ML20211M731
| ML20211M731 | |
| Person / Time | |
|---|---|
| Issue date: | 12/11/1986 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 ACRS-GENERAL, NUDOCS 8612180033 | |
| Download: ML20211M731 (64) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of:
COMMISSION MEETING Periodic Meeting with Advisory Committee on Reactor Safeguards (ACRS)
Public Meeting Docket No.
l
/
Location: Washington, D. C.
Date: Thursday, December 11, 1986 Pages:
1 - 59 ANN RILEY & ASSOCIATES Court Reporters 1625 I St., N.W.
8612180033 861211 PDR 10CFR Suite 921 PT9.7 PDR dashington, D.C.
20006 (202) 293-3950
o e
1 D I SCLA I MER 2
3 4
5 6
This is an unofficial transcript of a meeting of the 7
United State's Nuclear Regulatory Commission held on G
12/11/86 In the Commission's office at 1717 H Street, 9
' N. tJ., (Ja sh i ng t on,
D.C.
The meeting was open to public 10 attendance and observation.
This transcript has not been 11 reviewed, corrected, or edited, and it may contain 12 inaccuracies.
13 The transcript is intended solely for general 14 Informational purposes.
As provided by 10 CFR 9.108, it is 15 not part of the formal or informal record of decision of the 16 matters discussed.
Expressions of opinion in this transcript 17 do not necessarily reflect final determination or beliefs.
No 18 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Commission may 21 authorize.
22 23 24 25
4 1
1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
4 PERIODIC MEETING WITH ADVISORY COMMITTEE 5
ON REACTOR SAFEGUARDS (ACRS) 6 7
PUBLIC MEETING 8
P 9
Nuclear Regulatory Commission 10 Room 1130 11 1717 "H" Street, N.W.
12 Washington, D.C.
13 14 Thursday, December 11, 1986 15 16 The Commission met in open session, pursuant to 17 notice, a't 10:02 o' clock a.m.,
LANDO W.
ZECH, Chairman of 18 the Commission, presiding.
19 20 COMMISSIONERS PRESENT:
21 LANDO W.
ZECH, Chairman of the Commission 22 THOMAS M. ROBERTS, Member of the Commission 23 FREDERICK M. BERNTHAL, Member of the Commission 24 KENNETH M. CARR, Member of the Commission 25
f 2
1 STAFF AND PRESENTERS SEATED AT COMMISSICN TABLE:.
2 S. Chilk 3
W.
Parler 4
D. Ward
'~
5 H. Lewis 6
C. Siess 7
J. Ebersola 8
D. Okrent 9
C. Wylie 10 W. Kerr 11 C. Michelson 12 F. Remick 13 P. Etherington 14 D. Moeller 15 J.C. Mark 16 M. Carbon 17 H. Etherington 18 19 20 21 22 23 24 25
_-3 s
4 3
1 PROCEEDINGS 2
CHAIRMAN ZECH:
Good morning, ladies and gentlemen.
3 Commissioner Asselstine is on travel overseas and will not be 4
with us this morning.
5 Today's meeting with the Advisory Committee on 6
Reactor Safeguards is for the purposa of allowing an 7
opportunity for the advisory committee to inform the 8
Commission on the results of some of their recent 9
deliberations on two topics.
10 The first topic is the effectiveness of programs 11 which address generic and unresolved safety issues and the 12 second topic is comments on work in areas of advanced and 13 standardized reactor plants.
s 14 The chairman of the advisory committee, Mr. David 15 Ward, will lead the meeting.
He will be assisted by 16 Dr. Chester Siess for the first topic and Mr. Charlie Wylie 17 for the second topic as I understand it and other members may, 18 of course, participate as they desire.
19 These are both topics which the Commission continues 20 to hold a high level of interest in.
We look forward to the 21 discussion this morning.
Do any of my fellow Commissioners 22 have any opening remarks?
23
[No response.]
24 CHAIRMAN ZECH:
If not, please proceed, Mr. Ward.
25 MR. WARD:
Thank you, Mr. Chairman and 1
r 4
4 1
Commissioners.
We do have two topics.
We anticipate that the 2
first topic should take about 30 minutes depending upon how 3
much discussion there is and that the second topic about an r
~" 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. So we have 90 minutes allotted for the meeting.
5 We appreciate the opportunity to be here.
We will 6
lead off with the first topic, Dr. Siess.
7 MR. SIESS:
Thank you.
In your letter of September 8
18, 1986, Chairman Zech, in guidance to the advisory committee 9
on reactor safeguards, you included the item to advise the 10 commission on the effectiveness of programs which address 11 generic and unresolved safety issues.
4 12 As you probably know, we have been involved in 13 reviewing unresolved and generic safety issues on a rather 14 selective basis.
There are a number of the major issues that 15 the full committee and its subcommittees have devoted a great 16 deal of attention to, A-45, A-46, essentially all of the 17 USI's.
18 It is not entirely clear to me at this stage just 19 what you mean by the effectiveness of the programs.
We have 20 been involved in the prioritization process.
The staff came 21 to us and we reviewed their plan and criteria for prioritizing 22
.the generic issues and as you know, we collect batches of 23 those, assign then to our subcommittees and we either agree or 24 disagree with the basis for the priority they decide.
25 CHAIRMAN ZECH:
Would you move the microphone a
5 1
little bit closer, please?
Thank you.
2 MR. SIESS:
In a number of cases, we have disagreed 3
with the staff and after some discussion have reached some 4
agreement at a priority level.
Just to give you a little 5
background of a problem,.I have gotten something recently from 6
the staff of a statistical nature.
7 There were 709 generic items.
I don't know at what 8
rate they are being added to, but of those 709, they have 9
resolved in one way or another about two-thirds of them.
10 There are 228 that remain to be resolved at this time.
11 Of those, 154 have been assigned priorities and of 12 those 154, 12 have been made unresolved safety issues and 73 13 have been classified as high or medium priority which means 14 they will be worked on.
15 The remainder, 69, have been prioritized as low or 16 drop which with current resources means nothing is going to be 17 done about them in the near future.
So about half of those 18 remaining issues that have been assigned priorities have ended 19 up at a level where they will be Worked on with some degree of 20 effort.
21 The USI's, of course, are the highest effort.
There 22 are 79 that have not yet been assigned priorities and we have 23 not reviewed them at all.
If the ratio so far holds, about 24 half of those will end up at high or medium which means that 25 out of the original 709, there will be about 128 that still I
l
6 1
remain to be resolved.
2 Now just on those statistics, I don't know whether 3
you or I would say that the program has been effective or 4
not.
At this stage, what I am mentioning here is only the 5
question of resolving or assigning priorities to and 6
resolution does not mean that anything has been done.
7 Sometimas resolution means nothing has to'be done.
8 Sometimes resolution means that something should be done in 9
the future but nothing should be backfitted.
Sometimes 10 resolution means we know what we ought to do, but we haven't 11 gotten around to doing it yet and it might take six months or 12 in another case, it might take five years.
13 Our review of resolutions has been a lot more 14 selective as I tried to mention.
Of the 449 that have been 15 resolved, this committee or its subccamittees has not looked 16 at every one.
We have looked at the major items.
I am trying 17 to develop a list of those we have looked at it but they are 18 obvious ones, the USI's, the A-45, the A-46 and so forth.
19 So if effectiveness means how efficiently the staff 20 has been working on this or effectively they have been working 21 on it with the resources they have had, that is one measure of 22 effectiveness.
23 of course, another measure of effectiveness would be 24 the extent to which the resolution of generic items has 25 increased safety.
7 1
Now case by case, we have commented on that in the 2
letters we have written but overall, I don't really know 3
whether we have enough information now and whether that is 4
what you really intended for us to get into.
5 So in a way, I am asking for some additional 6
guidance on what type of effectiveness you would like us to 7
comment on and to what breadth and what depth.
8 CHAIRMAP ZECH:
All right.
Fine.
Thank you very 9
much.
Do my fellow Commissioners have any comments?
10 Commissioner Roberts?
11
[No response.]
12 CHAIRMAN ZECH:
Commissioner Bernthal.
13 COMMISSIONER BERNTHAL:
Are there any other comments 14 on this subject from members?
15 MR. SIESS:
I should say that we did not have time 16 this morning to review this within the committee.
They are l
17 hearing what I said for the first time because we had some 18 other more urgent business.
19 CHAIRMAN ZECH:
Then perhaps we should allow.
20 Dr. Okrent.
21 MR. OKRENT:
A less procedural and more perhaps I 22 will call it substantive issue to bring up in this regard and 23 it is particularly my own, we didn't talk about this within 24 the committee, and let me preface my remark by saying I think 25 that it is important that the major opinions of the commission t
-.7.
8 1
be robust, independent of which party holds the presidency and 2
I think, in fact, in your safety goal policy as best as I can 3
tell, you have a policy which comes as close as you can to 4
meeting that kind of criteria.
