ML20236P838
| ML20236P838 | |
| Person / Time | |
|---|---|
| Issue date: | 08/06/1987 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8708130075 | |
| Download: ML20236P838 (67) | |
Text
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ORIGINAL UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l
Title:
Periodic Meeting with the Advisory Committee on Reactor Safeguards Location: Washington, D. C.
Date: Thursday, August 6, 1987 C
Pages: 1 - 63 Ann Riley & Associates Court Reporters 1625 i Street, N.W., Suite 921
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Washington, D.C. 20006 (202) 293-3950 kD PT9.7
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5 l 6 This is an unofficial transcript of a meeting of the
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d 7 United States Nuclear Regulatory Commission held on
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8 8/06/87 .. In the Commission's office at 1717 H Street, 9 'N.W., Washington, D.C. The meeting was open to public 10 attendance and observation. This transcript has not been 11 reviewed, corrected, or edited, and it may contain
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[ 12 inaccuracies.
13 ,
The transcript is intended solely for general 14 informational purposes. As provided by 10 CFR 9.10S, 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 10 pleading or other paper may be filed with the Ccenission in 19 any proceeding as the result of or addressed to any statement.
20 or argument cont a i r.ed herein, except as the Commission may 21 authorize. s 20 f 23 24 25
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1 i
UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3' ---
4 PERIODIC MEETING WITH THE ADVISORY COMMITTEE 5
ON REACTOR SAFEGUARDS 6 .__
7 Public Meeting 8 ---
9 Nuclear Regulatory Commission 10 '
Room 1130 11 l
'1717 H' Street, N.'W.
12 ,
Washington, D.C.
71 '13-
. N.2.-
14' THURSDAY, AUGUST 6, 1987 15 16 The Commission met in open session, pursuant to 17 notice, at 2:02 p.m., the Honorable LANDO W. ZECH, Chairman of 18 the Commission, presiding.
i 19 }
20 COMMISSIONERS PRESENT:
21 LANDO W.
ZECH, JR., Chairman of the Commission i 22 THOMAS M. ROBERTS, Member 23 FREDERICK M. BERNTHAL, Member 24 'KENNETH M. CARR, Member
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- i. iT o' 2
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. j, NRC STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:
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' _( 2-3 W. Parler
/
-J. Guttman 4 W._Kerr F.'Remick 5 H. Lewis D. Ward
, 6 D.'Moeller D. Okrent 7 M. Steindler C. Seias 8 J. Ebersole 'C. Michelson 9 c. Mark C. Wylie 10 G. Reed 11 12 C' 14 15 16 17 18 19 20 21 22 23 24 ,
25
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,; P' R O C E E II I N G S -
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N 2 CHAIRMAN ZECH: Good afternoon, ladies and gentlemen.
3-This afternoon'theLCommission will' meet with the Advisory 4 Committee on Reactor Safeguards to discuss the committee's 5 comment on three subject areas. Before'I. mention those subject 6
. areas.I would like to compliment the Advisory Committee'on a 7 number of the recent papers they've'sent us, which as far as
- 8. I'm concerned are every valuable, very helpful. And I just 9 believe'that that is exactly the kind of support this
.10 Commission needs. I really do believe that those papers will 11 certainly contribute to our ability to make better-positions.
12 They're thoughtful papers and I'm very grateful to the 13 committee for that kind of strong support.
14 This afternoon, we're going to discuss the 15 Implementation Plan of the NRC's Safety Goal Policy, draft 16 NUREG-1150 on Reactor Risk Reference Document, and the 17 Integrated Safety Assessment Program. All three of these 18 subjects are of considerable interest to the Commission and we 19 value the comments of the ACRS on these matters.
20 I have recommended as regards the Safety Goal that 21 the Commission endorse the committee's recommendations on this 22 subject.
My fellow Commissioners I know are considering that 23 recommendation now. We've got a let of material to cover this 24 afternoon on thsae three important subjects. I hope we can 25 finish on time.
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4
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Do any of my fellow Commissioners have any opening 2 remarks to make?
3 COMMISSIONER BERNTHAL: I just want to make a very 4
short remark that whether or not all of the members of the ACRS 5
managed to get on because it was on short-notice, I sent down a 6
short meno suggesting -- I can't even find it now -- suggesting 7
that they might also discuss today any views they hold at this 8
time on capability of Mark-I containments to withstand severe 9 core melt accidents. That really wasn't the reason I wanted to 10 make a comment.
11 This is probably the most illiterate memorandum I 12 have aver sent out and I want to apologize for at least two
'~ 13 errors in it. I'll try and do better next time.
14 MR. LEWIS: What makes you think we would find them.
15 (Laughter.)
16 CHAIRMAN ZECH: Are there any other comments from my 17 fellow Commissioners?
18 (No response.)
19 If not, Dr. Kerr, will you begin, please?
} 20 MR. KERR: Thank you, Mr. Chairman. I appreciate 21 your comments and I shall ignore Mr. Lewis' reply.
22 (Laughter.]
23 I do want to take note of the fact that Dr. Martin 24 Steindler has joined the committee --
k 25 CHAIRMAN ZECH: We welcome you, sir.
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'l MR. KERR: And we're delighted to have him join the
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2 group.
3- CHAIRMAN ZECH: We're delighted to have him, too.
4 Thank you very much.
i 5 MR. KERR: The first item on the agenda that you've 6
mentioned, the letter we wrote on the implementation of safety 7
goals, I've asked Mr. Ward to take the leadership in beginning 8 the discussion of that.
9 MR. WARD: Thank you, Dr. Kerr. The subject was 10 discussed in our letter to you of May 13th of this year, and we
- 11. worked for -- you know, we've had a particular interest in the 12 safety. goal all along of course and its development, and we've
{ 13 been very interested in how it's going to be used. So this 14 letter represents really several months of work on our part, 15 and I think there is pretty strong -- with a couple of 16 exceptions -- on some aspects, a pretty strong committee 17 consensus behind it.
18 I know you've all had a chance, or most of you have 19 probably already read the letter, but I will take just a few 20 minutes to summarize what we said, and then try to leave most 21 of the time for an interchange over any of the ideas that you'd 22 like to discuss in it.
23 First of all, we recommend that a proposed plan for 24 implementation of the Safety Goal Policy should consist of
\- 25 three elements. First, we think the policy should be used to i
6 1
, judge the adequacy of regulations, of the body of regulations 2
and their effectiveness, rather than be used to make judgments 3
about the adequacy of particular plants or particular plant 4 designs.
And I'll talk a little bit about cach of these as we !
5 go along.
6 Second, we recommend that an explicit hierarchical 7
structure among the several criteria embodied in the goal, 8
either formally or suggested, be recognized.
9 And third, we think that there should be a continuing 10 program of risk assessment of particular plants really as a '
11 sampling process to help determine whether indeed the existing 12 body of regulations are doing the job that you want them to do, 13 and to assure that we have plants that meet the safety goal.
14 First of all, we disagreed with our interpretation at 15 least of the staff's proposal for implementation in which the 16 goal was going to be used~to assess individual plants and make 17 judgments about whether improvements, specific improvements, 18 should be made to individual plants. And I think basically, 19 our problem with that approach is that the Safety Goal and PRA 20 is a good tool but it's a coarse tool in that it really becomes 21 very difficult to finally differentiate decisions about 22 individual plants based on just sinply the quantities that come 23 out of a PRA because of the large uncertainties associated with 24 those quantities.
25 We think that instead of the -- if the goal is used
i .
7 1 in more general terms to. judge the adequacy of the body of 2 regulations, that -- it really is just one of the things used 3 to judge the body of regulations -- that human judgment can be 4 inserted and the problems with the uncertainties in the 5 quantifications can be dealt with in that way.
6 So far as a hierarchical structure, I guess we didn't 7 invent the hierarchy or we didn't invent all the elements of 8
the hierarchy, but given the several elements of the Safety l
9 Goal Policy, we believe that they should be used in a logically 10 inter-related way. And we suggest then this five-l'evel 1
11 hierarchy where we think that the highest level really serves 12 as the Commission's, as your statement of intent to the public 13
(~ and to the Congress on what you mean by safety regulation of 14 nuclear power plants. You're saying to the public and to the 15 l
l congress that this is how safe we intend to make the plants 16 through our regulations, and we're expressing that as best we 17 can at the present time with the technology we have available 18 through this highest level of the safety goal.
19 1
Well, because the highest level of the safety goal is 20 what we often call kind of a " motherhood" statement -- that l
21 doesn't mean it's empty of content but it is a very general 22 statement -- it's not really very useful to -- it's not 23 directly useful to the people who have to make, direct active 24 regulatory decisions. So there needs to be, as we see it, some (s '
25 sort of a supporting structure underneath that, and where each
"i' ,
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, 1 ,_, 1 lower level of the hierarchy would be consistent.with the level 2
of above, but would become a quantification or a more objective 3 statement, a more nearly measurable statement that could be 4 used in a more practical way.
5 Now,-we've particularly emphasized, however, that we 6
don't think there should be added conservatism as you go down 7 each level. We think there needs to be enough conservatism to 8
accommodate the simplification that's being made as you go from 9
the general statement to'something more specific, but nothing 10 more than that.
11 COMMISSIONER BERNTHAL: If I may, since we're 12 discussing this at some length already, that is precisely the 13 point at which I don't understand exactly the memorandum, 14 because on the one hand you say that the lower levels in the ;
i 15 hierarchy should not be used as a surrogate, and more 16 importantly as you've just said, should not in-fact be more 17 stringent requirements than those above them. Those 18 qualitative safety goals of the Commission's -- we can all pack 19- up and go home if that's the end of the safety goal because 20 it's clear that by any reasonable analysis today, nuclear 21' electricity generation is the safest method of generating 22 electricity. There may be disagreement on that from those who 23 haven't looked carefully at the numbers and there may be a 24-
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broad public perception that that is not the case, but in fact,
\ 25 if you really add it all up I believe that it's easily
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1 demonstrated..
