ML20246N787
| ML20246N787 | |
| Person / Time | |
|---|---|
| Issue date: | 04/13/1989 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8905220004 | |
| Download: ML20246N787 (96) | |
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. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIS SION i
L Titl6:
BRIEFING ON IMPLEMENTATION OF SAFETY GOAL POLICY STATEMENT i
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LOCatiODl ROCKVILLE, MARYLAND I("O'I' Dat@l APRIL 13, 1989 e
[sG65l 72 PAGES NEALR.GROSSANDCO.,INC.
COLRT RtPORTER$ AND TRANSCRIBERS
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1323 Rhode Island Avenue, Northwest Washington, D.C.
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b DISCLAIMER This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on April 13, 1989, in the. Commission's office at One Faite Flint North, Rockville, Maryland.
The meeting was open to public attendance and observation.
This transcript has not been reviewed, corrected or edited, and it may contain inaccuracies.
-~.
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,
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NEAL R. GROSS court RipoRTERS AND TRANSCRIBERS 1323 RHoOf 15 LAND AVENUE. N.W.
(202) 234-4433 WASHINGTON, D.C.
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1 U!IITED STATES OF AMERICA 2
NUCLEAR REGULATORY Col!MISSIO!!
3 4
BRIEFING Ol'. IMPLEMENTATION OF 5
SAFETY COAL POLICY STATEMENT.
6 a
7 PUBLIC 11EETI!!G 8
9 tiuelear Pegulatory Commission 10 One White Flint North 11 Rockville, Maryland 12 13 Thursday, April 13, 1989 63" 14 15 The Commission met in open. session, pursuant to 16 notice, at 2:00 p.m.,
the Honorable LATIDO W.
- ZECH, JR.
17 Chairman of the Commission, presiding.
18 19 COMMISSIONERS PRESENT:
20 LAtIDO W.
- ZECH, JR.,
Chairman of the Commission 21 THOMAS M.
ROBERTS, Member of the Commission 22 KE!!!!ETH C. ROGERS, Member of the Commission 23 JAllES R.
CURTISS, Member of the Commis:sion 24 25
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STAFF AND PRESENTERS SEATED AT THE COMMISSION TABLE:
(.-
k-2 SAMUEL J.
CHILK, Secretary 3
WILLIAM C.
PARLER, General Counsel 4
JAMES TAYLOR, Deputy Executive Director, Operations 5
R.W.
HOUSTON, RES 6
TOM MURLEY, NRR 7
THEMIS SPEIS, RES 8
9 10 11 12
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E E Q C E E Q l Il G E
(.-
(2:00 p.m.)
3 CHAIRMAN ZECH:
Good afternoon, ladies and 4
gentlemen.
5 The purpose of the meeting this afternoon is for 6
the staff to brief the Commission concerning the general 7
framework and the revised plan for the Safety Goal Policy 8
Implementation.
The staff last briefed the Commission on 9
this subject on October the 19th, 1988.
10 Today the staff will provide us recommendation 11 for the general approach to the use and implementation of 12 the safety goals and quantitative objectives.
The staff l%
13 should be prepared to point out areas in which it is in 14 disagreement with the ACRS.
15 This meeting is an information briefing this 16 afternoon, there will be no vote tWen.
17 I understand that copies of the slides are 18 available as you enter the room.
19 Do any of my fellow Commissioners have any 20 opening comments, before we begin?
21 filo response) 22 CHAIRMAff ZECH:
If not, Mr.
Taylor, you may 23 proceed.
2a MP. TAYLOR:
Good afternoon.
)
25 As you indicated, Mr. Chairran, this meeting is (202)234-4433 TIE AL P.. GROSS & COMPA11Y, IITC. (202)232-6600 1323 phone ISLAttD AVETIlfE. II. W., 17A SHItiGTOil,
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1 meant to brief the Commission on additional guidance, and I;
2 '
2 to get the Commission's agreement with the staff's ideas 3
on further utilization of the Safety Goal Policy in the 4
decisionmaking process.
5 You mentioned that the ACRS and the staff has 6
had extensive interaction with the ACRS, and we do intend 7
to outline the similarities and differences in the 8
briefing.
And I would note that I believe the Commission 9
is due to hear directly from the ACRS at your May 3rd 10 meeting with the ACRS.
So they will have a chance to 11 brief you directly.
12 With me at the table are Dr. Murley from tiRR,
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13 Dr. Speis, from the Office of Research, and Wayne Houston.
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.14 And Wayne will give the detailed briefing this afternoon.
15 CHAIRMAN ZECH:
All right, thank you very much, 16 Mr. Taylor.
17 You may proceed.
18 MR. HOUSTON:
Mr. Chairman, Commissioners, it is l
l 19 a pleasure to be here this afternoon, after many, many 20 months of effort on our part to bring to your attention 21 our proposals with regard to the further evolution of 22 Safety Goal Policy, and particularly its methods of 23 potential implementation by the staff.
24 Our purpose today, if I may have the first
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e-25 slide, slide number one --
(slide) -- is, in a sense, (202)234-4433 NEAL R.
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threefold.
Perhaps the primary purpose that we have as a
(
2 staff is to request your approval of additional safety 3
goal guidance to the staff.
And when I say additional 4
safety goal guidance, I am recalling that the policy 5
statement that was published in 1986, in Part V of the 6
Policy Statement, does deal with the issue of guidance to 7
the staff.
8 And what we are saying here, if approved in 9
whole or in part, could lead then to a modification of 10 that guidance statement, and we feel that it would be 11 desirable to actually incorporate that in a revised policy 12 statement itself.
(
13 From a more technical point of view, our purpose is to really try to develop better clarification of the 14 15 role of probabilistic risk analysis and quantitative 16 safety goal objectives as partners in making future 17 regulatory decisions.
In part, what this means is to 18 identify what safety goal objectives are, or are proposed 19 to be, and what they are not.
And as we will see in the 20
- briefing, I think some of these are fairly important 21 considerations to understand.
22 If I may have the second slide, please.
(Slide) 23 The overview of the briefing is sort of three parts.
I 24 will discuss, hopefully, with some brevity, and summarize ii 25 the recommendations that have been made to you by the (202)234-4433 NEAL R.
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-1 ACRS. The bulk of the briefing will be on the staff l-2 recommendations, including both the general approach and 3
the principal elements of our recommendations, of which 4
there are four.
5 Finally, we will have a few words to say abcut 6
the industry objectives for evolutionary light water 7
reactors that appear to have a relationship to safety 8
goals, although not identified as such, and then, finally, 9
a summary.
10 If I may have the next slide, please.
(Slide) 11 T.he ACRS recommendations were made in a letter dated May 12
- 13th, 1987, and it had three principal elements.
They g.,
13 identified the purpose of their proposal was to etialu s.s c
the adequacy of rules and regulatory practices.
14 15
- Secondly, they suggested an approach which 16 involved what they referred to as a five-level hierarchy 17 of objectives, or goals, which reflected a top-down 18 succession of surrogates for the principal goal, which 19 were the qualitative goals expressed in the Commission's 20 policy statement.
21 Finally, they identified the association of the 22 implement to their proposed method of implementation, with 23 what they referred to ag a sampling program of PRAs. This 24 recognize.i that it may be sometime into the future, if i
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Level Three PRAs on all of the plants in the United 2
- States, so that the sampling program was intended to 3
convey the idea that something less than 110, or whatever~
4 the proper number might be, of probabilistic risk analysis 5
for individual plants, should be an adequate basis for 6
drawing conclusions about what they refer to as.the 7
adequacy of our rules and regulatory practices.
8 Basically, what this means is, in the sampling 9
program, is the review of PRAs that are done -- in some 10 cases the effort might initiate PRAs -- but, basically, it 11 is to analyze why, not so much the whether question of 1
12 whether plants meet the quantitative objectives or not, 13 but if they do, why they do, and if they do not, why they 14 do not.
15 In other words, it is the insight, as we 16 sometimes say, from the PRAs themselves that are the 17 important things; the comparison with the safety goal 18 object'ves is merely an indicator of what kinds of things 19 to loot for in terms of why they do or why they do not 20 meet the objectives.
and with 21 It is our understanding that the 22 respect to the ACRS hierarchy of objectives, and referring 23 to this as a top-down succession of surrogates -- that the 24 ACRS did intend to admit the possibility of some i
5....
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starting from the top and going down to the bottom level, W
2 which they identified as the body of regulations and 3
regulatory practices.
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4 And the purpose of this would be to accommodate 5
uncertainties.
In other words, if the quantitative health j
6 objectives which have been identified in the Safety Goal 7
Policy Statement, if a methodology were available to make l
8 a clear and unequivocal determination as to whether or not 9
those were met or were not met, and that that 10 determination could be made with high confidence, the rest 11 o.f the quantitative objectives perhaps tr o u l d be 12 unnecessary, but because there is uncertainty in it, they
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13 have identified the possibility that there can be, and 14 perhaps should be, some conservatism, but not so much 15 conservatism as to create what they referred to as de 16 facto new policy, and what we have heard from some 17 recommendations by some, could be interpreted as really 18 creating a different policy than that which the Commission 19 intended.
20 The program that they have in mind has appeared 21 to us to be what I might describe as a rather global view 22 of the activitids of the NRC, the regulatory activities.of 23 the NRC, and that it could, in principle, or in practice 24 if one looks at it tlia t way, take a very long time i
.k 25 actually to complete the program that is suggested there.
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- Perhaps, also, of considerable importance--
2 they used the word " adequacy" in their original letter, 3
and we will say a few more words about the word " adequacy" 4
and the words " adequate protection" which, of course, 5
bring to mind the question of the statutory standard.
6 If I may have the next slide, please.
(Slide) 7 Again, summarizing some additional letters that have been 8
received from the ACRS in April 1988, they had some 9
further comments, intending to clarify meanings of some of 10 the things in their earlier letter.
It included some 11 thoughts of the ACRS on how a definition of a large 12 release might be characterized.
And they suggested that
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13 they preferred a definition which' treated a large release i
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14 as an actual release of radioactive material into the I
15 environment.
16 The staff discussion of the disposition of that 17 question is incorporated, primarily, in the Enclosure 1 to 18 the Commission paper which you have received.
l 19 Secondly, they went to some lengths to discuss l
20 the problem of definition of the word " core melt" or " core 21 damage".
And in this particular area the staff has I
22 adopted the definition, except the staff prefers to use 23 the words " core damage" rather than " core melt".
The 24 problem here is that although there is fairly common usage i;
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distinction between them, the ACRS has pointed out quite l'-
2 properly that the initiation of core damage is probably a 3
higher frequency event than a core melt situation, which 4
implies rather complete or substantial melting of material 5
in the core, and actual failure of the pressure vessel, 6
and this is often referred to as a " core on the floor" 7
situation.
8 In most PRAs that have been done, from a 9
probabilistic point of view, there has been no difference.
