ML20247H128

Transcript of Commission 890503 Periodic Briefing by ACRS in Rockville,Md.Pp 1-71.W/supporting Documentation

ML20247H128
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Issue date:	05/03/1989
From:	NRC COMMISSION (OCM)
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REF-10CFR9.7 NUDOCS 8905310163
Download: ML20247H128 (90)

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r l O DISCLAIMER 1 This is an unofficial transcript of a meeting of l the United States Nuclear Regulatory Commission held on May 3, 1989 in the Commission's office at One White 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 g-. 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 o addressed to, any statement or argument contained herein, except as the Commission may authorize. HEAL R. GROSS Coutt Repoattts AMO TRANSCRIBERS 1323 RHOct l$ LAND AVENUt, N.W. (202) 234 4433 wasteMetoN, D.C. 20005 (202) 232-e000

1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION { l If 1 PERIODIC ERIEFING EY ADVISO Y COMMITTEE ON REACTOR SAFEGUARDS (ACRS) PUBLIC MEETING Nuclear Regulatory Commission One White Flint North f.ockville, Maryland Wednesday, May 3, 1989 The Commission met in open session, pursuant to notice, at 2:00 a.m., Lando W.

Zech, Jr.,

Chairman, pres;0ing.

CO!"'! S SIOI!ER S PRESENT: Lando W.

Zech, Jr., Chairman of the Commission Thor as M.

Roberts, Commissioner Kenneth C. Rogers, Commissioner 4 James R. Curtiss, Commissioner { d I i NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) N WASHINGTON. O C. 20005 (202) 232-6800

2 +. "TAFF SEATED AT THE COMMISSION TABLE: ( D: F:rres*- J. r emick, Chairman, ACRS ~ ~ : '. ; : - Michelson. Vice Chairman, ACRS Chest r F. Siess, ACRS D: Mar:16 V Levis, ACES D. Willia.T Eerr, ACRS i David A. Ward, ACRS Charles J. Wylie, ACES James C. Carroll, ACRS Dr Ivan Catton, ACES (: 1 9 1 i NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W. (202) 234 4433 WASHINGTON DC.20005 (202) 232 6

1 3 o F-R-O-C-E-E-D-I-N-G-S ( 2:04 p.m. _~ CHAIEMA" "ECH: Good afternoon, ladies and j 4 gentle:ren. E C or r i s sioner Carr will not be joining us 6 toda. 7 The purpose of today's meeting is for the ? Advitcry Cornittee on Reactor Safeguards to bring the C Cor ; i s sion up to date concerning the results of its

n revie of four specific matters.

First, the intended 1: use cf ""EEO-1150, while the report is undergoing 12. pee: '_r

Second, implementation plan f car the

3 Safety Goal Policy.

Third, the proposed final h.!

14 rule ud ng related to maintenance of nuclear power 15 plants.

Finally, the Commission has specifically

f recluestec the ACES to discuss its letter of April 17

lith, 19E9 regarding an integrated approach on 16 regulatory matters.

19 All of these important matters are under 20 Commission consideration at this time. Copies of the 21 ACRS letters relating to these topics are available at 22 the entrance of the room. I 23 Do any of my fellow Commissioners have any 24 opening comments to make? e 25 If not, Doctor RemiCh, I Want to Welcome you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVENUE, N W. (202) N WASHINGTON, D.C. 20005 (202) 232M

i 4 s f - 2 he m bers of the Committee. On behalf of ^ f( i yr. 'f r, n ? 511 the Commissioners, the worr: you perforn u prte ' to us. Your views are highly 4 i

regarded, highly respected, as you know, by the 5

ccrrissier 6 Ycu may proceed. 7 DOCTOR REMICK: Thank you, Chairman Zech, O Co" iss; n rs. It's a pleasure for the ACRS to meet 0 wit i ye. Scair t odr.y The last time that we were 10 h-n abcu+

• ronth ago I guess, there were on3y three il cf us thr-could make it.