I want to congratulate you, in 5
fact, on doing that.
6 CHAIRMAN ZECH:
Thank you.
7 MR. OKRENT:
I am less certain that in the way 8
backfitting and severe accident policy is proceeding and that 9
includes generic items, of course, that that is the same.
j 10 It seems to me at some point the Commissioners 11 themselves are going to have to ask very seriously of 12 themselves why is it that major countries in light water 13 reactor technology like Germany and France and countries like 14 Switzerland and others in Western Europe, Finland and so 15 forth, have gone well beyond what the U.S.
is requiring of its 16 current plants both with regard to prevention and with regard 17 to mitigation.
l 18 I will say both and I think there are numerous 19 specific examples of this, things that seem to be unlikely to i
20 pass the backfitting rule if you apply first some kind of cost 21 benefit test, let's say using $1,000.00 per man rem, and then 22 apply further a question, is it some significant effect on 23 risk with "significant," of course, a subjective term.
24 So this is why I say that it seems to no that in the l
l 25 end, the commissioners need to look into this issue rather l
l
9 1
deeply and have their own policy position for why it is okay 2
not to do let's say what these other countries are doing and I 3
am talking about things in fact in large part were done before 4
5 Even in Germany they instituted these things before 6
7 I will leave it at that.
8 CHAIRMAN ZECH:
All right.
Thank you very much.
9 Any other comments?
10
[No response.]
11 CHAIRMAN 22CH:
Commissioner Bernthal.
12 COMMISSIONER BERNTHAL:
I am sensing a slight 13 disconnect between the subject and the comments.
14 MR. OKRENT:
I said it was not directly down the 15 procedural path.
16 COMMISSIONER BERNTHAL:
All right.
Excuse me.
17 Tcday's agenda, okay.
I am hardly in a position to ask 18 probing questions on the major point that you make nor do I 19 necessarily disagree with it.
20 I guess I would like one clarification at least and 21 that is my sense which is based on less data than yours I am 22 sure that if you go country by country and even within a given 23 country, you will indeed find fixes, preventive measures, 24 mitigation measures that we have by in large not instituted 25 anywhere at any of our plants and the fact that we have a
10 1
third of the plants in the world then certainly broadly 2
speaking the paint can be made that you make.
3 Is it equally trus though and is it also the case 4
that any of those countries you mentioned before Chernobyl, 4
5 now afterward, I think, there clearly are some trends that you 6
can see, but is it equally true that before the Chernobyl 7
event any of those countries issued broad and generic 8
requirements that you can broadly say are both preventive and 9
mitigative in a way that we have never done?
10 I know there are a couple of areas.
I think station 11 blackout is one, for example, where we trail the other 12 countries but could you comment a bit more on that?
13 MR. OKRENT:
I would be glad to.
I think the record 14 is clear that in what are probably the two major LWR countries 15 in Western Europe, France and the Federal Republic of Germany, 16 before Chernobyl they were taking significant additional steps 17 to try to prevent core damage and they were taking significant 18 steps to try to mitigate severe accidents.
19 I am talking primarily about large dry PWR's 20 although Germany has a BWR as well.
Switzerland which is a 21 smaller country took some very strong measures before 22 Chernobyl.
The Swedes for political as well as technical 23 reasons did before Chernobyl.
24 I don't know whether Finland is before Chernobyl or 25 after.
11 1
COMMISSIONER BERNTHAL:
Let's see.
Can you be 2
specific though?
I mean, bunker decay heat removal systems, i
3 independent decay heat removal in Germany I understand and one 4
can also say the French began down the path of a separate 5
generic requirement for some kind of filtered vent.
Are there 6
other things that you can name specifically?
7 MR. OKRENT:
Yes.
In France, I happened to be there 8
when they instituted what.you would call a severe accident 9
policy in a pragmatic way.
In fact, they postulated failures 10 of each safety system and I asked EDF to tell us what is going 11 to happen and what can we do to mitigate this.
i 12 So different things were implemented and in fact the 13 NRC staff has a very nice report which compares Paluel with 14 one of our BWR's and lists a variety of things, one of which, 15 for example, is trying to keep the seals on the PWR from 16 failing in a station blackout and thereby aggravating it with 17 a LOCA which we have taken no steps as far as I know in this 18 country and they have others.
19 Germany has moved to the N Plus 2 which gave them 20 greater redundancy in all their systems.
They had moved to 21 trying to even out the contribution to risk from any scenario 22 before Chernobyl.
23 They decided on filtered vent containment before 24 Chernobyl it turns out.
25 COMMISSIONER BERNTHAL:
Germany also as well as
12 i
1 France.
2 MR. OKRENT:
As well as France, and France has other 3
mitigation measures such as the last ditch ways of getting 4
water and so forth.
5 So the thinking about this, I know in France began 6
around 1977-1978, pre-TMI even.
7 COMMISSIONER BERNTHAL:
All right.
Is there any 8
other comment on.this separate subject?
9 MR. KERR:
Without necessarily disagreeing with i
10 Dave, I would say that there may be differences in 11 interpretation from what has been done and the particular one 12 Dave has.
I think if you want to discuss this topic in depth, 13 then we probably should do it at a meeting devoted to the 14 subject.
It is certainly an important area.
15 CHAIRMAN ZECH:
I agree with that.
I think it is 4
i 16 important and I am not so sure all of the committee members i
17 would agree with Dr. Okrent but I think.it is a subject that 18 probably should get further discussion on your own committee 19 and then perhaps if you think when you have some kind of a 20 recommendation or some kind of a committee minority or 21 majority view, it might be well worth discussing it at a 22 future time.
23 MR. WARD:
I think that is right.
24 CHAIRMAN ZECH:
All right.
25 COMMISSIONER BERNTHAL:
I would like to do that.
I 1
i
, - ~__-- --.--- -.-.
13 1
think there are important points here that Dr. Okrent has 2
raised and let's put it on the agenda next time.
3 MR. EBERSOLE:
I would like to extend that 4
discussion into the institutional bases for these differences 5
that Dave has mentioned.
They have greatly affected the 6
greater success that France and Germany have had compared to 7
the success that we have had.
8 CHAIRMAN ZECH:
Please move the microphone closer to 9
you, Jesse.
10 MR. EBERSOLE:
The need for electric power among 11 these, the bigger involvement of the national government in 12 these plants and recognition for that option.
13 CHAIRMAN ZECH:
It sounds like it would be a 14 fruitful subject for committee review and then perhaps bring 15 to the Commission later on.
It certainly does.
16 MR. EBERSOLE:
I would even extend this to why these 17 companies have chosen the PWR's which they obviously have over 18 the options that we have here.
You know, we are about split 19 50-50 and the institutional bases for those, for extrapolation 20 of the submarine successes which is clearly what they have 21 done.
22 MR. WARD:
I think that is appropriate and we are 23 considering this in another context at the present time.
21 CHAIRMAN ZECH:
All right.
25 MR. MICHELSON:
Commissioner Bernthal, I think, had
14 1
asked if there are other areas in which similar arguments 2
might pertain.
I 3
COMMISSIONER BERNTHAL:
Yes, that's right.
I 4
MR. MICHELSON:
Of course, one is clearly the 5
question of sabotage and security protection of nuclear 6
plants.
The Europeans have a significantly different approach 7
than we seem to have in this area, another one to add to the 8
discussion.
9 MR. WARD:
When you say the Europeans, some of the 10 Europeans do.
11 MR. MICHELSON:
Let's get the details later but I 12 think you will find it is a vast majority of the plants.
13 COMMISSIONER BERNTHAL:
Broadly speaking, I would 14 tend to agree.
There is greater protection against sabotage 15 and attack from the outside.
13 CHAIRMAN ZECH:
But not on all of them.
I have seen 17 some that I don't think you can say across-the-board.
18 MR. MICHELSON:
That's right.
No, not clearly 19 across-the-board, no.
20 COMMISSIONER BERNTHAL:
On the other hand, I think 21 the perceived risk is greater over there but that is a 22 separate, another subject yet and again, one that we can't 23 probably very well talk about.
24 CHAIRMAN ZECH:
All right.
Commissioner Carr, do 25 you have anything?
15 1
COMMISSIONER CARR:
No.
i 2
COMMISSIONER BERNTHAL:
I am sorry.
l 3
CHAIRMAN ZECH:
Go ahead.
I am sorry.
4 COMMISSIONER BERNTHAL:
I want to get to the other 5
subject here now which is the primary one, I guess, and that 6
is unresolved safety issues.
7 There is an overlap between the point of view raised 8
by --
9 MR. OKRENT:
I considered these unresolved safety 10 issues.
11
[ Laughter.)
12 COMMISSIONER BERNTHAL:
Raised in a different 13 context, but there is an overlap on one key point that you 14 mentioned Dave and that is how the backfit rule perhaps 15 combined with the Commission's safety goal may impact the 16 resolution of those issues.
