ML20236C817

Transcript of 890227 Briefing in Rockville,Md Re Final Rept on BWR Mark 1 Containment Issues.Pp 1-33

ML20236C817
Person / Time
Issue date:	02/27/1989
From:	NRC COMMISSION (OCM)
To:
References
REF-10CFR9.7 NUDOCS 8903220330
Download: ML20236C817 (36)

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{{#Wiki_filter:.V. g 1 P UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIS SION 1 l Ti(16lBRIEFINGONFINALREPORTONBWRMARKICONTAINMENTISSUES i {QG3({Qg,'ROCKVILLE. MARYLAND Qg(g; FEBRUARY 27, 1989 1 l pgggg* 32 PAGES NEALR.GROSSANDC0.,INC. COURf REPORTERS AND TRANSCRIBERS 1323 Rhode Island Avenue, Northwest Washington, D.C. 20005 (202) 234-4433 I 8903220330 890227' A P .7 PNV gG oh

s. f DISCLAIMER This is an unofficial transcript of a meeting of 1 the United States Nuclear Regulatory Commission held on February 27, 1989 in the Commission's office at One White Flint North, Rockville, Maryland. The meeting was open to public attendance and observation. This t,ranscript has not been reviewed, corrected or edited, and it may contain inaccuracies. 7-. The transcript is intended solely for general informational purposes. As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed. Expressions of opinion in this transcript do not necessarily reflect final determination or beliefs. No pleading or other paper may be filed with the Commission in any proceeding as the result of, or addressed to, any statement or argument contained herein, except as the Commission may authorize. HEAL R. GROSS COURT RIPoRTER$ AND TRANSCRISIRS 1323 RHoOE l$ LAND AVINUE, N.W. (202) 234-4433 WA5HINGToH D.C. 20005 (202) 232-6600

. q n.- i 4 1 1 UlIITED STATES OF Al! ERICA i 2 ITUCLEAR RE",ULATOP.Y COtIMIS SIOII L j l i l . }. I i 1 4 BRIEFIlfG O!! fit!AL REPORT O!!. BWR MARE I ) J l. l-5 COtITAIITMEITT ISSUES 5 . e n 1 '7 PUBLIC MEETIIIG 3 9 Muclear Regulatory Cornission i .i 10 One tihite Flint ITerth 11 Rockville, Maryland-14 d<. 13 Monday, February 27 19?? 14 l t 1 15 The Commission met in open session, pursuant to-16 notice, at 2:00 p.m., the Honorable LAlfDO 11. CECH, JF., 17 Chairman of the Comrission, presiding. <e Av 19 COMMISSIOtiERS PRESE!!T: r 1 20 LAtIDO t7 ~,ECH, JP. Chairman of the Commission 21 THCMAS M. ROBERTS. Member of the Cormission 20 EE!iUETH !!. CARR, Menber of the Ccmmission ^ '. F'Ef fifETH C. ROGERS, Merber of the Comr.ission l l 22 JAt!ES ?. CURT!SS, !! ember of the Commission 1 i 6. '89 r, ,"_,%s,, l's L n J.,4 ..,C, e e 4 r , 4 J s, - ** ", C U r, k.,/l,,,*,. T he i 1, +64ve ,...c. i w v l,, me aw 6 s .,w w 1 S^9 p 11. W U 7

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.l',- 3 I-4 t--, 1 STAFF A!!D PRESE!!TERS SEATED AT THE COMMISSIOff TABLE: --{] 2 SAMUEL J. CHILF., Secretary 3 UILLIAH C. PARLER, General Counsel 4 DR. FOREST REMICK, Ch air:na n, ACRS - 5 DA'/E UARD, ACRS, Chairman, Cont air ment Requirements 6 Subcommittee 7 DR. BILL KEP.R, ACRS, Chairman, Severe Accidents 5 S ub c o mrii t t e e 9 10 11 12 i L_ _ 13 L i 14 15 1 l l 16 I 17 l 18 19 k a as ok es nn o 23 i de 4 i l 25 l-i r '*001234-1433 ! TEAL R. GROSS & CO!!P A!!Y. !!fC. '202)222-660 l 1323 ?HCDE ISL A!!D A'IE!TUE. tr.U.. NASHIliGToti, D.C. 20005

c, q t l 3 1 g g q c E E Q l'fl Q S 2 (2:03 p.m.) i l J 3 CHAIRMAli SECH: Good afternoon, ladies and 4 gentlemen. ) 5 Today 's.neeting is with the Advisory Committee 6 on Reactor Safeguards,- the representative group of the 7 Advisory Committee. 8 In a recent staff letter, SECY P,9 - 1 7, and in a i 1 9 public neeting held on January 26th, 1989,. th e MRC staff 10 recommended that orders for plant-specific backfit

c. f 11 boiling water reactors using Mark I containments be issued 12 to require certain safety improvements that the staff 1

l \\ l 13 deemed ta be both cost-effective and .a substantial 1 14 enhancement to the safety of these plants. '] i l 15 In this meeting the staff referred to.the ACRS 16 letter of January 19th, 1989, on this subject, in whic.' 17 the Advisory C o.- mi t t e e on Reactor Safeguards recommended 18 that the staff's proposed improvement; plan be drcpped,.so 19 that licensee and liRC resources could concentrate on the 20 more effective individual plant examination approach. 21 The Commission has.been told by the MRC staff, 22 essentially, that boiling water reactors using Mark I 23 containments did not pose an undue risk to public health 24 and safety, that the overall risk to the public from these 05 plants is comparable to that posed by other plant types, 1 l l (202)034-2433 MEAL R. GROS 3 & CCM?AMY, IMC. (2021232-660 1 ^3 RMOCE 25LAMO A"EMME, U.17 ' 17A3M MGTO!!, D.C. 20005 l l c

l',, l 1 l 4 l I 1 and that these plants could continue to operate safely. L s 2 I understand that ACRS is in agreement with this l l l 3 staff's overall conclusion. However, the staff also told 4 us that in the highly unlikely event' of a severe ccre 5

damage accident for a boiling water reactor, the liark I l'