10 That is, the assumptions have been made in doing the PRA, 11 that the state-of-the-art of understanding the melt 12 progression phenomenon is such that given core damage,
.i 13 core on the floor was determined to be, or assumed to unit. probability -- that is, it was going 14 have, simply a 15 to occur.
16 The ACRS has observed that, in their view, the 1
17 likelihood of that occurring is probably considerably less 18 than unit probability.
And I might add parenthetically 19 that, in substantial measure, that is a major focal point i
20 of the accident management program, to try 7 get j
21 appro.priate procedures and, to the extent that it may be 22 necessary, some modifications in the hardware that give 23 operators the best possible opportunity to stabilize or y
24 reverse the progression of an event which may start with i k...
25 some initial core damage, before there is melting and (202)234-4433 NEAL R.
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f ailure ' of the pressure vessel and, of course, the one t'.
2 example ~ t h a t.. we have of a rather serious - core melt-3 accident, TMI 2,
in fact,. did result in a reversal of 4
that, and there was not a failure of the pressure vessel'.
5 The-next item, the ACRS have recommended 6
something that they call a " plant' performance objective",
7 which they characterized as how well a plant is operated.
8 Both the ACRS and the staff seem to agree that we don't 1
'9 know how to do.this in a quantitative sense at the present 10 time, and so no such objective was identified in the staff 11 recommendations.
12 As a result of this, the ACRS has recommended, 13 and I think quite properly so, that there should be-some 14 caution expressed by the Commission, with respect to the:
15 absence of such an objective, to improve the public 16 understanding of what the extent of the reach is of Safety
'17 Goal objectives, and the reach of probabilistic risk 18 analysis to deal with human factor situations, the 19 effectiveness, efficiency if you will, of the management 20 of plants.
21
- Finally, and perhaps in one sense one of the 22 more important recommendations that the ACRS has made is 23 that cost-benefit should have no role when the purpose of 24 making a modification to the rules and regulations is i
Q_ :.
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objectives.
The interpretation which the staff places on i.:D~
2 this is that that is tantamount to, or equivalent to, a
j 3
statement of adequate protection which, in accord with the 4
backfit rule, when changes are made that are necessary in 5
order to assure adeqyate protection, cost-benefit cannot 6
be part of the argument.
7 I would add parenthetically at this point, it is
.8 certainly not clear to us that the ACRS necessarily had in 9
- mind, in using the word "ailequacy of the regulations",
j 10 something that has some sense of minimal acceptability to 11 it.
Our view is, and our understanding is, that their and you may get clarification from them in a few 12 view 0
is that there should be just one standard, one
{l 13 weeks 14 standard set of safety goals which are applicable to all 15 plants, and the regulations when properly structured, and 16 the regulatory practices when properly structured, should o
17 be both necessary and sufficient to be able to make a 18 determination that when they are met, then there is l
19 adequate and sufficient protection, and no additional 20 protection should be required of plants.
21 This view was reinforced by an ACRS letter in 22 July of 1988, the subject of which was the DOE sponsored 23 advanced reactor designs.
They raised, again, the age old k
24 question of how safe is safe enough.
And to us it appears
- l
\\W-l 25 that they equate this to the term " adequate protection".
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And, again, they state very clearly in that 2
particular letter that the safety goals should be the same 3
for all
- plants, present and future.
The staff I
4 recommendations do not make any specific recommendations 5
witn respect to most of the classes of potential futur.e 6
plants, particularly those that in the non-light water 7
reactor class.
8 If I may have the next slide, please.
(Slide) 9 Turning now to the staff recommendations, the general 10 approach deals specifically with use of PRA in regulatory 11 decisions.
Reminded that the safety goal policy itself 12 was largely created because of the recognition of the 13 potential for the usefulness of the methodology of 14 probabilistic risk ana;rsis in the decisionmaking process.
15 And you will see that our recommendations very 16 closely align themselves with the characteristics and the 17 state-of-the-art of PRA methodology.
18 The quantitative objectives that we refer to are 19 proposed to be considered as targets for generic 20 regulatory requirements, rather than criteria for 21 individual licensing decisions.
That is, one of the major 22 points we have attempted to make in the paper is that we 23 do not ask a plant to demonstrate that it meets a i
24 particular quantitative objective.
It is in this sense 25 that the essence of the recommendations being made to the l
l l
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Commission are guidance to the staff, and not some 2
- proposal, or even-hidden proposal, to create in some 3
- sense, in the future, a speci#ic regulatory requirement 4
that would be couched in the same kinds of quantitative 5
terms that the quantitative objectives we talk about here 6
are couched.
7 It also-is the intent of the staff that in the 8
implementation of safety goal policy, it.should play a key 9
role in the implementation of the Commission's backfit l
10
- rule, 10 CFR 50.109.
It provides some additional 11 benchmarks to gauge substantial increase in overall 12 protection.
13 By additional benchmarks, I mean the following:
14 In the safety goal policy statement two benchmarks have l
15' already been identified and approved -f or use by the staf f,
16 approved by the Commission for use by the staff, and these 17 are the two quantitative health objectives that are 18 specified in the policy statement.
19 In addition to those, as you will see, we 20 propose benchmarks that can be identified with the large 21 release guideline, which the Commission asked the staff to 22 consider for possible incorporation in this process and, 23 in addition, a proposed benchmark for core damage 24 frequency.
I 25
- Now, as we will see in a few moments, these i
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coordinate quite nicely with the characteristics of PRA p -
2 methodology, and we will have a Vu-Graph in a few moments L_
3 that will demonstrate that.
4 I'd also bring -- would like to bring to your 1
5 attention the point that is made in the paper, that the 6
Commission may wish the staff to consider developing a 7
statement on the relationship, if it wishes to identify 8
- any, of safety goal policy to an adequate protection 9
standard.
The reason for this is that it may be and has, in fact, been perceived by some--
10 perceived 11 that what the staff is proposing here is tantamount to 12 defining the roof of the structure, or the roof of the 13 house, without defining the foundation.
E i
14 If one perceives of the concept of an adequate 15 protection standard as some minimal level of 16 acceptability, then what we are talking about here is what 17 one might, by contrast, regard as a maximum level of need 18 to require.
That is, what we are talking about is a set 19 of objectives which, when the regulatory requirements are 20 suitably adjusted, should be regarded as sufficient and no 21 further regulatory requirements should be necessary and, 22 in fact, it should be impossible for a justification for 23 additional requirements to occur, based upon cost-benefit 24 recommendations -- that is, the benefit would be too 25 small.
i _
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1 COMMISSIO17ER CURTISS:
On this point. I take it I
i
't-2 from what you've said that the major dif f erence. between j
l 3
your approach and the ACRS is that the ACRS ' t o p-d o'wn 4
approach envisions that the safety goal would be used to 5
define adequate protection, or adequacy, and the staff's 6
proposed application of the safety goal would result in 7
its use primarily in the backfit arena.
8 MR. FOUSTON:
That is correct, yes.
9 Now, again, I want to say that our reading of 10 the ACRS is such that I cannot say that they are specif-11 ically identifying their approach with the concept of an 12 adequate protection standard, with its legal meaning--
'i 13 and this may be a point on which you may wish to s e e 'r 14 further cl a ri fication from them -- but the way they 15 characterize the process, and given -- if you put that in 16 the context of the existence of the present backfit ruir 17 which does identify circumstances in which no cost, for 18 example, would be considered when the objective cf a 19 change is to neet adequate protection, and also in con-20 junction with the backfit rule where there are provi-21 sions and requirements imposed upon the staff to properly 22 justify any substantial improvements in safety that do 23 admit cost considerations, when it is placed in that 24 context, one can draw the conclusion that the ultimate i
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create a definition for the s t a r. : -
of adequate 2
protection.
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3 COMMISSIONER CURTISS:
One other question on 4
this point.
From the standpoint of the practical day-to-5 day implementation of the backfit rule then, if the 6
staff's approach is pursued, what you are envisioning, as 7
I understand it, is to proceed with the two quantitative 8
health obsactives that the Commission has already approved 9
in the policy statement, the Safety Goal Policy Statement, 10 and to fashion benchmarkc for large release and core 11 damage frequency to be applied in that arena.
12 MR. HOUSTON:
That's correct.
13 COMMISSIONER CURTISS:
All right, proceed.
G~
'E 14 CHAIRMAN ZECH:
Proceed.
15 MR.
HOUSTON:
If I may have the next slidis, 16 please.
(Slide)
There are four principal elements in the in the 17
-- not necessarily all of equal importance I
l'8 recommendations that have been made to you.
One is the 19 establishment of a hierarchy of objectiver, which bears 20 some similarity to the ACRS proposal but is not identical 21 to it, and does not share all of the characteristics of
(
22 the ACRS proposal.
23 The second element is,
- again, is similar, 24 essentially identical to the ACRS recommendation.
They i'
'P-25 have used the term "a tampling program of PRAs", we refer 3
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here to a review of PRAs to assess the effectiveness of 2
regulatory requirements.
And regulatory requirements 3
there can be read to be either existing, or proposed.
4 Thirdly, the third element is an integration of 5
the risk reduction modifications and the testing of 6
proposed modifications.
- This, as we will describe a i
7 little bit later, can perhaps most conveniently be thought l
l 8
of as an accounting mechanism for keeping track of 9
modifications as they are made in plants, on a plant-by-10 plant basis, to have sore sort of record of how far we 11 have gone towards meeting the safety goal objectives, and 12 how far there may be yet to go.
l l
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13 Finally, we are proposing the use of what we are 14 calling subsidiary targets, particularly for generic 15 safety issue resolution.
And the reason for this is that 16 this is actually one of the principal applications of 17 quantitative targets that the staff has already used, and 18 has had a process for.
One particular, I think, very 19 noticeable example is in the development of the station 20 blackout rule.
The staff set for itself an objective of 21 core damage frequency of 10 to the minus fifth per reactor 22
- year, and then created a proposed set of regulatory 1
23 requirements in a more deterministic sense, to try to meet i
24 that goal. And this was the way the station blackout rule
,,(
25 was created.
So, it is that rame kind of process that we (202)234-4433 NEAL R.
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.1 have'in mind-.here.
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2 Most PRAs that have been done are not' full scope
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3 and.most of them are not full Level Three PRAs.
And in
~4 order to make use'of this kind.of a philosophy, if you 5
- will, it seems pragmatically necessary to break the 6
process down to some extent, so that one can use 7
quantitative objectives that are matched with the 8
information that one has in hand.
And that's why we talk 9
about the subsidiary targets.
10 COMMISSIONER CURTISS:
How many of the PRAs-i 11 cover external events?
1 12 MR. HOUSTON:
Probably, of those that we have 13 done or that we have available to us, somewhat less than.
k
,14
. half, perhaps 25 percent, or a third, somewhere in that 15 neighborhood.