17 I would like to hear whether you have talked about 18 that much.
Has there been more discussion on that than you 19 have offered here?
20 MR. SIESS:
On the major issues that we have devoted 21 a lot of time to, that has been part of the discussion, A-45, 22 A-46 type things.
In fact, the implementation has been i
23 probably the major part of the discussion and not just the 24 technical implementation but the schedule of the backfit.
l 25 Those are individual cases.
I am not prepared to
16 1
talk about them now.
2 COMMISSIONER BERNTHAL:
The question is broadly 3
speaking, is the backfit rule going to do what it is intended 4
to do which I think is an estimable objective.
That is, we 5
don't do things that are not reasonably justified on the basis 6
of cost and cost effectiveness.
7 But on the other hand, is the process too 8
cumbersome?
What sort of evaluation do you guys place on 9
that?
Have you thought about it or looked at it carefully?
10 I don't think you need to discuss specific cases.
11 MR. SIESS:
The process on these issues is basically 12 CRGR.
13 COMMISSIONER BERNTHAL:
That is my next question.
14 MR. SIESS:
From what I have been able to see of how 15 CRGR operates, it certainly is not cumbersome in relation to 16 all the time that has been spent on the technical resolution 17 of these things.
I don't think that the CRGR process 18 represents a significant delay in time.
19 Some of these things have been worked on for ten 20 years.
As to whether the process leads to a backfit or not to 21 a backfit, that is the decision that is made on the basis of 22 the cost benefit and the regulatory analysis and so on.
23 It is certainly an issue on the decay heat removal 24 reliability.
25 COMMISSIONER BERNTHAL:
Do you have any opinions on
17 1
the role that CRGR is playing on the need for CRGR to continue 2
now that we have the backfit rule in place?
Some of these 3
issues have been brought up and kicked around here.
Have you 4
folks thought about that?
5 MR. SIESS:
Well, the backfit rule I thought was 6
intended for plant specific backfits primarily and let CRGR 7
continue with the more generic backfits.
These were all 8
generic issues.
9 I don't think the committee has addressed that as a 10 committee.
I am sure we all have individual ideas.
I am 11 chairman of the generic items subcommittee and have been 12 trying to follow the CRGR activities.
13 We look at what they do.
Another committee is 14 reviewing reg guides and rule changes and we try to follow 15 those through CRGR, see them before CRGR and after to see if 16 there have been significant effects and in most of these that 17 I am familiar with we have not seen CRGR preventing needed 18 backfits although I am sure there may have been some cases 19 where somebody else thought they were needed and CRGR didn't.
20 My impression is that they have certainly made the 21 regulatory staff a lot more aware of making the case for what 22 they want to do and I think the backfit rule has had that same 23 effect out at the individual reviewer level where the 24 ratcheting sort of thing went on without anybody doing 25 anything about it, not providing uniformity or anything else.
i
18 1
COMMISSIONER ROBERTS:
That was certainly the 2
intent.
3 MR. SIESS:
That is my personal view.
4 COMMISSIONER BERNTHAL:
For these generic 5
requirement areas, CRGR still has a place and performs a valid 6
function.
7 MR. SIESS:
I think so.
I 8
MR. WARD:
I think it does.
9 MR. LEWIS:
I think what Chet says is right.
We 10 have a committee view but many of us have individual views and 11 I certainly think CRGR has done a good job in the past on 12 balance and keep a good thing if you have it.
i 13 MR. EBERSOLE:
I will just say one thing.
I was a 14 little dismayed about the view they took on electric power 15 where there was going to be a graded system of upgrading on 16 site power.
It had a very unilateral off site power system 17 and to strike a balance and my impression is that CRGR put 18 their foot on that.
19 We just recently have a plant on the east coast up 20 here --
21 CHAIRMAN ZECH:
Bring that microphone a little 22 closer again, please.
Thank you.
23 MR. EBERSOLE:
-- which iced up and is going to 24 bring up that question again.
It is going to be a chronic 25 case of icing up and the question will be raised again, do you
19 1
relate the reliability of on site power to this specific 2
unreliability or characteristic of the site in question.
3 COMMISSIONER BERNTHAL:
I don't know whether you are 4
prepared to discuss any of these specific unresolved safety 5
issues.
Station blackout is one that I suspect we are going 6
to have a broader Commission discussion on.
I know the 7
Chairman is interested in that and several of us are.
8 I wanted to get a quick opinion / update from you on 9
one other and that is the shutdown decay heat removal 10 requirement.
Rumor has it that staff may be coming forth with 11 some recommendations in that area and I wondered what the 12 status of your view is and whether you have reviewed that and 13 whether you are prepared to offer an opinion or maybe this 14 isn't the right day and time.
15 MR. WARD:
We have been reviewing it all along.
We 16 have a meeting scheduled next month and we have been keeping 17 abreast of it.
We are really not prepared to give you an 18 opinion.
We don't have a committee opinion at this time.
It 19 possibly will be controsersial.
20 COMMISSIONER BERNTHAL:
That is what I understand.
21 MR. WARD:
Right.
22 MR. OKRENT:
Could I ask a question that arises from 23 this?
24 MR. WARD:
Yes.
25 MR. OKRENT:
I unfortunately don't have time to keep
20 1
up with all of the topics I would like to but it is my 2
impression that the staff group and their contractors who are 3
doing studies on shutdown heat removal are making estimates of 4
the contribution of a loss of the ability to achieve shutdown 5
heat removal which gives numbers larger than ten to the minus 6
four per year for at least a considerable number of the plants 7
they have studied.
8 Correct me if I am wrong, but that is what I 9
recollect.
10 on the other hand, when I read things like drafts of 11 NUREG-1150 and severe accident drafts and severe accident 12 policy implice.tions from the rebaselining and so forth, the 13 talk is of core melt figures, something like ten to the minus 14 five.
15 So either I am remembering something wrong, but I 16 don't think that is so, or there is one set of reactors here 17 that has one set of numbers and there is another set which has 18 another set and the other set, 1150 and so forth which are 19 supposed in some way to be used for making policy decisions i
20 are not -- either don't believe this first set or are not 21 recognizing they exist or assuming everything has been fixed, 22 but there is an air of unreality in my mind.
23 I will just put it right on the table.
24 MR. KERR:
I don't thinh that is questioned as 25 something to be put on the table.
i l
21 1
MR. OKRENT:
But I think the commission should be 2
conscious of this if my memory of what I have been reading is 3
correct because I know people are coming in and saying in 4
4 connection with fixing up BWR containments, "Well, we are 5
calculating a few times ten to the minus five for Peach 6
Bottom and you can't get much from cost benefit."
7 This is just one example of a number for one plant 8
is sometimes used generically but when they look at Quad 9
Cities and look at the contribution from loss of decay heat 10 removal, again my recollection is the number is something j
11 times ten to the minus four.
12 That is just one source.
Seismic hasn't entered 13 into either of these and there are a variety of things that 14 haven't entered into either of these.
15 CHAIRMAN ZECH:
Again, I submit that this is 16 probably a good subject to consider with the other matter you 17 have brought up and perhaps the committee would like to 18 discuss it themselves and bring it up to the commission at a 19 later date.
I think that would be most appropriate.
i 20 MR. WARD:
I agree.
21 COMMISSIONER BERNTHAL:
I am finished on this 22 subject, I think, for now.
I feel like I am pushing a wet 23 noodle a little bit to tell you the truth.
Someday I am going i
j 24 to understand what we are supposed to do in these meetings, I 25 guess.
Maybe I will just stop with that for now and we should
22 1
go on to the next subject.
2 MR. OKRENT:
I should note, I had wet noodles for 3
supper Tuesday night.
4
[ Laughter.]
5 MR. OKRENT:
I guess I brought some here.
6
[ Laughter.]
7 CHAIRMAN ZECH:
Commissioner Carr.
8.
[No response.]
9 CHAIRMAN ZECH:
Let me just address Dr. Siess's 10 question really on effectiveness.
Frankly, what I had in mind 11 on effectiveness is both subjects that you bring up.
I would 4
12 say asking the ACRS to see whether you felt that the generic 13 and unresolved safety issues, whether we were making 14 progress.
You have given me that assessment to a degree.
15 The second part though, I think, also I had in mind 16 was are they increasing safety.
Are we making a contribution 17 to increased safety?
{
18 I would like at some time for you to try to address i
19 that subject, also.
20 Has the ACRS had a briefing on the Safety Issues 21 Management System, the SIMS program, that is being put in 22 place now?
If not, I would recommend that you do have such a 23 briefing on that program.
It does address generic and 24 unresolved safety issues at least to some degree and it is an 25 effort, a management effort to keep track of progress and to i
1 f
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23 1
track and put milestones as well as plans of action on these 2
programs.
