide.)
14 Getting to our revised resolution, basically-I 15 think one could characterize what we are trying to do as, i
16 number one, resolving A-17 and, number two, if there's other
! 17 things outside the definition of this issue and a number of '
- 18 other issues, actually, that they should be dealt with in 19 the longer term, in a different way maybe, and I will talk
- 20 more about that.
21 Specifically, actions for A-17 are kind of broken 22 I down by what actions we think are being done under A-17 and 3
, 23 ' what one can maybe call spinoff actions.
24 First, and pretty much consistent throughout all l
i 25 the drafts of the resolution of this issue, we are proposing i
i
! ! ACE-FEDERAL REPORTERS, INC.
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T._/ DAVbur 1 to issue a generic letter for information only. It will 2 deal with about five areas of functional interactions.
3 As I said, it is for information only. It would 4 go to all the licensees as a generic letter, and we would 5 expect that it would get treatment under their ongoing 6 activities to review all sorts of I&E notices, generic 7 letters, and so forth.
8 The next aspect is a statement on the reliance on 9 the resolution of USI A-46, which is seismic qualification 10 of equipment and operating plants.
-11 Specifically as part of the original draft 12 resolution of A-17 Dr. Okrent referred to back in August of 3 ) 13 '85, as I said before, we had a recommendation for spatial 14 walkdowns. The two areas that we were focusing on in that 15 proposal were related to seismic. The other one was related 16 to an area I will just refer to as flooding right now, but 17 it is certainly more than just flooding.
18 The resolution of A-46 over the last year has, I 19 will say, broadened somewhat, in the sense that they are 20 lealing with some seismic -- potentially seismically induced i
21 systems interaction. Based on that somewhat expansion of 22 , scope, A-17 is relying on that work.
l 23 l Now, admittedly, A-46 addresses operating plants, 24 and it is a certain set of operating plants, but along with 25 that we believe that newer plants are covered by SRP ACE-FEDERAL REPORTERS, INC.
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(,)1DAVbur l' requirements' and specifically Reg Guide 1.29, which all~ talk 2 about the possibility of seismically: induced systems 3 interaction.
4 Now, the A-46 program goes from the first 5 operating plants up through the plants-that are committed to 6 IEEE requirements before 344, 1975. The reg guide that.I 7 referred to that covers newer plants was issued, I -.t h i n k ,. a s 8 a safety guide in 1972.
9 So we think there is sufficient overlap there to 10 cover all plants, but there is a possibility that some may 11 'have slipped by, and we are going to cover those plants if 12 they exist. We are going to look at the possibility that
) 13 there are plants like that and in some way have confirmation 14 that all plants do indeed -- are either covered by A-46 or 15 by more current requirements in the SRP, and particularly 16 Reg Guide 1.29.
17 So based on that, we think that a major portion 18 of the seismic aspect or the spatial aspect, that being 19 seismic, is covered by the USI A-46 activities.
20 Now, I also mentioned that the original proposal 21 had or required more activity in the area of flooding. In 22 our resolution package that came before you back in the 23 April-May timeframe, we were proposing not to take any 24 action on flooding. We were going to rely on ongoing 25 industry activities in that particular area.
ACE-FEDERAL REPORTERS, INC.
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. -DAVbur. 1 In our present day resolution we have changed
'2 - this. We now are going to go out with a request, which is a 3 - requirement that they respond,'a request'for verification of
- 4 flooding.
5 It may be interpreted as reliance on industry, 6 4 but we considered the fact that we are going out with a set 7 ' of quest. ions, a very specific set of questions.- We think 8 that way we can audit what was done by the industry and by-i 9 the utilities in response to a number of' flooding concerns.
10 11 2
12 13 14 15 16 17 l 18 i.
19 20 l 21 22
! 23 l 24 25 ,i ,
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( ,/ - DAV/bc 1 Now, the definition of flooding that we've used 2 in our program is, as I said before, much broader than just 3 ' how much water. gets on the floor' during an event.
4 We have made the definition address' things like 5 spray, moisture, generally all kinds of water intrusion 6 problems.
7 As I said, it's now a 5054(F) request, which is a 8 requirement that all utilities respond. That's how we're 9 now proposing to follow up on the original concerns 10 expressed in a-17 on Flooding.
, 11 Now, a number of spinoff actions we are 12 proposing. The first one on here is:
() 13 Provide for integration of electrical power 14 concerns. Back in May, we were also stating that aspect of 15 the program. At this point, we' re a little bit further 16 along than at that time. We've now got a generic issue, 17 generic issue 128, which is an integration of a number of 18 previously existing generic issues on electric power 19 systems; specifically, for example, A-30 on DC power; GI-48 20 on limiting conditions of operation on vital buses. And 21 GI-49, which had to do with tie-breakers.
22 But there were a number of ongoing generic issues j 23 in the area of electrical power. And we've now integrated 24 them into a single program, which I mentioned was GI-128, 25 We are proposing that the information that's ACE-FEDERAL REPORTERS, INC.
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(_) DAV/bc 1 coming out of A-17 in its first redaction be. utilized in 2 that program.
3 If you look at the generic letter for 4 information, for example, the first item in that letter 5 that's highlighted is the electrical power system area.
6 So there is a definite, natural flow out of what 7 is going on in A-17. And what is flowing out of there into 8 this new generic issue 128.
9 The next item is:
10 Provide guidance for PRAs. We always have that 11 in the program. I think what we stated from the beginning 12 was that we couldn't make a recommendation on a method that
() 13 a PRA used, but we could make some recommendations on where '
14 they looked the hardest, where the problems have been, and 15 so forth. And we're still proposing that same kind of 16 guidance.
17 And, really, the guidance, again, flows out of 18 those first three items. The generic letter for information 19 talks about areas to look at. The second one of course is in the coismic area. And the third one is the flooding 20 l 21 l '
area.
22 ! Those are the areas that A-17 I think should be 23 focused on in any kind of PRA work.
24 As far as future plants go, we originally, as I 25 said, had a standard review plan cect ion proposed. We i
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( ) DAV/bc 1 removed it based on the fact that people thought the SRP 2 .already covered the kinds of things that we were talking 3 about.
4 We now are proposing that we develop a reg 5 guide. We envision that that reg guide would have guidanca, 6 as reg guides typically do, guidance in where to look, and 7 again flowing out of the first three bullets would be most 8 of the information for the development of that reg guide.
9 Now the last one. Develop scope concerns as 10 potential issues for prioritization.
11 As I mentioned on the previous slide, the biggest 12 area that we saw as a problem area was the question of A 13 definition and scope. In our response on August 1st, I
(_/
14 think we used the words, or words that could imply that we 15 were going to develop one generic issue that would be 16 prioritized, that generic issue being what flowed out of 17 these kinds of meetings as not being covered by our A-17 i 18 program.
i 19 I think now that we've further defined what we 20 ! plan to do, we're thinking that maybe it isn't going to be 21 f just one issue, that it's maybe multiple issues.