But I'm pleased to point IT out 11 of us are here today except for Doctor 13 Shewnon who could not be here.

s

'd 14 I'd like to also take a moment to welcome 15 Iv eu Catton, our most recent member to the Committae, "0 sitting down at the end, and indicate that we 17 appr<ciate that he's been appointed to the Committee. 18 He's a long-tire consultant and is familiar w.ith our 19 activities, but it's a fine addition to our effort and 20 we appreciate it. 21 CHAIRMAN ZECH: We too would like to welcome 22 you, Doctor Catton, and recognize that you're taking 23 on a big responsibility for not only the Advisory 24 Corrittee but also for the Commission and for our 2T country We greatly appreciate your willingness to NEAL R. GROSS C/. JRT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (2' ) N WASHINGTON. D.C. 20005 (202) 232-660C 1

t 5 . o.- i?L country. We're grateful to have you on the Se. e ,(' C- .: tee and v. know you'11 make a contribution. You h au-in +% past and we welcome you very much to the 4 Ece sir E DOCTOE CATTON: Thank you. E DOCTO REMICK: Chairman Zech, did you want 7 us to proceed in the order in which you identified the E tcp ec? E CHAIEMAN ZECH: No, any order you'd like to

• C proceed.

l' DOC"SE F.EMICE: All right. Fine. We had 'I intend ' t cover the safety goal first. 13 CHAIRMAN ZECH: Fine. I think that's 14 appropriate too. IE DOCTOF REMICK: All right. I might make a 16 few introductory comments before turning it over to 17 the appropriate subcommittee chairman. IE I'd like to point out that the ACRS has been 19 a long tire supporter of safety gcals, as I believe 20 you know, because we felt that it could help answer 21 the question of how safe is safe enough from the 22 standpoint of regulation of nuclear power plants. We 23 thought it might help truncate the endless search for 24 a zero risk technology, which we know does not exist. 75 We t h ou rgh t that it might help bring some stability and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE (SLAND AVENUE, N W. (pop) m WASHINGTON, D.C. 20005 (202) 232 6000

1 6 o rre etsbility to the regulatory process. ( ^ re sincerely applaud the Commission's l cftr:e to issue the safety goal as you've done. I I 4

wrsonally feel that there's general acceptance of 5

that safety coal as har been issued, and I find that 6 it has helped me in talking to the public, in 7 describing the qualitative goals and the quantitative 8 he** objectives. What I tell them, the members of the public, ~r 'Pe-if you live near a nuclear power plant, it's 11 anticipated that your risk would be no greater than l' "./100^ 4.s of the risk of being killed in an accident 13 compared to all other risks that you might have of ? 14 being killed in an accident, or your chances are no 15 greater than one in a thousand that you'll see fatal 16 cancer or suffer fatal cancer, one-thousands of that 17 compared to cancer from all other causes. The public 18 has an understanding, I think, of that. They don't 19 understand 10-5 and 10-6 and those type of numbers, 20 but I think there has bean general accer.tance and some 21 understanding. 22 Now, there are those who would continue to 23 endlessly search for goals that are more to their 24 individual liking. There's no question about that. I 25 can remember a time when the industry said that the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W. (2g2; m WASHINGTON, D C. 20005 (202) 232 6

I t 7 rr ;osef safety gcalt vere far too stringent. I can ( w h e r-the staff said that they weren't ^ h, i t j r' O er - enoup Well, ve think that the time has l,

1. cr the Commission to decide, and although v-5afety goals are being used within the Commission staff in nurerous ways that I'm sure you're aware of, 1

7 we think it's time for the Commission to decide the 6 v+ p -hat yct vant it to be implemented. j Ue've written you many letters containing ~~ m-advir. on how to do that and we came today, at yet ' r e ~,u e s t to discuss those views with you, but to ~~ rerinc