1 1 6 containment has a higher likelihood. o f.containmen t 7 failure. l l 3

Thus, the focus of the staff's effort in its 9

review of Mark I containment performance was to provide a 1 { 10 balance between prevention and mitigation of so ter= 1 11 accidents for Mark I plants, by reducing the likelihood of 12 containment

failure, ther'eby improving accident

? l i I L-13 mitigation. 14 In carrying out the Commission responsibility 15 for public health and safety, the Commission, as you know, 16 relies on the advice of the Advisory Cc=mittee on Reactor 17 Safeguards to provide an independent technical assessment l 18 of matters related to nuclear safety. I 19 Accordingly, the Commission requested this 20 neeting with the Advisory Co:rmittee on Reactor safeguards 21 in order to assure that we hav-complete understanding of 22 the ACPS views on the ITEC's staff's recommended M a r t. 1 23 containment improvements, before coming to a decision on i 1 24 this matter. 25 There is no vote scheduled for the meeting this (20:1234-4433 iiEAL R. GP,O S S & CO!!P AlfY, Ilic. (202)232-660 1323 P'40DE ISLA:iD AVEMUE. it. U. 17 A S HI!iGTot!, D.'. 20005 L _ _-_1-

v i 1 t 1 afternoon. The Commission will vote on this matter at a 2 later date. 3 D o. any of my fellow Commissioners have anj 4 opening comments, before we becin? 5 (tio response) 6 CHAIRMAff CECH: First of all, Dr. Renick, before 7 you proceed, I would like to congratulate you on your i 3 recent appointment as the Chairman of the AC P. 5, and 9 welcome you and your colleagues to this meeting today. l 10 You may proceed, Dr. F.erick. 11 DR. REMICK. Thank

you, Chairmar.

C e c ',., 12 Commissioners, it is a pleasure for us to be here, and

j 1

1 13 discuss our January 19th letter. i 14 Perhaps I first should explain why there u> i 15 only three of us here. 17 hen we got word of your request. 16 we tried to arrange a i:i:ne when the full co: rit tee aculd 1 17 meet with you, and found

• hat in the February-liarch ' ti:':a la frame, we couldn't come to a mutually agreeable time.

Ic 19 we went back and said,

well, who are the essentia 20 attendees, and it turned out that three of us are'the ones l

21 -- and I will explain in a minute why. 22 'fe did invite other nembers to attend, if t h -: y l 23 could, but they were not able to join us today. So that's i 1 04 why there are only three of us here. l i 25 CH AIRM Alf CECH: 17e ll, we appreciate very much (20 2) 2 34-44 33 !!EAL R. 3ROSS fr COM?A:fY Itic. '20:! 22-460 1323 RHn9E ISI AtiD AVE!T!IE, 17. 17 ~ 7 A S H!t!G"'O:' D.C. 20005

~ . I... S 1 your being with us today, all of you. l U 2 DR. RE!!ICK: Good. '3 And the three, Dave tiard is the Chairman of our 4 Contai.nment Systems Subcommittee, and Bill Kerr is 5 Chairman of our Severe Accident Subcommittee. So, that's 6 why it was essential that Bill and Dave be here, arid I an 7 to keep them separated, I believe, i l 8 (Laughter)- l 9 DR. REllICK: Before we-get into a discussion of 10 the letter, I thought it might be helpful to put thar 11 letter of January 19th in the c on t e:-: t of some things that 12 the ACRS has been saying re cently on rela ted :ra t ters. And i 13 I would like to specifically refer to three letters that I t-l l 14 we have written in the last year. l l 15 The first one, tlarch 15th, which was entitled i 16 ACES Comments on the lieed for Greater Coherence Among IIe w I 17 Regulatory Policies. And I would like to just abstract a 18 few sentences from that letter, where we said that "The ] 19. problem we see is an increasing lack of coherence and 20 integration among several separate areas of policymaking 21 within the ifRC". 22 tie go on to say later, "The severe accident 23 policy is only one of a number of new Commission policies 24 and programs concerning nuclear power plants that have t 25 been advanced over the past two or three years. Others (202)234-4433 ffEAL R. GROSS & CO!!P AlfY. I !C. (202):32-660 1323 MHCDE ISLAttD AVEliUE, II. b'., tiASHIIfGTC-ti, D.C. 20005~

.j i 7 1 relate to the safety goal, standardized plant designs,, 2 ISAP and advanced reactors. In addition, the resolution s 3 of USIs and GIs has led, or might lead to'important new ') / 4 requirements and guidance for licensees in several areas. 1 5 "Although the 11R C staff, the ACRS and the 6 Commission have provided some overall-guidance toward 7 integration of these policies and. new requirements, -we 8 believe this has been insuf ficient. As a result, 9 licensees can be confused, or burdened with contradictory 10 new requirements from different parts of the IIRC staff."' 11 Then on May 10th, in a letter which was entitled l 12 Proposed Generic Letter on Individual " Plant. Examin ations i 13 and the Proposed Integrated Safety Assessment Program, we l 14 said that "These two programs, developed bydifferent ifRC 15 staff groups, have not be*en integrated, even though they i 16 deal with many of the same issues. 17 "Ue believe that the IPE program shoald be 18 expanded to incorporate all outstanding 'afety issues, not s 19 just those under the severe accident rubric. The generic 20 letter should be revised accordingly." l 21 And further in the letter we said, "In cur 22 report of March 15th, we expressed our concern that there 23 was .a l a c 'r; of coherence among the several principal l-24 regulatory programs of the Co.-mission. Ua believe the IPE 25 program offers an opportunity for providing improved (202)234-4433 IIEAL R. GROSS & COMPA!!Y, IIIC. (202)232-660 1323 RHODE ISLA!iD AVE!!UE, it. U., WASHINGToti, D.C. 20005

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^ n r..d.- w.. a .r...e S alu.a, n., e-y op sc a -f.. ,s w.sc. v o 2 charact-rized as felicus: 5 "The purpose of the IFEs wculd be a c k n c vi-; d g e '. as broader than the original intent of searching far ~ outliers.