I 22 j The staff, I think, has learned that broad safety 1
23 i concerns do not get addressed well and that we need more l
24 focusing.
l 25 i So we're proposing that a number of scope ACE-FEDERAL REPORTERS, INC.
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(_j'DAV/bc- I concerns that:have been expressed, particularly by the ACRS 2 on issues like A-17, but also A-48,-there were a number of 3 discussions on scope. And that was highlighted.in the~ACRS 4 letter on A-46 also.
5 You will probably also be hearing about USIA 47, 6 which is control systems in the near future. And you will 7 see in that program that there's limitations on scope in 8 what they're doing. They're stated pretty clearly up 9 front.
1.0 The program that we' re initiating right now is to 11 deal with all these areas that have been raised that are not 12 addressed by those kinds of USIs. And also other programs.
() 13 It's not just USIs, it's the fire protection program. It's 14 the environmental qualification because, as I'm sure you're 15 all aware, they all have some relationship to systems 16 interaction.
17 of course, the only problem with that is that 18 almcot everything that's a safety problem is a systems 19 interaction. But we do intend to try to develop the 20 concerns. And I think the words are importants 21 Try to develop the concerns in the issues that we i 22 can work, and that's the major aspect that I think we'll try j
l 23 to deal with thin question of scope and definition of the i l
} 24 l issues.
25 ; That'n basically all I had to say. Of course, 1 i
! I i
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()DAV/bc 1 we' re available for comments. I hope I covered everything 2 that Dr. Okrent promised I would.
3 DR. OKRENT: I think you did what we asked.
4 Mr. Ebersole.
5 MR. EBERSOLE: This was the undisturbed portion.
6 Now, can you back up on the slides again?
7 MR. THATCHER: Did I make it in 15 minutes?
8 DR. OKRENT: You did it in sufficient time.
9 MR. THATCHER: Which one?
10 MR. EBERSOLE: Let's see, the third one, where it 11 starts: Recommend more walkdowns.
12 MR. THATCHER: That's the ACRS letter? Okay.
) 13 MR. EBERSOLE: I have a problem with walkdown as 14 identifying what really needs to be done. For one, I don't 15 think you can get special perspective just by pure visual 16 perception frcm wherever you happen to be, surrounded by 17 walls and equipment.
i 18 DR. KERR Excuse me, Mr. Ebersole. Are you 19 disagreeing with the ACRS letter?
20 MR. EBERSOLE: I'm asking for an expansion of the 21 term "walkdown" .
22 DR. KERR: You are stating that the ACRS letter 1
23 I is incomprehensible?
24 (Laughter.)
O 25 I MR. EDERSOLE: Since we're talking about more ace-FEDERAL REPORTERS, INC.
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('_')TDAV/bc 1 walkdown activities, we ought to elaborate on what we mean l I
2 by "walkdown". It's just a term.
3 And I think the consideration in spacial 4 arrangements, in particular, the coupling of spacial 5 volumes, is a vital part of this because you just can' t 6 stare at a room and forget perhaps that on the other side of 7 it is a boiler or a huge tank of CO 2 or something that 8 ought not to be there.
f 9 So, an extension of the term "walkdown", I think
, 10 is critical to understanding what you've got to do.
11 MR. THATCHER: I think you've caught me with the 12 problem I had with Dr. Okrent yesterday. He said that I
() 13 needed to elaborate on some of my terminology that I used 14 because of different interpretations, and so forth.
- 15 And given the time limitations, I didn' t do all
, 16 the terminology. But, from the beginning, I think, you i
17 know, if you look at the proposals, we meant by "walkdown",
18 I mean we used the term "walkdown" to mean an investigation 19 , that started with a paper review to know what your systems I
20 ' are.
i 21 MR. EBERSOLE: Spacial allocation of functions.
! 22 l Where do you put the furnishings? What is the potential 1
4 23 implication of the furnishings being in the same room?
l 24 l DR. OKRENT: Would you accept walkdown using O' 25 (
I x-ray vision?
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2 MR. EBERSOLE: I can recall a particular case 3 where a huge CO 2 tank.was put,'in essence, in the spreading-4 room of a plant. And the design of that_ invoked the theory 5 that NRC said vessels don't fail. He was extrapolating.
6 Anyway, that's just one point. Now,'the ACRS 7 letter recommended new standard review plants. And I think 8 11t'73 extremely unfortunately that that has not come to pass.
9 It's been removed by the staff'. I say that's a 10 natural result of tossing the problem to a compartmentalized 11 review process which will not see a need for doing anything 12 in their domain.
O)
\,_ 13 It's a bureaucratic problem. It's standard that 14 it would come out analyzed the way that it did because, I 15 know, I've been through it. I used to catch myself in the 16 wrong department because I was an electrical engineer and I 17 was in the civil section -- what the hell are you doing 18 here?
i 19 So that compartmentalized attitude and all of the l
politics, if you will, of reviewing these things inevitably l 20 l 21 leads tot 22 Don't get some generalist in here to cause any I
23 problems. I've got my job to do. The hell with you, get j
24 out of my room.
25 l And that's what produces the refusal to put this i
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) DAV/bc 1 as really sort'of in a system integration portion of the 2 standard review plan, which I think is sadly needed.
3 It's a natural result of the review process which 4 you used to get it examined.
5 In a further extension of this notion, I suggest 6 that it would be your problem, if you haven't already done 7 it, to come up to us and, in the actual language of the SRP, 8 validate the position taken by the staff.
9 Go through the SRPs and cut out the words that 10 say: They do consider system integration and system 11 interactive matters in the degree which we think is 12 important; that might result in about 50 papes of paper.
() 13 MR. THATCHER: More than that.- Definitely, more 14 than that.
15 MR. EBERSOLE: As the project leader on this, you 16 must see yourself, not rely on their position. You ought to 17 look at that.
18 MR.' THATCHER: I think we can provide you those 19 papers.
20 l MR. EBERSOLE: These would be excerpts.
21 MR. THATCHER: It would be a significant portion 22 ! of the SRP.
i 23 ! MR. EBERSOLE: Just get out the excerpts to I
validate what you have taken for granted as a position from 24 l O 25 l i
them.
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(_,.( DAV/bc 1 MR. THATCHER: I don't think we've taken it for 2 granted. I don't think that's true. I have personally been 3 through significant portions of the SRP. I threw one out 4 yesterday at the subcommittee, and then I went back to make 5 sure that what I said was really true. And I got it.