1. -

the. our letters represent our collegial 13 consenrus on those views. '4 At this point then, I'd like to turn it over 15 to David Ward, who is Chairman of our Subcommittee on 16 Safety Fhilosophy, Technology and Criteria, to 17 sumLarine our letter of 16 February. l'e Dave? 19 MR. WARD: Thank you, Forrest. 20 Our letter of this past February was 21 actually the third in a series of letters that we've 22 written with our ideas of how you and the staff might 23 implement the Safety Goal Policy. The first was 24 written in '57, then '88 and now this most recent i 15 letter. So the Committee has given a lot of thought NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W. (202) M33 WASHINGTON, D C. 20005 (202) 232 6

6 .8' 2 to this. .I hope our letters have been useful to you, .(n 1 At the beginning we had some rather sharp differences with the ' proposals that' the staf f was 4 developing and we th1nk we've come.together to a great 56 cxtend on those over.the lastJ two years. There are 6-still a couple of differences.between what we suggest 7 in. our letter o f-February and ' what-the s:t a f f ' i s 6 presently-proposing and I'll talk about those. 1 l 9 But.first, what I thought I'd ' do is' just-10 surmarize briefly where we agree with the staff l i l 1:

prcposal, be. c a u s e you've heard that and ' read that 12 rec +ntly. and then talk a little bit about the several 13 1 e:taining dif f erences.

14 First, we agree with the present planned 15 proposal of the staff that the Safety Goal Policy 16 should be used to judge

• he adequacy of the 17 Commission's regulations and not the adequacy of the 18 design and operation of a particular, specific plant.

19 I think this is probably the most important concept t-20 for the implementation of the Safety Goal Policy. 21 It's one in which I think there was ' disagreement 22 between the Committee and the staff two years ago, and 23 I think we now agree that this is the proper use of 24 the Safety Goal Policy, as a tool for evaluating the 25 regulations, not for evaluating the details and making NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISMND AVENUE, N.W. (202) N WASHINGTON. D.C. 20006 (202)232 4000 2_-_________-___--________________________.___

9 i -sc f.cally

well, as we

said, narrowly

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1. 1. v e r. t i ? : s f 6ecicions about particular plants.

So t' 's / + 2,, : pcr: ant. i i l' .h-second area of agreement we have is that I the severe.1 cbjectives, quantitative objectives that f v ere stated in the Safety Goal Policy could be laid 7 out in kind of a hierarchical logical arrangement, C going fror abstract to fairly concrete at the bottom ? c.' - hier?rchy

^-

3 r. the intent there was to, at the upr er ot level to have a couple really fairly 1.^ abstrut - state ents, but statements which mean 13 sorething. are expressing the Commission's philosophy

S

/

abou' reactor safety regulation in a way that's I 1E t'u : clearly understandable to the public and to 16 general policy ' takers. But then as you go down the 17 hierarchy, you develop goals that can be more 18 spec fically applied by the engineers, by designers 19 and operators of the organizations that are operating 20 nuclear power plants. 21 And so we agree with the staff in the l 22 development and use of that sort of hierarchy. And in 23 fact, we're in precise agreement on the definition of Ca the fire' two levels in that hierarchy. We have some h 2? difference in the definitions that might be used in l NEAL R. GROSS l CoVRT REPORTERS AND TRANSCRIBERS f 1323 RHoOE ISLAND AVENUE, N W. l' (202) N WASHINGTON D C. 20005 (202) 232M { l

l 1 l 10 l 1 ~ I +' - + ! r? - fourth levels, and I'll talk about those I (- 1 'n'. A r.d finally, we agree with the staff i ~ l l J d coC f b: useful to incorporate certain parts i i i i a d cf _ le _ r irpierentation plan into the policy itself, sc " hat they have standing and can have a clear ~ etandir.; for the Agency and for the industry in being used. F Okay, now the differences. First, in one of I t' ' h i n '- we called it Level Three of the safety 10 g ^:

s proposal that plants that the l'