)
i 16 If I may have the next slide, please.
(Slide) 17 This shows what we mean by a hierarchy of objectives, five 18 levels.
And in that sense, there is a similarity with the 19 ACRS recommendations, starting at the top with the 20 qualitative safety goals.
At Level Two, the quantitative 21 health objectives which, of
- course, relate to the 22 individual risk of early mortality and latent cancer 23 mortality.
3
~
24 Level Three and Four are focal points for i.
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25 proposed objectives, with the staff recommendations, a i
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large release guideline, and something which we would call r
2 an accident prevention objective.
And, finally, at Level C,
3-Five, the body of regulatory requirements.
4 As we have said, Level Three, of course, the
'l 1
5 large release guideline, was proposed by the Comnission l
6 for staff consideration.
And I might note of some 7
- interest, that it is one of the more dominant problems 8
associated with the staff's recommendations, has been to 9
come to grips with how one might best try to quantify what 10 a large release is.
i 11 On the next slide, if I may have that -- (slide) 12
-- you will see how these relate to the various fairly 13 well known levels of probabilistic risk analysis.
Levels i
14 Two, Three and Four which are the quantitative objectives, 15 associate themselves' tihen with, at L'evel Two, a full PRA, 16 which goes all the way to what we call here " consequence 17 mitigation", in an off-site sense.
18 Level Three is the accident mitigation, Level 19 Two of a PRA,
- and, finally, at Level Four -- in the 20 hierarchical level, this can get a little confusing with 21 respect to what kind of levels we are talking about, but 22 it corresponds tQ a level one PRA, which essentially 23 focuses on the in-plant systems and can be thought of as 24 an analysis of the accident prevention mechanisms -- that h
25 is, the things that are present in the plant, how they are (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.,
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1 configured which, if used properly, can prevent core F-~'
L.
2 damage accidents.
3 So, the hierarchy here is a little bit different.
4 than the ACRS recommends, in that they are not 5
specifically surrogates for successive levels.
- Rather, 6
what we are proposing is a reduction in the scope of the 7
objective to correspond with these levels of PRA and the 8
information that one has from the PRAs that are available.
9 To put it another way, if one has only Level Two 10 PRAs available, one cannot draw any conclusions with 11 respect to off-site mortality risk.
12 If I may have the next slide, please.
(Slide) 13 Looking now specifically at the Level Three objective
[L
~14 which focuses on combined prevention and mitigation, the 15 proposal in the safety goal policy statement was to have a 16 large release guideline, which is characterized as an 17 overall mean frequency of a large release should be less l
18 than one in one million per reactor year.
19 We are proposing in this paper, although this is 20 not a major part of it, that we ascribe to the word 21 "overall" here the meaning of a collective average over 22 all plants.
This refers to a question raised quite 23 sometime ago, I think by former Commissioner Bernthal, I 24 believe it was.
And the distinction here is that a fair h.
25 reading of the Safety Goal Policy Statemenc itself would
~~
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suggest that the only interpretation that one can place on 2
the Level Two objectives, the quantitative health 3
. objectives, would be on an individual plant basis because 4
they are che.racterized and essentially defined in such a 5
way that that is the only interpretation that can be 6
placed on them.
7 With respect, however, to both the Level Three 8
and the Four objectives, we are proposing to characterize
.9 these as collective averages over all plants.
Dow, the 10 reason for doing this is that it would reflect an 11 expectation of, and a tolerance for, the fact that when 12 particular PRAs are reviewed, they will tend to show some
,.2 13 variation about some mean value for them -- that is, they and there would be a
~14 will not all come up the same 15 tolerance for something being close to, perhaps, without 16 trying to quantify what that means, a particular 17 quantitative objective, and an expectation that this will 18 happen from time to time.
19 I am reminded of the fact that in the UK, in 20 conjunction with some hearings on a proposed plant, an 21 almost unteachable objective was set, which was not met by 22 the evidence that they had, yet it was a tolerable -- it 23 was an expectation and something which was determined to 24 be tolerable, and I think that same point of view can be d
l l
25 recognized here.
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23 1-One of the key problems with trying to come to
(
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2 grips with this Level Three objective, or the large 3
release guideline, has to do with the definition of what 4
the words "large release" means.
And we have considered a l
5 number of definitional options. These are primarily 6
discussed in Enclosure 1 to the Commission paper.
And 'we 7
have considered primarily four different possibilities.
8 One is to define a large release in terms of 9
health effects one is to define a large release in terms 10 of doses to individuals.
We have also considered, 11 although it is not mentioned in the paper, doses to 12 populations.
A third one is to consider it as a release.
strongly suggested, I should add, by the
( '-
13 as suggested
~14 ACRS -- which is sort of tantamount or equivalent to 15 identifying it as a source term.
16
- And, finally, the fourth option that we have 17 considered and proposed is an option which defines, in 18 effect, a large release in terms of containment failure.
19 And we will discuss that a little bit when we get to it.
20 If I may have the next slide, please.
(slide) 21 Continuing with this Level Three objective, we perceive
' hat there is sonsthing that I have called here a 22 t
23
" threshold problem" in coming to grips iv i t h the 24 definition, and I think it is a fairly easy problem to
(
25 understand, and let me characterize it this way.'
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If one were to propose to define a large 2
- release, for example, in some definition of curies of 3
material, a large release would be a very large number of 4
curies -- perhaps a million, perhaps 10 million -- and it 5
seems to me that it would be very difficult to explain why 6
one million or 10 million curies is a large release, and 7
99 million or 9,900,000 curies is not a large release.
8 There is no clear-cut knee in the curve, if you 9
will, no clear-cut threshold transition in terms of curie 10 releases, that one could quantitatively define, other than 11 somewhat arbitrarily as a large release, and then be able 12 to explain that something that is a little bit smaller
(
13 than that is not to be considered a l'arge release.
~14 That problem is really inherent in any 15 definitim-of a large release.
It is somewhat analogous 16 to the problem of defining doses to an individual that 17 might be below regulatory concern, but there you are 18 dealing with small numbers.
Here you are dealing with 19 larger numbers.
And so although there is an analogous--
20 it's an analogous situation, I think it is even more 21 difficult to understand, or would be more difficult to 22 understand such a definition.
23 And this is one of the main reasons that we have 24 departed from the ACRS recommendation, although we studied l-25 that quite extensively in various different possible (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.,
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forums, of characterizing large release as a source term,
.1 -
L-2 or as a release of radioactive material.
3 There is another aspect to creating a definition 4
for the large release, and that is the question of 5
consistency within the hierarchy of quantitative 6
objectives.
The safety goal policy itself identified the 7
fact that, which was pretty well known at that time and 8
nothing that we found out in the meantime would dispute 9
it, that the controlling objective here in the 10 quantitative health objective for early mortality risk, 11 and the specification placed on the quantitative health 12 objective for latent cancer mortality is not a controlling I
13 objective.
That is, if the QHO for early mortality risk e
14' is met, there is almost a hundred percent certainty that 15 the quantitative health objective for latent cancer 16 mortality would be well. met.
17 This was rather well demon.strated, for example, 18 in the treatment of the five plants in the draft of NUREG-19 1150, which was published in February of 1987, for the 20 l
five plants considered.
l l
21 Given that the QHO for early mortality risk is 22 controlling, what ws have focused on primarily with l
23 respect to coming to grips with a large release 24 definition, is a definition that is not inconsistent with p
25 that quantitative health objective.
As a matter of fact, (202)234-4433 NEAL R.
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1 this is, in one sense, why in the proposal that was made l
2 to the Commission back in early 1987, the one that 3
contained the matrix and so forth, it was recommended that 4
the large release definition be associated with the 5
concept of one or more early fatalities occurring outside 6
the plant boundary.
7
- And, as a matter of fact, a demonstration of 8
that computation was also made in Draft 1150, back in 9
1987.
That has the perceptual problem -- while that is an 10 interesting and potentially useful definition, and the 11 staff would like to continue to explore that as what I'd 12 call the surrogate for our proposed qualitative
(
13 definition -- it does have the apparent disadvantage that it seems to be a restatement of an objective in terms of 14 15 specific health effects, namely, early mortalities.
- And, 16 therefore, it would tend to " fight with, and not 17 necessarily be consistent with, the quantitative health 18 objective for early mortality risk, although calculated in 19 a somewhat different way and given a somewhat different 20 definition.
21 DR. MURLEY:
Excuse me, could I make a point 22 here?
23 MR. HOUSTON:
- Sure, 24 DR.
MURLEY:
With regard to reviewing the i
g R.
25 advanced evolutionary light water reactors, there is a (202)234-4433 NEAL R.
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proposal that -- it has come to be known as the EPRI large i
L-2 release guideline that we are, in fact, using and have 3
been using for the last couple of years, and it is the 4
following, if I've got it right -- the chances of an 5
accident yielding a dose of 25 rem at a half mile should 6
be less than one in a million per reactor yer.r.
7 That, I think, is consistent with the proposed 8
definition here, that Wayne is using, but I wanted to 9
interject that there is one that we have been using, that 10 the industry has proposed, and that we have accepted, that l
l 11 seems to be consistent with what we are proposing today.
12 MR. HOUSTON:
I agree, Tom, and I do have this h
13 on a later Vu-Graph here.
14 DR. MURLEY:
Oh, okay.
15 MR. HOUSTON:
It is certainly not inconsistent 16 with it, I think, is perhaps a better way -- it is a more apparently a more stringent goal that we are 17 stringent 18 talking about here, but it is not inconsistent with our 19 proposed statement, which is a qualitative statement that 20 a large release is any release that has the potential for 21 causing an off-site early fatality.
22 This statement is made primarily to assure an 23 element of consistency with the controlling quantitative 24 health objective ut, in and of itself, it is a qualitative i
i t
1 i
L._
25 definition, and requires some further definition in order (202)234-4433 NEAL R.
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to make use of it in a quantitative sense.
2 And to this end, what we have proposed at this 3
time is two potential, what we call " surrogates", for that 4
definition.
And one of them is basically the same as we 5
spoke of a moment ago, what we sometimes refer to as the 6
one or more early fatalities definition, as demonstrated 7
in NUREG-1150 draft, but with a slight variation on it.
8 And the variation would be that because the intent of the 9
large release guideline is to focus on the safety of the 10
- plant, and not contributions from site-related 11 characteristics, including emergency planning, the way it 12 would be used for this purpose would be in conjunction 13 with some standardized definition of site characteristics 14 sufficient in order.to make the calculation, but that same 15 standard site would be used, a hypothetical site, would be 16 used for any application, regardless of what plant the 17 balance of the PRA might have referred to.
18 And in that way, you would cut out site-to-site 19 variation, and focus just on those things that affect the 20 safety of operation of the plant itself and the design of l
21 the plant itself.
I i
22 COMMISSIONER ROGERS:
What would be the elements 23 in such a characterization of a standard site?
l 24 MR. HOUSTON:
The principal element would be the 7
i 25 meteorology that one ascumes here.