3 It might be of use to the committee and at some 4
future time when we pursue the subject, Dr. Siess, I would 5
like your views on what you think of this management system.
6 So I think with that perhaps we can move into the 7
second subject for today, Mr. Ward.
8 COMMISSIONER BERNTHAL:
If I can just interject one 9
further comment, I would like at some point to have a 10 discussion here and to hear some opinions separately or 11 collectively if you wish on the safety goal as promulgated by 12 the Commission.
13 I am not sure we have ever done that.
I understand 14 the ACRS has talked about it at 16ast some.
That issue weaves 15 itself into some of the points that have been raised here 16 today and the Commission to say the least, I think, surprised 17 a few people in the final form that the safety goal took and 18 also indicated that that was not necessarily the final final j
19 form.
20 My personal judgment is that there is some work to 21 be done there yet and if we can put that on the schedule at 22 some point, I would like to hear the products of whatever 23 thinking has been going on by the ACRS on that subject.
24 CHAIRMAN ZECH:
That gives you another subject for a 25 future session.
Fine.
Good.
Anything else?
24 1
COMMISSIONER BERNTHAL:
No, that is it.
2 CHAIRMAN ZECH:
All right.
Proceed, please.
3 MR. WARD:
Mr. Wylie.
4 MR. WYLIE:
What we understood that you wanted to I
5 talk about on this next subject was the review of draft 6
NUREG-1225, implementation of the NRC policy on nuclear plant 7
standardization.
8 I believe when you introduced the subject, 9
Mr. Chairman, you referred to it as advanced standards for l
10 nuclear power plants.
While that is a pertinent subject and 11 one in which the committee has been considering over the last i
12 few months in a separate subcommittee headed by Dr. Okrant 13 regarding advanced light water reactors and the features that 14 those should take, that was not the subject we were prepared 15 to talk about today.
16 CHAIRMAN ZECH:
You are just going to confine it to 17 the standardization.
18 MR. WYLIE:
To the standardization issue.
19 CHAIRMAN ZECH:
That's fine.
20 MR. WYLIE:
Although Dr. Okrent may want to comment 21 if you have specific questions about our activities in that 22 area.
23 CHAIRMAN ZECH:
If you are not really prepared to 24 get into that, I would really just rather confine it to the 25 standardization program.
I think there is enough to discuss
25 s
1 on that subject.
2 MR. WYLIE:
Yes.
In our letter of October 15, the 3
ACRS supplied you with comments on draft NUREG-1225 and we 4
stated that in general we were in agreement with the draft 5
except we did make several observations.
In the revised staff 6
draft of NUREG-1225 submitted to you by the EDO's letter of 7
November 10, some of our comments were addressed to some 8
degree but not all.
i 9
Perhaps it would be advantageous to discuss the 10 comments contained in our letter and if you agree, that is the 11 way I will proceed.
12 CHAIRMAN ZECH:
Yes, that is fine.
Thank you.
13 MR. WYLIE:
The first paragraph of our letter, wo 14 stated that we falt it beneficial to seek public comment on 15 the certification by rulemaking options.
We noted that the 16 EDO in his letter submitted to you a proposed federal register 17 notice in the standard policy statement and the proposed 18 NUREG-1225 which we interpret then that it was to go out for 19 public comment.
20 We had recommended that the criterion threshold for 21 standing and interest in the rulemaking hearings for 22 certifying designs be stated in NUREG-1225.
However, that was 23 not done.
We understand that the staff intent is to define 24 that in the notice of rulemaking in the federal register for 25 the specific rulemaking proceedings.
4 i
26 1
We advised that if that is the case, that should be 2
stated in draft NUREG-1225 and again, we noted that this had 1
3 not been done.
4 I don't know if there is any comment on that point 5
by anyone.
6 MR. REMICK:
Could I elaborate on that, Charlie?
7 MR. WYLIE:
Sure.
8 MR. REMICK:
The question of rulemaking goes back a 9
few years and it goes back to the time when I was your 10 director of Office of Policy Evaluation.
We were looking at 11 regulatory reform with others and people were proposing that I
12 for standardized plants or for design certification, one would 13 use the process of rulemaking.
(
14 That sounds very good but having also been a 15 licensing board member for ten years, I knew enough to be 16 confused by what does one mean by rulemaking.
17 So I began asking people in OGC, ELD, technical 18 staff, OPE and so forth, what is really meant by rulemaking 19 and found that people had general thoughts but there was 20 nothing fleshed out.
21 I continued to do that for several years every time 22 I heard rulemaking was going to be used and found that people did not know and I am not saying that it is not possible, they 23 24 had just not fleshed it out and some of you on the Commission 25 for several years might remember that on at least two
27 1
occasions, I remember when we were up here I asked the 2
Commission, "I don't think anybody on your staff knows what is 3
meant by rulemaking for standardized plants."
i 4
Now the last time I did that was last May and I 5
think Commissioner Bernthal and Asselstine said, "Oh, yes, we 6
know what rulemaking is and they expressed it."
It was 7
interesting, that very night I was at a social function where 8
some of your senior legal and technical people were and l
9 several came up and said, "We didn't know that is what was 10 meant by rulemaking."
11 But putting all that aside, that is background to 12 why when we look at the standardized policy and know you do 13 have fleshed out various alternatives for how rulemaking might 14 look and that is great.
Somebody has spent some time and 15 said, "Here are different levels of rulemaking we might use 16 and you are going out for public comment for that" and I think 17 that is great.
18 But the one thing that I think is missing if you are 19 truly seeking public comment is who can participate in that 20 rulemaking and I think you have an obligation to let the 21 public who you intend to participate in that because you say, 22 "Well, gee, we have faced that many times" and that is true 23 and through precedent and appeal board decisions and so forth 24 which you have let stand, interest has basically been defined 25 in the power reactor area as people who live within 50 miles.
28 l
1 If they live within 50 miles and they want to t
2 participate in a hearing, you say, "Well, they have interest i
3 and we will allow them in."
4 But when you are talking about a standardized plant, i
5 there is no site in might in general.
You are talking about a 6
rulemaking for design certification presumably before anybody 7
has decided to buy this or a site has been specified.
So as a 8
general member of the public, it seems to me that if I was 9
really reading this with interest, I would want to know if I 10 have a concern in that rulemaking, am I going to be permitted l
11 or not.
l 12 So that was the background in which I brought it up i
i 13 before the committee and they agreed and why it is in there.
14 It seems to me that in this where you are going out for public 15 comment, you know have different alternatives, some of which j
16 would be hearings and different formats, that as a courtesy to-17 the public, you ought to express your views on who you are 18 going to allow to participate.
19 That is where the interest and the standing comes i
20 from.
That is the background for it.
Now the thing we hear i
21 is that the staff intends at the time of the specific 22 rulemaking, they will specify and that is good, they will have i
j 23 to do that, but the whole point is that when you are now going j
24 out on getting comments on your standardized policy and what 25 you might mean by rulemaking to let the public know in i
i
29 1
general who will allowed to participate in that rulemaking 2
process.
3 COMMISSIONER BERNTHAL:
Would somebody refresh my 4
memory?
I am having difficulty remembering but my vague i
5 recollection was that either in connection with the proposed 6
legislation that we have sent to the Hill or maybe in another 7
document or forum that there had been some thought given to 8
that issue and that broadly speaking there was some sense at 9
least of who would have standing and be able to participate as 10 a party in these proceedings.
11 I am not getting much help here.
I don't see 12 anybody nodding their head.
Maybe the General counsel can 13 help me.
14 MR. PARLER:
I am not familiar with the details.
I 15 understand the discussion but I was not aware that the points 16 that were raised had been a problem in the past.
Perhaps 17 several things need to be separated.
18 One thing, the thing that has been discussed of who 19
)
may participate, our statute says who may participate in these 20 things, rulemaking or adjudications, any person whose 21 interested may be affected by the proceeding.
22 I would assume that if anyone was to comment in a 23 rulemaking on a standardized design or on any other rule 24 whether it be ECCS criteria, leak rates or what have you that 25 the comments will be received and entertained.
What weight
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4 formal or informal, formal being the' adjudicatory, type that we t d' rj 5
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11 COMMISSIONER BERNTHAL:
Why in any' case would the
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ff 16 The departure here, of course, is that'you\\would i5 s'
17 carrying out a rulemaking with i.b,e adjudicatory' process more 18 or less formally carried out for a class of plant that 1
19 presumablywouldthennolongerbe'litigatedonplantspaciNic/
i 20 issues at least as opposed to, site specific'and could be 21 readily licensed anywhere in the country except for the site i
e 22 specific issue without further litigation.
r 23 Again, I don't see why the problem is vastly greater 1
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31 1
nuclear waste repository proceeding that we are going to have.