Instead, i t would call far a general rd 't reassessment. cf each plant. using tha bcdy of infor: ' t i vi availabic frc.m the TMI accident e :-:p a r i e n c e, kt 1cpt --

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.e -e- -. : n t e- .w w, ..ua. .. a u rc e v. e,s e a L,. . s. a e,, g.r a. _ 13 M*C s aff already has been e;;panded well beycnd ~'a enh fr outliers concept. In subsuning l' S I - 2 4 5, c h r ', 'a . 3 ;., g. a. 3 r- ..c.n,al r a ~., u i r c'.- =. ". *a ' o". '

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1 for Clar,ure of Severe Accident Issues, we said, "iN 1 commend the t!P.C staff for its efforts to develcp an .s 3 integrated approach for dealing with the various s e v a.r e 4 accident issues, and to centralice responsibility for 5 resolving them. SECY 83-147 describes the first drep 6 towards develeping such a plan, namely, identifying r s l e v a n r. issues; however, it gives little inf orn t i an c: ~ .1 2 c'.* ths-farious issues are to be int-grated, F. a t h e ', d'- l 0 9 discusses the-severe accident-ielated issues an:. pryra1.s 10 that should be integrated, but does not descr.ibe 'the 11 process to be used," l l l

1. 2 And in closing, in that letter we

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l l 13 " Finally we encourage the staff to contintw i ts affert.= I' ( '. 4 toward integration of the v a r iot"; pregrams being develcred. '5 fer resciution of the severe accident issues. "e believe 16 that the :m o s t recent draft generic letter describing the program represents.a ove in the alrection wc ..nu Arr 4. 13 r e c o m"'e n d e d in our letter to you of May 10th, 193?. 19 are convinced that further integration can serve - r e s c u r : ::. S' of both the staff and th e licensees, and can contribut.: :: a - crs effective process fer risk re hc". ion im operatinc. p, a n t s,,. 4,. 4, e.ha... u a,. .,t a .w ... a r. .t... t ,, t,. s .s v. . c ^a le rer cf January 19th should be read In other wcrds ir ^5 u s -- we.have been e phasizing a need for ccherence, s 3. .s.,.

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v. .I 10 l' need'for integration, and a need for regulatory stability. V'- 2 At that point'I would like to turn over to Cave 3 Mard, to address the letter itself. I 4 MR. WARD: Thank you, Forest. 5 I am prepared to summarize the letter, just take i 6 five minutes, or so to do that, but if you are familiar l ] 7 wi th it,- have just read it, we could just go ahead and-- 1 8 I would like to hear what questions you have, and it might ) 9 just -- l 10 CHAIRMAtt ZECH: Well, we would appreciate - - m: 11 will have some questions for you, I'm sure, but I think a 12 five-minute summary would be helpful to us. 1 13 MR. UARD: Okay. Fine. l 14 CHAIRMA11 ZECH: Thank you very much. 15 MR. UARD: This is the latter,of January 19th, 16 of this year. And we pointed out that the Mark I plants 17 have been singled out for special attention because af 18 indications that there could be a high probability of 19 containment failure in certain severe accidents _, but L: l-20 despite

this, these plants seem not to present a 1

21 particularly high risk to the public because their core 20 melt probability -- estimates of core melt probability of 23 this class of plants seem to be quite low, and because L i 24 they end to have -- these BUR plants tend to have highly 25 versatile and capable emergency core cooling systems. (202)234-4433 tiEAL R. GROSS & COMPAtIY, !!!C. (202)232-660 1303 RHCDE ISLA:tD AVE:tUE, ii.U., WASHIt!GToti, D.C. 20005

v-i 1 11 1 There are a lot of-ways to get the vault water into the 2 corei and this shows up in any sort of a risk analysis. l 3 So, if the risks from these plants isn't too 4 high, what is the problem? For. example, do they meet the 5 safety goal? 6 Well, f; rom our perspective, the answer to the 7 question do they meet the safety goal is, yes and no. If 3 we accept the ACRS proposal for fleshing out the safety 9 goal and as you

know, we've had a series of 10 interchanges with jour staff on the development of 11 fleshing out the safety goal.

12 ~ If we accept that approach to the safety goal, l 13 then it would seem that the Mark I's as a class, seem to l 14 meet' the risk part, the public health risk part of the 15 safety goal. They seem to meet the core melt quantitative 16 goal, but they do not seem to meet what we are going to 17 call "the ba17nce goal", and that is they don't meet the 18 goal for minimum containment performance. 19 tie w, the ACRS has suggested tha; there be a goal O for minimum containment performance as part of the overall l 21 safety goal, to provide a balance between prevantion and l 22 mitigation. And we see this as an important part af 23 providing defense in-depth for the reacter systems. 24 Well, given that, then cur disagreement with the 25 staff proposal for the Mark I improvements is that it (202) 234-4433 !!EAL R. GRCSS & ' COMP AtIY, Itic. (202)232-660 l 1323 PHODE ISLAUD AVEtiUE,- II. U., WA SHIITGTOIT, D.C. 20005

v il1 il 10 1 prescrilas things that appear to be effective in making L' b- ,0 the core melt probability lower -- that is, reducing still 3 further core nelt probability' that is already within-- 4 conforms with the_ goal, the safety goal, but these things l 5 .do not seem to make much of an improvement-in containment 6 performance. 7 So, they don't seem to improve the area.c f S weaknesses that has been of concern with the Mark s. .9

Well, it hasn't been easy to identify a 10 straightforward way to fix the containment, to give them a 11 higher predicted performance in these very severe 12 accidents, and neither the staff nor the ACRS ner, for i

13 that matter, I think the industry, have been able to 14 pinpoint specific solutions to some of' the proble:rs. 15 And for one thing, there are indications. the 16 such fixes to vulnerabilities in containment -- Mark I 17 containments seem to be very plant-specific, both the i 13 vulnerabilities, the particular detailed vulnerabilities, 19 and the optimum ways to fix those, to address, them s e e n-l 20 to be plant-specific. l 1 21 So for this reason we, the ACRS, propese that i 22 the -- what I might call the kind of semi generic fixes j 23 that have been proposed by the staff for Mark I l 24' containments be dropped and, instead, the individual plant i 25 examination, the IFE process, be used to idantify (202)234-4433 IIEAL E GROSS & CCMFAliY, Ilic. (202)232-660 1323 PHCDE ISLAliD AVE:iUE, ii.U., U ASH MG"'Oli, D.C. 20005