2 And therefore, a goal that is so easily' met -- none 3 of the other criteria would meet.that requirement; that the 4
lower. levels.in the hierarchy not be more stringant than the-5' qualitative goals that the Commission has set. So' I'm really 6 confused by that aspect of the memorandum. Maybe I'm 7 misunderstanding something that you can explain to me. That's 8
why-I called, by the way, and wanted to chat with you.
9 MR. WARD: Okay. Well, I think first of all, we do 10 think that each lower level is a surrogate for the level above 11 it.
12 COMMISSIONER BERNTHAL: But you're saying not to be 13 more stringent, and in fact they'are clearly more stringent
.13 requirements.
15 MR. KERR: Excuse me. When we said not more 16 stringent,werewethlkingaboutthequalitativegoalsorthe 17 quantitative guideline,s? You're talking about the qualitative-18 goals.
19 COMMISSIONER BERNTHAL: Well, but I'm looking at the 20 hierarchy. Level One is -- this is the pair of qualitative 21 goals which basically starts out Level One saying that nuclear 22 . power should be no more hazardous than other methods of 23 electricity generation, and Lord knows it's less hazardous, 24 easily, than coal generation. By any reasonable calculation.
25 MR. WARD: Well, there is dispute about that. But
10
- 1-when you cg> on then to say in your Safety Goal what y6u mean by 2 that, you define what you mean by that as the pair of 3
quantitative health objectives, the two 10 percunt number. l 4 COMMISSIONER BERNTHAL: That's right, which are also 5 quite easily met, by the way.
6 MR. WARD: Well, --
7 COMMISSIONER BERNTHAL: It seems to me, at least.
8 MR. WARD: I think there are uncertainties involved, 9
and that is much of what the debate is about; how well they are 10 met. I guess I might argue or take some issue with the fact 11 that they are very easily met.
12 But I agree, most of the evidence is that the 13 population of plants today generally meets the safety goal, and 14 that's your intent of regulation. You've been successful.
15 COMMISSIONER BERNTHAL: But then this remainder, the 16 very important elements it seems to me -- and it's clear that 17 ACRS considers these very important elements -- I don't want to 18 say that they wouldn't be taken seriously, but they would fade 19 into insignificance if we literally interpreted the hierarchy 20 in the way that the ACRS seems to suggest in their memorandum, 21 because the core melt criterion, the containment criterion and 22 then finally the Commission's 10 to the minus 6 criterion which 23 is, almost without doubt, the most stringent criterion of all, 24 we would in effect be saying that we shouldn't use those A 25 because they are more stringent than those higher in the t
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11 f l' ranking. And I don't think that's what you meant to say.
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l 2 .That's why I'm a little confused.
I 3 MR. WARD: No, we.aren't disagreeing with the use of (
4' i those numbers, but we're saying -- you know, what I'm saying is !
4 5
-that your guideline of.10 to the minus 6th for a large release l 4
6 provides you assurance that you're going to meet the two 7 quantitative. health objectives.
8 COMMISSIONER BERNTHAL: I agree, but by a substantial 9 margin, I would say.
10 i MR. WARD: I really think it's a difference of 11 opinion how substantial that margin is.
12 I think the point we tried to make in the letter is 13 we don't think that margin should be any greater than is 14 necessary to accommodate the uncertainty involved with 15' simplifying in going from one level to the other; that you 16 don't want to introduce, in effect, a new safety goal policy
-17 with the lower levels of the hierarchy.
18 MR. KERR: Also, it depends, it seems to me, on how f 19 you define a large release, and this has not yet been done 20 carefully.
21 COMMISSIONER BERNTHAL: Does, of course, yes, I 22 agree.
But even if we define it rather liberally, -- itts been 1 l
23 suggested for example that we use one early fatality which 24 means that Chernobyl would not qualify. I don't think we 25 intend to do that.
. , i.
12 1
But even if you define it rather liberally, I still l I
2 don't dispute the underlying' rationale -- and if the_ rationale 3
is that as a matter of fact, it's time we got a level playing 4
field,'that nuclear hazards should be considered in the same 5' domain as all other' risks that society endures, you know, we're l 1
6 all preaching to the choir, I think. l But I simply don't 7
believe that that is the standard by which this country is !
8 going to judge nuclear power. And I think if that's all we 9
require, the technology is unlikely to survive, quite frankly, '
10 MR. WARD: Well then you made the wrong statement in 11 your top level safety goal.
12 COMMISSIONER BERNTHAL: But the difference I think ,
13
{' was that the 10 to the minus 6th was a provisional safety goal, 14 and however you interpret the -- that was provisional --
15 however you interpret what was, in fact, stated as part of the 16 safety goal, that there should be reasonable assurance that a 17 core melt accident will not occur at a U.S. nuclear power 18 plant, a reasonable interpretation of that is pretty 19 quantitative stuff.
And that is a fairly stringent safety goal 20 that I would argue is at least in the neighborhood of an order 21 of magnitude more stringent by most reckoning, certainly, when ,
22 comparing with other methods of power generation.
And probably 23 as compared with the loth of a percent goals, although I agree ;
24 that's probably a more stringent criterion than the first.
A 25 So what I'm saying is that I think the commission, by
13 1 intent, set a fairly high quantitative standard when it said 2 reasonable assurance that there will not be a core melt !
3 accident, and I think in so doing correctly reads the mind of 4 the public in this country. And for us now to -- what would be 5 in effect -- retreat from that requirement I think is a 6 mistake, and I know that's not what you mean for us to do.
7 But that's why I'm troubled by these statements that 8 were associated with the so-called hierarchical structure, 9 because I think that 10 to the minus 6, provisional though it 10 may have been, was viewed as perhaps the benchmark that we ___
11 should be striving for here, and as a matter of fact, depending 12 on how you interpret large release, that is the benchmark that 13 Sizewell and -- they didn't make it but at least they intended 14 to achieve, as I recall. Where are they, 10 to the minus 5 for 15 core melt or something like that.
16 So that's what my problem is with the hierarchy as 17 you've laid it out. Now maybe I'm missing something; I'm sure 18 I am.
19 MR. LEWIS: May I say just a couple words? Three 20 t'hings. One is I think that there is a disconnect here because 21 the first safety goal of the Commission is labeled the 22 qualitative goal but is stated in quantitative terms.
23 COMMISSIONER BERNTHAL: That's right.
24 MR. LEWIS: And so that's a disconnect, and your
- 25 preblem with transferring that down to two is based on j - _ _ _ _ _ _ _ - - _ - -
i 14
,, ' 1 interpreting the qualitative goal as a quantitative goal, and I I
k 2 think probably the commission never meant that. )
3 As you know, I've never been in real sympathy with 4 that anyway.
5 COMMISSIONER BERNTHAL:
1 As you know, neither am I.
6 MR. LEWIS: Okay. Second point is I would have been 7
happy if you'd just used the 10 to the minus 6 and forgot the i
(
8 rest, because I agree with you that it's a reasonably stringent 1
9 goal and it's a practical one for nuclear power. s 10 l But I think the main point of the hierarchical 1 11 structure that we're not mentioning now is we were trying to 12 find a way to put together these various disparate statements 13
( that the commission has made out its safety goals in some kind 14 of logical structure instead of simply having different people 15 do different things.
And as Dave has said, and not make policy 16 at the very, very lowest levels of interpretation. And there 17 are reasonable differences among people about how these various 18 goals translate into each other.
19 So I guess I'm not uncomfortable with the fact that 20 they don't entirely hang together because I don't think any of 21 them are that quantitatively meaningful anyway, and the point 22 is to find a way in which, as you now know more than you did 23 last week, you really have to decide what is undue risk to the 24 public, and that'r what this has all been about all this time.
25 So I'm not as uncomfortable as you are, Fred.
15 1
COMMISSIONER BERNTHAL: .Well, okay,-but you would .
2 agreeI that there'is~a disconnect of some proportion.--
3 'MR. LEWIS: Oh, yes.
4
. COMMISSIONER BERNTHAL:- - .in the quantitative 5 interpretation of those so-called qualitative goals, which in 6
fact have very quantitative implications, whether one wants to 7
write them down as numbers or not, and this 10 to-the minus 6, I
8 which is a fairly stringent goal. But I think one not 9
unreasonable to try and achieve in the longer term.
10 So what concerns me is that it'seens like there's a 11 contradiction between saying.that those bottom elements of the 12 hierarchy should not. serve as a safety goal in and of 13 themselves, and at the same time, sort of say that well, staff 14 should use these in the regulatory process. It seems like :
15 those are self-contradictory.
16 MR. KERR: Mr. Seiss? ;
17 MR. SEISS: I think we've perhaps been wrong in 18 ordering the safety goals into a hierarchy, and I guess my (
'19 l question is will the real safety goal please stand up. f 20- COMMISSIONER BERNTHAL: That's kind of mine, too. I 21 think you've summarized it.
22 MR. SEISS: And I think we took them sort of in a l 23 chronological order and they're still coming. But if you l
24 really think that reasonable assurance of no core melt accident
\- 25 or severe core damage accident in our lifetime, your lifetime -
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- some. difference -- is~the safety. goal, it's'a different point
'2 to start from.
3 ' COMMISSIONER BERNTHAL: Well, it's mathematically' 4' indeterminate, but I think we can all understand-what we mean.
5 MR. SEISS:- We can spend'the next'few months trying 6 to agree on a mathematical definition.
'7 COMMISSIONER BERNTHAL: But reasonable assurance of !
8~
no core melt in our lifetime means to me that you clearly have 9 to have a good margin on 10 to the minus 4; I think t'lat's a 10 reasonable interpretation.
11 MR. LEWIS: But it doesn't say "in our lifetime" in 12 your goal'. It doesn't say that at all.
(' 13 COMMISSIONER BERNTHAL: No, but -- okay, but. lifetime 14 of the plants.
15 MR. LEWIS: It doesn't say that either. It says 16 reasonable assurance of no core melt,-period. And that's one 17 thing I can guarantee you can't have.
18
' COMMISSIONER BERNTHAL:' I know.