2 MR. PARLER:
Part of the consideration la for the 3
rules of the game to be spelled out in advance so that one 4
would not have a standardized plant approved say in year one 5
and then at year five when the standardized design is intended 6
to be used in a particular place having some citizen who has 7
moved into the neighborhood where the plant is going to be 8
located saying that they didn't have an opportunity to 9
participate, et cetera, et cetera, in the standardized design 10 proceeding.
11 In that regard, the situation isn't vastly different 12 from a citizen who for whatever reason earlier on did not have 13 any particular interest in participating in a particular 14 rulemaking proceeding such as ECCS criteria and who later on 15 after the rule or the regulation is on the books for whatever 16 reason developed such an interest.
17 MR. REMICK:
Let me try to address that.
The 18 difference in my mind between all of the power reactors i
19 including Clinch River if we are talking about the hearing and 20 remember in standardization you have thrown out several 21 options one of which discusses just notice and comment that 22 your staff says they don't recommend that and then going up 23 different types of hearings including the formal adjudicatory 24 process.
25 If you have the formal adjudicatory process, your
32 1
precedent has been basically with reactors in the past 2
including Clinch River that it is basically, the interest is 3
defined through precedents that basically anybody within 50 4
miles has a right if they meet the other thresholds and so 5
forth.
6 But this one, you haven't defined the site in 50 miles and therefore, people might not know if they are going 7
8 to be admitted to the rulemaking or not.
I don't see it as a 9
legal question.
10 COMMISSIONER BERNTHAL:
That seems to be the single 11 issue though.
The 50 mile thing, I agree with you, it seems 12 inapplicable to this particular problem and I never was under 13 the impression that it would apply quite frankly.
14 MR. REMICK:
All I am saying is if you have 15 thoughts, if you resolve that everybody can participate in 16 this, I think just as a courtesy, if you can say that it ought 17 to be said because if I take myself back as a member of the 18 general public and I read your document and I want to know 19 when there is eventrally this rulemaking if I want to 20 participate in that rulemaking am I going to be permitted.
21 What is the threshold?
What is the criteria?
What interest, what standing must I have if I want to participate 22 23 and I am saying that is not defined and if it is going to 24 follow standard Commission practice and that can be said, that 25 is just a courtesy to the public.
e
33 1
I see it not as a major block to the policy 2
statement.
I don't presume it is a legal question although 3
I will let Bill address that but it is more a courtesy to the 4
public.
5 MR. PARLER:
I certainly agree with the point what I 6
call the rules of the game should be defined at the outset.
I 7
think they should.
I don't see any problem in taking care of 8
what is an obvious thing that has to be taken care of because 9
if it isn't, the complete objective of standardization would 10 not be. achieved because you would not really settle anything 11 with any finality when you are approving the standardized 12 design because if you don't give people adequate notice, 13 issues could be opened up later on when the utility makes the 14 decision to use the design at a particular site.
15 CHAIRMAN ZECH:
Obviously, this is something that we 16 can consider during the process and certainly will.
17 COMMISSIONER BERNTHAL:
It is a good point.
I think 18 we may all have been going down this path assuming that 19 everybody understood how this was defined.
It may not be 20 written down anywhere.
I was under the impression that we all 21 understood but maybe we have not read anything that says that l
22 or had to put out anything that says that.
23 MR. REMICK:
I think the Commission has come a long 24 way in defining at least what are rulemaking options, the 25 things you have under consideration.
34 1
So I think those are reasonably understandable.
It 2
is just one additional thing and as I say, it is not a big 3
issue, I think, it is just one additional fine touch that 4
could be a courtesy to the public.
5 CHAIRMAN ZECH:
But your point is that it ought to 6
be in plain language and defined as well as possible.
7 MR. REMICK:
Yes.
8 CHAIRMAN ZECH:
Certainly I would agree with that 9
and I think we should take a look at that as we proceed.
10 Let's see, where were we?
11 MR. WYLIE:
We could move on to the second point.
12 CHAIRMAN ZECH:
All right.
13 MR. WYLIE:
The second point we made in our letter 14 was that we did not consider that the scope and level of 15 detail of information required for design certification were 16 adequately defined in the draft NUREG.
17 We felt that it should be made clear that in 18 addition to providing a level of design detail equivalent to 19 that required by the regulation for a final safety analysis 20 report that they should provide additional information which 21 is customarily reviewed by the staff in order to prepare a i
22 final safety analysis report and do a final review.
23 In that regard we have suggested that cognizant NRC 24 staff members, reviewers, that are experienced in reviews and 25 various industry organizations with pertinent experience
35 1
provide input and that the information required be more 2
defined in greater detail.
3 Now this would take considerably more effort than 4
has been done to date and it would take some more time in 5
order to do this in the NUREG but the committee felt like this 6
should be done in order to decide what is meant by 7
" essentially complete design."
8 I don't know whether anyone wants to comment further 9
on that or not.
10 MR. MICHELSON:
You should indicate how the staff 11 regarded that comment.
12 MR. WYLIE:
In what manner?
13 MR. MICHELSON:
Did they adopt it?
14 MR. WYLIE:
No, they did not adopt it.
Well, they 15 haven't done it.
16 MR. MICHELSON:
They did not adopt it.
17 CHAIRMAN ZECH:
As I recall, the staff had different 18 views on that.
19 MR. WYLIE:
They had different views on that.
20 Basically they have provided a listing of categories of 21 information which should be provided and have not gone into i
22 great detail as to defining what is in those categories.
23 COMMISSIONER BERNTHAL:
It makes me feel a little 24 better to see that the ACRS and the staff can't seem to agree 25 on what a complete design is because the commission has never
4 36 1
been able to agree on it.
2 It seems to me that this is a problem that should 3
lend itself to objective analysis and solution.
I guess I 4
don't quite understand why we can't reach closure on it.
5 MR. KERR:
We were very objective in our view.
6
[ Laughter.]
7 MR. WYLIE:
You could go ahead and define to great 1
8 detail all of the information that the reviewer needs in order 9
to do the review.
They have done it enough times that they 10 know what they need.
That would take a sizeable effort to do 11 that and it is a question of where you stop, I suppose.
12 CHAIRMAN ZECH:
That is a matter of judgment, of 13 course.
14 MR. WYLIE:
It is a matter of judgment.
15 CHAIRMAN ZECH:
Perhaps we will never be able to 16 all agree exactly where that line should be but it is my view I
17 that frankly we are making process in this standardization i
18 program and even though there is not complete agreement 19 across-the-board, I do think that it has been a rather i
20 important and valuable effort and I do think we are making 21 progress.
That has been my view.
22 MR. WYLIE:
I guess the point we made was that there 23 are experienced reviewers in the staff and there are 24 experien~ced industry representatives that could better define 25 the detail if they would get together and do it.
37 1
COMMISSIONER BERNTHAL:
Could you give me a specific 2
example or maybe a couple of specific examples of when it 3
comes time to build the plant of something that would not have 4
been clearly specified by following the path that the staff 5
seems to be preferring now that in your judgment and the 6
judgment of the ACRS could have and should have been specified 7
when it comes time actually to build the plant?
8 MR. WYLIE:
In the course of review the staff asked 9
for considerable amount of supporting documentation as far as 10 system analysis and things like that are concerned.
11 These being standardized plants to a great extent 12 they will be not site specific as far as the standardized 13 design is concerned.
14 Now they will have to be adapted to specific sites 15 where cooling water of ultimate heat sink requirements may 16 vary from one plant to another.
17 COMMISSIONER BERNTHAL:
Right.
18 MR. WYLIE:
Also, the location of those plants in a 19 utility's grid has an effect on the electrical supplies, off 20 site power and this kind of thing during start-up of the 21 plants and what have you.
22 So the systems have to be tailored to those site 23 specific and grid specific considerations.
24 COMMISSIONER BERNTHAL:
That, I think, we all agree 25 on.
l 38 l
1 MR. WYLIE:
That should be addressed to some extent 2
and considered by the designers of the standard plant because 1
3 if you are going to design for the worst case, then you are 4
going to have to take into account when you come up with a 5
standard design.
6 COMMISSIONER BERNTHAL:
Give me a specific 7
engineering example of a system, are we talking about station 8
blackout capability, for example, or what are we talking 9
about?
10 MR. WYLIE:
That could be depending on where the 11 plant is located.
It could be that the number of transmission' 12 lines into that site are limited, for example.
There may not 13 be an on site switching station, for example, that you are 14 going to have bring in off site power for that total plant and 15 depending on the voltage level of the grid and the location of 16 that plant, you could have a grid that was fairly week and 17 during start-up, you may have to take into account the fact 18 that that voltage sags way down when you start that plant up.
19 COMMISSIONER BERNTHAL:
You are saying --
20 MR. WYLIE:
So your auxiliaries have to be designed 21 to accommodate that.
22 COMMISSIONER BERNTHAL:
You are suggesting that 23 failure to consider the worst case siting scenario at the 24 outset in the standardization proceeding could somehow lead to 25 a fatally flawed standardi ation policy?
r--
y,
39 1
MR. WYLIE:
I would not say that it would be fatally 2
flawed.