i 13 1 containment improvements that might be warranted at 2 specific plants. 3 tio w, along the way, in our letter, we also 4 express some disagreement with the cost-benefit approach 5 which is being proposed by the staff for use in arguing 6 the necessity and the justification for the !!a r k I 7 improvements. And our disagreement is namely that it ic S an attempt to apply a generic analysis of cast a n >l 9 benefits. to situations where both the benefits and the 10 costs seem to be very highly plant-specific, but this 11 question, this disagreement over the cost-benefit analysir ~ 12 really becomes moot if our recommendation is adopted. 13 I think the work that the staff has done has 14 been of considerable benefit in f oc\\using on the key issue., 15 and / vulnerabilities, and I think it should bs of 16 considerable use to licensees when they conduct their IFE 17 programs and, particularly, indicating the need fer 18 empaasas o r, the containment evaluation part of the ~PE 19 programs for these Mark plants. The staff analysis has 20 brought together brought to light some veri important 21 issues in this particular area. 22 That's what we said in the letter, and I think 23 the mest efficient thing now would be to ask for 24 questions., comments from you, !!r. Chairman, or the other 25 Commissioners. (2C2):34-4433 IIEAL K. GROSS & CCMPAtiY, IITC. (202)232-660 1323 REDE IS' Al?D AVE!!UE, II. U., U A 3 HItir.TOIT, D.'. 20C05

3 a l :- 14 1 CHAIRMAli ZECH: All right. Fine. L L-2 Mr.

Kerr, do you want to hold up on ycur i

3 presentation? Dr. Kerr. presentation. i 4 DR. KERR: I don't have a 5 CHAIRMAIT ZECH: Okay, fine. 6 All right, Commissioner Roberts? j j ~7 COMMISSICITER ROBERTS: I have no questions, just I l, 9 8 an observation. In my time here, it would appear to me j '1 9 the members of the ACRS are quite outspoken individuals, 1 { 10 and are never hesitant to make their individual v: ews I l 11 known which is, I think, admirable. And I note there are t 12 no additional comments by any member, and I think that is l i 13 significant. j i l 14 I don't have any questions. I I i 15 CHAIRl!Ali ZECH: Commissioner Carr? l J l 16 CCMMISSIOt:ER CARR:

Uell, it sounds l i '; e juu 4

.1 17 think there is nothing you can do to fix the containmen-c., i l 18 and all the f i:< e s are so the containment doesn't get 19 tested, is that reasonably stated? l t i l 20 MR. UARD: !To. I think that's the conclusion j 21 you night draw from the set of proposals the staff has j 1 1 22 developed. I don't think we agree with that. 23 COMMISSIOt*ER CARR: Uell, what do you think-- i 24 you are only discussing what the staff has said they would i 25 de, and you note that that would fix only -- that would l (302)234-4433 t:EAL R. GROSS & COMPA!iY, It!C. (2021232-660 1323 RHODE IsL A:tc AVEi!UE, ii.U., UA SHI?IGTOli,. D. C. 20005 t i ._____.___..i.___________----.______--

l . 5 L 1 only. reduce the probability of melt, rather than fix the 2 containments. 3 Uhat kind of fixes do you recc:rmend we do to the 4 containments? 5 MR. WARD: Well, that's the good questibn. And 1 6 the indications we have from the staff, is that.the -- and i l l l 7 from other analyses we have seen, is that the t 'a r k I 3 vulnerabilities and the fixes for them are very plant-l 9 specific. And I think that is the heart of this who'e 10 problem, is that we see a probler -- you know, everyc>e 11 perceives there is some sort of a problen wi.h "h, 12 con *ainments. We haven't figured out what to da abc t 13 this, so we are going to work on another problem instrad. l 14 COMMISSIO!!ER CARR: Uell, i t seems logical that 15 if you expect the containment to be weak, it only makes 16 sense to vent i t before it catastrophically ruptures, se 17 that you at least have a controlled vent. is that -- la MR. WARD: That is certainly one possibility. 19 Bill wants to say something, 70 DP. KERR: Ue did not, as Dave says, a t t err p t to 2 ^. deulop alternative recommendations. He didn't discuss l 20 char in a r.y detail, so.I will speak only for yself. 'T would think . hat probably, whether it is done in an !?~, 24 cr as part of this proposed program, that Mark I's would ^5 c e n c l u c' - that the installation Of a hardened vent is a ^2):7*-4423 "TAL R. GROSS & CO!!P Ai!Y INC. (^02)23^-660 . 4....I L *.,..1w.M v. s./ M Y 1. 4 d O p 34.. 7 e ) eiM

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q Ll b. l \\ ao q 1 1 good idea. And,oin h d, from my point of view, *his was .] W y - t. ~ the only part of the staf!'s proposal tha t one ' t ;. h t 3 . identify as increasing the capability of the contain's x ) a 4 A'n d I think what we f +1 t - was that alscar 5 everything else had. to do with decreasing acre :4 0, hnd 'S that, indeed, this wonid be what one would be.1 coking:for 1 1 7 in the IFE. And it, therefore, made more s e n s e, r, 8 integrate this with other things that night be p:r e d to a 9 prevent core melt, or possibly to conclude that the ccra 10 melt probability was sufficiently' low, ~ l 11 So my view, from what I have seen in the staff's 12 analysis, would be that the vent hardening is probably 13 worthwhile. 14 tio w, this is not based on any significan: 15 analysis that we have done independently. And, indeed, we 16 did not see numbers indicating that the staff had drue 1 17 careful analysis to show what improvement in contain;:ent 18 performance this would produce. I don't. think one h e. s 19 been made. 20 There is a consensus that it will increase the I 21 capability, but how much is, I think, still an open 22 question. 23 COMMISSIOliEP CARR: Well, it doesn'r seer like i 24 it would increase the performance at all. It seems like 25 it would enable you to not -- (200):34-4433 liEAL R. GROSS s Col!P AliY, -Il!C. (202) 30-660 1323 RHODE ISLATID AVE:!UE, :f. U., UASHIUGToti, D.C. 20005