19 MR. REMICK: I think that's the big disconnect that 20 you have.
That was inserted and I'm not sure that's consistent 21 with what the Commission said is the qualitative goal, the 22 quantitative objectives. There's a slight disconnect to the 10 23 to the minus 6 but I don't think great; I think it's generally 24 consistent with the quantitative objectives. But the
{- 25 disconnect is to say no core melt, period. That is a major i
17 1 disconnect that the Commission generated, and I don't think --
2 I could be wrong -- that that's the general interpretation of 3 what the rafety goal means.
4 COMMISSIONER BERNTHAL: Well, that --
5 MR. REMICK: If so, the Commission didn't make that 6 fully clear.
7 COMMISSIONER BERNTHAL: I couldn't agree with you 8 more that that is an indeterminate statement, so what one has 9 to do is carry forth with a little bit of Talmudic 10 interpretation, I guess, and try and figure out what a l
11 l reasonable interpretation is, and the reasonable interpretation 12 l
l it would seem to me is that the average person shouldnt expect
'" 13 i N. to experience a core melt in his lifetime, perhaps.
14 MR. WARD: And express that as a number?
15 COMMISSIONER BERNTHAL: Well, as I say, you've got to 16 do something with something that is indeterminate because 17 that's what is in our safety goal.
18 MR. SEISS:
i The other question is where does it go in I
19 the hierarchy; down at the third level where we put it, or 20 would you put it back up ar, the safety goal?
21 COMMISSIONER BERNTHAL: I would ignore it, frankly, 22 as an anomaly and focus on 10 to the minus 6, which I think is 23 something that everyone can understand.
24 MR. SEISS: Ten to the minus 6 on no large release.
25 COMMISSIONER BERNTHAL: That's right, once we
18 1 determine what large release means.
2 MR. SEISS: Now that's a different creature than the 3
severe core damage because it brings in another whole element 4 o# the plant, the containment.
5 COMMISSIONER BERNTHAL: True.
6 MR. SEISS: It's more of a bottom line. So now I'm 7 even more confused. Should we look at the 10 to the minus 6 8
which requires you to look at containment, look at mitigation; 9
should we concentrate on the other one which mainly is 10 prevention.
11 CHAIRMAN ZECH: Well, I think the sense of -- the 12 majority of the Commission felt that what we're really talking 13 about is harm to the public. What we're really talking about 14 is radiation release, and that's what the safety goal is 15 supposed to address, and I think it did.
16 MR. SEISS: Now if I accept that, do I look at the 10 17 to the minus 6 on a large release or do I look at one-tenth of 18 one percent of other things? Or do I make the definition of a 19 large release consistent with that first quantitative goal?
l 20 COMMISSIONER BERNTHAL: Well, Chet, you have stated l
21 my reservation here better than I did in a single comment, will 22 the real safety goal please stand up. I think that's a fair
?3 characterization.
24 Now, the Commission did not -- I suspect in part
\' 25 because of the uncertainty about what large release means --
19 1 the Commission did not say other than that this was a 2 provisional safety goal. But I felt and I still feel that in 3
and of itself, 10 to the minus 6 for a large release is a very 4
worthwhile safety goal to attempt to achieve, and I entirely 5 agree with the ACRS in focusing on 10 to the minus 4 for core 6
melt on the average, at least a factor of 10 mitigation by 7 containment on the average. And so we all end up at sort of 8
more or less the same point I think, but I'm concerned that 9 this may all come tumbling down if we argue that what are lo clearly less stringent criteria should be viewed.as the 11 predominant safety goals in the upper levels of that hierarchy.
12 MR. KERR: I think what our message tried to be, at 13
( least I would interpret it, is that the safety goal should be 14 something that is set, and it should not be abrogated by a 15 lower level of hierarchy. One should not introduce sufficient 16 conservatism so that whatever one picks actually becomes the 17 real safety goal rather than the original safety goal.
18 CHAIRMAN ZECH: I agree with that.
19 MR. KERR: I think that was what we were trying to ao say.
l 21 CHAIRMAN ZECH: That's what you said and I think it 1 22 makes sense. That's what a goal is, and then try to be 23 supportive. But you have to keep focusing on the goal, and I 24 think it did do that.
,' 25 COMMISSIONER BERNTHAL: But you can't abrogate in the
20 1 normal interpretation with something that is more stringent.
/
2 It seems to me --
3 MR. KERR: Oh, sure you can.
4 MR. WARD: Sure you can because the --
5 COMMISSIONER BERNTHAL: I guess you can.
6 MR. WARD: A goal is approached from two sides.
7 COMMISSIONER BERNTHAL: Well, agreed. Technically 8
you can abrogate by saying that you are going to adopt 9 something more stringent. But normally when I abrogate I say 10 that I'm going to adopt something less stringent.
11 MR. WARD: You know, I think we interpreted the 12 several elements of the goal, or we suggest you interpret it, 13 in this way. You have set the highest level goal, the pair of 14 qualitative statements, and then you're saying what we mean by 15
-- you turned to the staff then and you say -- what we mean by 16 that is the two quantitative health effects.
17 MR, SEISS: But by highest level you don't mean most 18 stringent, do you? You're talking about abstract level.
19 MR. WARD: Level of abstraction. We're talking about 20 levels of abstraction.
21 l
COMMISSIONER BERNTHAL: And what we mean by the l
22 health effects is --
23 MR. WARD: What we mean by that is 10 to the minus 24 6.
25 COMMISSIONER BERNTHAL: Core melt containment?
21 1 MR. WARD: And then what we mean by that is that i
2 level four, and level four does something else; it introduces i 3 the concept of defense-in-depth. That you're telling the staff 4 10 to the minus 6 isn't good enough, if you put that all in the 5 prevention basket, let's say. You're insisting on a ~
6 distribution between, in simplest terms, prevention and 7 mitigation.
8 COMMISSIONER BERNTHAL: Okay. I entirely can buy and 9 understand what you're saying if in fact you mean that what we 10 mean by Level One is loth of a percent; what we mean by loth of 11 a percent is this core melt, this containment criterion; what 12 we mean by that is 10 to the minus 6 large release, however we 13 may choose to define it.
14 MR. LEWIS: I thought that's what we said.
15 MR. WARD: That's what we tried to say.
16 COMMISSIONER BERNTHAL: Well, that is not at all 17 clear I think from --
3 CHAIRMAN ZECH: That's what I thought you said, too, ,
19 and I thought it was reasonable clear. About as clear as you 20 could make it.
21 COMMISSIONER BERNTHAL: Would you care for me to read 22 some quotations?
23 MR. SEISS: If it were all that clear we wouldn't 24 have to have these meetings.
25 COMMISSIONER BERNTHAL: Well, that's right.
22 1 MR. WARD: We got that far. Let me go on to the so-P 2
called Level Four where I'm talking about defense-in-depth.
3 MR. KERR: May I let Hal interject.
4 MR. LEWIS: He's being nice to me because I have my 5 hand up.
6 MR. KERR: And Mr. Moeller comes next.
7 MR. LEWIS: Just let me say one or two things about 8 the 10 to the minus 6. As you know, I was an advocate of using 9 the 10 to the minus 6 and scrapping all the rest because I 10 think that it's a definable gdal even though we don't know what l 11 a large release is, and we get away from an awful lot of these 12 logical conundra, if that's the plural for conundrum, if we l
13 were to stick to it. But nonetheless, we now have this entire 1
['^
%.l 14 structure.
15 And something Lando said earlier is relevant here 16 because these numbers are numbers which are both goals that 17 determine the way in which -- we hope -- the way in which you 18 write your deterministic regulatory requirements, but they are 19 also statements to the public. And in my experience, 10 to the 20 minus 6 is identical with zero to nearly all members of the 21 public and to a lot of the people around the Nuclear Regulatory 22 Commission, too. Because people tend not to distinguish 23 between -- you know, who knows the difference between 10 to the 24 minus 6 and 10 to the minus 7, as a matter of practical 25 everyday life. They really don't.
23 1 And so I can give you a list of other things in which 2 people have used 10 to the minus 6 as a safety standard in 3
military affairs, in which really there's no analysis, they 4
think it's a way of saying zero without getting caught for 5 saying zero. And the right way to find out whether these c 6
numbers make any sense, of course, is to ask yourself if you 7 were an insurer, at what level would you write an insurance B policy. And I'm sure you all know the story, which I won't 9
tell you, in which Lloyd's of London insured Cutty Sark against 10 the capture of the Lochness monster in the year 1971, and how 11 they calculated the premium for that coverage. It's an 12 interesting story, 13 But if you look at the recent battle on Price 14 Anderson, and if you take your 10 to the minus 6 seriously and 15 really mean 10 to the.minus 6 and not zero, and take the cost 16 l
of an accident at, say, $10 billion, you name it, and multiply 17 that by 10 to the minus 6 you're talking about an assessment of 1B
$10,000 per year per reactor, which is Diet Coke money, or 19 something like that.
20 So I conclude from going through that arithmetic that 31 nobody really means 10 to the minus 6 when they say 10 to the 22 minus 6, and I think that's a dilemma that you're really 23 dealing with. People, depending on their biases, think of it 24 as either zero or much too large, and nobody does the
,t fk. 25 arithmetic associated with it. And a useful thing for the
4 8 84 1 Commission to do would be to be quantitative about these 2 things, and in fact, that $10,000 number could have been used 3 during the Price Anderson debate. There are people who 4 understand insurance even if they don't understand the 5 probability of 10 to the minus 6.
6 COMMISSIONER BERNTHAL: Let me just read the source 7 of the confusion and maybe that's enough said. I'm reading 8 from your memorandum. "Each subordinate level of the hierarchy 9
should be consistent with the level above but should be a more 10 practical surrogate, representing a simplification or 11 quantification of the previous level. Each surrogate should 12 not be so conservative that it creates a de facto new policy."
13 And then down below I think a fair example you say, 14 in talking about the question of 5 or 25 R at the plant 15 boundary, the latter of which by the way is the one that EPRI 16 has chosen to attempt to meet, "A definition of a large release 17 as one that will lead to a whole body dose of 5 or 25 R to an 18 individual at a plant boundary, as has been given some public 19 mention, does not satisfy this criterion. Such a definition is 20 so much more restrictive than the Level One and Two goals that 21 it, in effect, establishes an alternative policy rather than 22 serving as a more easily applied surrogate."