They would just have to take that into consideration 3
as they designed the standard plant and be able to adapt to it 4
later.
It is something they would have to consider.
5 MR. WARD:
Carl, you have given this some thought.
i 6
Could you give an example of the sort that Fred is looking 7
for?
8 MR. MICHELSON:
I am not quite sure what he is 9
looking for but perhaps this is along that line.
In designing 10 a process, an RHR system, other types of ECCS systems, the 11 first thing you do is prepara a basic flow diagram which 12 identifies what the pipe sizes are going to be.
It doesn't 13 say where they will be.
It just lays out the flow.
14 You also design a basic plant lay-out in which you 15 put little b. locks around the plant and say that the pump will 16 be here and so forth.
17 That is a first level of detail which is readily i
18 provided generally even at a PSAR stage.
At the FSAR stage, 19 the documentation generally does not yet identify where the pipes are except for the major pipes, primarily system piping, 20 21 probably the main turbine piping.
22 But it does not identify a lot of piping.
In fact, 23 most of the piping is still unknown as to where it is.
Now a reviewer essentially has to decide whether there are pipe 24 25 break concerns, things of this sort, and if he does this
40 1
review without the piping drawings, then he is a little 2
lost.
The best he can do is make sure that the criteria for 3
doing such studies is adequately prescribed and passes 4
judgment on that basis.
5 So in a standardized design, how far down do 6
you want the piping to be detailed, all six inch and above, 7
all one inch'and above or where, clearly, this is a large 8
operation much of which is done part way through the 9
construction process and they are still detailing the routing 10 of smaller piping.
So that is an example perhaps that you are 11 searching for.
12 MR. EBERSOLE:
I would like to add to that.
At 13 the bottom and of this scale, the very small pipes is the 14 critical static impulse or instrument line of the 15 hydraulically connect transducers to processes.
These are 16 frequently even left to field run and in many cases nobody 17 knows where they went.
18 This would have to be refined and laid out on paper 19 in advance as perhaps one of the ultimate details of the 20 standard project so you understand the spatial 21 interrelaticnship with other potential sources of influence.
22 COMMISSIONER BERNTHAL:
So you are saying that the l
23 path that the staff seems to be proceeding down right now 24 means that large amounts of piping and other systems I gather 25 would not be specified in any way within the plant.
41 s
1 I would say, if that is the case, that certainly was 2
not my impression.
3 MR. MICHELSON:
You asked for an example.
I was 4
pointing out these levels.
5 COMMISSIONER BERNTHAL:
That's right.
6 MR. MICHELSON:
Now what is the case, I believe, 7
though is that it is unclear from the standardization document 8
where the line will be drawn and I believe that is what 9
Charlie was suggesting that people should sit down and deal 10 with these kinds of questions and a number of others in the 11 electrical area, cable routing areas and so forth which again 12 you can't do good fire analyses.
13 You can't do a number of these other analyses if you 14 don't know yet where the cable is routed.
So it is that kind 15 of questioning, I think, that we need a more learned committee 16 to sit down and deal with it.
17 The ACRS doesn't have the time to deal with those 18 kinds of questions in that kind of detail nor necessarily the 19 full range of competencies that might be needed.
I believe 20 that is what Charlie was suggesting.
21 MR. LEWIS:
That is absolutely right.
The papers 22 that I have seen say " essentially complete."
The buzz word is 23
" essentially."
24 COMMISSIONER BERNTHAL:
That's right.
25 MR. LEWIS:
It certainly is not going to be t
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- 42 4
1 complete.
Nothing is ever built from complete plans and you 2
do have to define what you mean by " essentially."
I6 1s going 3
to be very hard because you are talking about plants that are 4
going to be presumably ordered ten years after you accept the 5
final design document.
Technology will change.
Components 6
will change and we will know more.
7 It is, in fact, foolish to freeze a design, really 8
freeze it, long before construction starts.
So that is a 9
dilemma that you have to confront.
10 MR. MICHELSON:
Presently an FSAR reviewer doesn't 11 have those details in front of him in the FSAR.
What he does is he sees areas where he has questions.
He asked the vendor 12 13 or the utility, " Send me the drawings in this area or that 14 area" or alternatively he goes to the utility shop and looks 15 at the drawings.
16 From my earlier experiences, I had a great deal of 17 interplay with the NRC in this regard.
The reviewers would I
18 come down to the shop and they would look through the drawings 19 and they would see how the routings were laid out, what the 20 instrument lines, what the electrical lines were, how they 21 were done.
22 That kind of detail is not ever going to be i
23 available to the standard reviewer, probably will never be 24 available, simply because it costs a lot of money to get the 25 plant to that level of detail before it is even sold.
4
43 1
MR. EBERSOLE:
I would like to add to your comment, 2
. Carl.
I think we should observe here that the enetsous 3
importance of this intricate detail is largely due to the 4
absence of dedicated shutdown heat removal systems --
5 CHAIRMAN ZECH:
Excuse me, could you come a little 6
closer to the microphone, Jesse.
7 MR. EBERSOLE:
-- which would take your problems
'away to a clear and distinct area for initiating and carrying 8
9 out the shutdown function.
We are talking about details that 10 would influence the shutdown function in principal most of 11 them and piping relationships and other things, these are 12 things that will upset that process.
13 To have that process in place and I cannot envision 14 myself a standard plant which wouldn't be in a configuration 15 of an advanced LWR with this type of system is simply to 16 recognize the sensitivity to these things is something we 17 ought not to have, the sensitivity to fine structure.
18 We have too great a sensitivity to fine structure 19 and that has to be eliminated somehow.
20 MR. MICHELSON:
That is a part of the standard 21 design consideration.
Also, of course is to how far you go on 22 dedicated DHR.
I think the point being that if you had a 23 hardened dedicated DHR, you might be able to relax on worrying 24 about fire, worrying about pipe breaks and so forth.
25 Therefore, you would need less understanding of the details
o 44 a
1 and still be able to pass judgment on the acceptability.
It 2
is kind of a nice idea.
I have some reservations though on 3
how easy it is to do.
4 COMMISSIONER BERNTHAL:
I agree with you, the 5
concern you raise and, in fact, if anything my concern was 6
that the Commission might have been heading too far in the 7
direction of specifying every nut and bolt in the plant when 8
we started down this path.
9 If we are falling far short of that to where we 10 really don't have a complete design, then it seems to me we 11 ought to watch that carefully.
I still remain under the 12 impression, I hope not the illusion, that the final design 13 certification itself though is going to be a pretty complete 14 set of drawings and plant design that really is everything but 15 the plant specific items or rather the site specific items.
16 MR. WYLIE:
I am not sure that it has to be to that 17 detail.
For example, in a standardized design I think as far 18 as cable routing goes, you don't need all the cable routing 19 information.
20 All you need is the criteria by which you are going 21 to route that cable.
22 COMMISSIONER BERNTHAL:
Why should it be different 23 unless there is a reason for it to be different?
Do you mean t
24 get into the same stuff that we are in right now?
25 MR. WYLIE:
You are saying from site to site?
i i
45 1
COMMISSIONER BERNTEAL:
Yes.
2 MR. WYLIE:
No, it shouldn't be except for the site 3
specific stuff.
I was addressing the point that you would 4
have all the details of the design and I don't think that is 5
necessary.
6 COMMISSIONER BERNTHAL:
Except for the point Hal 7
raises that maybe somebody comes in with fiber optics instead 8
of copper cables, we should be able to adjust to that but 9
except for that sort of thing, it shouldn't be different.
10 MR. KERR:
The point I thought was being made and 11 maybe I misunderstand is that it was the feeling that the 12 existing document didn't really say how much detail one 13 wanted.
14 MR. WYLIE:
That's right.
15 MR. KERR:
We weren't making an effort to say that 16 every nut and bolt has to be specified but rather that the 17 document didn't make it clear to a prospective applicant how 18 much detail would be required.
Is that right?
19 MR. WYLIE:
That is correct.
I think the staff has 20 l
done a good job in identifying the general categories of 21 information they want but the extent of detail has not been 22 defined.
23 MR. SIESS:
Isn't that going to be determined the 24 first time they start a review?
25 MR. WYLIE:
Oh, sure.
It will be going back through i
o 46 1
the normal review process.
2 MR. SIESS:
I don't think the staff is going to 3
approve a standard design if they don't have enough 4
information.
The concern is not that they will approve 5
something that is improper but that the people who come in 6
with it will probably and up going through the same process 7
they do now in custom plants.
8 The staff has never taken an FSAR that came in and 9
issued an approval on the basis of it.
Usually by the time 10 you get through, there have been enough amendments and changes 11 that the original isn't even there.
12 MR. MICHELSON:
This is different.