6 MR. EBERSOLE: On the matter of flooding, I think 7 we talked at the subcommittee meeting flooding means more 8 than flooding. It means intrusion of vapor, hot air, dust, 9 whatever you want to call it.
j 10 So, flooding is a too narrowly-defined function 11 of invasion, influx.
12 Okay, that's all I had to say.
O l
(_) 13 DR. KERR Other comments or questions?
14 DR. OKRENT: Carl, any comments?
15 MR. MICHELSON: I had a number of comments, but l
l 16 not any questions on the presentation. I think the l 17 presentation covered what was covered in the subcommittee, l
l 18 so maybe I'll be just giving my comments.
19 DR. OKRENT: I think it's appropriate.
l 20 l MR. MICHELSON: As a personal matter, I was j disappointed in the progress that was made on systeins 21 l i
! 22 i interaction, but certainly in no way fault the people who
' I 23 l were doing the work. I think they've actually made 24 commendable progress, it just fell somewhat short of what I
\ -) 25 I would have liked to have thought we would get to at this l ace-FEDERAL REPORTERS, INC.
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2 But, certainly we're a lot closer to I think now 3 understanding what systems interaction might-involve, 4 although there are many areas yet that we don't understand 5 because we haven't really sat down and thought through 6 carefully.
7 I assume that's a part of what will go on when 8 they start to scope the next phase of system interaction, 9 which I believe is a promise that the staff is making, that 10 they will go and scope some new potential generic issues and 11 then see if they are sufficiently important to pursue it.
12 So I guess the disappointment derives from not O
(_j 13 seeing it done already but rather now having to wait another 14 year.
15 We haven' t heard very clearly the schedules on 16 all of this. Maybe the staff could, first of all, tell us .
l 17 the regulatory guide schedule which you have in mind, and 18 also the scoping.
19 When do you think these scoping documents for
) 20 future generic issues will be completed?
21 MR. THATCHER: On the reg guide, right now we 22 , don't have a schedule for that. I admit I didn't 23 particu1~arly worry about that because of the lack of new 24 j licensing activities.
25 But the other one, the scopo questions, which I ACE-FEDERAL REPORTERS, INC.
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4100 05 11 60 DAV/bc 1 feel is the more important one to start tying some of these 2 loose ends down, we presently have -- I thought it was going 3 to go out about two weeks ago.
4 But it got hung up in somebody's office. 4 5 technical assistance program that's basically outlined to do 6 this scoping type of study. And the schedule on that, as I 7 recall -- now, of course, we might get a month late start--
8 I think was supposed to be finished in September of this 9 year.
10 MR. MICHELSON: What will be finished?
11 MR. THATCHER: Finished as far as what we have in 12 that. It's a description of the concerns that have been
) 13 expressed by yourself, other members, staf f members, and so 14 forth, in those areas.
15 Maybe I should mention that the title of the 16 program is called multiple system responses to plantwide 17 events. I'm not sure about the end of that. But it's 18 certainly a broad umbrella.
19 Under that broad umbrella, we want to look at the 20 ! concerns that have been raised and describe those concerns, 21 e develop those concerns so that we can turn them into what we 22 call issues to be worked.
23 } MR. MICHELSON: And the issue is to be identified 24 by September? Is that the idea? And then it will go out.
G 5J- 25 You'll pick somebody to work on the issue, and so forth?
i I
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()DAV/bc 1 MR. ANDERSON: There's one step in there. Then 2 the issue will be prioritized.
3 MR. MICHELSON: By the staff or by a contractor?
4 MR. ANDERSON: Well, by a contractor through the 5 staff.
6 MR. THATCHER: But that process wouldn' t start 7 'til September. ,
8 MR. MICHELSON: When do you think the 9 prioritization will come by? Is that another three months, 10 or something?
11 MR. THATCHER: The latest thing I had seen on 12 prioritization was that they typically, given that an issue
() 13 was given to them with enough background information and 14 specifically NRR of fice letter 40 type material, there had 15 been at one timo at least, I recall, a commitment to 16 prioritizing within a six-month time frame. Maybe three 17 months.
18 MR. ANDERSON: The six month is probably a pretty
- 19 good number if there is sufficient information. The 20 problem that's hung up a lot of prioritizations is they're 21 very ill-defined issues and we really didn't know what to do 22 with them.
! l l 23 ' MR. MICHELSON: This will perhaps be in that i
j 24 category until everybody agroes it's fully defined. You 1
25 will send us a copy of the issue in September, I assumo, and l
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2 MR. THATCHER: That copy of the issue, as I tried.
3 to indicate in our letter response, did kind of imply that 4 it would be one issue.
5 But based on what we see right now, it may be 6 many.
7 MR. MICHELSON: If I may proceed, let me go 8 through some of my other comments.
9 In the near-term now, your resolution calls for 10 sending a generic letter to the licensees for information.
11 At the subcommittee meeting, we brought up the question of, 12 well, to what extent do licensees necessarily even have a
() 13 program to review information notices?
14 To what extent are they required to review 15 information notices?
16 And you are I think going to come back and tell 17 us what you found out.
18 MR. TilATCllER: We didn't really do any more in 19 this investigation.
20 MR. MICilELSON: It was an important thing though 21 because I know, in the case of LERs, they're not required to 22 review any LERs except on their own plants.
23 The question was, woll, how about information noticon?
24 Are they even required to review them if they 25 aren't, shall we say, directly relating to somo that ace-FEDERAL REPORTERS, INC.
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4100 06 01 64 i-DAVbur 1 MR. ANDERSON: They are not required. We are not i 2 really expecting them to come back with any formal 3 response.
4 MR. MICHELSON: The question is: are they 5 required to review the information documents in documents 6 that they have reviewed?
7 I think they can ignore them completely.if they 8- wish.
9 MR. ANDERSON: That is their right. They can.
10 MR. THATCHER: I don't know if that is entirely 11 true.
12 MR. MICHELSON: I don' t know what they do with 13 them. They are not required, I believe, to do anything with 14 what you are going to send them.
15 VOICE: Periodically -- and this is done in the 16 regions periodically -- the inspectors that go out, both at 17 the site, the residence, and the ones that come in from the 18 regional headquarters, look at what is being done. This I
19 goes in through their periodic SALP ratings.
MR. MICHELSON: All they can do is look and see 20 l 21 l what, if anything, the licensee did with the information you 22 sont them, but they in no way can regulate this. It is 23 ' really difficult to even spot them for not having reviewed ;
24 it, since there is no requirement.
L- 25 i So I am not sure what the generic letter will ACE-FEDERAL REPORTERS, INC.
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2 -It is just a comment.
3 _ VOICE: It will bring all of these matters to 4 their attention not called in a systematic way.