23 And my problem is that I would say that 10 to the 34 minus 6 does precisely the same thing because it is clearly, I 25 think by any reasonable measure, a more stringent policy. That
) __ ____ _ _____-___-____ - - __ -
25 1 really was the difficulty and that's why it seemed to me --
2 CHAlRMAN ZECH: Do you all agree with that?
3 MR. WARD: No.
4 MR. KERR: No. We did not say that it shouldn't be 5 more stringent; we said it should not be so much more stringent 6 that it, in effect, becomes the safety goal itself and 7 completely ignores the other two. One may have had to add some 8 addiuional stringency because of uncertainties or something 9 like that. So I don't think we meant they should all be 10 exactly quantitatively equal.
11 MR. SEISS: But the limit imposed by what you call 10 12 to the minus 6 can vary by two or three orders of magnitude
~
13 depending on~what you define as a large release.
14 COMMISSIONER BERNTHAL: I agree, I agree.
i 15 MR. SEISS: So the 10 to the minus 6 isn't enought 10 16 to the minus 6 with one fatality or one rem or 1000 rem?
17 COMMISSIONER BERNTHAL: Well, there is that big l 18 loophole, I agree, but certainly if we define it as one instant 19 fatality and Chernobyl does not qualify, then you're clearly in I
20 the name ballpark. But I don't believe that we really want to al do that.
22 MR. SEISS: I would be happy to work with 10 to the 23 minus 6 on a large release and try to define a large release to 24 satisfy public perception of a danger.
25 MR. KERR: If you use the release at Chernobyl and
26 1 use the CRAC code we could get zero fatalities.
3 2 ' COMMISSIONER BERNTHAL: I don't know. I would guess
- 3. you probably.would not.
)
But I don't know.
)
.4 MR. KERR: It seems to me it's not altogether -- '
1 5 unless we know the answer to that because we're talking about a )
'6 modeling which would make use of something like the CRTM code.
a 7 COMMISSIONER BERNTHAL: Okay, well, let's go on. j 8
qq CHAIRMAN ZECH: Yes, let's proceed if we-may.
$b MR. KERR: Did Mr. Moeller 'get his?
10 MR. MOELIZR: If I could just;' add a quick remark L
11 referring to Commissioner.Bernthal's earlier statement. XI 12 -found myself somewhat confused where you stated, or as I heard' og a 13
(~ you say it, that the qualitative goal was that nuclear power 14 should be safer than the other methods --
15 COMMISSIONER BERNTHAL: No. Equal safety, comparable 11 6 safety.
M17 MR. MOELLER: Oh, comparable I guess I had 4
18 interpreted it that if you adopted the ualitative safety-19 goals, the pair of qualitative safety goals, then that would 20 come about. Not that that was the goal which led to the 21 qualitative safety goals.
- 22 COMMISSIONER BERNTHAL: Wel2, the commission's 23 qualitative safety gor 5, one of them'was that societal risk to t
24 life and health from nuclear power 7 plant operation should be {
(
^- 25 comparable to or less than the risks of generating electricity Y \
27 1
by viable competing. technologies, and that's really what I was
\' '2 referring to.
3 MR. WARD: Well, we've talked about Level Four of the 4 hierarchy and I said this is where we talk about sort of I 5
dividing up this 10 to the minus 6 number in a way that assures 6 what we usually call defense-in-depth. So it isn't 7
mathematically done quite this way, but in essence what we're 8 trying to say is okay, part of tihat should be devoted to 9
mitigation or to prevention; that is, preventing a core melt-10 accident from ever occurring. Part of it should be devoted to 11- mitigation so that the public is protected if one core melt
'12 accident does occur.
13 But then we threw in'a sleeper here which we need to 14 -call to your attention. We say the third performance 15 objective, which we're sort of arbitrarily putting in parallel 16 with these other two, would be an expression of how well the 17 plant is operating. Now, I don't know that it really logically 18 fits right there, but you've got to get this concept in 19 somewhere if the safety goal is really going to be something by
'20 which you assess the operation of plants.
21-'
Because PRA is primarily a tool for looking at the 22 design of plants.
And I know there are some operational things 23 that are kind of ground into it, but it's essentially looking ]
{
24
-g at a line diagram of a plant and making an analysis.
A 25 So somewhere we have to get some sort of an i
l
28
- 1. operational guideline in there if the safety goal is going to 2 be comprehensive and really cover what you intended to cover.
3 We don't know how to do that; I don't think you know how to do 4 it yet. So this recommendation we made implies that there j 5 l should be a significant effort'within the staff to figure out l 6 how to do something in this' area. Certainly your performance 7 indicator program is something in that direction. 4 8
I don't think the committee is saying that we really 9
expect you to have some sort cf a logic diagram that.can be put 10 up on the wall and some number-is going to be clicked in here 11 at this point. We really added this in the letter and in our 12 discussion to make sure that you recognize that that point i 13
\.
can't be overlooked, that it's essential to have a safety goal 14 which is concerned with the operation of plants and not just 15 with how they're designed.
16 CHAIRMAN ZECH: I thought that was a very important 17 point.
I don't know that we've discussed it very much.
18 Perhaps it has come up over the years as the safety goal was i 19 reviewed and designed by so many people, but I hadn't heard 20 that emphasis. I think you're absolutely right that when we 21 think of most of these things we do think of design, and that's ;
22 appropriate of course.
i But I do think the opportunity to do 23 something to contribute to safe operations should be factored 24 t'
in. I don't know exactly how to do that either, but I think
\- 25 your bringing it up is extremely important, and I do think it
/ 29 1-merits some kind of consideration because it's certainly an
\ 2' important fact in safe operations, overall safety.
3 COMMISSIONER BERNTHAL: I agree,'and I in fact had 4
drafted a numbs.r of comments here which I don't haive out yet, 5-partly because I didn't understand the hierarchy business.
6 MR. WARD: And now you do, right?
7 [ Laughter.]
8 COMMISSIONER BERNTHAL:- No, I still don't understand 9
it, but it doesn't matter that much because as you well know, 10 the 10 to the minus 4 and 10 times mitigation effect is 11 something that I urged a year ago and we have yet to adopt. So 12 on all cf the substance I'm entirely in agreement with you;
~
13 just the way it was expressed was a bit difficult to 14 understand.
15 On the point, though, of operations, would you 16 suggest that something like keeping track of perhaps folding in 17 statistically if it could be done, percentage of time that 18 i safety systems are inoperable or statistics like that be taken 19 into account? I mean, I enti sly agree it would be nice to get 20 this stuff in but I'll be darned if I know how to do it.
21 MR. SEISS: Some of that is factored into PRA now.
22 COMMISSIONER CARR: Well, if you want to put
'23 Chernobyl in it all you have to do is count the things that 24 override the safety systems and that would have fallen out.
25 COMMISSIONER BERNTHAL: We know they did it once.
l 30 1 MR. KERR:
We have talked about this a lot and I 2 don't think we know how to do it.
3 CHAIRMAN ZECH: I would think it has come up. It's 4
very difficult, but it's important to bring it up.
5 MR. KERR: I think Mr. Okrent had something.
6 MR. OKRENT: Well, the point I want to make is 7 related to this prior discussion. I wanted to call attention
.8 to the fact that the single thing that the ACRS highlighted as 9
an implication of Chernobyl was the need for very capable, very 10 knowledgeable management. So it's not supervisor, shift 11 supervisor and below that we're talking about but starti,ng at 12 the top and getting down to the plant operating staff. And if 13 you look at the letter it talks about the people in the L
14 engineering staff understanding their plant, including where 15 precipices are and so forth.
16 Unfortunately, the NRC Staff didn't seem to emphasize 17 that point in what they wrote, nor does it appear in this 18 latest SECY from Stello to the Commissioners dated July 28th 19 talking about the CSNI Chernobyl report, where again the 20 importance of what I'll call the -- not only the management 21 dedication to safety but that there be the knowledge in the 22 plant operating staff and so forth, and the knowledge of how to 23 manage an accident if it occurs and everything that is implied 24 in this, which doesn't exist in the bulk of the U.S.' plants. I 25 don't know how many foreign plants. But I'm willing to take l
4 4 .
31 1:
the position it'doesn't exist in the bulk of'the U.S. plants.
4 p,.
2 It's not easy to quantify this and put it in a PRA; 3- I've tried a little bit myself and you run into road blocks 4 quickly. However, I am not so pessimistic that one could not
'5
' develop qualitative requirements that took you a long way 6-toward having a management of this character, and that might be 7
really more important than teaching the PRA people how to put 8 it into PRA. So'I'd just like to make that comment.
9 CHAIRMAN ZECH: Well, let me just emphasize,.too, 10 that I agree with tne fact that it's not .just the operators, !
11 it's not just the people.in the control room; it certainly is a 12 tremendously important factor to have management involved. I 13 k mean the plant manager, the site manager, the'vice president 14 for nuclear and so forth. Management involvement is one of the 15 keys to safety.
I've been more impressed with that every day, 16 so that's a good point, too.
17 When we talk about operators, at least when I talk 18' about them, I really do think about the whole operational 19 people in the plant. And you mentioned, too, that includes the 20 engineers and those who are contributing to operational safety.
21 But I do think that the people part is what we're 22 talking about, some way or another is extremely important, and '
23 perhaps should be -- at leact we should attempt as best we can 24 to factor that in.
\- 25 All right.
I
32" 1.
( ._
MR. WARD: Well, the final level in this' hierarchy --
2L excuse me, Chet.
]
3 MR. SEISS: I wanted to comment briefly about 4 prevention and mitigation. We're all'in favor of defense-in-5 depth, but in our review of preliminary designs at least for 6 some of the advanced reactors of the future, I see there are-7 efforts being devoted chiefly to prevention;' inherently safe, 8 passive systems. If we really want this combination of 9
prevention and mitigation, the defense-in-depth containment, 10 we'd better get that >1essage out.