13 MR. WYLIE:
I think in all fairness to the industry 14 though, you need to define what level of detail is going to be 15 required because if you go through the review process and you 16 get down to that point, you say, "I have to have more 17 information."
18 MR. KERR:
Let me say and Charlie correct me if I am 19 wrong, the staff has defined the level of detail as being that 20 that they would expect to see in a FSAR at the licensing 21 stage, haven't they?
22 MR. WYLIE:
That is correct.
23 MR. SIESS:
I think those words are in there and the 24 point is that the staff does not issue a license based on just 25 what is in the FSAR.
They have to make certain findings i
o 47 1
according to the standard review plan and if the information 2
in the FSAR isn't enough, they go out and ask to see some 3
drawings, walk through the plant or whatever.
4 I think they are kidding themselves if they think 5
they are going to get it on that basis.
6 MR. WYLIE:
Let me correct that a little bit.
What 7
they have defined is the level of detail required for a final 8
design approval review not FSAR.
9 MR. MICHELSON:
They have not really defined that 10 level of detail in the document.
That, I think, was what 11 prompted the comment.
12 CHAIRMAN ZECH:
What we are trying to home in on, I 13 think, is very important and that is as has been mentioned, 14 what does " essentially complete" really mean.
15 of course, as I think we can all see there are 16 various views on it.
We don't want to preclude as Dr. Lewis points out the things that might happen during that ten year 17 18 period that obviously could improve but that would et be 19 considered something that would make the plant not standard.
20 on the other hand, how far do you go in being 21 prescriptive and it is an important point to consider.
I 22 think the effort has been to be reasonably specific as far as 23 the finding " essentially complete" but not go so far as to be 24 cookie-cutter prescriptive thereby eliminating any new or 25 innovative processes that could improve safety.
48 1
This is the very fundamental part of the whole 2
effort and perhaps there will never be complete agreement on 3
what is essentially complete, where do you draw the line.
But 4
it is very important that we give in my view as much --
5 essentially complete to me means just as complete as we can 6
make it other than being site specific and other perhaps that 7
putting nameplate data and picking out ahead of time which 8
pump should be bought from which company.
9 That should not be done in my view but we should 10 come as close to being sp6cific as we can and still provide 11 some judgment for site specific as well as other things that 12 could be considered processes that would lend to increased 13 safety.
14 It is a judgment call and we are homing in on it but 15 it is a very important issue.
I agree with you.
16 MR. EBERSOLE:
May I ask a question?
Could there 17 be a mixed process whereby you could get approval on the same 18 design at some given level of detail which would by no means 19 include the earloads of paper that you eventually have to turn 20 out in design but then be a collateral effort as that 21 diminished detail was expanded in its final form so that you 22 followed it on through toward its total evolution to 23 completion?
24 In other words, you would trail it after an initial 25 approval in high detail and have agreements reached on a y-
49 1
participating basis as you finish the design in all this gory 2
detail that it must eventually have to face.
It is a 3
follow-up, in other words, a tight follow-up.
4 MR. WARD:
There is a level of detail in a plant 5
when it is constructed that depends on the practices of the 6
particular constructor.
I think, Charlie, you would agree 7
with that.
8 If the safety robustness of the plant is dependent 9
on that level of detail and I think Jesse has implied ha 10 thinks it is then I think there is a severe problem with the 11 whole concept of standardization.
12 I am not sure I agree with Jesse that it is 13 dependent on that level of detail.
14 MR. EBERSOLE:
I would rather it be replaced by such 15 things as dedicated decay heat removal systems and other 16 back-ups to the highly sensitive systems we presently have.
17 MR. WARD:
I think what you are suggesting, Jesse, 18 is that plants of the present designs should not or can't be 19 standardized but I am not sure.
20 MR. EBERSOLE:
Yes, I will say that.
I can't 21 envision a standardized plant unless it is an advanced LWR 22 configuration with due regard to such matters as dedicated 23 shutdown heat removal.
24 MR. SIESS:
I think what we are forgetting is you 25 are not going to issue a license for a standard plant.
You
50 o
1 are only going to issue a license for a standard design as far 2
as that design goes and nobody is going to get that plant 3
built and that plant get an operating license without further 4
review.
5 I can't share some of the concerns that the thing is 6
going to get built with something wrong in it.
I do share 7
Mr. Wylie's concern that people are going to come in with what 8
they think is an adequate FSAR and find out it isn't but I 9
don't know what to do about that.
10 CHAIRMAN ZECH:
Let me just say this.
I think that 11 if we step back for a minute from the trees and look at the i
12 forest what we have now is really no standardization policy.
13 This is really a giant step forward even though we are talking 14 about where to draw the line.
15 So I just think that we should not necessarily look 16 for perfection in this because it is so significant a step 17 forward in my judgment that we should probably try to get the 18 best line we can but in any case make a decision and move 19 forward.
Dr. Okrent.
20 MR. OKRENT:
I would like to make three related 21 points.
One is an experience I had in talking to a senior 22 vice president at some plant that was getting to the operating j
23 stage and whom I asked --
24 MR. LEWIS:
Dave, grab a microphone.
She is having l
25 trouble hearing you.
51 1
CHAIRMAN ZECH:
A little closer, please.
Yes, thank 2
you.
3-MR. OKRENT:
A senior vice president for a plant 4
4 near the operating stage whom I asked if he could do one thing 5
different what would you do and he said, "I would have bought 6
a detailed lay-out of the plant so I wouldn't have the 7
problems I had with interferences and so forth."
8 The second comuent that I would like to make is I 9
don't see why one cannot have specification in rather great i
10 detail and still the option of coming in with some new 11 technology to replace a part of that.
The one doesn't outlaw 12 the other so far as I can see.
13 I can't see that the current staff wording leads to i
14 nobody knowing the staff nor the designer just how much detail 15 is needed and this could well vary from plant to plant and so 16 forth and furthermore, with a certain amount of it 1
17 unspecified, it is just those things that you are putting in 18 that are not ordinarily in the FSAR that are not looked at 19 carefully from a systems interactions point of view or other l
20 kinds of sensitivities that could in my opinion be in a plant 21 lay-out.
22 So if you care suggesting that one can go pretty 23 far, I am inclined to agree.
In fact, it doesn't remove 24 flexibility for bringing in improvements in technology.
25 CHAIRMAN ZECH:
That is my view, too.
May I say l
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1 that I have another commitment.
I hope that we can wind up 2
here at least by 11:30 and I appreciate that very valuable discussion but I would hope that we could move along.
3
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4 COMMISSIONER BERNTHAL:
If I can just try once more 5
to define the problem for myself here, is the problem that 6
maybe we aren't clearly making the point that I at least
-7 understood that design certification as opposed to PDA's and 8
FDA's which is by in large stuff that the staff does around 9
here, the Commission doesn't particularly get involved in a 10 preliminary design approval or even a final design approval 11 but the Commission will be involved in a design certification.
12 This is going to be a rulemaking proceeding and my impression was always that the design certification would go a 13 14 significant step beyond what is required in the FSAR.
Now 15 that understanding is not reflected in your letter and maybe 16 that is where we are running into problems here.
j 17 MR. WYLIE:
We thought it did.
We use words like, 18 "It should be made clear that, in addition to providing a 19 level of design detail equivalent to that required byl0 CFR 20 50.34(b) for a final safety analysis report, an applicant for i
21 a final design approval (FDA) should be prepared to supply 22 such other information as is customarily required by the NRC I
23 staff."
24 In other words, all the information he requires to 1
25 complete the final review.
+
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53 1
COMMISSIONER BERNTHAL:
Right, but then the next 2
paragraph says,
...the certification process ideally should 3
require little additional design information if that supplied 4
with the FDA is adequate."
I would suggest in most cases it 5
isn't.
6 MR. WYLIE:
The intent was that it be complete to 7
the extent necessary to get a certification.
8 COMMISSIONER BERNTHAL:
I agree and it clearly, I 9
think, is understood not to be adequate for an FDA and I don't 10 anticipate an FDA coming up here to the table and with a few 11 extra marks on it becoming a design certification.
That, I 12 think, is not going to happen.
At least that is my view.
13 MR. WYLIE:
One last comment on it from my 14 standpoint, I think you can define it if you get the right 15 people together to do it, the level that is necessary and that 16 is what we suggested basically.
17 CHAIRMAN ZECH:
All right.
Thank you.
18 MR. WYLIE:
The last point was that we felt that 19 there ought to be some comment made in the NUREG regarding the 20 fact that if you get a design certification on a particular 21 plant design, that you can't pick up portions of that out of 22 context and use it in another design someplace else without 23 going through the whole process again.
24 In other words, that just doesn't blanket design 25 everything in the plant, that you can take pieces of it and i -
5 54 1
use someplace else because it may be inappropriate to do so.
2 That has not been mentioned in the NUREG.
3 MR. LEWIS:
I want you to know Charlie, there isn't 4
a clean line between doing that and taking almost everything 5
and changing one component.