A second element would (202)234-4433 NEAL R.
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be some characterization of the off-site population. This i
U-2 might be simply to specify that you have -- assume that 3
there is an individual at some specified distance from the 4
plant, such as the mean distance that is characterized in 5
the quantitative health objective, which would be roughly 6
a half a mile from the plant boundary.
Those are examples 7
of the way that might be done.
Those would be the 8
principal ones.
9 There would be a residual question as to whether 10 in that calculation you would give any credit for 11 emergency planning, but that would be a washout when you 12 are comparing two or more plants together.
It's primarily n
13 the meteorology that would be the one.
t.---
14 The other surrogate that we are proposing would 15 be couched in terms of early containment failure.
- Now, 16 the reason the word "early" is there is because " hat in
~
17 general, one of the conclusions that one can draw 1.'m PRA 18 studies to-date, it is predominately situations, accident 19 sequences if you will, which lead to early containment 20 failure which, in turn, are predominately responsible for 21 the risk to individuals, the early mortality risk to 22 individuals, as distinct from late containment failures.
l 23 So here,
- again, what we are proposing is t
24 something which we believe would be consistent with -- as
- L_
25 nearly as we could make it in these terms -- with the (2021234-4433 NEAL R.
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quantitative health objective, but quite possibly somewhat 2
more conservative.
3 Now, one-of the reasons that we say in proposing 4
this as a surrogate at this point in time, rather than, 5
for example, as simply a proposed definition is, in part, 6
because we have not done enough analysis to determine just first of all, ifz it is 7
how conservative it might.
8 conservative, and
- secondly, if it is, just how 9
conservative it might be.
And we think this needs some 10 further examination.
11 To perhaps further amplify the meaning of using 12 this definition as a " surrogate" for a large release, what
- ~ "
13 is intended here is a situation in which an early open 14 pathway is created in the plant for, radioactive materials 15 to be transported from a damaged core, through the 16 containment, into the environment -- that is, all barriers 17 to fission product release have been lost at this point.
18 So that is, in a sense, the essence of that.
19 There are some other definitional problems with 20 applying it, s'uch as how large an opening, for example, in 21 containment, but once you get beyond something that is-22 perhaps a foot or more in diameter, it makes very little 23 difference in terms of what gets out.
7-24 If we may turn now to the next slide -- (slide) i t.-
and begin to focus on the Level Four, or accident 25 (202)234-4433 NEAL R.. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.,
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prevention objective.
I might say that we well recall I
2 that a number of years ago, in the proposed version of the 3
Safety Goal Policy Statement itself, it had been proposed 4
to incorporate an objective for core melt or core damage 5
frequency and, of course, that was removed frcm the policy 6
statement that was published in final form in 1986.
7 This is,
- however, a very useful quantitative 8
objective to the staff, and we feel also, to a large 9
- extent, to the industry, to designers of plants, for 10 example, for future plants.
11' We mention here two optional definitions, I've 12 alluded to it before.
One uses the words " core damage",
i.Q 13 and the other uses the words, " core melt".
14 We prefer to associate th.e word " core darage" 15 wi th the definition that it means basically the loss of 16 adequate core cooling. That is, an event has proceeded to 17 the point where water is no longer beino delivered to the 18 core. And that's the point of departure, and that is very 19 close then to what one might call incipient core damage.
20 The term " core melt" is often considered to 21 mean, as we indicated earlier, pressure vessel failure and 22
" core on the floor".
Our proposal is to focus on the 23 prevention of an accident, as is done in a Level One FRA, 1
j 24 and we recommend the use of the term " core damage", and p&
l 25 that it be given a definition understanding that is to (202)234-4433 t!EAL R.
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mean loss of adequate core cooling.
2 Turning to the next slide, 12.
(Slide)
The 3
quantification that is recommended here is that the 4
overall mean frequency. of core. damage events should not 5
~ exceed 10.to the minus 4,
that's one part in 10,000 per 6
reactor. year.
- Here, again, we would employ the same 7
connotation to the word "overall" as an aggregate average, 8
over.all plants that are operating at any given time.
9 CHAIRMAN ZECH:
It seems to me we have been 10 through this before, sometime ago, didn't we?
Hasn't this 11 been brought to the Commission before, the use of this 10 12 to the minus - 4.
and we had some discussion on it.
As 49.
13 I recall --
M 14 MR. HOUSTON:
That is correct, that is correct.
15 CHAIRMAN ZECH:
As I recall the Commission 16 policy statement did not contain those elements.
17 MR. HOUSTON:
That is correct.
18 CHAIRMAN ZECH:
You are going to tell us your 19 views on that now, I presume.
20 MR. HOUSTON:
And it's our view that it would be 21 a desirable thing to have in a plan tu implement the 22 Commission's safety goals, and that it really should be 23 part of the -- what we've called the hierarchy of 24 quantitative objectives.
the ability of a PRA, 25 It is, in one sense (202)234-4433 NEAL R.
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Level One,,probably produces the most robust bottom'line p-
~~
2 result of any part of a PRA. The main reason for this is 3
'that you are dealing with systems in place, in the plant,.
4 when-you deal with it. Whereas when you get to a Level 5
Two, you - are' now dealing with systems that are out of 6
- control, you-are dealing with phenomenological
^
7 circumstances inside a vessel with a progression of core 8
melt and uncertainties associated with how that might 9
proceed, and uncertainties in containment performance, et q
10 cetera.
11 This is basically on the grounds that it.is a 12 very useful objective to the staff to deal with potential C
i-13 modifications to regulatory requirements that can be 14 associated with the.pr.evention of accidents.
15 I
mention
- here, perhaps somewhat 16 parenthetically, a subsidiary target for future designs.
17 COMMISSIONER CURTISS:
Let me jump in there, 18 before you get to the future designs.
Back to my earlier 19 question on the relationship of this approach to the 2O backfit rule.
Applying this approach in the context of 21 what we currently do on backfit, that if this objective 22 were adopted, one times 10 to the minus 4, that would mean 23 that that is the definition for purposes of this - - - of 24 core damage, of substantial additional protection?
25 MR. HOUSTON:
Yes.
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COMMISSIONER ' CURTISS :
In other words, if a L.
2 plant were below this --
3 MR. HOUSTON:
If a PRA on a plant reflected a 4
bottom line result for. core damage f r e q u e n c y t h a t.
was 5
considerably below-this,- an initial observation and -the 6
initial conclusion that one might draw, is that one: does 7
not need to impose any additional requirement on that 8
plant for accident prevention purposes because that target 9
is already met.
10 COMMISSIONER CURTISS:
And if it is above it?
11 DR.
MURLEY:
Wait a minute, I
thought we 12 concluded we were not goirg to use --
h' 13 MR. HOUSTON:
We can't, that's correct.
14 COMMISSIO.NER ROGERS:
,I was getting very 15 uncomfortable.
16 MR.
HOUSTON:
I was about to introduce that.
17 qualification.
18 COMMISSIONER ROGERS:
Yes.
i 19 MR.
HOUSTON:
Nevertheless, as I had said up 20 front, the comparison of a bottom line PRA result with a 21 quantitative objective in a safety goal hierarchy is 22 inevitable.
It is a comparison that anybody will make.
23 And the question would be asked "Does this plant meet that 24 safety goal target?"
25 Now, it is not a very satisfactory answer to say (202)234-4433 NEAL R.
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i with numbers staring you in the face, that I can't answer 2
that' question.
That would be a logical answer because it 3
may well be that the FRA you are looking at, for example, 4
did not include ali external events.
_And as you will see 5
in a moment, we incorporate in this definition the concept 6
that the FRA, in order to make a fair comparisor it 7
really should be a full. scope PRA that deals with internal R
and external avents, 9
DR.
MtfRLEY:
I would enter another reason. and 10 that is that the numbers that go into calculating risk for 11 an individual plant have to make some assumptions about 12 human error rates -- That is, how well a plant is k
13 operating.
14 There is no way that an analyst. sitti ng at his 15 desk cranking out these numbers can assess how well a 16 plant is operating, but he makes some assumptions, based 17 on averages taken from, actually, from Air Force studies.
18 And those are adequate for making generic decisions.
19 In my judgment, they are not adequate for 20 substituting our judgment on how we d a plant is being 21 run.
Therefore, I am vary skeptical about using PRA 22 no-hers for making judgments comparing with a safety goal.
23 So.
Wayne's point about having numbers staring i
24 us in the face and how do we deal with them, I have no 25 troubia with that at all because that tells me that i
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assuming an average way.of operating a plapt, this-is how 2
-- it is an indication of how good the design is, that's 3
.how I view it, but it is not necessarily a reason for.
f 4
taking action if they don't meet the goals, or a reason 5
'for accepting it if they do meet the goals, in my 6
judgment.
MR.
HOUSTON:
- Yes, that's correct. And I w a's 7
8 about ~ to qualify my response to that effect.
Again, I 9
will go back to the statement I made near the-beginning, 10 that the comparison that one might make is sort of 11 inevitable. The conclusion that'you draw from it, though, 12 should go to the effectiveness of our regulatory
,U
'13 requirements, and not the plant itself.
A 14 But one. sample -- one PRA,.in and of itself, may 15 be an inadequate sample size to draw, to make a definitive
,16 conclusion that would cause one to immediately change a 17 rule, for example.
18 COMMISSIONER CURTISS:
But with those two 19
- caveats, the human performance caveat and the generic 20 average
- caveat, this is not going to be used for or for evaluation of specific plants.
If 21 application 22 you reached a situation where a group of plants, or all 23 plants, did not meet this standard, and if this approach i*
,7 24 is going to be used in the backfit arena, once you have
\\.s 25 made that determination, do you then undertake a cost-(202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 m-ommmm a c o a nom noenmoa m o onamommamm a n anaam
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benefit evaluation of whether or not to take additional L_
2 action?.
3 MR. HOUSTON:
Yes.
And what we are saying is 4
this would be part, but not all -- this would be part of 5
~the evaluation of the benefit, if you will, or. the 6
improvement in safety.
This would be one piece ~ of 7
evidence,.not the only piece, but one piece of evidence 8
that one would cite in that regulatory analysis.
-9 MR. TAYLOR:
I would like to mention, I think it 10 was a few weeks ago or so, that the Commission was briefed 11 on NUREG-1150, up through the core damage aspect. And you 12 recall we talked about a particular design issue at Zion i
I' 13 that had, by the analyses, showed an outlier, due to a t
14 component cooling. water issue, which is strictly related 15 to the potential design failure.
L 16 Now, that was a tool to show that.
And, as a 17 matter of fact, I believe even before the staff got' to 18 brief you, Commonwealth Edison had looked at that as a 19 useful thing to work on and, in fact, identified a very 20 simple fix to help to reduce that possibility.