5 MR. MICHELSON: It.certainly will inform them of 6 your. concern.
7 These flooding studies now that they are going to 8 do, I think you clarified and I assume that the few comments 9 that we had will be made sufficiently clear in your final 10 documentation, that it makes it clear that they go beyond 11 water, and I am sure you realize they have to go beyond the 12 liquid phase.
) 13 DR. MOELLER: Excuse me. What do you mean they 14 go beyond water?
15 MR. MICHELSON: The important thing is that the 16 early pipe break studies done back in the early '70s in 17 response to the Giambusso letter addressed only what they 18 called flooding, which was interpreted to mean water on the 19 floor that was rising. As long as the water didn' t, for 20 instance, rise up to a pump level, the pump might still be 21 considered operable.
22 They didn't consider the fact that the flood was 23 on the floor above and dripping down on the junction box, or 24 whatever. They also didn't consider the steam around the 25 building, but they looked at the water coming from the ACE-FEDERAL REPORTERS, INC.
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(_) DAVbur 1- broken high energy line, which is of course part water, part 2 steam.
3 They looked at the water flood but didn' t look at' 4 the steam, and of course that is where you begin to get your 5 potential for system interaction.
6 MR. NYLIE: Carl,'in that regard, can it be 7 concluded then that flooding includes all hazards that may 8 be in the area?
9 MR. THATCHER: How about we stop right here, and' 10 I will read you the definition that we are using in the 11 Generic 50-54(f) request.
12 MR. MICHELSON: That would be useful.
13 MR. THATCHER: As you will see -- I think I heard 14 dust here. It is not dust -- internal flooding, as used in 15 this document.
16 " Internal flooding includes all 17 forms of water or moisture release 18 internal to plant structures; for 19 example, leak or ruptures of water 20 or steam, fire protection system 21 actuation, et cetera. Regardless 22 of the means of release, the failure 23 mechanism is intrusion of water or 24 moisture to critical components."
25 MR. EBERSOLE: Question. I think there would be ACE-FEDERAL REPORTERS, INC.
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4100 06 04 67 j DAVbur 1 lost in that some phenomenon, which has been happening to 2 the embarrassment, I hope, of the people to whom it has 3 happened.
4 As you know, in its wisdom NRC elected not to 5 make fire equipment seismically competent or 1E or otherwise 6 safety oriented. So we have large manifolded systems of 7 carbon dioxide which, upon just minor faults, can be 8 triggered into spatial areas containing critical 9 equipment -- that is why you want to protect it -- in 10 unlimited amounts sufficient to explode in the various 11 places they discharge into just by the failure of a single 12 timing valve, which is supposed to emit just so many cubic n
(j 13 feet into that space but can instead discharge the whole 14 tank farm into it. -
15 We had rooms blow up for this. So I can easily 16 give you an example of a system interaction in the seismic 17 event.
18 If I have one of these systems that feeds into a 19 l battery room, I don' t need hydrogen to blow it up. I am k
20 going to blow it up with CO-2. In the sense that these are I
t 21 ' adjacent walls, I will take both of them down.
I Mr. Ebersole, is this simply --
22 DR. KERRt 23 MR. EBERSOLE: It is an example of a system interaction that is not covered in the scope. I think you f^
24l1-(s)' 25 ! are talking about water sprinklers.
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<. DAVbur 1 ~DR. KERR Your point is that you don't think 2 that the scope is being considered?
3 MR. EBERSOLE: Sharply defined, it might be.
4 when we said vapors.
I 5 MR. MICHELSON: 'I don't know the rewording and
- 6 ' don't want to pretend to reword it for you, but I'think'the.
7 point is that you really are considering=the rupture of both-8 high and moderate energy lines, and whatever they contain, 9 whether it be CO-2, water, steam, hot water, cold water, i
10 whatever. You are looking at the rupture of these lines and 11 the effect on the plant.
12 MR. THATCHER: You may be looking at that. We 13 are not.
14 MR. MICHELSON: I thought that is what this was 15 going to do.
16 MR. WYLIE: -I think this is basically limited to-17 water and water vapor.
18 MR. THATCHER: I think you are right.
19 MR. MICHELSON: And not to high energy steam, 20 although he says steam in there, but I am not sure where it 21 is coming from.
22 MR. THATCHER: Only as a moisture intrusion. I 23 think I just heard an example of one of our numerous systems 24 interactions of something going into an area and exploding.
25 No, water intrusion into critical equipment.
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(,).'DAVbur 1 MR. MICHELSON: I am just trying to find out what 2 -your scope is. I would suggest that your intrusion of 3 steam --
4 DR. KERR: Have you read the Staff's response 5 letter to our previous concern about pipe break? This may 6 bear on some of the questions.
7 OR. SHEWMON: Is that addressed to srl or the 8 speaker?
9 DR. KERR: Carl.
10 MR. MICHELSON: I am sorry, I didn' t hear. I was 11 talking to Paul.
12 DR. KERR: Have you read the Staf f's December
() 13 18th response to our comments on SRP 3.6.1.
14 MR. MICHELSON: Yes, I have.
15 DR. KERR: Are there further questions of 16 Mr. Thatcher or comments?
17 MR. MICHELSON: I haven't finished my comments 18 yet, but if you wish we can cease.
, 19 DR. KERR I was waiting for Mr. Ebersole to make 20 comments and I didn't realize you hadn't finished.
21 MR. MICHELSON: I still have a couple of 22 comments.
23 DR. KERR: Please go ahead.
i 24 MR. MICHELSON: One of the other points that you s 25 brought up -- and it is quite right -- A-46 is going to ACE-FEDERAL REPORTERS, INC.
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'! , DAVb'ur 1 resolve some of these problems. Until'I see the resolution-2' of'A-46, which I don't know yet how they are. going.to
[ '3 handle'it -- we have heard from the Staff as to how they 4 might be handling it ;-- we are not quite 'sure what portion 5 of our' letter is addressed. _
6 We will just have to reserve it till later.
s 7 The question that was raised in our letter, of 8 course, was what happens when a tank on one side of the room' 9 fails during a seismic event and the water runs across the I 10 floor to an inverter on the other side of the room. We said 11 that seemed like a 1caical interaction, already. accounted 12 for in A-46.
.( ) 13 The A-46 people in the past said, no, they 14 weren't going to account for it until recently. Well, it is 15 no longer clear whether they are or they aren't.
~
16 As I understand it, the CRGR package would not i
17 require it, but the industry thinks they are going to do it
- 18 anyway, which is commendable. But I don't know the l 19 situation.
! 20 DR. KERRt What is your point here, Carl?