7:9:Jslity of an accidental large release from any 'ri ,-se: pla nt should be no more probable than once in a tillion reactor years of operation. We 14 agre. with that, with the once in a million reactor ~~ ye al 5 vitt the staff's proposal, but we still have 1C sc e disagreement on exactly what is meant by a large 27 release. We asked the staff to develop a proposal in 18 terre of perhaps a fraction of the core inventory of 19 radioactivity or perhaps in terms of curies, but 20 s o:t e t hin g that was truly and understandable as a 21 release itself. 22 The staff has proposed that instead they 23 would use a definition which is the release that would 24 cause c s ird e fatality at the plant boundary at this 25 frequenc; level once in a nillion reactor years. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE N W (202) N WASHINGTON. D C. 20005 (202) 232-6600

__,__-_3_;, J 11 o 1 Our probler with that-is that we lose.the k' edvastage of this hierarchical arrangement. As I l i 3 raf.6, the hierarchical arrangement is-to go from the-4 abstract to a more concrete' definition of a goal. In E going from a higher to a lower level, the intent was 6 to provide for scce simplification so that there were 7 concrete numbers that could be used by engineers, but-E also not to introduce so much conservatism in going 9 frer a higher level to a lower level, that there was-a 10' la fecto new Safety Goal Policy being introduced. But '. I rather that the conservatism introduced should be just 12 enoup to accommodate the simplification. 13 Wil, we think that the staff's definition x.? 14 of large release in terms of a single fatality at the 15 plant boundary fails that test and is, in essence, too 16 . conservative. In fact, it's redundant with the health 17 effect safety goal, but much, much more restrictive. 15 In what we call the Level Four, we have a 19 disagreement in thtt we wanted to provide in Level 20 Four a means of balancing or providing some sort of 21 horar in the defense-in-depth concept by providing a 22 quantitative goal, not only for the probability of 23 core melt or threat to a containment system, but also 24 in parallel to provide a conditional probability of L. -~ 25 failure of goal for the actual performance of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVENUE, N W. (202) N WASHINGTON. D.C. 20006 (202) 232 4000 . _ _ _ _ _ _ _ _ -________________________ - _- __ _____________ - - - _ _ _ D

L 12 l

+ i nn e r syster.

l '(. l We felt that with this sort of a safety )

1 r :- = ' this would assure that the regulations ere iII 4

e.1v e y e providing for defense-in-depth in the form of r brth a containment or mitigation capability and 6 prevention capability in terms of keeping the 7 probability of core melt sufficiently low. 8 The staff does not have in its proposal this e b=.:r ce which we think is necessary. We think it's 2r r. tan + We think that's a rather important 1: c' _ f f e i n e e that needs to be maintained so that the 12 n e e e. f:r defense-in-depth or this balance between 13 prevention and mitigation is fundamentally part of h.. la the -- and will be maintained as part of the Agencys 1E regulatory system. 16 We also had some difference in opinion on 17 the quantitative goal that would be assigned to the 18 core darage probability. A number of once in 10,000 19 reactor years has been proposed for existing plants 20 and I think the staff is proposing once in 100,000 21 reactor years, 10-5 for future plants. The Committee { 22 sees no real reason to make a difference between 23 existing plants and future plants, although within the 24 industry there is some movement to provide design 25 goals fer future plants that might have a core darnage NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W. (202) N WASHINGTON, D.C,20005 (202) 232-6600

t 13 j I low as 10- t. We think that's perfectly )

_

2 :.;;ity I

(' i T -- u i l.~ 1 e, accepte.ble if that's the industry's choice. l

j E.

=t f.r as regulating for public health and safety, h ^ 4 _f -5 is gocd enough, and we believe it is, it's ~ rnough for future plants as well as existing 6 plar.ts. 7 One other thing. The probablistic risk E a s s e s sr ei: t s which are necessary for the evaluation of 9 r: P t> cr sarple plants against the safety goal are

_

_ted in their ability to model what I might call t11 anC organizational performance of the plant.