And there 21 it is strictly as a stimulant, an understanding that 22 wasn't particularly apparent before this analysis had been 23 done.
P 24 CHAIRMAN ZECH:
General Counsel, do you have a L_
25 comment to make?
Did you want to enter into this?
Did (202)234-4433 NEAL R.
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you have something --
2 MR. PARLER:
Not reallir, except as I listened to I-3 the discussion I asked myself._ this question:
Presumably 4
this document is not going to be equivalent, at least at 5
this stage, to adequate protection as the ACRS'seemed to
-6 prefer.
7 I ~also understand from the discussion that 8
presumably this document, if it is put' into effect, would 9
not be used for plant-specific backfit purposes.
About-10 the only thing that is left then is for generic purposes, 11 in ru:emaking, and I have a footnote to that.
Apparently 12 there is some concern that still remains as to whether or 13 not the backfit rule itself should apply. to generic 14 rulemaking.
15 So, I suppose, Mr. Chairman, that's why I looked 16 kind of like puzzled.
17 DR.
SPEIS:
If I
may add one thing, Mr.
18 Chairman.
19 CHAIRMAN ZECH:
Go ahead.
20 DR. SPEIS:
It is possible that you can utilize 21 the results of the PRA on a plant-specific basis.
' iou 22 look at the numbers and then you will scrutinize the'PRA 23 and see-if there is something that looks suspicious. And 24 then you will focus on it farther, and then if you think
~
25 there is merit in pursuing a fix, then you will apply the (202)234-4433 NEAL R.
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backfit rule to that issue.
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2 So, the PRA numbers then will go to the l
3 scrutinization of the study itself, and see where you take
.i i
4 it from there, but it doesn't avoid using the backfit rule 5
at that point.
6 CHAIRMAN ZECH:
As I recall some of the previous 7
Commission discussions we have had on this subject, one of 8
the things that we try to keep in mind is that the safety 9
goal is one thing, it is a goal.
It's a goal that should 10 provide a foundation for our thinking, and our review of 11 our various requirements.
We should be able, for example, 12 looking at it as a goal, to test new and existing 13 requirements, to see whether they are consistent with our 14 safety goal.
15 We also discussed the PRA itself, and the whole 16 process. And I agree, they do get intertwined, but it 17 seems to me that our discussion at that time led us to 18 conclude that although PRA has great value -- and we 19 appreciate the logic process going through in formulating 20 a PRA and in examining the potential weak points in the 21 plant, or the weaker points in the plant, to see whether 22 actions should be taken, and we, I think, generally agree 23 that that's the greatest value you get from a PRA -- but f
24 it does seem to me that we all, at least the Commission at 6..-
25 that time, felt that we should be very careful about (202)234-4433 NEAL R.
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coming up'with a bottom line PRA number and. latching onto 11-2 it, and then using it for regulatory requirements, or 3
other specific actions.
Notwithstanding the fact that we 4
recognize the value of the process, it is the bottom line 5
number that I think was a concern-to us.
6 And if.I recall when we came up with the safety i
7 goal itself, there was considerable discussion about this 8
very issue, whether or not we should include core ~ damage 9'
to the extent that we might consider PRA numbers and so 10 forth.
And for that very reason, we came up with that 11 statement in the goal, not in the goal itself but in the 12 statement, as I recall that went along with the goal, that e'(-
13 said to the effect that we were looking at some number 14 like one in a million,-for a large off-site release, which 15 would include, of course, core damage plus containment 16 failure.
17 Now, that's as close as the Commission at.that 18 time at least would come up with any kind of number. And 19 that, again, I think was stated reasonably clearly, to be 20 used by the staff as an objective, if you will, rather 21 than a rigid requirement.
22 So, I guess the only thing that is important j
23 would be to recall some of those previous discussions we l
i:
24 had going over this very issue, was that we were trying to
(
25 focus on our primary responsibility of this agency -- at (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600
'4.,
p 41 and that is for public health 1
least I was at the time
' nd our goal is public health and safety.
2 and safety.
A 3
That's the mission of this Commission.
4 And I think it is important that we keep.that in 5
mind in everything we do.
And - a t that time I know we 6
talked about on-site release and off-site release and so 7
forth, and I. understand you are going to talk about that a 8
little bit-later, but the only point I am trying to make 9
here now is that if our mission truly is public health and 10 safety, and it is, then we are concerned about damaging 11 the public,. hurting the public.
12 We also had discussions about damage to the in t_ _.
13 environment, you know, from a major release.
So, to me, 14 the saf ety goal is the-very broad goal.
It should be used 15 in terms of broad thinking.
We should, indeed, try to 16 test our requirements to the goal, but I think we must be l
17 very careful before we bring in these bottom line numbers.
l 18 And I think, as Dr. Murley was pointing out, the 19 greatest use of the whole procedure is to see where we 20 should perhaps take actions to address safety issues, but 21 we should refrain from saying that something is 22 sufficient or is not sufficient, based on the number 23 itself because that number itself can draw us off in the
[.3 24 wrong direction.
- a. 2-25 I believe that is kind of what we discussed.
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42 1
.DR. MURLEY:
It was.
2 CHAIRMAN ZECH:
Does the staff have any 3
different thinking at the present time?
4 MR. TAYLOR:
That is staff's thinking.
5 CHAIRMAN ZECH:
All right.
Thank.you.
6 COMMISSIONER ROGERS:
I would just say a little 7
bit on it. -
I quite agree with that interpretation and 8
approach.
And it seems to me that the way the' objective 9
is stated in a sense implies that because it is a-mean 10
'that is stated, not -- and that implies that there is some 11 kind of a
statistical distribution that that mean 12 characterizes, but there is nothing more said about that k.l~ \\
e l
13
' statistical distribution, namely, a standard deviation or 14 anything of this -sort.
So, it is not a step to try to-15 really make it, although it implies there is a
16 distribution because we are talking about a mean.
It 17 doesn't try to characterize that distribution any further l
18 by saying that a number has to have a standard deviation l
l 19 on that number.
20 Furthermore, the number itself, to those of us 21-who use numbers in the technical sense, is an imprecise L
22 number.
It is one, 1.0, one, approximately one -- I mean, 23 the one looks like it is precise number, it really i
24 isn't.
We are talking about something of the order of 25 one, close to one.
There isn't a decimal point involved (202)234-4433 NEAL R.
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1 there, it'is not 1.0 ',imes'10 to the~minus 4.
L:_
'2 So, there is a certain lack of precision in this 3
statement that is what, in' fact, I think we want.
It does 4
imply that we.are looking at this issue from a. statistical 5
' point ~ of. view.
There is a distributions And within that 6
.mean that's what we hope to achieve, but we know that when 7
you have a mean, ' you 'will _ have. something above and L
8 something below, you don't have a mean.
Either you have 9
o n e' n' umber that characterizes every element inL that 10 distribution, or you have a distribution-about that mean.
11' So, that's built into the language here to ~ some
' 12 extent, and I think that is fully consistent with' this
- P i '
13 view of usina it that way.
It isn't precise.
You 14 couldn't take the-one-to mean
.9 fails, and it doesn't say 15 anything about what is acceptable within the distribution.
16 I would like to, without taking us off in a 17 totally different direction, point out though that we 18 should keep in mind that there is this distribution.
And 19 if we had 10 reactors in the country and they met that, 20 and -- by being close to that number, and we created a 21 hundred reactors that still averaged the same number but 22 had a much wider distribution, I think we would be 23 worried.
't"
.F 24 So, that distribution ought to sharpen up in L.;_
25 time, as we learn more and more how to build, construct (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600
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1
'44
)
1 and operate safe reactors, not broaden in time, if.you
/
I 2
know what I mean.
3 MR. HOUSTON:
That's right.
~4 CHAIRMAN ZECH:
Shall we proceed?
5 MR. HOUSTON:
Yes.
We pointed this out in the 6
Commission paper, that the IPE program itself is. intended 7
to move in the direction of narrowing that distribution.
l 8
Continuing on page 12, we are suggesting here a 9
subsidiary target for so-called future designs of a core f
10 damage frequency of 10 to the minus 5 per reactor year.
11 When we talk about future designs, we are talking about 12 situations which are still in a stage which can, in 13 principle certainly and in fact, are'in the design stage, i
14 and they can be designed to some specified standards.
15 So, the situation is a little bit different for 16 future plants than it is for present plants.
That number 17
'is one that has been. suggested by the INSAG Report, the 18 International Atomic Energy Agency, in 1988.
Although by_
19 no means should it be inferred here that that was 20 suggested as a regulatory objective, or regulatory 21 standard, simply a standard for the plants.
22 It is also identical to what was proposed by 23 EPRI for advanced light water reactor designs in the ALWR i
24 requirements document. And it has been proposed by General l
25 Electric Company, and accepted by the NRR staff, for the (202)234-4433 NEAL R.
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4 45 1
advanced boiling water reactor as a target or objective I
k-2 for the ABWR.
3 DR. HURLEY:
Can I make a point in that regard?
4 Here we are not being slaves to the exact numbers, like 5
you mentioned, Commissioner Rogers,
.9 or 1.1, but I think 6
it is fair to say that we believe that the advanced 7
reactors can be at least a factor of 10 less likely to 8
have core damage accidents than the current generation, 9
just by improved design.
10 I think tha t 's a proper use of th's kind of 11 numerology.
12 CHAIRMAN ZECH:
- Well, I don't know what the L.
13 right number is. but there is no question that for future.
c.-
~
14 designs we should, indeed, attempt to make them inproved, 15 as far as safety is concerned, for future designs.
And I 16 think that is what you are saying.
17 DR.
MURLEY:
And n factor of 10 we think is 18 about right, and the industry thinks is about right.
19 CHAIRMAN ZECH:
Yes, and that is something that 20 I think is something reasonable to shoot for as an 21 objective.
And that's what you are labeling it here, and 22 I think that's appropriate.
23 Let's continue.
24 MR.
HOUSTON:
Turning to the next page, 13--
i p
k.-
25 (slide)
-- I would like to say a few words about the 1
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46 that is, bottom line 1
process of' comparing-PRA results 2
results.-- to safety goal objectives. :First, and we have i
3
.already alluded to this,. is the question of what I will 4
call scope.
The objectives th'at ' we. are identifying'here 5
are intended to mean'that all initiating events, external 6
and' internal,.except sabotage,-should be incorporated in 7
the concept of the target there.
8 And this'is entirely consistent with,. identical 9
with a statement in.the Safety-Goal Policy Statement with 10 respect to interpretation of the quantitative health 11 objectives.
All we are saying here is we want to be ~
12 consistent-with that approach.
That is, it is intended I
(;
13 that these are objectives, when one has gotten all of'the 14 kinds of initiating events, except sabetage.
15
- Finally, I wanted to add on this question 16 because we do have external event PRAs, many of which
> 17 treat matters of seismic concern.