11 COMMISSIONER BERNTHAL: ;Well, absolutely. One of the 12 problems here is that 10 to the minus 6, if it were met
13 k strictly for severe core damage a la Fort St. Vrain, are we 14 prepared to say that that is, in and of itself, a sufficient 15 requirement for protection of public health and safety. Now we 16 did it once in this country. It does seem to me that at some 17 point you have to decide where is the level of safety against 18
' severe core damage at which you're prepared to say that at 19 least minimal containment is necessary.
20 MR. SEISS: And what level of confidence you'd be 21 willing to --
22 COMMISSIONER BERNTHAL: That's right. Is it 10 to 23 the minus 6, is that sufficient? Is it 10 to the minus 77 And 1
24 that's another problem that we ha/en't addressed and we're A
- 25 going to be asked to on this commission I would guess within
a o-33 1 five years.
2 MR. WARD: Well, what we see as the final level of 3
this hierarchy is really just your existing body of regulations 4 and regulatory practices. And as we said in the letter, let me 5
read the sentence, we said, "The overall policy implementation 6
that we propose consists in effect of transforming a bottom-up 7
system of regulation to a top-down system as the maturing of 8-the nuclear industry and regulation and understanding of risk-9 have permitted."
10 So we see the -- you know, we have no reason at the 11 present time not to believe that the existing body of 12 regulations is not giving us plants that satisfy -- in general, 13 is not giving us plants that are satisfying the safety goal.
14 But we think that you need to go on and establish that and 15 confirm that tentative conclusion. There are programs to do 16 that.
17 So we think that although we're proposing that the 18 safety goal be a test of regulations rather than of the plants, ;
19 we think of course you have to test the product of the 20 regulations; that is, the plants, through a risk analysis in 21 order to tell yourselves whether the regulations are working-or 22 not. And so we think a program such as carried out under 23 NUREG-1150 -- and we're going to be talking about that later --
84 is an essential part of that but we think it should be extended N- 25 and more explicitly recognized as a means of sampling the
Ah %
34
- 1. ~ product tx) tell-you whether the-regulations are really giving Y.. 2 you products that are meeting the safety goal.
- 3. Then'the last point is we recognize there are a lot 4 of. limitations to the Safety Goal Policy and I think we have to' j 5 be upfront about these and recognize them. And these are' 6
essentially the limitations inherent in the PRA methodology, j i
7 and they're caused by our fundamental inability to accurately i
8 predict and calculate values of risk. There's variability in 9- data,. uncertainty about applicability of data, imperfect 10 understanding of phenomena, and then inevitable incompleteness 11 in all our analyses all contributing to this limitation.
12 But all of these things aren't introduced by PRA -- I !
13 ki mean, the uncertainties aren't created by PRA or attempts to 14 assess things versus the safety goal, but rather these things 15 just put some focus on the uncertainties. You and your staff 16 have always had to deal with uncertainties in this area. Use 17 of a safety goal and use of risk assessment in a quantitative 4 18 way just sort of Tays these out on the table and gives you an 19 opportunity to consider them and discuss them rationally. But' 20 they are there and have to be considered, and are very much 21 limitations on application of the safety goal.
22 Bill, that's all I wanted to say.
23 MR. KERR: Mr. Okrent?
24 MR. OKRENT: Just a brief dissent with what Mr. Ward i 25 said. I think he said we meaning the committee have no reason
35 1
to think that the plants are not meeting the safety goal. I 2 can't support that position. I think too many plants have been 3
shown to have really large outliers when people have looked at 4
them so that before they were fixed they would not have met the 5 safety goal by a margin. And even for those which seem to meet 6
the safety goal with recent'PRA's -- that's in the last several 7
years -- within some band of uncertainty, I think there's 8
enough knock in the PRA's that there is not a basis for making 9 too strong a statement in that regard. I think we have yet to 10 learn.
11 COMMISSIONER BERNTHAL: Getting back to the guestion :
1 12 of operations, how much is not in the PRA in your judgment that 13
(~ deals with human error and the attempts to estimate human 14 error? I guess what I'm really asking is we recognize the 15 difficulty of putting all th'at in, but is that in part what 16 you're saying? Do you assume in PRA's to a significant if not 17 a predominant extent that the plant is, one, very well 18 maintained, and two, very well operated? I have not done PRA's 19 personally, I'm asking the question.
20 MR. LEWIS: No, there's some allowance -- Dave can 21 say it -- there's some allowance for human error. There's 22 almost never any allowance for human unusual performance on the 23 positive side, and we have a longstanding disagreement about 24 which one is the me,re important omission. But error is always
\ 25 included somehow.
4 .
36 1 MR. WARD:
I think there are methods in PRA analysis 2
'to factor in human error'and different sort of things, but in
.3 general they're kind of generic approaches. I mean, we know
'4 very well that the staff at one plant is going to do things 5 better than the staff at another plant. I don't think any 6- PRA's are refined enough to recognize that sort of difference.
7 You know, we often have licensees come in using sort 8
of PRA techniques to show that at their plant the performance 9
of this system or the performance of their operators or their 10 grid or something is better than average, and therefore, they 11 want to use that ag an argument for some special reason, 12 opposite some regulatory activity.
{ 13 Well, if somebody is better than average, there's 14 somebody out there that's worse than average and I don't think 15 we've ever heard anyone come in and say we need to put in 16 another_ system because we're really worse than average in this 17 area. But in most cases, the PRA's are using some sort of 18- smeared-over industry generic averag'e sort of number.
19 COMMISSIONER BERNTHAL: Would you agree with what I 20 think I hear Hal Lewis saying, that this has been a very 21 conservative process where error is considered but not i
22 extraordinary ingenuity, shall we say? '
23 MR. WARD: Probably, yeah.
24 MR. OKRENT: I don't disagree. I mean, I don't agree k- 25 with Mr. Lewis ' assessment, either with regard to the role of
4 1 37 1
, humans and whether it's been assessed conservatively or 2
optimistically, and I'll use two empirical accidents to argue i 3
my point because the things that happened at Chernobyl were 4
related to humans and management and management knowledge. The 5 same was true at Three Mile Island.
6 And again, the things that are wrong ~at Browns Ferry 7
are not in a pRA, and your problems at Sequoyah were not in the 8
first PRA.and they were not in the second -- I think there were 9 maybe three PRA's for Sequoyah. So -- and that's just one 10 aspect. So I'll stand on my statement.
11 MR. KERR: Since TVA was mentioned, I do think in the 12 case of the Browns Ferry fire that the operator showed 13 considerable ingenuity in providing raolant to that reactor so 14 that although it certainly was.a setzous fire and a serious 15 accident, the core was not damaged, and it certainly wasn't 16 damaged because they used conventional means to cool it.
17 MR. LEWIS: Well, this is a thing which is extremely 18 hard -- I agree with what Bill said -- this is very hard to 19 quantify.
It's like asking for the effectiveness of a burglar 20 alarm system. You know how often it's been breached but you 21 don't know how often a burglar has looked at it and been 22 deterred. So it's very hard to get your finger on that, and 23 the differences of opinion, you see, are based on a certain 24 amount of visceral emphaloskepsis.
{
25 )
CHAIRMAN ZECH: Maybe we ought to move to the next l
38 1
subject.because we've got a ways to go, and we probably won't 2
' finish this afternoon but that's all right, we can always !
3 reschedule. But I think it would be appropriate if.we move !
i
- 4. along. lI l
5 COMMISSIONER BERNTHAL: We never do finish these 6 meetings.
7 CHAIRMAN'ZECH: No, we don't, but they're always t
8 productive and useful.
9 MR. KERR: The letter that we wrote on NUREG-1150 was 10 written in the context of.this being a draft report and-we 11 commented on it as such. It was our understand that this 12 report reported a study which was meant to do risk 13 rebaselining; that is, a number of plants that had been studied 14 earlier were looked at again both because some changes had been 15 made in them as a result of earlier studies, and also because i
16 't was. intended I think to use up to date methods, new data and i
17 new insigats that had developed before some of the earlier 18 PRA's were performed.
19 The study also made an effort to develop a scheme for 20 estimating uncertainties and to carry out uncertainty
. 21 calculations for the risks that were calculated in connection 22 with these five plants on which the report comments. I won't 23 try to go through our letter in detail except to point out what 24 I think are at least some key comments.
I k-- 25 First, we wanted to emphasize that the report did not
. - - - _- __ -______ _ _ _ _ __ a
L 39 1 . include external events, and we understand why it didn't but in l
2 interpreting the results of the report I think one certainly l
3 must keep in mind that external initiators were not included l 4 and the results might well be changed if one did include those.
5 We also expressed some concern about some of the 6
methods used in the report, particularly the way in which 1 7 expert opinion was used in predicting uncertainties. It 8
appeared to us that the way.in which it was applied could lead 9
to serious biases, and that it was obscure enough in terms of 10 the information we had that it was almost impossible really to 11 review it and to determine the -- to make reasonable' comments 12- on the method. It is also the case that a number of the codes 13
( used in the calculations were fairly new and their validity is 14 not yet well established, and in many cases they are not 15 accessible to people who might want to review them.
16 Perhaps one of the more important comments we've 17 made, or perhaps more controversial, is in the last paragraph, 18 and I want to emphasize the language that, *one might conclude, 19 both from the report and the comments made by the staff, that 20 the existing regulations are inadequate to determine plant 21 equipment and procedures necessary to protect the public health 22 and safety."
23 What I think we meant, as far as I understand it, had 24 to do with the degree with which the staff felt that one could 25 extrapolate the results of calculations made for these five
_ - - _ _ - - _ _ _ _ _ _ __.____.-_._-____-___m______.m_. _. _ _.__________m_ _ _ _ _ _ _
.a ,
40 1 plants.
, And I think it was at least' an open question and 2
perhaps.a hope'that by analyzing five or six or seven plants 3
one can make some general statements about the risks of plants 4
generally, or at least' draw some conclus'ons i about.the state of 5 these plants.
6 We explored that at some length and I think.the 7
. report saysTin many cases, emphasizes, that as'a-result of the' 8
calculations the staff feels that they have a fairly good 9
understanding-of the risk produced by internal initiators for 10 these five plants; but also, that as a result of this 11
. experience'they arefconvinced that one can't say anything very 12- significant about the risk of plants that have not been 13 analyzed.