{ 21 MR. MICHELSON: The point here is that that is a i
- 22 part of our letter, that is a part of our concern. I just 1
l 23 want to bring to the committee the fact that that part of 24 our letter has been rejected, at least by the Staff, ,
i i 25 although it may be picked up by the industry.
l t
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/ [ DAVbur 1 Is that correct? -
2 MR. ANDERSON: I think that is essentially it.
3 This particular item, we have told you we were concerned 4 about something structurally falling onto a component, but 5 we are not worrying about its contents.
6 In-A-46 we had taken the position then -- and I 7 think it is still true -- that that type of floo6ing is part 8 of this 50-54(f) letter we are proposing under A-17.
9 MR. MICHELSON: For which no action is required?
r 10 MR. ANDERSON: No, no, no. This is the part 11 which requires an action.
12 MR. MICHELSON: All you are requiring -- this
() 13 should be made clear to the committee, too -- all you are 14 requiring is that they tell you what they have done?-
15 MR. ANDERSON: That is correct.
16 MR. MICHELSON: And if they have done nothing,
, 17 that is a correct answer, also?
18 MR. ANDERSON: That is correct. They submit that 19 under oath and affirmation, and we will go from there. If 20 there is something they haven't done that falls within their 21 licensing basis and previous requirements, we could go out 22 under the order and make them do it.
23 Now, as I mentioned to you Wednesday, the Senior 24 Seismic Advisory Panel are recommending that when they do go
/
25 through, they do look at the water, and they think it is e
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( ) DAVbur 1 reasonable. They are very reluctant at this time, with the 2 state of the A-46 package, to go back and revise that and go 3 through this process again.
4 I think we are covered under the A-17, asking the 5 detailed questions, and I think there is a high probability 6 that this review will get done in the A-46 implementation.
7 DR. OKRENT: Can I ask a question in this regard?
8 Mr. Hernan mentioned during the subcommittee 9 meeting on Wednesday that there was a letter from the Staff 10 to the ACRS, or a copy of a letter, which described in some 11 way some modifications, I think, in the scope of A-46.
12 Do I remember this correctly?
(m
() 13 MR. HERNAN: There was a letter in response from 14 the Staff to the ACRS on A-46, specifically on ACRS ' letter 15 of concern that A-46 did not cover plants that are yet to be 16 licensed or plants that fall under the A-46 response.
17 I have not been back to my office since then, and 18 I have not tracked down the letter. I don' t know if 19 Mr. Anderson brought it in or not.
20 MR. ANDERSON: I am sorry, I did not.
21 MR. HERNAN: We will get a copy of that letter.
22 DR. OKRENT: I just don't remember having 23 received the letter.
4 24 MR. HERNAN: It is a fairly recent letter. I O 25 would guess the end of November, early December.
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DAVbur 1 DR. OKRENT: It will probably reach us for 2 Chinese New Year.
3 MR. HERNAN: If we are lucky.
4 MR. MICHELSON: I would like to get to my bottom 5 line so that at least you know my views on it.
6 I think the Staff has done the best job that-they 7 can in view of the controversial nature of the subject, in 8 view of the poor definition of some of it, the lack of full 9 understanding of what might be involved in this issue.
10 I believe the promises that they have made, when 11 properly implemented, will eventually get to a new issue 12 here.
() 13 I believe the resolution they are proposing is 14 only hitting the easier part of the issue,-but certainly one 15 that they can manage.
16 So my own view is that we should go ahead and do 17 nothing at this time. I would propose that we review the 18 public comments when they come back, and unless we have 19 strong feelings at that point in time about the situation, 20 we should go ahead and accept this present resolution, with 21 the understanding that these promises will be carried out 22 in some timely fashion, and that we work closely with the 23 definition of the scope next time to see that they do cover 24 the areas that we are concerned with.
25 That is my position. Thank you.
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( ): DAVbur. 1 .DR. KERR ' Can I interpret some of those 2 comments.as somewhat complimentary?
3 MR. MICHELSON: I think the Staff-did a fine job, 4 you know. .This is not a simple, easily dealt with issue.-
5 It is a sensitive issue.
6 MR. EBERSOLE: What I hear you saying, though, 7 Carl, is that they have put a valiant, desperate effort to 8 do something but they have been defeated by other 9 processes.
10 MR. MICHELSON: You can say it that way if you 11 wish. That is probably another view of the-same thing.
12 RD:R. KERR: That is an interesting translation.
-( ) 13 Are there further questions or comments?
14 Mr. Wylie?
i 15 MR. WYLIE: I will just say this.
- 16. I just think it is unfortunate and unfair to the 17 utilities to go forward with the resolution of A-46 and do 18 l the plant walkdowns and not look for the other potential 19 hazards that are there at that time and then come back later 20 and make them do it again. And I think that is where we are 21 headed.
22 I just think that is unfortunate. I think it
- - 23 ought to be done where they do it one time.
24 MR. MICHELSON: In that case, then, one should I
l 25 vote against the resolution.
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(_) DAVbur 1 DR. KERR: Mr. Thatcher?
2 MR. THATCHER: I just wanted to make a comment on 3 that.
4 We view the flooding work that we are asking 5 questions about as mostly having been done.
6 We also see that possibly A-46 walkdowns that are 7 yet to be done may be looking at some tank failures and some 8 water problems, too, which could be supplemental information 9 to respond to our flooding concerns.
10 I think this.is a good example of the overlap of 11 systems interaction. It wasn't planned that A-46 be around 12 and A-17 was coming to a conclusion or anything like that, f'
(,j) 13 but it just so happens that almost all these safety issues 14 could involve systems interaction.
15 And I think the Staf f on A-17 is not asking for 16 more walkdowns unless they haven' t done anything. Maybe 17 then they ought to be doing something.
18 MR. WYLIE: But how are you going to know that l 19 there is not a potential hazard out there -- say, for I
20 example, in hydrogen gas? How are you going to do that?
21 MR. THATCHER: We are not going to do it under l
- 22 A-17.
1.
l 23- MR. WYLIE: That is right.
24 i Would you be concerned if you had a seismic event
~T (d
25 !
l and you blew up a plant because of the release of hydrogen l \
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/~N U DAVbur 1 gas?
2 MR. THATCHER: That -- you know, the seismic 3 aspects, the seismic-induced kinds of things are definitely 4 the kinds of things that we are going to be'looking at in 5 this program that we said we are going to work now to 6 define, the things that weren' t covered under A-46, A-17, 7 A-47.
8 MR. WYLIE: What you are saying, though, is you 9 are going to go back and do it again?
10 MR. THATCHER: But we think that we will go 11 back -- if we do go back and do it again, we will ask the 12 utilities if it comes out that way to go out and look for
, ) 13 hydrogen bottles or something. That is very specific.