And there is a tendency 18 in external event PRAs to deal with what is sometimes 19 referred to as
" bounding treatments of the events" 20 because, in the absence of some detailed historical data, 21 for example.
So it becomes a little bit (.ifficult to 22 really interpret very cleanly in a quantitative sense, i
h l
E 23 some of the external event PRAs.
24 And in a moment I will have another statement
.(r).
25 that I will make that also alludes to this same problem, i
l
m.
-47
^
regarding making such 1
but there is another ' question
.2
- comparisons, and this has to do with the matter of how p
' L :-
3 uncertainties are treated in a PRA.
4 As Commissioner Rogers has pointed out, we've 5
defined these objectives, and we are proposing that these 6
objectives be defined in terms of mean values, which
)
7 implies a distribution.
Now,.many PRAs are done making 8
point estimates of bottom lines.
And 'there may be AL 9
discussions of uncertainties in the analysis, but.the
.1 10
' uncertainties are not propagated through the analysis, so
.j i
11 one does.not obtain a distribution.
And, therefore, by d'finition, you don't obtain a mea'n value.
12 e
13 It could be an analyst's estimate of what a'mean b.
14 value might be.
It could be an analyst's estimate of what 2
15 a most likely value would be. But this is a caution on 16 making comparisons.
I don't mean to imply that one cannot 17 under any circumstances make the comparison, but it can be
'13 something like an apples and oranges comparisen because 19 they are not stated and defined on the same basis.
20 On the other hand, if mean values are used, it 21 implies shat uncertainties have been propagated through 22 analysis and this would be, theoretically, the correct way 23 to make the comparison.
24 Going on to the next slide -- (slide) -- page
(;]
the next 25 14, I will say just a few brief words about (202)234-4433 NEAL R.
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- 48
.. a 1
element, I'think was. identified as the third earlier -- on 2
the integration of risk' reduction modifications.
I Il 3
referred to. 'i t,
in introducing' it earlier, as an 4
accounting tool.
We have had under development in the i
q j
5' Office of-Research for a number of years, some codes that l
.6
.can actually be run on a personal computer, which appear l
.7
.to.have veryL great utility in
'd e aling - wi th - PR A 8
information, in part, as simply ' a fi'1'ing system- 'for 9
compiling information from a PRA, 'which has been done,.
10
.which can then be readily accessed on a:PC by' members of 11 the staff, as-they' gain experience with'the tool.
12 The'information contained therein on file-can be 13 updated from time to time, either with new PRAs, or when gs U
14 plants have actually made modifications that would change 15 some ' of. the results - of ' the PRA, then the file' can be.
16 updated on that.
17 Then at any. given time, that file and whatever 18 number of plants are.available, and it is a growing number 19 in the data base that we have, one can use that as a means 20 of testing the potential for risk reduction modifications.
21 As you can, if you will, play "what if" kinds of games on-22 the computer to determine what kind of reduction in core 23 damage frequency, or reduction in health effects, or 24 reduction in large release frequency -- one can query the
~
25 system in that fashion.
~ (].
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.1 So, what all this is is an element that we feel' 2
that it is very appropriate, and desirable to continue 3
work on the use of this kind of tool.
A' nd it has very 4
definite application in the implementation plan.
5 Proceeding to the next slide (slide) -- we 6
identified a key element of the plan to review PRAs, to 7
assess regulatory requirements and, again, a few more 8
words on what. this means.
It is still basically a 9
sampling process.
The size of the sample will be expected 10 to grow in time.
At any given time if a decision.is made, j
11 a particular regulatory decision is made, it will be made 12 on the basis of some particular sample size, which may be
([ ^
13
- small, it may be 1.a r g e,
depending on the number of
~14 relevant PRAs one has available.
15 We expect 17UREG-115 0,
in its ultimate final--
16 currently revised form and - ultimate final form, to have 17 utility in this process.
It would be a PRA which, efter 13 the completion of the peer review, we feel that one could 19 have very high confidence in the conclusions and.the 20 insights that one can draw from it.
21 We are hopeful that we will be able to apply j
l 22 this in the further evolution of the Containment 23 Performance Improvement
- Program, the CPI program, 24 particularly with respect to the use of perspective
- l k..
25 definitions of a large release and the large release I
i
~
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guideline, to try to demonstrate the impact upon that 2
number as an objective with respect to any proposed 3
changes, or modifications, or improvements-that the staff 4
might suggest for various containment classes.
5 We would expect to also be able to consult and 6
review PRAs that have been produced by industry. There are 7
a number of them that are presently in-house that have i
8 been voluntarily submitted by licensees, for the. most 9
part, for the purpose of suppert for license amendment 10 applications that they may be simultaneously requesting,-
11 but these also have useful information, which we propose 12 tb draw on, and ultimately, when IPE results are made 13 available to us several years from now, a larger sampling
(
14 of PRA, or PRA-like results will be aveilable to the staff 15 for use in this process.
16 A word about the general use of PRA in safety 17 issue resolution.
This is an activity in which the staff 18 has engaged in for a number of years.
It has been i
19 utilizing PRAs in the process of resolving generic safety l
20 issues.
And in a sense what we are talking about here is l
21 suggesting that this process might receive some sort of l
22 formal acknowledgement or acceptability on the part of the 23 Commission, provided it is used in a manner which is I
24 consistent with safety goal policy and any authorized l(,
25 quantitative objectives.
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CHAIRMAN ZECH:
Why don't you come to the l
F 2
Commission with recommendations, so you can word it f
L_
3 careftilly and we can look at it carefully, if that is what j
4 you want?
5 MR. HOUSTON:
We can certainly do that.
6 CHAIRMAN ZECH:
Let's do it.
If that is what 7
you want us to do, word it carefully and let us review it 8
carefully, and we will get back to you.
9 MR. HOUSTON:
Turning to the next slide, if I the subsidiary objectives.
A key point 10 may -- (slide) 4 11 that I alluded to a little bit earlier was the use of 12 internal event only PRAs, since they really do constitute 13 a majority of PRAs that we have available.
And it would y
14 seem not particularly constructive to say we can't use 15 them because they'are~' dealing only with internal events.
16 And what we are proposing here and suggesting is 17 that we use the same numerical objectives.
This creates 18 an apparent anomaly, a philosophic or a logic anomaly, and 19 it has the c2fect which is sometimes called the one plus 20 one equals one syndrome.
We choose to suggest it this way 21 on the grounds that we would prefer not to partition the 22 safety goal objectives and give the appearance of allowing 23 so much for internal events, and allowing so much for 24 external events.
So that's a major reason for it.
25 The other is that in the context of the 1
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1 uncertainties.. associated with PRAs, it does not make 4
- 2 sense,,for sxample, to take an objective of, say, 'in terms 3
- of core damage frequency, half - of it be allowed to be
' 4 initiated by external events, and half of it be allowed to
.5 b e. a-target for internal events because the PRAs 6
themselves have uncertainties which sort of swamp that-7 kind of division by two, or by any other number, the 8
distinction that one might make between the two.
.9 DR. MURLEY:
In other words, one plus one does 10 equal one, which was as accurate as we can measure --
11
'MR.
HOUSTON:
In ' PRA space that's a true 12 s'tatement, one plus one equals one, right.
13 And another one which is not a major point, is
,14 that we would propose t c-use subsidiary objectives, or 15 formalize the. use cif ' subsidiary' objectiv'es, f or limited 16 range initiating events PRAs.
For example, in dealing 17 with the station blackout rule mentioned earlier, the 18 initiating events, by definition, were associated with 19 station blackout events.
It did not incorporate when-the 20 PRA work was done, insights drawn from them, so that the 21 bottom lines and core damage frequency, or health effects-22 if they were calculated, would not correspond precisely to 23 the -- definitionally to the objectives that had been set 24 up.
These, of course, should be consistent with the i l l((
25 principal objectives that are approved.
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53 1
Turning to the next slide --
(slide) -- Dr.
l I
l-2 Murley has mentioned some industry objectivas.
The ACRS 3
has addrassed this, should they be identical.
The ACRS d
view, of course, is that they need not be identical. The 5
staff does not disagree with that.
What the staff is 6
doing with respect to proposed industry objectives is 7
simply to recognize that they are laudatory objectives and 8
the staff is quite willing to measure the results of the 9
design in terms of the proposed objectives that have been 10 set by EPRI or General Electric Company.
They are not, 11 however, requirements placed on those designs.
12 In the case of the EPRI ALUR requirements P
13
' document, they have identified what they call a
L
~14 quantitative investment protection goal. which is the core 15 damage frequency.
They see this in terms of protecting a 16 utility's investment, and quite properly so.
17 They have also identified another goal, which is l
18 the one that Dr. Murley alluded to several minutes ago, 19 which they characterize as a quantitative public safety 20 goal. This is the ons which conveys a sense of association 21 with the idea of a large release, although they do not use 22 that characterization of it, but it is the one that they 23 propose to be 25 rem in a half mile, at a mean frequency 24 of 10 to the minus 6 per reactor year.
I' j,
k... -
25 In the case of the advanced designs by DOE, (202)234-4433 ffEAL R.
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they've proposed a goal that really relates to off-site
'~
2 emergancy preparedness, in particular, an even rore 3
stringent goal which would, if met, in fact, and with high 4
assurance, could give the appearance of alleviating the 5
need for certain aspects of off-site emergency 6
preparedness.
7 (Slide)
In the last two slides, I attempted to 8
summarize the principal recommendations and the principal 9
things that we are asking for Commission authorization or 10 approval.
These are the proposed statements and 11 definitions associated with the quantitative objectives, 12 at what we call Level Three and Level Four in the
'(.
13 hierarchy, the large release definition and the core
~14 damage definition at Level Four.
15 ISlide)
On the last page, we are proposing also 16 that it is probably appropriate if the Commission were to 17 approve, in whole or in part, the proposed recommendation 18 for implementing the safety goal policy. We believe that 19 probably the best method for doing this would be to 20 construct and bring back to you a conforming amendment to 21 the safety goal policy statement itself, which would 22 primarily be part five of that policy statement, the 23 subject of which is guidance to the staff.
24 Although not having mentioned previously in the i
k 25 briefing today, the matter of cost-benefit is something
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that still bears some: association to the safety goal L2-2 policy statement.
It was part and parcel of the original 3
intent on the part of the Commission to deal with cost-4 benefit issues.
5 The staff has indicated that we associate the 6
implementation plan to a very large extent wi th. matters 7
associated with implementing backfit policy which, of 8
course, applies to existing plants, but we did want to add 9
here that another recommendation of the staff is that in 10 accordance with the advice of the General Counsel, that 11 approval be given to the incorporation of diverted on-site 12 costs as the net cost trade-off, in the fashion that they 13 have suggested is not only legitimate, but virtually L.