Th e; ' r-quite good at modeling the machine and )

3 failures in the machine, but they're limited, they're l'?

incomplete in modeling the performance of the humans 15 a n,' organizations in that plant. We know from 1E observation and, I guess, common sense that the 17 performance of hurans and organizations is extremely 18 inportant to the safety of the nuclear power plants 19 you're regulating. 20 So, we suggested that the staff should 21 attempt to come up with some sort of a goal, 22 quantitative, or at least some sort of objective)v 23 stated goal for performance of the human and 24 organization component in a nuclear power plant. They 25 werer'; able to. We weren't surprised. Frankly, I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234 4433 WASHINGTON, D C. 20005 (202) 232-6600

i 14 .~ .cuyss ve really didn't expect'them.to. What we really ( . anted t c. do'was wave a flag here and point out that-w ? t h-probablistic. risk assessments that are being.done-4 are really incomplete in that they're not able to deal 5 in a Every comprehensive way quantitatively with.the 6 risk contribution from the failures of humans - and 7. human organizations.. S All we're suggesting is that'that needs-to 9 be called out by we suggested some sort of a 10 pr rinent caveat in the Safety Goal Policy that the l '. evaluation is essentially incomplete in that respect.- 12' I think we agree that. it's really not- '.h 13. practical.at this E, t a g e, perhaps it never will be, to 14 put any sort of a quantitative goal on organization If and human performance. Perhaps some kind of a more. 16 objective statement about what the goal might be 17 possible in the future. We're really not ready with 18-that. But we do think that a caveat of some sort in 19 the policy is needed. 20 Of course, that summarizes really the major 21 agreements and differences and perhaps it would be 22 more 'useful now to take a little time for other 23 members to say something or to respond to comments or 24 questions f ror; the Commissioners. 25 CHAIRMAN ZECH: Why don't we see if you have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W. (202) 234 4433 WASHINGTON, D.C. 20005 (202) 23241000

15 c'- . Nrr that would like to comment. (

c. _.. v.- REMICF-All right.

I see none. CHAIRMA?J ZECH: All right. It's very good L t i +: ' h i r. k that the ACES can be tha': together on their I recorimndations. I commend you for that. 6 COMMISSIONER ROGERS: Is this the way all 7 your meetings run? ? DOCTO REMICE. No, I can assure you not. 9 CHAIRMAI1 ZECH: I wish the Commission could ^^

ve;s % thxt sure 11 DOCTOR REMICK.

I think it will fall down as

c w,

y -:, ng today 13 CHAIRMAN ZECH: Yes. 14 DOCTOR LEWIS: You corrupt us at noontime. 1? DOCTOR REMICK: As I say, we've been working 1A on this for two years. We've had a lot of discussions 17 about it. 18 CHAIRMAN ZECH: Well, I'm sure you have and 19 I appreciate it very much. 20 Well, before we move on then, let me see if 21 there are questions from my fellow Commissioners. 22 Commissioner Roberts? 23 COMMISSIONER ROBERTS: No. 24 CHAIRMAN ZECH: Commissioner Rogers? 25 COMMISSIONER ROGERS: Just how you think NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W. (202) 234-443-WASHINGTON. D C. 20005 (202) 232-6600

n. ..D 16 w 2

a+'

4 incorporating guidelines into. the policy. 'You .k . di 6 r '.t 's ay very much about that -'in your' l letter' of f

^

-Febru:try 16th. You did' touch on'it. But I wonder 4 what your -- if you'could say just a little bit what 5 your thinking is. 6 MF. WARD: We really didn't consider it that 7 much. 1The staff had suggested that by amendment to 5 the policy statement that some.of the parts of_this 9 implementation plan that kind of flush it out, make it 10 rore'of a shele should actually be put into the policy 1: s' 'c. tent. I think we don't -- we think that would be 12 e.7006~ina. We don't have any problem with it, but 13 we don't really.hsve a lot of comments about it. ' hi: 14 COMMISSIONER ROGERS:

Well, I noticed in 15 your letter of February 16th that you -- in talking 16 about a definition of adequate protection, you said 17 that you "believe the safety goals should be used to 18 judg.5 the adequacy of the regulations from-the 19 standpoint of whether those regulations result in 20 classes of nuclear power plants which can be and are 21 operated in such a way as to meet the safety goals and 22 thus provide adequate protection to the public."