14 MR. WYLIE: What about hydrogen pipes for bulk 15 storage throughout the plant?
16 MR. THATCHER: I don't know.
17 MR. WYLIE: You don't know. That is the point.
18 I MR. EBERSOLE: I think he is right. 15et me give 19 you a more delicate thing.
20 i I just have a modest earthquake someplace, and 21 these great big weight-operated seal pumps and CO-2 control 22 systems, they blow uncontrolled volumes of CO-2 into a 23 battery room and blow down both walls. I haven't really had 24 a big earthquake, but I have blown up the batteries.
+
's 25 MR. THATCHER: That is another example.
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i)s_ DAVbur 1 If I can respond to these comments, I notice 2 Victor Stello said the same thing, but I don' t know if there 3 is a question on some of these. Sometimes I feel like I am 4 interrupting your discussion.
5 But we come down to ACRS meetings, my 6 predecessors came down to ACRS meetings, and there's 7 examples. We can all think of them. Like we can go around 8 the table. We can all think of them.
9 But it borders on asking the utility if you think 10 that systems interaction is a focused safety issue instead 11 of what I consider a broad safety concern. It borders on 12 going and asking the utilities to go out-and do -- hey, it
() 13 is more than walkdowns, in my opinion, that they have to do, 14 but go out and do good. It borders on that being that 15 broad.
16 And I don' t think the Staf f would know what to do t
17 with the response to a position -- go out and do good; go
[ 18 out and look for your hydrogen bottles; go out and look for 19 your CO-2 problems.
20 We wouldn't even be able to list them because we 21 would come down with a list and everybody would have ten s
J 22 l more.
23 So our requirement would be go out and do good.
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( ) DAV/bc 1 DR. KERR: Let me try to formulate one. Would 2 you think it would make sense to have two separate 3 walkdowns, both of which would be effectively systems 4 interaction?
5 That was the question Mr. Wylie was raising and I 6 don't believe you've responded to it.
7 MR. THATCHER: I don' t think it's logical to do 8 that. But, given the way -- it's not logical on one hand, 9 but on the other hand, maybe it is.
10 What are all the systems interaction issues we 11 should be looking at when we send them out to do this 12 wonderful, first and forever all walkdown? I don't think we
) 13 know them all.
14 There may have to be a second walkdown; I don't 15 know. If, today, we knew all the systems interaction and 16 all the things to look for...
17 DR. KERR: If you don't know what to look for, 18 ' now certainly you have to ask people to look for something 19 later on. But, if it's all a matter of waiting two or three 20 l months, or six months, until we know what we're looking for, 21 ! it strikes me that might be something worth considering.
22 ' MR. THATCHER: I don't think it's six months to 23 find out what we're looking for.
24 1 DR. KERR: Maybe it's a good idea to encourage (9
\/ people to have an annua walkdown, I don't know.
25 ;
1 1
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) DAV/bc 1 MR. THATCHER: Given the modifications, maybe it 2 is.
3 DR.'KERR: Mr. Okrent.
4 MR. OKRENT: I'm not clear on what the 5 responsibility of INPO is. But certainly systems 6 interaction can be interpteted in large part as operating 7 an safety question.
8 I'm just wondering if we were to follow Carl's 9 proposal of not holding up the staff with this proposed 10 approach, which they would have to send out for comment 11' anyway, and perhaps, at that point, judging whether we 12 should write what amounts to a strong letter, it is still-r 13 not relevant somehow to point out to the Commission that the 14 current efforts by the staff are limited in the kinds of 15 systems interaction that they are both looking at; and 16 proposing to call to the attention, or ask that the 17 utilities review, and that we think that it may be 18 appropriate for INPO to develop a broader scope of systems 19 interaction approach.
20 That is done by the utilities with the help, 21 formulation, structuring of INPO and review by INPO. I'll 22 put that on the table.
23 DR. KERR: Have we got other questions for 24 Mr. Thatcher?
ok- 25 (No response.)
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.DAV/bc 1 MR. HERNAN: Mr. Chairman, I would like to 2 correct the record on one ir, sue , if I may. The statement 3 was made that there was no obligation on the part of 4 utilities to look at information notices, generic letters, 5 and the like.
6 There was a TMI action item, 1C5, entitled 7 I procedures for feedback of operating experience from plant 0
8 staff, which, to my knowledge, has been implemented at all 9 plants, and very specifically requires that the plants have 10 procedures to feed back any information relative to the 11 safety and operation of the plants, and any procedures to 12 specify who within their organization gets this information, o
(_) 13 down by position.
14 From this standpoint, it's my belief that the 15 information such as we would issue on A-17 will reach or i
16 l will receive some attention by the utility if they properly i
17 l implemented this TMI action plan item.
18 MR. MICHELSON: I would strongly recommend you 19 talk to Jack Heltemes on this matter. He'll refresh your 20 i memory. What I want to know if the current status.
21 l Back in 1980 or about '81, I signed out a letter 22 l in which we reached agreement between the agency and INPO 23 i that INPO was going to do this job except for events 24 , occurring directly on that plant. INPO was going to do all l l
(~/
'm 25 ! the review because each utility couldn't possibly review all i
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() DAV/bc 1 the LERs , the effect of all the information notices, and so 2 forth.
3 It was to be done as a consolidated job by INPO.
4 Now, I think that's still the case.
5 MR. HERNAN: I don't believe that letter relieved 6 the utility.
l 7 MR. MICHELSON: Yes, that letter superceded the i 8 requirement. Essentially, it satisfied the action plan item l
9 as to how this done. Now, each utility must still name a
! 10 person to coordinate this activity at the utility, 11 But the utility is not responsible to sit down 12 and read every LER, for instance. I didn' t know on p
(_) 13 information notices, and that's why I asked for the 14 clarification.
15 Are they actually still expected to read and act 16 on every information notice as appropriate, and document 17 that they've done it?
18 MR. THATCHER: I think the answer to that is yes.
19 MR. MICHELSON: I don't know the answer.
20 MR. THATCHER: LERs may be passed on, but you 21 must remember that, on A-17, we did look at LERs and we 22 ! condensed that information into possible applicability to 1
23 ! all plants. And that's what our generic is.
I 24 l MR. MICHELSON: I think it's important to get it m
N- somehow clarified before the committee though the exact 25 ;
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i, ) DAV/bc 1 obligation. All it takes is a call to Jack and ask~him to 2 tell you.
3 MR. HERNAN: I'll get that clarification.
4 DR. KERR: Mr Shewmon.
5 DR. SilEWMON: I guess I'll say this to 6 Mr. Thatcher, and anybody else can listen.
7 Some people who are inherently more optimistic, 8 perhaps more naive, such as myself, feel that, indeed, if 9 there are things out there which are going to rise up and 10 bite you, that you'll see them and perhaps CO 2 won' t blow
'll out the walls on the worst possible day of the year, when 12 you have something else going on.