17 L ) 1 DR. KERR: By performance, I mean the capability j l 2 of the containment to withstand a very severe accident. 1 3 And if, for example, one uses this before core damage has l 4

begun, then you don't really need containment at that 5

point. You then have a containment with integrity when 6 core damage does occur, if a particular sequence was one 7 that involved those kinds of events. l l 3 It was in that sense that I was using'the te-i 1 9 " performance". ) i i 10 COMMISSIO!!ER CARR: I understand. ] 11 DR. REMICK: If I could answer that. I don't 12 believe that we have concluded that the I t a r '- I 1 I 13 containments are deficient. Our view is that that's.part l l l l 14 of the IPE process, that you will look at t h e:n, and 15 perhaps you will find some deficiencies there. l 16 tiow, I agree with Bill, that the venting is 17 certainly one step in being able to keep over-13 pressurization of the suppression pool, and so forth, that 19 that is certainly one step that might improve containment, 20 but the staff has indicated that these represent no undue 21 risk, and that the modifications are not required 'or 22 adequate protection. s 23 our question is why forge ahead when you'v-24 just put out a letter on IFE, asking people to go through 25 Phis process, to c a.m e along then i-mediately after and I20:1234-4433 ITEAL R. GROSS & COMPAITY, IIIC. (202)232-660 1323 RHODE ISLAIID AVE!!UE, II. 'd., '7ASHI!!GTO!I, D.C. 20005

l i 13 1

say, "But, oh, yes, but you need to do these right away".

i'~ 2 And there are. I think, implications en that 3 because s o m e t i:n e s we overlook -- if you nake those 4 modifications, you have to revise procedures and you have 5 to train people. And that takes time. And then if you 6 come along, after the IFE process, and say, well, mayb-7 shouldn't have done that and make revisions, you are 8 adding a lot of confusion to the operating people, 1-t 9 alone-consuming their time and their resources. 10 So that's one reason we feel why rush ahead? 11 Uhy not provide some coherence to the program, provide 12 them this information -- as Dave points out, there is ve:/

• 3 valuable information that has been generated -- :ake it 14 availabla to licensees for incorporation into the IPE 15

process, 16 CHAIRMAti ".ECH:

Commissioner Rogers? 17 COMMISSIOtiER ROGERS: . fell, I think it is ' -c r y 18 important for us

r. o understand exactly what the meaning

e. f 19 your letter of January 19th really is because it seems

t. n 20 me there's a couple of different interpretations of it, 21 and maybe some of those might not be your intended 22 interpretation.

23 "" h e last ptrsgraph says, "We recommend the i 24 proposed improvement plan for Mark I contairnents be 25

dropped, so that licensee ar.d !!R C resources can (202)234-4433 tiEAL R.

GROSS & COMPAtIY, Ilic. (202)232-660 1323 FHODE I SL AIID A V E!iU E, t i. '.l. ~,1 A S HItiGToti, D.C. 20005

v 19 t. 4 1 concentrate on the more effective IPE approach". 2 One. might-read into that that the elenents of 3 that. plan, the five specific improvements for Mark I j. 4 containment plan that were in the staff plan,_ were 1 1 8 l 5 objectionable'to you in some way. And if that is not the t 6 case, I think we should be very clear on that you are not 7 objecting to those specific elements, as ~ such,.but that l 's you want to see that done in the context of an IPE rath-;r 9 than as an add-on, but I think if you have any l-10 reservations whatsoever about any of those five elements, 11 then we would like to know -- I certainly would like to 12 know what they are -- because one of them is new hardware. 13 -- that's the vent capability -- but some just represent l l 14 procedures and training, and staff actions. 15 Four and >five of the five elements were-- 16 number four was extended emergency procedures and. 17 training. And number five was accelerated staff actions, 18 to implement the station blackout rule. 19 And I think it was made very clear, someplace, I 20 know, in something I read, that that acceleration was of 21 staff actions, not licensee actions necessarily. 22 And so I would like to be clear en whether you 23 had any objection to those elements t h e :n s e l v e s, one by 01

one, because some of then I don't see any particular 25 raason why they necessarily relate to an !PE.

Four and I (202)234-4433 IIEAL R. GROSS & Cot!PatiL Itic. (202)232-660 1323 RHODE.ISLAt!D AVEtilE, !!.W., WASHItiGToti, D.C. 20005 1

I j.. i 20-1 five, I don't'see do maybe. f our might,. perhaps,.but i k-2

five, the accelerated staff actions -' to implement the s

3 station blackout rule, I don't see what that's got to do 1 4 with an IPE. l 5 S o,- in other words, I would like to be very l 6 clear on what it was you really meant when you said that 1 .7 the plan be dropped, whether that means that ~he elcents l l 8 of the plan are unacceptable and should ba, dropped, or l 4 9 whether some of them could be -- you know, the totality of 10 the plan, whether the plan could be implemented in part, 11 even if the part is only the accelerated staff' actions to 12 implement the station blackout rule, or'some other parts t l l 13 -- you know, just what you'really mean there. l l 14 I think that would be very helpf ul ' to us, te ) 1 1 15 have you make that clear. 16 MR. UARD: Okay. I think you have made a good i l 17 distinction, and we need to make -- cur objecticc. to the 1 18 plan is to generically apply this group of elements to all 19 plants. Some of those i ndi v i.du a l eierents will probably 20 apply to sp-cific plants, but we would like to ses the IP 21 process he used, and-let those elements fall where'they l 20 will in that IPE process. If they are indicated to - be 23 necessary, er worthwhile. in the IPE process, then they i 24 should be adopted for that particular plant. 25 And this is the sort of thing I meant, that the (202)234-4433 tiEAL R. GROSS & C O M P A!!*i, ItiC. (.202)232-660 13 2 3 E!3CDE ISL A!iD. AVEtiUE, 17.'.1., - U A S H I ir.,T O il, D.C. 20005

s a 21 4 1 material that the staff has developed will be useful to 2 the licensees, and to the staff, in going ahead with the 3 TFE process, but the blanket imposition of that group of 4 things on all Mark I's does not seem to us to be 15 warranted. 6 COMMISSIO!!ER ROGERS: Uhat is your feeling on 7 this? 8 DR. KERR: It is my own feeling that many 'o f 9 these things are worthwhile, but I would like to see them ..i 10 weighed against other things that one would do in the. l l 11 course of the IPE. One is not going to necessarily dc l 12 everything, obviously. So one has to balance those things l 13 that are most cost-effective, or most likely to eliminat+ 1 1 14 risk. 15 And you mentioned the station blackout, I agree 16 that's an extremely important issue, but it could depend i 17 very markedly on what one does about decay heat renoval. 1 l i 13 That is one of the reasons the ability to work a station l 19 blackout is extremely important. 20 So, even on that issue, I think if one does it 21 at the same time that one is looking at the total syst.u. i 22 to try to make the risk appropriate, it is likely to be l 13 more offective and more efficient. 1 Od COMMISSIOtiER ROGERS: Except on that one, there 25 is a rule now that is t6 be implemented on station (2001234-4433 tie AL P.. GROSS & COMPAtIY, Itic. (202)232-660 1323 RHODE ISLA?ID AVEtii1E, ii. W., W A S HitiGTCII, D.C. ?.0005 2