~14 required, if I recall the --
15 CHAIRMAN ZECH:
Perhaps it would be appropriate l
16 for the Ganeral Counsel to make a c o m m e n t-,
17 1:R. PARLER:
The question was asked several 18 years ago, as I now recall, by a Commissioner who is no 19 longer a member of this collegial body.
The response was 20 provided.
The response essentially was that if a licersee 21 incurs on-site costs to protect the licensee's property 22 and things on the site, that should, in effect, for cost-D ben
- fit purposes be viewed as a benefit to the licensee 24 and, therefore. the overall or the net cost should take i
p
-L.
25 into account.
It was not something that we recommended in t ?.0 2 ) ? 3 4-4 4 3 3 TIEAL P.
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a i
a 56 1
connection with this particular pap r It was something 1
V 2
that we were asked to provide advi a mn by f or v r 3
C orn i s s i cn e r Bernthal several years ago.
IJe did, and T 4
haven t %ard any negative reactions to it.
3 CH AIR M Ai! ZECH:
It is the same position, though, 6
you have taken before?
7-MR. PARLER:
Yes, which we stick by.
8 CHAIRMA!! ZECH:
All right, fine.
9 MR.
PARLER:
It is really a common sense 10 position, which --
11 CHAIRMAN ZECH:
I just wanted to make sure it 12 wasn't some new approach you were taking.
~
13 HR. PARLER:
tio, sir.
~14 CHAIRMATI ZECH:
Thank you.
15 All right 16 14R. HOUSTOM:
I would just say in conclusion 17 that the specific requests being made to the Con mis sion 18 are identi fied in the Commission paper itself, the things 19 that we think are most important for your attention.
20 CHAIRMATI ZECH:
All right, thank you very much.
21 MR. HOUSTON:
Thank you.
22 CHAIRMAtt ZECH:
Any questions from my fellow 23 Commissioners?
Commissioner Roberts?
24-C OMtiT S S I O1IER ROBERTS; I
don't have any i
(c:,. c 25 questions, I sure want to hear from the ACRS. And at this (202)234-4433 NEAL R.
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57 point I am certainly not prepared'to accept a number of 1
- C JOM-2 the' staff recommendations.
3 CHAIRMAN ZECH:
All right, fine.
4 Commissioner Rogers?
5 COMMISSIONER ROGERS:
Just a couple of things.
6 I thought this was~a very helpful-briefing.
It helped me 7
to put things in a perspective.
It has been difficult for 8
me..
Some of these things seem to float around in a way 9
that it is tough to pin-down, but I think there were a 10 good many clarifications 'came out of this briefing.
It 11 still requires a great deal of thought, though.
12 Could you just review very briefly again, h
13 because I am not sure I got tihem point by point, where the 14 really substantive differences are between your proposal 15 and the ACRS?
If you could just go over those once again.
16 MR. HOUSTON:
All right, the principal one~--
I 17 think one could say the principal one deals with what we 18 have called the adequate protection issue.
It would 19 appear that a)though the methodology we are talking about 20 bears very much similarity -- as a matter of fact, it is 21 essentially the same, but the ultimate object with respect 22 to what any modifications to rules, or regulations would 23 mean in terms of adequate protection, is different, that's 24 the main one.
L 25 A second one is that the hierarchy -- what we (202)234-4433 NEAL R. GROSS & COMPANY, Il?C. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.,
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58 i
1 have called the hierarchy in the staff recommendations, J
it is really not the hierarchy in the same 2
does not 1
3 sense, or in the sense that the ACRS properly used that I
4 term.
i 5
The reason I say that is that what we have done 1
6 in the hierarchy is to really reduce the scope of the--
7 as one goes down the levels, so that one can no~ longer 8
regard the successive levels as surrogates for the level 9
above.
And they stand somewhat independently, but related 10 to one another and tied into the characteristics of doing 11 the PRA.
In other words, we have associated it more 12 strongly with PRA methodology than has the ACRS.
i I
[*
13 A third one is the large release definition.
14 We've spent a great deal of time interacting with the ACRS 15 on that particular point.
It was primarily, I must say, 16 at their suggestion and recommendation that led us to the 17 proposed qualitative definition because they made the 18 point that it really should be consistent with the 19 quantitative health objectives, but we think we have 20 created arguments that we don't think it is appropr'iate to 21 try to define it as a release.
So, that's another major 22 difference.
23 The fourth major difference is that -- and the 24 final one, I think -- is that the -- well, there are two
- I 7(
j l
25 more. They felt very strongly that there should be some (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.,
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(
W 1
identification in a hierarchy-of safety goal objectives, l l:.
2
'of a need to come to grips with trying to, in--some sense, 1
3 quantify what is meant by the term " hew well a plant is
-1 4
operated".-
These are things that include the human j
1 5
factors considerations that Dr. Murley mentioned a little 6
while ago, and they agree, and we agree that we don't know I
7 how to do'this, but they are concerned about its omission-i 8
from the general framework of safety goal policy.
9 COMMISSIONER ROGERS:
- Well, I guess we are 10 concerned about.it, too, but we just don't know how to'do 11 it.
12 MR. HOUSTON:
That's correct.
And that's what b
13 we-say.-
It is not that we disapree with it in principle, L- -
14 as we don't know how to do it.
15 DR.
MURLEY:
That seems very strong in 16 principle.
17 MR.
HOUSTON:
- And, finally, one thing that I 18 have not mentioned in the briefing, but the ACRS may 19 consider it to be very important, particularly in the 20 light of recent correspondence between the Commission and 21 the ACRS, they did suggest that there was potential 22 usefulness for an objective of what I will call 23
" conditional containment failure probability".
And we 24 discussed that with them extensively.
They didn't call it 25 quite that, but that is basically what it was, that (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.,
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60 1
containment should -- to try to bring some quantification 2
to'the concept of defense in-depth, between prevention and 3
- mitigation, they felt it was desirable to establish some
.4 sort of a target.
They suggested 10 percent, or
.1.
.5 And there is discussion of that in.the paper, 6
and we decided, at least for the time being, that we don?t 7
really know a good way to do that', to make it generically 8
applicable to all plants.
And we feel in the meantime 9
that if the large release guideline can be put into 10 effect, that that goes a long way toward achieving. a 11-recognition' of 'the full plant performance, including the 12 containment, without putting any arbitrary, or possibly'
(,,
13 even artificial limitations with respect to how much 14 should be mitigation. and how mui:h should.be prevention.
15 COMMISSIONER ROGERS:
All right.
Here in the
.16 SECY you mention, or used the word "further testing of 17 potential surrogates".
What do you mean by testing in 18 this?
What does that mean?
19 MR. HOUSTON:
Well, what it means is, basically, 20 we call it reviewing, and it might be in many 21 instances, it might have to do with a little bit of 22 supplemental analysis from existing PRAs, to associate it 23 with the definitions that we are performing.
PRAs that--
i 24 typically, PRAs that have gone all the way to Level Three, n..
25 for example, have presented consequence results in terms (202)234-4433 NEAL R.
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-1 o f. so-called complementary cumulative-dis,tribution I.
2 functions.
3 They may have used -- they may have ' presented, 4
for example, information on early fatalities that.doesn't 5
recognize
.t h e definition of the quantitative health 6
objective in the safety goal policy statement, which deals 7
with the individual risk within one mile from a plant.
8 So it would be supplemental analysis to bring 9
the results to bear in the specifics of the definition.
10 It 'also means that we would like to see the plants that 11 are currently being treated in 1150, dealt with in this 12 same framework, with a consistent set of definitions to
.h-13 see how they compare.
14 COMMISSIONER.R ROGERS:
H.ow long would this 15 testing take?
16 MR. HOUSTON:
Well, it depends on -- if we were 17 able to devote appropriate resources, I would say probably 18 six months, something of that nature.
19 COMMISSIONER ROGERS:
All right, thank you, 20 CHAIRMAN ZECH:
Commissioner Curtiss?
21 COMMISSIONER CURTISS:
Just three or four 22 questions.
In th'e section on recommendations at the very 23 end, last paragraph, page 16, you are asking for the I
24 Commission's guidance on whether to proceed as you have p..
t..a 25 described in this paper, with the safety goal and what you (202)234-4433 NEAL R.
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'l call a.- c l e a r relationship _ between the policy and. the l-2 statutory standard of' adequate protection.
L 3
'I must say. I-am not sure I understand, based 4
- upon this discussion, what t,he relationship is between the 5
safety goal policy statement and adequate, protection.
6 MR'.
HOUSTON:
At the present time there 'is' no 7
apparent relationship, and that's the issue really,'should 8
there be.
9 DR.. MURLEY :
Do we want to quantify adequate 10 protection is really the question.
11 COMMISSIONER CURTISS:
What you are really 12 saying here is you are proposing this approach, the use of
.q.
C;3 13
- a 'saf ety goal as an alternative to the ACRS approach, 14 which would use. i t.
for the_ questio.n of adequate 15 protection?
16 MR.
HOUSTON:
That's correct.
Which can be 17 co,nstrued as implying a definition.
18 COMMISSIONER ROGERS:
They would just connect 19 the two together.
I mean, they could substitute into each 20 other --
21 DR. MURLEY:
We are not prepared to do that.'
i 22 COMMISSIONER ROGERS:
-- and you are saying no.
23 MR. HOUSTON:
We are not prepared to do that.
I 24 They are not so concerned, I think, with the idea of k.)
25 establishing a standard for adequate protection.
And I (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.,
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- a't 63 1
think.this ma,y come.out in your briefing with them.
They-1m 2
are concerned with just having a level
'I would. prefer
' *~
3 to use the word -- something is acceptable and somethiag.
4 is unacceptable.
And they are concerned with just having 5
one set.of goals for it, and not deal with cost-benefit.
6 COMMISSIONER CURTISS:
The ACRS would use the 7
policy statement to define adequate protection, is that a.
l 8
fair statement?
9 MR. HOUSTON:
I think what they have said, it 10 can be drawn -- that conclusion can be drawn by a reader.
11 They have-not.said that that explicitly.
12 COMMISSIONER CURTISS:
If they are saying that, y..
13 and~we will ask them that in May, or I will, then I have 14 two questions'.
One,. why are you not, prepared to.do that?
15
- And, two, in the absence of an approach like 16 that, how do you define adequate protection?
17 MR. HOUSTON:
The answer to the second question 18 is, we don't have a definition as such.
And there was 19 extensive discussion with the publication of the recent 20 revised backfit rule on this question.
What the staff and 21 what the Commission have done heretofore is make a finding 22 that there is adequate protection, without defining it.
23 It is presumptive evidence of adequate protection, when i
24 compliance with the rules and regulations can be stated to I'
t.w-25 bt the fact.
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- 4 64.
.1 But ~ in terms of giving it a real definitional
~
2 attribute in some quantitative sense, is the question
.3 here.-
'And 'the Commission as a matter of fact, the 1
4
. Union of Concerned Scientists seems to be suggesting that n.