) 13 And then, indeed, the systems interactions, which 14 are important and bothersome, will show up over a period of 15 time for people who are at least interested in seeing these 16 precursors .
17 And they'll get a pretty good idea of the ones 18 that are important without having to go out and having to 19 kick over all the rocks and keep harrassing themselves and 20 others about whether or not they have found all the 21 i conceivable interactions.
I 22 l So, over the years, perhaps you'll get to know 23 I what the important systems interactions are simply if we 24 , keep our eyes open. Without doing all the things you're i
Os 25 ' afraid we might be asked to do.
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(_) DAV/bc 1 DR. KERR: Mr. Thatcher.
2 MR. MICHELSON: I think that's a good follow-on 3 statement of pre:isely what INPO was supposed to do, so each 4 utility didn't have to bother.
5 DR. KERR: Mr. Thatcher, we thank you for your 6 presentation. And the staff members. I declare a recess 7 until 10:4 5.
8 (Recess.)
9 DR. OKRENT: I said there were going to be 10 several options. The committee could'make a choice for 11 either action or inaction. And one can do that either now 12 or on Saturday.
() 13 DR. KERR: Is it the sense of the committee that 14 we should write a letter at this meeting, or that we wait?
15 MR. MICHELSON: Do you want to ask for a vote?
16 DR. SHEWMON: I'd rather hear some discussion, so 17 I can know which way to vote.
18 MR. WARD: What would the letter say, in general?
19 MR. EBERSOLE: I think it would say two things.
20 Extrapolate funding that would include more than liquid water. And I would personally make the complain'. that this 21 l 22 doesn't appear as the part of the SRP, the integrating 23 l aspects of the SRP; because I'm perfectly confident it's i
24 j been stamped out by a proceeding through the 25 compartmentalized process.
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) DAV/bc 1 MR. MICHELSON: Would it_make any difference if 2 we say that now or say it three months from now?
3 MR. EBERSOLE: I don't think it would make any 4 difference anyway because they're going to have to wait for 5 something to happen.
6 DR. KERR: I've heard one suggestion that we-7 should write a letter. Does anyone else think we should?
8 (No response.)
9 DR. KERR: My sense is that we don' t write a 10 letter at this point.
11 Mr. Okrent, you are next on the agenda, for some
- 12 odd reason, to discuss Chernobyl.
() 13 DR. OKRENT: You will recall that, at the last 14 meeting, we spent some time on the draft Chernobyl letter.
15 And toward the end of the discussion, our wise, then 16 cha i rman . . .
17 DR. SHEWMON: Then wise or still wise?
18 DR. OKRENT: Our then chairman said that he 19 thought this was an important letter. We probably didn' t 20 have to get it out in December, and it might be well to i 21 reflect on it for a month.
22 And I certainly wouldn' t disagree. So we asked 23 that people provide comments in the office that they might 24 have on the letter.
25 I must say there was one very detailed comment i
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4100 07 08 85 DAV/bc 'l from Paul Shewmon. It'was sufficiently detailed that I 2 thought I could use it to prepare an alternate draft 3 letter. I didn't want to throw away the first one because 4 of a suggestion by one member, but it leads to a shorter 5 letter which cuts out some of the recommendations and 6 shortens discussions on some of the recommendations, and so 7 forth.
8 -And I made only what I would call no major 9 changes in what I'll call the old letter -- sort of 10 editorial type things. And I still left some things in 11 there repetitive because I didn't know, if the committee 12 stays with that one, which of two short paragraphs or long 13 paragraphs on the same subject they would like.
14 I didn't make any effort to remove duplication 15 from that letter since, again, that letter is somewhat of a 16 camel with contributions from various members.
17 I would propose that we quickly read through.
18 Before we do that, we have Brian Sheron and the staff. I 19 propose we hear from them very briefly -- maybe.five 20 minutes. He said maybe he might not even need that much.
21 He can tell us in the first place what the 22 schedule is, whether they need a letter from us, and any 23 changes if major in what they have written that we had 24 available to us in December, et cetera.
25 So I'd like to start with Brian Sheron and only
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(,j DAV/bc 1 pose questions to him that we think are really important for 2 purposes of our own letter.
3 Either you'd like to know more about why 4 Chernobyl did what it did -- we're not even going to discuss ,
5 that in the letter, for example.
6 So, if it's agreeable, let's hear from Brian.
7 MR. SHERON: Thank you. The status righ: now of 8 the two reports. One is the factual report. There was a 9 meeting on December 19th with all of the authorc from 10 various agencies and organizations.
11 We agreed at that time that we would publish the 12 report as a review draft. This basically means that we are
() 13 l
going to issue it, we think now, on February 6th for about a 14 45-day comment period.
15 We wculd not be issuing it in the Federal
> 16 Register, but rather issuing it to cognizant people. Each 17 agency will issue it to their own constituency.
18 For example, EPA may have people they would like 19 to have review or comment on it. NRC would issue it, and
- 20 the like.
21 At the end of that 45-day comment period, the 22 d proposal was for all of the organizations that participated i I 23 '; to get back together again and see if we could agree on a i I
! 24 i final version which would be released as the U.S. report, l /~T kl 25 I'd say.
I 1 .
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,a g_) DAV/bc 1 If there was no agreement that could be reached 2 and each agency could do what it liked with the report, for 3 example, we will be assigning a NUREG number to the report.
4 We asked each of the agencies if they wouldn't 5 like to assign a number, a report number from their agency 1
6 to it.
7 I think all of them declined at this time. So 8 we'll only have a NUREG report, although the title will-9 identify each agency which contributed.
10 We're preparing right now to brief the Commission 11 on both the factual report as well as the implications 12 report on Februaryr 6th. We're scheduled, I believe, at 10 (m_) 13 in the morning.
14 We are going to send down to the Commission a 15 Commission paper transmitting both the factual report and 16 the implications report the week of January 20th.
17 And I think really that's going to be dictated ?)y 18 the printing schedule for the report. How soon we can get 19 it turned around and printed.
20 ' With respect to the implications report, we have 21 really done very little since we have spoken to the 22 committee last time, which I believe was around December the 23 12th. The only thing that we've done is some minor cleanup, 24 editing, and the like.
O- 25 li There's been no change in the conclusions that n
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(_) DAV/bc 1 were reached or the recommendations. We did find that the 2 committee's comments in three arqas of the operator section, 3 which I believe is chapter one, were very helpful. And we 4 made some changes to reflect those comments in the writeup.
5 other than that, the report remains basically 6 unchanged from what you've seen last' time. And, again, we 7 are preparing to send our Commission paper the week of 8 January the 20th, so we would very much like to have a 9 letter from the committee prior to that so we could 10 certainly reference it.