v. .j. .p s l. t 22 1 blackouts. So the question -- this recommendation, I take 2 it, is accelerated staff actions,. that 's !!RC staff, not 3 necessarily licensees. 4 DR. KERR: But the way in which one interprets 5 the rule depends on local conditions, and on-the plant 6 itself, I believel.that's my impression. '7 COMMISSIOtIER P,0GERS: Well, I think I' understand 1 3 where you are coming from a little.better now becaus-it 9 is really the plan itself, as a unit, a kind of nonnlit" l 10 that is being imposed. And you are not objecting l 11 necessarily to any of the elements of the plan but, 12 rather, the way of proceeding, whether to proceed through l l 13 IPEs, or through.the imposition of this as a generie 1 l 14 requirement. 1 15 Given

that, what would you say about the 16 situation though if, for some reason, the IFE plan gets 17 delayed in some way. for any number of reasons, so.~e of 18 which ifRC might have no control over?

Have you thought 19 about the possibility that if we wrap this directly into 20 the IFE and take no other actions, that there might be 21 sore possibility of delays, t h a i. might set this back quite 22 a bit? These particular things back? 23 MR. WARD:

Well, one thing that is likely to 24 delay the IPE is the imposition of this plan.

i t 25 CHAIRMAti CECH: Would it be a concern to you if ! 02)234-4433 IIEAL Ps. GROSS & CCMPATIY, IIIC. (202)232-660 1123 FHODE ISLAIID AVEITUE, fi.U., UASHINGToti, D.C. 20005

-______y______ 23 1 there were delays? I 2 MF, ITARD: tio. 3 CHAIRMAtt ZECH: The answer is no, right? l '1 4 DR. REf FICK : The statement'-- I mean, the staff ) 5 has made the case-that there is undue risk and the 6 modifications are not needed for adequate protection. i 1 7 CHAIRMATT ZECH: Do you agtee. with that 1 i 8 statement? l 9 DR. REMICK: Yes. l l 10 CHAIR!!Ati ZECH: All right. l l j 11 COMMISSIO!!ER ROGERS: All right. So, you don't. l l

1. 2 see a big problem if there is a delay then?

1 13 DR. REMICK: 11e ll, of course the delay, if it 14 went out to infinity, I didn't say that would be good but, 15 if we are talking in the time span that the staff was 16 predicting for IPE, no. It's a three to five-year ie j 17 span, I believe, that they expect, depending on wh >. t h, r 18 people have an existing PRA and they are going to de a 19 level two, or a level three, and so forth. 20 DR. KERR: Well, if 1150 plants are to becone 21 part o f. the IPE, and we were told that there are very M llkely ro be first in line because of the rather extensive 23 analysis that has taken place, one of those plants is of [ 24 course the Mark I containment. And, presumably, that 25 would give one some experience in seeing what sort of 1 (202)234-4433 MEAL R. OROSS & COMPANY, Ilic. (202)232-660 1323 EHOCE-ISLAffD AVEtiUE, it. U., ITASHItfGTO!!, D.C. 20005

v I [ j i h 1

4 4

1 balance of containment performance and core melt frequency t 1 L-2 reduction is appropriate. And if it turns out that ) l 3 something unexpected develops in the course of that I l i 4 analysis, then one has another look. 5 I think it is obvious to you that we are trying 6 to give you our best judgment. l 7 COMMISSIOliER ROGERS: hs, of course. 8 .OR. KERR: And in no sense do we think we. a r, 9 necessarily wiser than the staff. We looked at t h i.s, and 1 10 we gave you a considered opinaon. I 11 As you mentioned, Mr.

Roberts, there was oc 12 dissent on the part of those participating i, th t j

l { 13 discussion. He did not, certainly, I think that into i 14 account what might happen, if there were an extended delay 15 in IPE. 16 tiow, I guess if that were to be the case, wo 17 would want to have another lock. I think that's a 13 consideration. 19 COMMISSIONER ROGERS: You raise some rIuestions 20 about whether the cost estimates I don't know whether 3 21 it is cost estimates or cost-benefit ratios -- probably i. t 22 is the ratios although I don't know -- that the c o s t-23 etimaces ar-not justifiable. i 24 Could you elaborate on that a little bit? Were b 25 you able to pinpoint anything there that you felt was (200)234-4433 !!EAL R. GROSS & COMPA!fY,- INC. (202)232-660 1303 RHODE ISLAi!D AVE!!UE, II. U., UASHIlfGTO!I, D.C. 20005

m u 25 4 1 particularly weak? 2 There is a dif f erence. between the industry 3 contractor-based studies and the !!RC 's tudies. Did you 4' look at'this independently in some way? Did you tend to 5 go more with the industry group's analysis, or what was 1 6 ynor guide in coming to this'-- 7 DR. REMICK: Of course, you certainly have one l l I 8 data point 'a t Pilgrim in which there was a fairly strong 1 9 estimate there, which differed,. basically, from the range l I 10 -of the staff. It is not unusual. The.s ta f f, I think l 11 traditionally, comes in -- under-estimates industry. 12 Dave, do you have anything? 13 MR. WARD: tio, that's all. I think tha 14 realities of actually fixing these plants I think we l l I 1 8 15 often see that the real costs -- they are higher than whar 16 -- substantially higher than what would be predicted eacly 1 '7 on by analysts, when it gets down to the hard, tough. 1 18 hardware, engineering estimates. l l l 19 As we have, as Forest pointed out, there is one l 20 firm data point, and there is kind of a disconnect between 21 the estimates and that data point. 1 l l 22 COMMISSIOtIER ROGERS: 'Yes. l l s i l' 23 Do you have anything to say on it, Professcr 1 24 Kerr? 25 DR. EERR: Only that, clearly, this is'an area l (202):34-4433 I!EAL R. GROSS & COMP AITY, Itf C. (202)232-660 I 1323 RHODE ISLAi!D AVEltUE, it.W., WASHIttGTOti, D.C. 2000,5 l ( lL __--__ _ _- _ _