14 Now, it was not that we were trying to be critical of 15 regulations, but since it seemed to us that the public risk 16 depended'very much on the course of severe accidents, if one 17 could not say very much about the possible likelihood and 18 L
consequences of severe accidents on the basis of existing 19 regulations but rather one had to do a detailed PRA, that this 20 was a rather interesting and significant conclusion.
. 2.1 And this is what we tried to say here, and we said in 22 another place in the report that we are somewhat skeptical of 23 this and that perhaps not enough attention had been given to 24 looking for possible general conclusions that one could draw;
\- 25-that one might conclude that though the regulations maybe had
41
'l missed some things that they had been reasonably successful in
.I
\c 2 seeing that the plants built were safe and that they were 3' operated in a safe.way.
4 CHAIRMAN ZECH: Did you discuss this statement of 5 'yours with the staff?
Did the committee discuss it during any 6 discussions? I 7 MR. KERR: We did not discuss that paragraph because 8
it was not written, but we did discuss -- we'had a considerable 9
discussion before we arrived at that.
10 MR. 1EWIS: We do have an answer that I saw at my 11- . place this morning from staff denying that they drew this i
- 12. . conclusion.
13 MR. KERR:
q And indeed, I do not say in here that they 14 drew the conclusion; I said that one might conclude, and I .
15 didn't use "might" deliberately because perhaps that was not 16 the case. But we asked in subcommittee meeting and in the full 17
, committee meeting whether cne could draw general conclusions.
18 MR. LEWIS: I agree with you, Bill. In fact, we had 19 a very tense conversation with the staff on just this important 20 question on what you can learn from sampling five plants. And !
t 21 I'll tell you my personal interpretation of that conversation- i 22 was that the staff did not entirely understand how one learns 23 about a population from sampling some of the members of it.
24 There's a transcript here which has one unfortunate -- I have
\- 25 to say this -- misquotation of me. A place where I said
-r l- . . . _ ..i.._._...i _ _ . . , _ __ _ _ _ _ _ _ _ _ _ _ __
42 1 "nobody around NRC understands something", it came out in the 2 transcript, "nobody other than NRC understands this thing."
3 [ Laughter.)
4 And I disown the transcript on that point.
5 But we did have a very long conversation, in answer I 6 to your question, and there is a deep need for some reasonable 7 statistical interpretation of what one learns from studying 8 five plants to the teeth out of a population of 100-odd plants, 9 and the staff, so far as I know, has not done that. And it's 10 awfully important.
11 In fact, if I had a single recommendation to NRC, I 12 would say hire yourself a half dozen good statisticians; it 13 will be worthwhile in the long run.
14 COMMISSIONER CARR: If I understand that statement, 15 though, it's no different than the one Dr. Okrent just said 16 when he said he would not say that the current plants met the 17 safety goals.
18 MR. OKRENT: I think in fact there is a relationship.
19 COMMISSIONER CARR: The way I read it, there is.
20 MR. OKRENT: And I'll elaborate that in this way.
21 I'm aware of very few NRC regulations that really address 22 containment capability to cope with a core melt accident.
23 There certainly are not a sufficient set. Well, there are some 24 limited regulations so I will not say --
25 MR. SEISS: But they weren't intended for that.
e .e.
43 L '
.1. MR. OKRENT: No. But if there are some that'were )
j"' {
C i 2 aimed at aspects of it like hydrogen in BWR's and so forth. So 3
I automatically have to ask myself is it by some miraculous 4
chance that the regulations do provide containments that will, 5
when in combination with other things, let me meet the safety j 6 goal, I think in fact the answer is clearly no for the plants 7 that were being looked at in 1975. I don't know what the 8 l situation is for individual plants that have been fixed up 9
because they've been looked at via PRA and a correction made i
10 here and a correction made there and so forth, primarily to !
11 decrease the estimated core melt frequency. '
12 But I think the regulations are inadequate in that 13 area,.and I think they really are inadequate in the areas 14 related to prevention of core melt; otherwise, we would not 15 have seen plants where there was an intermixing of DC and AC, a-16 variety of kinds of things that were just not prevented by the 17 regulations before one started learning what was actually 18 present in these plants by. probing.
19 So there are reasons other than the fact that in each 20 of these five, they find different principal contributors, 21 different principal failure modes for containment, or whatever.
22 It's the fact that designers have been able to include things 23 that were really not precluded by the regulations that led to 24 potential for relatively high frequency adverse effects. ;
\- 25 CHAIRMAN ZECH: Well, I'm sure we want to hear the 1
44
/ ,
1-staff's response to those statements and actually, to your 2 views in the letter. Again, I think we should emphasize that 3 the draft NUREG-1150 is just that, a draft, as we know. We're l
4 getting lots of comments on it.
5 MR. KERR: I want to emphasize that the letter does 6
not conclude that the committee thinks that a significant 7 number of plants don't meet the. safety goals.
8 CHAIRMAN ZECH: Yes. And that's important from the 9 committee's standpoint to be said, too.
10 MR. KERR: We didn't address that issue.
11 CHAIRMAN ZECH: No, we understand that. It's a 12 comment that Dr. Okrent meant, but I appreciate that the
("' 13 committee has not made that judgment, and I appreciate that
\_
14 statement.
15 COMMISSIONER BERNTHAL: To take one case in point 16 here, I have heard it said by the staff and members of the 17 staff that at least one of the plants that was analyzed in 18 NUREG-1150 was indeed unrepresentative, and this would seem to 19 be consistent with the message that the ACRS understood staff 20 trying to convey. That it was unrepresentative because -- I 21 don't know exactly what the statement was, something like
-22 everybody knows that it's one of the better of the plants 23 because it's had a lot of things done to it, and if you took a 24 more average plant or an average plant, I should say, then 25 you'd see something rather different.
45 j 1
sy .I would assume that's what.they're attempting to say, 2- but it would be disturbing if the departure-is so great that 3- you can't conclude anything from the analysis.
4 COMMISSIONER CARR: Well, I think they're expressing 5
the same degree of uneasiness that you're expressing. If you i
6 haven't looked at all of them, you can't definitely say that 7 all of'them are fine.
8 MR. KERR: But these plants, it's not that they have 9
not been looked at, and I'm not.trying to defend one viewpoint 10 or the other -- they haven't been looked at very carefully and 11 repeatedly from the standpoint of existing regulations. And
).
12 maybe the existing -- and Dave is right, for example, the 13'
{ containments were not designed,to take into account what we now 14 consider a severe accident.
15 But a great many other standards have been adhered to-16 in the construction and design of the pressure vessel, the 17 control system and even the containment itself, and the 18 containments have been built conservatively; in some cases more 19 conservatively than one would need to handle design basis 20 accidents. And operating experience has been that we've had 21 some near misses and we still have not had any accident that ,
~ 22 was nearly as serious as Chernobyl.
23 So it would puzzle me if one couldn't draw some 24
, general conclusion about plant behavior on the basis of
- k' 25 existing regulations. And we may have gone -- perhaps we
' t ;.
46 1 misunderstood what the staff had'in mind.
We did, after all, N 2 only spend a part of a day. discussing-this and it's a rather 3 difficult issue.
I 4'
Now, as far as your question, Commissioner Bernthal, 5 we do.not, as I'n sure you know, have a position on the i 6
question tha'c you raised, and-indeed in or' der to discuss it, I 7
think.it would be helpful'if we knew a bit more about what you 8 meant. A severe core damage accident can be, in perhaps one 9
extreme, an accident in which one simultaneously drops a 10 completely molten core into the containment instantaneously.
11 On the other hand, it could be one in which damages the core 12 considerably but doesn't penetrate the vessel. These are sort (I' 13- of the two extremes.
> (~ ;-
14 I think it would be helpful to us in commenting if 15 you'd give us a little more insight into what it was that you'd 16 like to get comments on. And indeed, if you want a committee 17 view eventually --
18 COMMISSIONER BERNTHAL: What I'm looking for is 19 really I guess the committee's response to some of the comments 20-and statement that, as I understand them, were made by some of '
21 the expert reviewers last spring, who suggested that for the 22 panoply of severe core melt accidents, I guess including core 23 on the floor or whatever you want to call it, that once you 24 i proceeded to breach the vessel -- and maybe that's the key
\~ 25 element here -- once you breach the vessel, then what is the
t 3
1 47 l
1 capability of the plant to -- or of the containment rather to 2 withstand that type of event. And, you know, that's the very 3 nature of the controversy right now and I didn't know whether 4
you had looked at that carefully yet within the context of your 5 study of NUREG-1150 or not.
6 But that was essentially what I was asking.
7 MR. KERR: I think if one looks at it in the context 8 of NUREG-1150, which of course treats total risk, the Peach 9
Bottom plant which is one of the ones analyzed looks very good.
10 COMMISSIONER BERNTHAL: Overall risk, yes.
11 MR. KERR: Yes. And this certainly includes some 12 consideration. We have not yet picked out the containment for
,' 13 detailed study, so whatever we would say -- and people who want t
14 to can comment -- would be based on individual judgment and 15 consideration.
16 I agree, it's an important question. I'm simply 17 trying to emphasize that we have not reached any committee 18 consensus on the question.
19 COMMISSIONER BERNTHAL: The question en overall risk 20 I entirely agree needs to be stressed repeatedly because it has 21 not been stressed publicly. But that does not answer the 22 question of containment performance in the event of a severe 23 core accident.
24 MR. KERR: I would say in a sense, I'm glad you 25 raised the issue because it seems to me it does add some
l 48 ]
L 1
emphasis to interest to develop containment performance i 2 criteria. And as you know, we have commented on that a number 1
3 of times, l j
1 4 MR. OKRENT: Well, I'll only note that it's an 5 incomplete PRA that you have in 1150. So besides the external 6
events that are not included, there are some things that we 7
just don't know how to include, and we were talking about 8
management a little while ago, but there are other things as ]
9 well.
So I would be even cautious on the statement that it's lo meeting your high level health and safosy goals.
11 CHAIRMAN ZECH: Well, let me just say I think it's f
12 very important that the ACRS concerns expressed on the draft
("
13 NUREG-1150 be addressed very carefully. You have raised some 14 significant concerns, and I think it's important that they be \
15 addressed with a great deal of care and study.