11 And in our Commission paper, I think from my 12 point of view at least, what we would hopefully be seeing in
-s s
(_) 13 the committee's letter is we would like to know if there's 14 any major omissions that you think we have not covered 15 properly, or any other major problems that you think we 16 might have with the report.
17 l I guess my feeling now is that I've not heard any 18 in the past two weeks, so I'm sort of presuming that there's 19 no major objections to what was covered in there.
20 But, if there are, we would certainly like the 21 committee to note them in their letter.
22 That's really all I have in terms of status, but 23 we can answer any questions.
24 DR. MARK: You speak of a mysterious bunch of 25 agencies. Is this one report subscribed to by everybody, ACE-FEDERAL REPORTERS, INC.
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ls,_)-DAV/bc 1 like the Food and Drug- Administration, the Department of 2 Labor and the Department of Justice?
3 DR. SHEWMON: These are only agencies that would 4 find Chernobyl has some relevance to-the areas which they're 5 involved in.
6 DR. MARK: Then who are they?
7 DR. SHEWMON: It's the Department of Energy, the 8 Electric Power Research Institute, the Institute for Nuclear 9 Power Operations, FEMA -- the Federal Emergency Management 10 Agency, and our Environmental Protection Agency.
11 Those are the agencies that are involved in the 12 preparation of the factual report.
() 13 DR. MARK: The Department of Health doesn' t come 14 in?
15 DR. SHEWMON: No.
16 DR. MARK: And there's one-report which may have 17 a stamp from each of these sources, but it would be the same 18 words?
19 DR. SHEWMON: Let me find one viewgraph. If I 20 could put it up, maybe that will help.
21 (Slide.)
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. (,p) DAVbur 1 MR. SHERON: What we had agreed to early on was 2 that we didn't really see the need for a whole bunch of 3 different agencies writing their own report on Chernobyl and 4 therefore.having the U.S. have four or five or six factual 5 reports floating around, each one maybe contradicting one 1 6 another.
7 We decided early on that really what we needed 8 was just one U.S. report.
P 9 So we sat down and we divided up the subject 10 areas. We said, okay, each agency and one person in that 11 ' agency is the lead author. They are responsible for writing 12 up the facts associated with that subject area.
() 13 This is how it-fell out, as you can see, and also 14 NRC assumed the role of the overall coordinator for the 15 report. We prepared the introduction, the summary, and a i
16 description of the accident scenario, and the radionuclide 17 dispersion and transport.
j 18 The Department of Energy wrote up the section on 19 the plant design description.
20 EPRI wrote up the safety analysis of the RDMK 21 reactors.
! 22 INPO wrote up the role of the operating 23 personnel.
'. 24 FEMA logically wrote up the section on emergency I
i 25 preparedness.
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(_) DAVbur- 1- And ' EPA did the environmental consequences.
2 The ground rules were that we did not have to 3 have every agency bless every chapter. We iwere having some 4' trouble because there was disagreement.
5 For example, I believe EPA used.the Bier reports,:
l 6 and there were some other people in different agencies which 7 . felt that they were maybe not the most appropriate reports-8 to use when looking at the radiological consequences or the 9 health effects, and'we can see that we would never get a 10 report out if we were trying to make everybody happy because 11' every agency has its own agenda.
12 So what we decided was that we would all comment
( 13 on one of those chapters and review it and try and provide.
14 constructive comments, but in the end each agency and 15 organization was ultimately responsible for that chapter.
16 And what that means is that when the report goes 17 out it does not mean that every agency endorses every 18 chapter in that report. When the report goes out, it is 19 nothing more than a compendium of different chapters written 20 by different organizations.
21 If somebody calls up and says, hey, we don' t like 22 what we saw about the emergency preparedness, then if DOE 23 disagreed with that, they can say, well, we didn' t like it 24 either and we don't acknowledge that we endorse that, and if 25 you have problems with it, go talk to FEMA.
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.4100 08 03 92 DAVbur 1 So'the report will go out.- We are going _'to try 2 and solicit comments from knowledgeable people. At the end 3 of 45 days we propose to get back-together again as a group, 4 the authors, sit down, digest the comments, try and put 5 together a final report that everybody can agree with.
6 If we can all agree with the report that these 7 are indeed a good description of the facts, then the 8 arrangement is that we would issue the report as a joint 9 agency report. Each agency would put their number at the 10 top, and they would endorse the entire report.
11 If we couldn't reach agreement, then each agency 12 could either join in or not in terms of endorsing the
() 13 report.
14 DR. OKRENT: Excuse me a minute. I am sorry to 15 interrupt.
16 But in a sense this is a topic that is not 17 directly related to what the committee has to comment on. I 18 was worried, when Brian said he was going to mention this, 19 thuat there would be committee interest in this.
20 I would like to use the available time, because 21 there is not a lot of time on the agenda today -- we now 22 have three versions of the letter -- if the committee will 23 permit me to sort of get on with the question of the l
24 ' committee reports?
O 25 DR. KERR: I am sure Brian won't be hurt.
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}. C). DAVbur. 1 DR.'OKRENT: Is that'okay, Brian?
2 MR. SHERON: Fine.
3 DR. OKRENT: I warned him before that I didn' t 4 want to take too much time.
5' DR. MARK: I am sorry I went into that diversion, 6 but I really --
7 DR._OKRENT: No, no, no. It is a very logical 8 question. I knew -- and as a matter of fact, I almost said 9 don't mention it -- I knew there were going to be' questions 10 on it.
11 DR. KERR: I should say I put this on the 12 bulletin board.
) 13 DR. OKRENT: I am sorry, I missed it. I have 14 been checking it for the-last couple of. days before I left.
15 I guess I had other things.
16 DR. KERR: I looked, and I thought it indicated 17 that you had seen it.
I 18 DR. OKRENT: In any event, we have three. Let me 19 read them through, if my voice permits, and I will give you 20 a personal opinion when I am done on how I think the 21 committee -- I think we will have to take a vote.
22 DR. KERR: Do you really want to read this i 23 through?
l i
24 DR. OKRENT: Let's do it. ,
r I 25 DR. SHEWMON: Do we want to take a vote on which l
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.O oavher 1 ef the three e ane te reed 2 2 DR. OKRENT: Are there more than three?
3 I think the committee should.
4 I can skip the first paragraph, I think. I will 5 read the thick one first, going from thick to thin, okay?
6 (Whereupon, at 11:05 a.m., the committee went i 7 into unrecorded session.)
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ACE-FEDERAL REPORTERS, INC. ,
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SUBJECT:
USI A-17 " SYSTEMS INTERACTIONS" DATE: January 1, 1987 PRESENTER: DALE THATCHER O
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