.t I

j i

26 d 1 in which th-re is even more uncertainty than in risk I'- 2 analysis because one is not only the uncertainty in the 3 risk analysis, but also the uncertainty in cost estimates. 4 And the fact that this was done generically, which is 5 probably the only way to do it, if one makes the -6 application generically, it leaves me a bit uneasy.if on9 7 is serious about the cost-benefit analysis. of something I l 1 8 going on an individual plant because I think the 9 population density, the' characteristics of the plant, and 10 other things, will contribute even more to the uncert4inty 11 in the calculation. 12 CHATRMAtt ZECH: Commissioner Curtiss? r-13 COMMISSIOffER CURTISS: fio questions. Thank you. l 14 CHAIRMAli ZECH: Dr.

Kerr, you've, I beliave, 15 answered the question I had about whether any of the 16 staff's recommended improvements might be specifica113 17 considered in the. category of co n t a i n:c e n t improvements, 18 when you indicated, I believe, that the hardened vent 19 would be in that category, but I think you mentioned that 20 you thought the others would be in the area nf cera melt, 21 is that a fair characterization of your statement?

22 DP. KERR: Yes, sir. 23 CHAIRMAli ~'ECH: And I presume then, Dr. Remick, i 'a whar you hwe sunma rized as the ACRS position, is that tha L = 25 ACRS would nor necessarily be opposed to the staff Mark I (202)234-4433 tiEAL F. GROSS fr C O M P AlfY, !!!C. (200)232-660 1323 RHODE I SI; Alf D AVEi!UE, II. U., U A S hit!GTOi!, D.C. 20005

4 27 4 1 containment performance improvements, if the cost-benefit 2 analysis were performed on a plant-specific basis. In 3 other words, done as part of the IPE program, is that 4 pretty much what your summary is? 5 DR. REMICi* : That.is correct, ide certainly don't 6 cliffer with the elements of what they propose. 17e are 7 saying it should be done as part of the IFE, and weighed i 3 with what -- l I 9-CHAIRMA!! ZECH:

• i'o u d o n ' t rejilly dif fer with the

) .l 10 technical improvements that might come about -- l 11 DR. REMICK: That's correct. 12 CHAIRMA!1 ZECH: but you do differ.with the 1 l l I 13 methodology, if you will, of application generically, l la rather than on a plant-specific basis, is that correcP i l 15 DR. KERR: That's correct. I would'put it in a 1 1 16 slightly different way. I do not differ that any of the 17 things that they have suggested ought to be locked at, bu' 18 in the context of the things that one would do at a given 19 plant whether they would turn out to be the most cost-20 beneficial I think would depend on an overall analysis. 21 CHAIRMA!! ZECH: But you do think. sone of the 22 improvements suggested, or perhaps all of them,. may be l l 23 appilcable to some plants? l 24 DR. KERR: Oh, yes, yes. M CHAIRMA!! ZECH: Do you think that the-- (202):34-4433 !!EAL R. GROSS & COMPAliY, Itic. (202)232-660 [ 1323 RHODE ISLAlfD AVE!!UE, II. ti., W AS HIIIGTOli, D.C. 20005

_i l 23 1 considering just the hardened vent, do you think h a r d,: n e d I I-- 2 vent or have you had a chance to lonk into it, to the 3 extent you would be confident a hardened vent could be 4 designed such that safety would truly be enhanced and not 5 detracted from? 6 DR. KERR: Speaking for me, the answer is no, I 7 have not looked at it in that detail.

You, perhaps, 3

recall that we are doing work on some efforts to write 9 some criteria for containment performance. And we have 10 underway some work that I hope will give us et 11 confidence in reconnendations that we would eventually 12 make, but I can't say from my perspective that I ar sure i 13 that there would be no disadvantages to this. Indad, I 14 can think of some concerns that one might have, if one h m1 15 a vent available. And, indeed, if I can be a litrie bit 16 facetious, I am not sure anybody would ever use a vent. 17 I think the decision to vent is going to be 18 e x t r e:wl y difficult because you have to estimate what is 19 going to happen to the plant, before it happens, in a 20 situation in which things are very uncertain. Even so. 21 from what little I know, I guess at this point I think it 22 probably would be a good idea, but this is based more on 73 I an reluctant tn use the term " engineering judgment" 24 because. as Harold Atherington ' phonetic) once said, "It i k 25 i *npl i e s that ons is both an engineer and has judgment"-- (202)234-4433 IIEAis R. Gross & cct!PAtIY, Itic. (2021232-660 1323 RHODE I SL AtiD AVEt!UE, II. U., UASHItiGTOti, D.C. 20005

,c 1 29 ) 4 l . laughter) -- but gut feling, or something. ( 1 2 DR. REMICK: And intuition tells me'that it is a 3 good idea. And the fact that you would be venting from 4 above the' suppression pool tells me that it makes sense. 5 Ue certainly haven't looked to see wha t' kind of valves 6 would be used, and this type of thing, and the reliability l l '7 of that type of thing, but from an intuition standpoint, l 1 I 8 it seems l'ke a logical type of thing to bead toward. t 9 CHAIRMAt1 ZECH: Well, I think you've made your j i 10 ACRS position clear. I think it has'been helpful to he*,r 1 11 from your today, in addition to your paper. l 12 Are there any other questions from-.. ; I 1 13 colleagues, before we conclude this afternoon? i l 14 (Ifo response) 15 CH AIRt! Att ZECH:

Hell, let me thank you very 16 much. And I thank you especially for coming to us on 1"

fairly short notice. And I know yon interrupted your own 18 schedules to do that, representing the ACRS, and I am 19 particularly gratef ul f or you all to be here today. 70 It is a very important responsible de-cision.tha t i i 21 is before the Cominion. 'It involves public health and 22 s a f e. ty. We take v"ry seriously those responsibilities, as 23 you know. U r-do rely, to a great degree, on the Adviscri 24 Comrittee on Reactor Safeguards. We have great respect 25 for your opinions, your conclusions, your engineering (202)?34-4433 IIEAL R. GROSS & cot!P AliY, IIIC. (202)232-660 1323 PHODE ISL AtID, AVEUUE, it U., U A SHIT!GTON, D.C. 20005