6 MR. WYLIE:
I understand that, yes.
7 CHAIRMAN ZECH:
Right.
That is a good point.
8 MR. WARD:
I would like to make one comment in
.e-9 reaction to some comments made just a few minutes ago.
I am 10 not quite as sanguine that we can have the best of both words 11 here as far as updating or improving a standard plant design.
12 I think if there is a commitment to a concept or a policy or 13 practice of standard plants, you have to admit you'are giving 14 up something and the thing you are giving up is the 15 opportunity to make continuous or yearly improvements in the 16 safety systems or whatever in the plant as the technology 17 permits.
18 I mean in the standard plant concept, you are 19 committing to making technical improvements, sort of in large 20 steps and unless you are willing to give up the benefit of i
21 continuous improvements, unless you think the advantages of 22 standardization out weight that, I don't think you want a 23 standardization policy.
24 MR. SIESS:
I don't think there is a plant existing i
25 today that hasn't been changed from how it was built mostly to
55 w
1 the NRC requirements.
There is a continuous improvement that 2
starts the day the plant is licensed.
3 COMMISSIONER BERNTHAL:
He is saying that that may 4
not happen.
He is suggesting it may not happen.
5 MR. WARD:
I am suggesting that it may not be 6
desirable if we believe in a concept of standardization and 7
we want to realize the benefits of it, I think that this is a 8
. practice.
9 MR. SIESS:
Are you saying that the NRC should 10 commit not to require changes?
11 MR. WARD:
I think that is what the industry is J
12 expecting from a standard plant policy.
13 MR. SIESS:
After the plant is built?
I am not 14 talking about after it is designed but I am talking about 15 after it is built.
TMI comes along and we go on and change 16 everything in every plant.
17 COMMISSIONER BERNTHAL:
We are committed not to 18 require changes unless there is a discovery.
19 CHAIRMAN ZECH:
Right.
20 COMMISSIONER BERNTHAL:
But then there are criteria 21 for that in principal.
t 22 CHAIRMAN ZECH:
Yes.
23 MR. CARBON:
I share Mr. Ward's views there.
I think either it is a standardized plant and you are going to 24 25 let it be standardized for some extended period of time
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-3 56 6
1 without change, without better brakes or better carburetors 2
or something or else it is not a standardized plant.
3 CHAIRMAN ZECH:
I agree and the whole purpose of 4
standardization and a very fundamental issue is to get a 5
design that you really do have confidence in that is proven, 6
that is generally accepted as a reliable and safe design 7
recognizing that you do want to keep it for a period of time.
8 That is the value of standardization and there is no 9
question about it.
In my view it does have considerable 10 value.
You can look at our custom built plants all over the 4
11 country right now and~we have custom built regulations for all' 12 these plants, too, and that is part of the problem.
13 COMMISSIONER CARR:
How long a period of time would 14 be -- I mean, you wouldn't want to say that we will design one 15 today that we would want to build in 2030.
Somewhere along 16 the line, you are going to say, "Let's make a block change in 17 the standard design."
18 You have to leave yourself that much room.
It looks 19 to me like the real problem is when the gent wants to buy the 1
20 plant and build the plant, he buys the standard design that 21 day.
22 Now if we change that the next year and the next guy 23 wants to buy one, he buys it as of that day and he buys it 24 with the block change in it.
I don't see the problem with 25 that.
We do that in a lot of other things.
i 57 1
MR. SIESS:
I believe the French, the fact that 2
their standard designs are on a consistent basis, they don't 3
try to do it every year.
4 COMMISSIONER BERNTHAL:
That's right.
5 MR. SIESS:
They save them up until they have enough 6
improvements and go in and make them all.
7 MR. LEWIS:
What you say is roughly the way type 8
certification in aircraft is done.
In the end, you have to 9
end up that way and there has been defacto standardization of 10 the nuclear steam supply systems in nuclear plants because the 11 vendors don't really change them an awful lot from one time to 12 the next.
13 The real variety is in the rest of the plant and 14 that is what you are trying to fix.
15 CHAIRMAN ZECH:
Yes.
That is absolutely correct.
16 Can we wind up in a few minutes?
17 MR. WARD:
I think we are finished.
18 CHAIRMAN ZECH:
All right.
Let me see if there are 19 questions from my fellow Commissioners.
Commissioner Roberts.
20 (No response.)
21 CHAIRMAN ZECH:
Commissioner Bernthal.
22 COMMISSIONER BERNTHAL:
I had only one last question 23 that we haven't talked about at all but my understanding is 24 that at some point last summer the ACRS did not concur with 25 the staff's view that standardized plants should be built on
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4 MR. WARD:
I don't really> recall where we exprersed' s
5 that if we did.
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6 MR. REMICK:
If I ttay, address that, if I, recall the
,/'.
s discussion was that standardized plants could;only be 4
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pre-approved and we thought that das too re$trictive and tb,arel 8
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9 was no reason to say it.
We were not against ;using standard tl 10 plants on pre-approved sites.;. As was the wording.
It seemed 11 to preclude it only for that case and we thought,there was no s
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13 COMMISSIONER BERNTHAL:
All right., In that casiah Q.
p 14 agree.
15 MR. WARD:
It shouldn't be limited to that, yes.
16 COMMISSIONER BERNTHAL:
The.wordingwashrobablynot 1
intended to be that.
17 l.
18 CHAIRMAN ZECH:
Anything else?
19 COMMISSIONER BERNTHAL:
No, that's all.
20 CHAIRMAN ZECH:
Commissionar Carr.
21 COMMISSIONER CARR:
I only have one other comment 22 and I would say with respect to the level of detail, it is obvious that the more detail that is supplied the more likely 23 24 it is that everybody is going to agree on the licensing at the 25 end.
(? -
59 O
,1 So I would think that the more detail you can get, 2
why the better the review will be.
I would encourage more 3
detail, I guess, in that regard.
4 MR. WYLIE:
The pleas I have heard from the industry 5
is, "Let's define that level of detail."
6 COMMISSIONER BERNTHAL:
That sounds like a 7
reasonable request.
8 CHAIRMAN ZECH:
That is, of course, what we are 9
trying to do.
10 Let me just say that I think that we have had a very 11 valuable discussion and I thank you very much for your 12 comments.
They are always very useful and very valuable and 13 whereas, the Commission, the committee and the staff may not 14 agree exactly on everything, that is what it is all about.
15 We are supposed to lay things on the table and have 16 our discussions and our views and that is what we are trying 17 to do, to do what we can to improve the plants and make public 18 health and safety better than it is.
19 So I thank you very much (e.r y ur discussion.
We 20 appreciate it very much.
21 MR. WARD:
Thank you, Mr. Chairman.
22 CHAIh;1AN ZECH:
We stand adjourned.
23
[Whereupon, the above-entitled Commission meeting 24 was adjourned at 11:29 o' clock a.m.,
to reconvene at the Call 25 of the Chair.]
D 1
2 REPORTER'S CERTIFICATE 3
4 This is to certify that the attached events of a 5
meeting of the U.S. Nuclear Regulatory Commission entitled:
6 7
TITLE OF MEETING: Periodic Meeting with Advisory Committee on Reactor Safeguards (ACRS) 8 PLACE OF MEETING:
Washington, D.C.
9 DATE OF MEETING: Thursday, December 11, 1986 10 11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the Commission taken
{
13 stenographically by me, thereafter reduced to typewriting by 14 me or under the direction of the court reporting company, and 1
15 that the transcript is a true and accurate record of the 16 foregoing events.
17 h
18 4-
J----------------
Lynn Nations 19 20 21 22 Ann Riley & Associates, Ltd.
23 24 25
SCHEDULIt'G NOTES FERIODIC MEETING WITH ADVISORY CCFMITTEE UN PEACTOR SAFEGUARDS (ACRS)
SCHEDULED:
10:00 A.M.,
THURSDAY, DECEMBER 11, 1986 (OPEN)
UURATIOn:
APPROX l-1/2 HRS TOPICS:
1.
STATUS OF COMMITTEE ACTIVITIES REGARDING CONSIDERATION OF THE EFFECTIVENESS OF PROGRAMS WHICH ADDRESS GENERIC AND UNRESOLVED SAFETY ISSUES 2.
COMMITTEECOMMENTSONVIORKINAREASOFADVANCEDANg STANDARDIZED REACTOR PLANTS (ACRS REPORT ON NUREG-1225 -
IMPLEMENTATION OF NRC POLICY ON NUCLEAR POWER PLAhT STANDARDIZATION DATED 10/15/86)
.-.--...,.w.
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TRANSMITTAL TO:
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/R !/l, !f h DATE:
I FROM:
SECY Correspondence & Records Branch Attached are copies of a Comission meeting transcript and related meeting document (s). They are being forwarded for entry on the Daily Accession List and placement in the Public Document Room. No other distribution is requested or required.
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