5 this would be a desirable thing to do.
And we are' simply
- 6
. making this a decision process for the Commission, as to 7
whether'the Commission feels-that it would be desirable to 8
make a statement with respect to what the perception 9
should E be, or is, between the safety goal policy and a 10 conceptual adequate protection standards.
It does not now 11 exist, that's the point.
what we are saying in 12 And it could be done i
13 the paper is, here is a perspective way that it.could-be 14
'done, but there.are.. I think,_some pitfalls associated 15 with it.
16 We. tend to think of, the concept of adequate 17 protection in the sense that if we make a finding that for 18 a particular plant there is not adequate protection, it 19 seriously raises the question as to whether that plant j
20 should be all:: wed to continue to operate without making 21 some change.
22 I believe it doesn't have to, but it does raise i,
l' 23 that question, certainly in the minds of the staff.
l 24 COMMISSIONER CURTISS:
To shift gears a minute,
(.
25 you have elected not to establish a
containment (202)234-4433 NEAL R. GROSS & CuMPANY, INC. (202)232-6600 323 RaOoE zS uno m uus, n.w., wASarnoTOu, o.C. 20005 C
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performance objective.
Could you expand upon the reason I
L" -
2 for that?
3 MR. HOUSTON:
As I said a moment ago, one reason 4
is that we.found it very difficult to define it in what I 5
would call a suitable generic fashion.
The ACRS 6
recommendation for point one, for example, may have merit 7
for some classes of containment, but it may be a not 8
sufficiently stringent standard.
We think some 9
containments can be better than that, for example.
10 This raises the question as to whether you have, 11 rather, just one containment performance design objective, 12 expressed in probabilistic terms, or some set of them, two h
13 or more.
And we have decided at this point in time that 14 we don't see any real. advantage.to doing that.
We don't 15 see any real advantage to trying to quantify in the sense 16 of defense in-depth galicy, just how far one shcr, J go 17 with prevention, and how far one should go with 18 mitigation.
19 We think it is far better to leave some 20 flexibility between those two, as, in fact, exists among 21 present designs.
22 COMMISSIONER CURTISS:
How would the policy 23 apply then in the CPI program?
p 24 MR.' HOUSTON:
What is intended in the CPI
- h....
25 program would focus primarily on the use of the large (202)234-4433 NEAL R.
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release guideline. which you did not see in the MAFE I-1-
E-2 paper.
It was not used there.
That's what we would like 3
to do.
4 C O M M I S S I O i! E R CURTISS:
Okay.
I just have 5
another question.
On your second to last chart you 6
summarized the staff recommendations, and on the question 7
of the main core damage frequency, as I understand it, you 8
are asking us to approve 10 to the minus 4 per reactor-9 year for the present plants, as the Level Four criterion 10 to use here.
11 MR. HOUSTON:
Yes, that's correct.
12 COMMISSIOTTER CURTISS:
You are using. or EFEI is E.,
13 using 10.to the minus 5 for future plants, and you allude C
14 to 10 to the minus 6 for plants without containment, in 15 answer to the Bernthal questions.
Are those numb'ets 16 numbers that you are asking us to approve, or how would 17 those be treated?
18 MR. HOUSTON:
All three of them?
Right now we 19 are just asking primarily for the 10 to the minus 4.
20 Remember.
the way it is defined is, it's an aggregate.
21 over all existing plants.
Now, if that same number were 22 put into effect and remained as part of the implementation 23 policy planning, or as part of the Commission's guidance 24 to the staff and were not changed, 25 years from now, for i
25 example.
if we had some plants in existence and this (202)234-4433 11EAL R.
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d 67 1
safety goal policy implementation plan were in effect, I
L-2 they would be part of the grouping of then operating 3
plants.
And you would still have this same 10 to the 4
minus 4 objective, which is the aggregate average.
5 So, the future plants would, as they would come 6
into existence, if and when, would tend to improve the 7
appearance of the average value for plants out there.
8 COMMISSIONER CURTISS:
That's all I have.
9 CHAIRMAN ZECH:
Yes?
General Counsel?
10 MR.
PARLER:
Mr.
Chairman, in connection with 11 the earlier discussion about the lack of a general, or a 12 generic definition for adequate protection, this tL 13 Commission is probably aware, that issue is now pending 14 before United States. Court of Appeals, although it is true 15
-- and you were asked this question in a congressional 16 hearing, I believe, a couple of years ago, whether or not 17 there was a generic definition.
l 18 Although there is none, we argued before the l-19 court that the adequate protection finding is made on a 20 case-by-case basis.
And in making the finding on a case-21 by-case basis we have an abundance of objective criteria l
l-22 in the regulations to decide whether or not that judgment 23 can be made.
p.
24 The point that I want to make is the absence of 25 a generic definition does not mean that we have no (202)234-4433 NEAL R.
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- 68
- 1 criteria at all.
Now, whether or not there should be a 2
generic definition at this-point-is a policy question.
It l
3
.may well be that if we get an adverse decision from the-I l
4 court,: that court decision is sustained up the appellate 5
route, that.we:may have to think more about this, rather 6
than'just in policy terms.
7 CHAIRMiti ZECH:
Thank you very much.
8
- Well, let me thank all.of you for a very 9
informative briefing on this important subject.
Your 10 efforts to provide a general approach to implementation of 11 the safety goal continues to have the support of the 12 Commission,.as you can see by this meeting today.
(
'13 Based on today's presentation, and the staff's 14
. previous interactions...with the ACRS,.it is clear that you 15 have gone a long way towards developing an acceptable 16 framework for implementation of the safety goal policy.
17
- However, as we know, there are still some areas gf 18 disagreement between the' staff and the ACRS.
And'we will 19 look forward to hearing from the ACRS on the 3rd of May of 20 this year, which is just a few weeks away.
21 The staff has indicated that you have used the 22 safety goal objectives in the process of resolving generic 23 safety issues, and intend to use them in the closure
- ~
p 24 process for severe accidents, which encompasses the
.k.
25 individual plant examinations, the IPE program and (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.,
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69 1
containment performance improvements, the CPI program.
- 4.
l
-2 Since the staff is using these safety goal'
~
3 objectives, it seems to me that the Commission should 4
consider approving ~some kind of an implementation plan'to 5
formalize and institutionalize this process.
The.ACRS and 6
the 'staf f have put considerable ef fort ' into trying to 7
define and agree on-an implementation process, and perhaps
'8 we have gone about as.far as we can go at this time.
9 After we hear from the. ACRS on the 3rd of May 10 this year, I suggest that the Commission consider at that.
11 time whether or not we should approve those parts at least 12 of the staff's recommended implementation safety goal
(
13 policy that they have presented us here in order to meet 14 the C ommis sion,'s obj ec tive o f as suring that our 15 regulations are appropriate.
16 So perhaps the Commission, after we have heard 17 from the ACRS, wants to take that suggestion under 18 consideration, 19 Are there any other comments from my fellow 20 Commissioners?
21 General Counsel?
22 MR. PARLER:
I would just like to point out, on 23 a low key at this point -
l*
F.
24 CHAIRMAN ZECH:
Please.
- 1...
a potential concern.
And that 25 MR. PARLER:
(202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600
70 1
is, if these policy objectives eventually are approved in 2
a policy statement, one would have to be careful to make 3
sure that if there are any conflicting requirements, in 4
existing regulations or in applicable precedents, I would 5
have to make it quite clear, you know, what the situation 6
will be; otherwise we are liable to have more litigation, 7
such as Limerick, which would be more difficult to deal 8
with if that kind of question is not clearly answered by when it decides whatever 9
the Commission when it adopts 10 it is going to do with these objectives.
11 CHAIRMAli ZECH:
A very inportant point, and we-12 want to, of course, do what is correct, as well as
(
13 appropri o. as far as our process is concerned, too, but
~14 I do believe that the staff is telling us that since they 15 are already using these, at least for guidance in some in 16 their determinations, it would be appropriate for the 17 Commission to at least voice our approval, or disapproval 18 of what they are doing, or at least let the staff know 14 whether they should proceed or not, and the form we do 20 that in, of course, as the General Coansel points out, is 21 very important.
So, we will take that into consideration 22 when we do give you that Commission guidance.
23 Are there any other comments?
24 CONMISSIOllER ROGERS:
Just to stress, again, the i
f, M..]
25 point that even though the safety goals, as they are being (202)234-4433 t!EAL R.
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71 1
formulated bere. are being stated in numerical language, l'.
2 they still are not an' exact or precise definition, a
3 numerical definition.
They are a guide, and a very useful 4
guide.
And I think that we should recognize that even 5
approximate numbers are very useful guides, and that it is 6
sometimes best to not try to make thea too precise because 7
then they bind us to something that we are not ready, 8
because of the state of our knowledge and our skills in 9
ma' ring analyses, to be that precise.
And yet an 10 approximate numerical guide is still a very, very useful 11 device to have.
12 So, I think we should try to keep this whole
!~~~
33 thina in that perspective, that while the safety goals, as U.__
'14 they are formulated, do have numbers in them, they are not 15
- precise, exact numbers'. They have a certain degree of 16 roughness to them because they reflect the state of our 17 ability to make these analyses.
18 CHAIPMAli ZECH:
Well, let me just emphasize.
19 again, we look forward to hearing from the ACRS on the 3rd
?O of May on this. And then after that time we will reflect 21 on your presentation today, and what we have heard from 22 the ACRS, and determine whether or not it would be 23 appropriate for us to give you any further guidance.
24 All right, anything else?
L'.
25 (lio response)
( 20 2 ) 214-4 4 3 3 !!E Ais R.
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72 1
CHAIRMAN ZECH:
Thank you very much for an 2
excellent briefing.
3 We stand adjourned.
4 (Whereupon, at 3:44 p.m.,
the meeting was 5
adjourned) 6 7
8 9
10 11 12
( r,.
13 v.
14 15 l
16 17 18 19 1
20 21 22 23 24 i
("
25 (202)234-4433 NEAL R.
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- 1f.
f' 1
j' CERTIFICATE OF TRANSCRIllER
- -).
This is to certify that the attached events of a meeting i
of the United States Nuclear Regulatory Comnission entitled:
. TITLE OF MEETING:
BRIEFING ON IMPLEMENTA'IION OF SAFETY GOAL POLICY STATEMENT PLACE OF MEETING: ROCKVILLE, MARYLAND DATE OF MEETING: '
APRIL 13, 1989 were transcribed by me. I further certify that said transcription' is accurate and complete, to the best of my ability, and that the transcript is a true and accurate record of the foregoing events.
LA OA.
4 W' y " " (j h'
Reporter's name:
Phyllis Young 4
\\
5
(
NEAL R. GROSS COURT Ref**MtTORS AND TRANSCRiefR5 1333 RHODE ISkAND AVENUE, N.W.
(300) 234-4433 WASHINGTON, D.C. 20005 (202) 232-6600
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