5 l .l' -6 a l} h 30 1 1 judgments. And.wa know they are judgments, but the staf f { l -J t- " - 2 has made a judgment, you have made a judguent, now'the l 4 - i 3 Conn:i s s io n will have to make a judgment. And. we are 4 trying to make the best one that we can, of course. 5 So I appreciate very much -- l l 6 COMMISSIOtiER CARR: Mr. Chairman -- t 7 CHAIRMAli ZECH: Yes. I 3 COMMISSIOffER CARR: I think the ACRS and the ) 1 l 9 staff both agree that we are not fixing something, it may

2. 0 be an improvement to something that is already adequate, l

l l 11 is that not correct? I l 12 DR. REMICK: I am not sure 'I caught the last l r- - 13 words.

1. 4 COMMISSIO!IER CAFR:

What's out there is safe 15 enough now, that we don't have to fix something. 16 DR. REMICK: We certainly agree with tha staff, i 17 that there are not risk outliers, or there is not undu t 1 i 13 risk, that's right. 4 19 CHAIRMAt1 ZECH: And I think the staff made tha. i 20 elear to us, too, but what they have presente.il to os is an i 21 enhancement to safety that they believe can be j u s r. i. f i e d ) a 22 on a cost-beneficial basis, not necessary for a,1equa te j l 1 23 safety. ! think we all agree with that but, still, I a 1 i 24 think it is responsible for the Commission to involva 25 incolf in enhancements as well as adequacy, and that's - 1 1 1 (202)234-4433 tiEAL R. GROSS & COMP AITY, It!C. (200)232-660. 132 3 RMCCE ISLAtID AVEtitiE, ii. W., UASHItGTOti, D.C. 20C05 1 .----.-....-.---.___---~A

=t. .s 4 -

v..

1 what we are trying to do in this regard. 2 It is important.to all of us that we really do 3 make a decision - that will enhance safety, and certainly j 4' not detract from it, but I just.want, again, to thank you 5 for'an excellent discussion. 6 The Commission will be taking this important matter up, and reflecting on.what we'have heard from the ~ 1 1 S . staff, as well as what'we have heard from the ACRS, before l t 9 ve de-make a decision, but it is 'important thatlwe havs l l f 10 heard. f rom you today, and I'thank you very. much fer ar l 11 excellent presentation, and for-ths continuing advice.and- ?? counsel from the ACPS. ( 13 ?, n d I'

hope, Dr.

Remick, you' vi'.1 ptss

• h.

1 i 14 Com.rission 's compliments to your colleagues thar hre Nt 1 l l 15 he re. with you today, 104 sincerely appreciat- '. c :. : i l l l 16 efforts, their continuing efforts to give the 20- 'ssior. l 1 l' the best technical, engineering, scientific advice thr-13 can have. 17 e need that, and we arr grateful to the ACES 19 -for their contribution, for the continuing saff operate:ns 20 of our nuclear power plants, ar d the ' other math rs-1.1.a r ?1 ynn get in on in the ACRS, but~we are graceful.to ji. and t i l l. 97 I think we would all appreciate it if you would pass ot.: 1 i l 23 respects to your colleagues. l l 24 DR. REMICis: .I most certainly will' pass it on, i 25 and we appreciate the opportunity te come and discuss the l-l (202)234-4433 IIEAL R. GROS S & COMP Airi, IIIC. (202)232-660 1323 PHCDF ISL AtiD WEtitIE, N. ii., ;7 A SHIUGTCli,. D. C. 20005

.$4-h 33 4 1 r:atter with you today. R l >J I ~ 0 CHAIR 14Ali ZECH : Thank you very much. 1 3 tie stand adjourned. ) 1 4 (Whereupon, at 2:44 p.m., the hearing was t 5 . adjourned.) 6 1 I 7 1 1 8 l l 1 9 10 11 i i 12 l '1 l 13 1

1. 4 l

l 15 16 l 17 13 19 20 l 21 22 23 i 24 1 25 (202)234-4433 IIEAL R. Gross & cc;jp A;r g, ;;7C (202)232-660 1323 P MODF '

• tL Atir Av7;iUE, II. U., 17 A S HIf fGTOi!

D.C. 20005'

y ,; s ? e -l ., 8 33 CERTIFICATE OF TRANSCRIBER. This is to certify that the attached events of a meeting of the United States Nuclear Regulatory Commission entitled:- l TITLE OF MEETING: BRIEFING ON FINAL REPORT ON BWR MARK ~I CONTAINMENT ISSUES PLACE OF MEETING: ROCKVILLE, MARYLAND i l DATE OF MEETING: FEBRUARY 27, 1989 were transcribed by me._I further certify that said transcription is accurate and complete, to the best of my ability, and that the t l transcript is a true and accurate record of the foregoing events. l l ,1 1 1 vb P - _. f/us' 1 Reporter's name: Phyllis Young l l l l l l l 1 8 l l' l l NEAL R. GROSS COURT RERORTERS AND TRANSCRittm$ 1 1323 RHODE IdCANO AYtHUS, N.W. (202) m WASHINGTON, D.C. 20005 (202) 232-6600

MfVWWWWWW6fV9tWW9VfVfVWWWfVW6WhfVfVW69VWh6WNNNddddNNNM) j TRANSMITTAL. TO: Document Control Desk, 016 Phillips f l ADVANCED COPY TO: The Public Document Room 8//e/ Nh DATE: 3 5 FROM: 5ECY Correspondence & Records Branch

I Attached are copies of a Commission meeting transcript and related meeting 1.

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Title:

b N YM 8Abd i 7AaALT Q & Q Meeting Date:

1. /#7/77

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• 8 to POR-Copy j

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1 i : 1 : ( 1 l i l l 2. I : 1: .J : 3 : a : 3. 3 3 : .3: 3 3 :. 4. 3 1

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C&R Branch files the original transcript, with attachments, without.SECY 0pp papers. p g 1 ams $}}