16 I would also make sure that we make the staff well 17 aware of the fact that as far as I'm concerned, they should be 18 addressed carefully, and I'm sure they will be.
19 Can we move along to the last subject here? I know
(
20 we're moving rather quickly but we'd appreciate that if you 21 could.
22 MR. WARD: I think we can cover this fairly quickly.
23 In cur July 15th letter we talked abcut the ISAP which is the 24 Integrated Safety Assessment Program. ISAP is intended as a
('
25 cooperative program between the NRC Staff and a licensee to I
I L i
q / s.
49
'~ 1 provide for optimized resolution of multiple safety issues. So T4 2 fari there's been a pilot ISAP with the staff working with
- 3 Northeast Utilities on two of the older utilities, Millstone
'4 Unit 1 and Haddam Neck.
5.
We think this is a good program and it's an' effective 6
way we think for dealing with what is really kind of an.
'7 inherent problem. There are a number of loose ends'out there 8
in the regulatory world, and-you defined those loose ends.in 9
terms of generic issues, or some of the more important ones are lo called' unresolved safety issues. And even in parallel with 11
<p those I could even put certain things that you're requiring 12 under-the. Severe. Accident Policy like the individual plant 13 assessment or evaluation, whatever it's called.
14 But there's a problem in that these things tend to 15 get compartmentalized even though they're inter-related, and 16 some of them are quite strongly inter-related. But in order to 17 be worked on' practically by engineers, the staff has 18 compartmentalized them and it comes up with opposite -- each 19 one of these generic issues comes up with a particular set of 20 new requirements or advice or suggestions or arm-twistings or 21 something which the licensees are going to have to deal with.
4 22 Because they are inter-related this presents a 23 problem to licensees.
There may be conflicts in meeting the 24 requirements or maybe unnecessary expenditures in meeting k 25 individual requirements. One way to deal with that would be I
_L - _ _ _ _ _ _ ____ ___ _
a.
..'w +:
50 p ,_ -1 for you to tell'the staff to hold T1p on all this stuff for five 1 \
2
-years'until you get them all worked out,-and then.let the staff 3
l integrate the new set of requirements and present them to all 4 the licensees at that time.
4 5
Another way is this ISAP approach, and that is to go 6
ahead and present these' individual pieces to the licensees, but 7
then permit the licensees to make an integrated response to 8 these. And that's what the ISAP attempts to do.
9 Now,.in order for the staff to go along with an-10 integrated response it requires the licensee to have some good 11 technical reasons, good technical basis for the responses it's 12 proposing, and in general we see this as being based on a
-13
( 'probabilistic risk assessment made for the plant, and that's 14 what has happened at Haddam Neck and Millstone. If the 15 licensee looks at the several new requirements that it is 16 having to meet and assesses them all and assesses its plant 17 with a PRA and then comes up with some specific projects which 18 will deal with that whole spectrum of things rather than having 19 to deal with each one at a time.
20 We think it's a good approach and we'd like to see a
'21 program developed within the staff to extend the approach to 22 licensees who are interested in using it and are able to use
'23 this sort of program effectively.
24
, CHAIRMAN ZECH: Are you s ggesting that we extend it k- 25 on a voluntary basis? Is that it?
f a i
- 1. MR. WARD: Well, I think Northeast Utilities is kind i
\ 2 of unique among utilities in that they have a large 3
1 comprehensive inhouse engineering staff, and they've gone about 4
developing their own risk assessment capability. Perhaps all 5
licensees in the foreseeable future aren't really going to have 6 that sort of inhouse capability. But yeah, I think something 7
like offering it to licensees who can use it to advantage and B
use it effectively and use it in a way the staff would' approve 9 could be a good approach.
10 MR. EBEPSOLE: I'd like to make a comment on that. I 11 think it's pretty likely that the owner / operators who as Dave 12 says are perhaps incapable of using or developing this method 13
{' are the very ones most needful of having to do it, and I don't 14 think I would endorse a voluntary program but rather one with 15 considerable pressure on it.
16 To say that a licensee can't do this is also to 17 endorse him as not being able to do lots of other things he 18 ought to do.
I 19 CHAIRMAN ZECH: Well certainly Northeast Utilities 20 has done an excellent job with this program, I agree that, and 21 I know they worked closely with the staff, and as far as I know 22 the staff has also found it a very useful program. <
23 COMMISSIONER BERNTHAL: It's an important point you 24 makes because it seems to me in the end the Commission is going
'- 2E to have to decide whether this is something that we are going i
,- G 52 1 to push with the licensees rather than asking them to step 2 forward as we have so far. I don't even recall how many but I 3 know that some of us have urged that the ISAP program be 4 continued, which is all well and good except that there's only 5 one utility that's been interested so far. So it doesn't make 6 much sense to budget whatever it would take, eight or ten l 7 people I suppose, certainly from the Chairman's standpoint I i 8 would think, because nobody is interested.
9 MR. EBERSOLE: I think it's very likely that the ones 10 that need it the most will be the ones least likely to endorse 11 doing it.
12 COMMISSIONER BERNTHAL: Well, that may well be. Your
'" 13 point is well taken and I think it's a question that we 14 probably need to decide; are we going to push it or not.
15 MR. SEISS: You said nobody is interested in ISAP?
16
- COMMISSIONER BERNTHAL: Only one utility to my 17 knowledge, and that's the one we've mentioned, has stepped 18 forward.
19 MR. SEISS: I know that the staff asked for an 20 expression of interest in the integrated living schedule and 21 didn't get much support. And the reason for that I think 22 chiefly was that it required a license amendment, and most 23 utilities don't see an awful lot of advantage in something that 24 requires a license amendment.
s 25 Is the same true for the ISAP7 The ISAP offers them
r G
, 53 e
1 more than integrated living schedule does.
( 2 CHAIRMAN ZECH: Well, I think it's a good program. I view it, frankly, as kind of a pilot program and I think it is 3
4 being continued now and it's my understanding it will be 5 continued next year, too. But I think your point that it seems 6 to have value and that you'd like to review the staff's 7
proposal for future use is an excellent suggestion and I think '
B the Commission feels the same way.
9 And I do think that -- you know to me, if I were a 10 utility executive and having to look at that program at least 11 to some degree, I think I'd want that kind of a program at my 12 plant.
It would kind of give me confidence that we're doing
(^ 13 the right thing. So it seems to me that it ought to be kind of
(.
14 a utility initiative, and I kind of agree, too, that perhaps 15 those that don't want the program ought to be looked at pretty 16 carefully. It just makes sense to me.
17 So I think it's something that we'll have to watch 18 ci sely, and we are continuing the program is my understanding, 19 and if you conclude and staff concludes and we conclude it has 20 great merit, why, no question but it probably should be pursued 21 more vigorously. But I think it bears watching right now 22 because it does seem to have merit, to me.
23 MR. SEISS: Have you given any thought to the 24 possibility that it not be an optional program; that it be a 25 mode of operation for NRC?
-n .. . . .s jg ;
u g 4 4 54
(. s f {'3 t s
l- CHAIRMAN ZECH: Yes, I have personally, but I think-1
(
2 so far I'm willing to watch it and see how it'r going.
I think 3
g1 we're doing -- this is a'rather favorab2e expe:-iment' we're 4 involved in here, as-I see'it.
4st It's'a utility that wants to do 5
the program that sees benefit in'it, so-I'm sure those who 6
would not see benefit are thosa who would perhaps not want to
- 7. do it. I think we've got to see whether we feel that.across~
8 the board it has merit before we make any kind of a requirement 9 for it. N 4 .,
30 But again, my personal feeling is that.if I. ware a 11 ' utility executive I would.
- It seems to have great merit,'even 9
12 to do it on a voluntary basis on their part. But certainly, if 13 we conclude it has as much'value as it does seem to have, at 14 least'to me and to others, it's something that we shotid 15 consider perhaps on a more than voluntary basis in th's future.
16 MR. WARD: One additional point. You know, we think 17 that the pilot program has been good but even there there are ;
l 18 some imperfections.
And we mentioned an appropriate scope for 19 the risk analysis. For examplo, the risk analysis done in 20 support of the program at Haddam Neck and Millstene 1 did not 21 include a full set of external initiators. It really wasn't as 22 complete a risk analysis as we'd like to see.
23 CHAIRMAN ZECH: That's important because we don't 24 want to get into something that we're fooled on. So those are
\ 25 the kind of things that we've got to look at carefully.
- s. *
~
55 l 1
,_ COMMISSIONER BERNTHAL: What are we doing right now?
.t 2
I'm not even aware -- once Northeast Utilities is finished, 3 Lwhat is the projection for the staff?
4 CHAIRMAN ZECH: Well, we haven't made any specific 5
plans but we planned, as I recall, to continue it, next year 6
continue it to '89 in the budget we're just discussing now as 7 you know, and continuing to support that at Northeast B Utilities. But we have not expanded it beyond that. I believe 9 that's where it stands now. We're really waiting for the 10 staff's recommendation, 11 MR. OKRENT: Just as a constructive suggestion, after 12 I've been so sort of negative. It seems to me there are a few
'13 things on the table or near the table that could be folded 14 together. The Severe Accident Policy Statement asks for some 15 kind of systematic review.
16 Earlier, we were talking about the importance of 17 !
management and I suggested that this should include in fact the '
18
, very good knowledge of the plant, in the management of the 19 plant.
That doesn't mean each person knows all the plant, 20 obviously. And if you try to fold those two ideas together in 21 ISAP in fact and require not only that there be a systematic 22 look at plants but in some reasonable number of years, a 23 technical knowledge of Aants as it were, and an ability in 24 effect to generate your own emergency procedure guidelines, not 25 have to rely on the vendor -- if you know the plant well enough i
I s -
56 1 you should be able to.
,_ I think those are not unrelated in my
-(
N .2 mind and might in fact be molded in some way.
3 CHAIRMAN ZECH: I agree. They do come together, all 4
of them, and certainly from the utility's standpoint, you know, 5
the management involvement and knowledge and competence --
6 nothing beats it. And also bringing those kind of issues 7 together. I agree, that's the essence of excellence, as I see ,
8 it, knowledge, competence, knowing your stuff and really 9 bringing it all together like that. So I think your comment is 10 well taken.
11 Are there other cornents on this issue? Other 12 comments from my fellow commissioners at all?
13
( COMMISSIONER BERNTHAL: Well, I would like to ask one 14 or two questions but somebody else ought to have a crack here 15 if anyone else wants to.
16 COMMISSIONER CARR: I yield my time.
17 [ Laughter.) !
18 COMMISSIONER BERNTHAL:
1 One short comment. I 19 entirely agree with what the Chairman has said that these 20 memoranda are timely and to the point and obviously from my 21 comments, raised a number of issues that are important, and i 22 that is exactly what we need, and the sort of vigorous 1 23 discussion that we've had here today is what I wish we could do 24 considerably more often, as a matter of fact.
l 25 I would also say that all of the recommendations
f
- I 57
-l' essentially that you've made in this safety goal paper, if I-
~ 2 may go back to that, I. find myself in agreement with; the t
3 substance in every case I agree with. As you know, it was the 4
single issue that I was having difficulty with. I agree with l 5 the 10 to the minus 4 core melt criterion, I consider that l 6 equivalent to the moving target that I have from time to time 7
l urged that there be a 100-year criterion which right now.
{
8 1
i amounts to about 10 to the minus 4. And the 10 to the minus 5, 9
i ihplied factor of 10 mitigation for large release is equivalent 10 to the 1000-year criterion for large release that I have often 11 urged. '
12 i And also, I concur that there should be no surrogate {
/~' 13
(- for regulations in these safety goals; they should be an 14 average. And in that respect, I think you're agreeing with 15 what the Commission decided when it urged that that matrix, the 16 so-called implementation matrix which really belongs I think 17 more in the context of the Severe Accident Policy 18 implementation that Dr. O.m nt refers to, that that matrix not 19 be used as a safety goal; that it be very strictly confined to 20 implementation.
21 Two quick questions if I may ask them. One, have you 22 considered, did you consider the question of population density i j
23 and whether the safety goals need to worry about that at all 24 I now when considering plants on the average. In one sense, {
25 using the one early fatality criterion, 10 to the minus 6 for $
l
- - - - - - _ - - _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ l
L g.> .
58 1
, large release, as staff suggested, I suppose does that fold in, t 2 in the average. But is that something that in your judgment is j 3 already sufficiently contained in the loth of a percent goals?
4 Is it something that we don't need to worry about as a matter 5
of principle for these broad generic targets for power plant 6
safety, or at least the success of regulation? Or is it
.7 irrelevant?
8 MR. WARD: I will comment on that. I think it's 9
definitely not considered in the 10th of a percent; density 10 isn't considered.
11 COMMISSIONER BERNTHAL: That's what I understand, 12 yes.
13
{ MR. WARD: Second, though, we didn't really consider 14 that question afresh in this current discussion because this 15 has been our views on implementing the goal as set forth. So 16 that was last year's discussion and I guess we haven't really 17 addressed it again.
1B COMMISSIONER BERNTHAL: Okay. l 19 MR. REMICK:
I'd like to make one ad 2itional comment.
20 If you go back in time, the way that was handled in some of the 21 early drafts of the safety goal, if you have a release at a 22 site with a large population presumably you're going to have 23 more man rems, and at the $1000 per man rem you could therefore 24 afford to have more money available to correct that. So there k- 25 was a leveraging. That no longer being in the safety goal, I j
.eg- ..
59 l-agree with what Dave is saying. Density is no longer in there.
2 COMMISSIONER BERNTHAL: I agree, yes.
31 MR. OKRENT: I would just like to observe that as I 4
understhnd the situation, the CCDF of one or more fatalities is 5 not something that treats sites equally, in a sense.- You.can i 6 i have a very large close-in population or relatively few and'get 7-almost -- get a similar result, but you don't recognize in the
'8 one case little chance of large numbers of early fatalities, 9
and in the other case it's -- the likelihood is not radically 10 different from a chance of one. In other words, 100 is not a 11 factor of 100 less than one; it may be 5 less than one.
12' MR. KERR: It seems to me it is possible to deal with 13 the population issue in a siting rule. Certainly, population
'14 density is important and the ACRS has been concerned with that 15 certainly for years before I came on the committee, and I think 16 it's just a question of how one deals with it.
17 COMMISSIONER BERNTHAL: But you don't feel that as a l
18 matter of policy it need be considered in the safety goal.
19 MR. KERR I do not personally, but I certainly think 20 it needs to be dealt with at some point in the process.
21 MR. REMICK: In fact, historically the Commission put 22 aside considering siting until it issued its safety goal and 23 then the idea was to go back and revisit the siting question.
24 That was about 1981 or 82.
Y 25 COMMISSIONER CARR: I think that was regarding 1
. )
a . <
60
_; 1 . application for the next permit. ;
4s 2 COMMISSIONER BERNTHAL: Ten years. !
3 MR. WARD: Yeah, but the goal itself, which is your 4 fundamental policy, doesn't address the issue.
5 COMMISSIONER BERNTRAL: That's why I asked the j 6 question, yes. '
7 MR. WARD: I mean, if a new siting rule addresses it, 8 it's setting policy different from the safety goal.
9 COMMISSIONER BERNTHAL: I Or at least in addition to, 1 l
10 yes. !
11 MR. LEWIS: You really would have to decide whether 1 12 you're talking about population at the time the plant is
/'~ 13 k_
started or at the time it ended 30 years later, because the 14 population will be very different.
15 COMMISSIONER BERNTHAL: That's right. Well, I 16 understand that you did not try and rewrite the safety goal, 17 and nevertheless has been a comment or two here.
18 And if we can take one sentence or a few-sentences 19 answer here, my last question is, if I may be so bold as to 20 ask, what would you do if you were to sit down and try and 21 distill these various, sometimes contradictory safety goal 22 statements, qualitative, quantitative, in the Commission's 23 statement, and focus on a single, rather simple criterion or 24 two or three; sort of a clean slate approach?
i A 25 Another way to ask that I guess is what do you think
e *' 4
.61
, , . 'l it's most important to focus on in your own summary l
.\ 2 hierarchical structure, whatever?
3 MR. KERR: You have read our report of some years ago 4 on safety goals, I presumo.
5 COMMISSIONER BERNTHAL: Some years ago. Entirely 6 possible that I have not, I'm not sure.
7 MR. KERR: That is a rather detailed discussion of 8 some suggestions. !
It was not a committee recommendation in the '
9 sense that this 1s it, but it did have a good bit of discussion 10 of the way in which safety goals might be formulated. Some 11 possible approaches. If you haven't seen it lately --
12 COMMISSIONER BEKMTHAL: How many years ago?
13 MR. KERR:
i
(
s- Five years ago, six years ago -- right 14 after TMI.
15 MR. OKRENT: NUREG-0739. 1 16 MR. LEWIS: It was a laundry list.
l 17 COMMISSIONER BERNTHAL: You still stand behind that, 18 I take it.
19 MR. LEWIS:
l No, no. It was not a committee position.
20 MR. KERR: It was a discussion of possible 21 approaches; it was not a distillation into one sentence, no.
22 MR. REMICK: If I may add a personal opinion, I think 23 it should address public risk. That's what the Act is all i 24 about.
25 And another personal opinion -- when you say the
e u 62 1-public'will understand 10 to the minus 6 or they won't A. 2; understand,-I don't think the public understands 110 to the 3 minus 6'no matter what the words say.
4 CHAIRMAN ZECH: I-think that's correct.
5 MR. REMICK: I think if you put it in words'that they 6 can compara it with the things they know.
7 MR. KERR: How about one'in a million?
8 CHAIRMAN ZECH: That's better.
9 [ Laughter.)
10 MR. REMICK: And that's what you have done.
11 CHAIRMAN ZECH: Commissioner Bernthal, anything else?
.12 COMMISSIONER BERNTHAL: That's it, thank you.
(e^
' '"^'""^" '" "' ^"" '"*"'
14 Well, let'me thank the committee for'a very 15 informative and interesting discussion this afternoon on these 16 three subjects. As I noted in my opening remarks, the 17 Commission values very much the papers, these and others, that 18 the committee has sent to the Commission recently. They're ,
19 very, very valuable papers, important papers. )
I 20 I would encourage your continued interaction with the 1 21 staff on the safety goal as well as your comments on the draft
)
22 NUREG-1150. I think it's very important to continue discussion 23 of that with the staff, resolving what we can with the staff.
24 I think the Commission would be most interested to assure that A- 25 that dialogue continues.
j
a v 6 l
63 l 1 Also, I think the commission and the staff should )
2 consider your, what I understand is a somewhat favorable l 3
endorsement of the Integrated Safety Assessment Program, and I 4 agree with that. I think the staff is doing that but I think 5
perhaps your endorsement should be looked at as just that, and 6
we should make sure that we're taking a good hard look at that 7
program; it does seem to have merit, although it's being f t
'8 continued as a pilot program perhaps we should move a little 9 more rapidly.
But I think the staff should take a look at 10 that, too. i 11 But I do appreciate very much the session this 12 afternoon, and unless there are any other comments from my 13 fellow Commissioners, we will stand adjourned.
(~ Thank you very 14 much.
15 (Whereupon, at 3:45 p.m., the Commission meeting was 16 adjourned.)
17 18 19 20 21 22 ,
I 23 24 o
N- 25
)
-eo 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 the Advisory Committee on Reactor Safeguards 8 PLACE.OF MEETING: Washington, D.C.
9 DATE OF. MEETING: Thursday, August 6, 1987 l
10 !
11 were held as.herein appears, and that this is the original 12 transcript thereof for the file of the Commission taken
%s 13 stenographically by me, thereafter reduced to typewriting by 14 He or under the direction of the court' reporting company, and 15 that the transcript is a true and accurate record of the i 16 foregoing events.
l 17 1
)
I 18
Tra'm" U yTJrtnTant-------
19 l l
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Ann Riley & Associates, Ltd. 1
{
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