23 I wonder whether that word " classes" had 24 sore significance, particular significance. When I 25 noted your comment on the incorporation of guidelines NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVENUE, N W. (202) N WASHINGTON. D.C. 20005 (202) 2324WO

)

s.

\\ 17 j intc the policy, whether there.- was some connection-('- '2 there between -- ) 3 DOCTOR - REMICF: I don't think. there.' was a 4 cor.nection between the two. 5 COMMISSIONER ROGERS: You saw something. 6-there. 7 DOCTOR REMICK: But classes, we generally .E -talk about ~ the population of plants, but realizing 9 when you say that there are such differences as Fort 10 St Vrain that right be different than a Mark I BWR 11 anc to forth. So, whether yon could take all 109 or 12 20 plants as a population or whether you need to take .13 several subsets of those because of different designs, )t 14 and that's where I think we use the word " class." 15 Hal, do you want to answer that? 16 DOCTOR LEWIS: No, I think you're right. I 17 do think it's an important point because the history 18 is that there's a tendency on the part of the staff to 19 want to have guidelines for regulation and regulation 20 inevitable occurs at the small number level, either 21 individual small groups of plants. 22 When we first heard about one of the early 23 briefings about the safety goal, the staff was taking 24 the position that there was nothing to be learned from 25 a group of five PRAs that could be extended throughout NEAL R. GROSS COURT REPORTERS AND TRANSCRIBES 1323 RHoDE ISLAND AVENUE, N.W.

(202) N WASHINGTON, D.C. 20005 (202) 232M

.h 4'. 10 n. thw. conr?.mi t y I think?the term " class,"'in addition. f i t t> taking-into account that there are different groups 3 of class. as Forrest said, is meant to be a little bit 4 fuz:y but to say,- you can learn something. f or. five 5 plants about all of.them. -You don't have to have a 6 .FRA on every plant in order to learn about the group 7 of plants, but'you have to use some judgment, just as 8 'you do in any sanpling procedure. 2 A reasonable example is two and a half times '. 0 a :,eny as went into watch 1400 but it's not the whole la collection. So you can judge the adequacy of the 12 regulatory cluster by look: Lng at -- of course you get 13 more information.if you looked at ten, and even more 14 if you looked at 30, but there's room for judgment in 15 there in dealing with groups of ants. The trick is 16 to not do it on each plant. 17 ME. WARD: I don't know if that explains it. 18 There are two different questions here. Our point _was 19 that if we have some PRA results from a group of Mark 1 20. X containment plants and let's say we've done PRAs on 21 a couple of these plants, and we have some reason to 22 believe that some characteristic of those plants that 23 might be common to all of them is causing the risk to 24 be somewhat higher than would seem to be acceptable 25 unde

• the safety goal.

What we're suggesting is that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHe0E ISLAND AVENUE. N W. 902) N WASHINGTON. D.C. 20006 (202) 232-6000 A

1 JL -19 .w j th-staff should look at its regulations by which [ i'm+ plan:s were designed an6 licensed. and find 2 C et's inadequate in these regulations. Should the ~ 4 ' regulations have required ' another system here or E sonething. That 's :the' approach. 'l 6 Rather. than look'at an individual plant and 7

say,

" Hey, you've got to put in another system of a 8 cer t ain. kind, " the staff should back off and say, ? " Loc 4, we've been telling people that if they built 10 plants to our regulations, they'll be adequately 11 safe Se, what we want is to look at those 9? regu:etions then and find out why this class of plants 13 isn'+ coming out, if that question has arisen. 'h. 14 COMMISSIONER ROGERS: I .ond'er if you could w 15 just enlarge a little bit on this question of the use 16 of the safety goals in judging the adequacy of 17 regulation. We've heard from the staff and its point 18 of view on this. I'd like to just have you review 19 that very briefly again, if you would, from your point 20 of view as to what that really means, how one uses the. 21 safety goals to judge the adequacy of regulation. 22 DOCTOR REMICK: I think the staff has 23 misunderstood what we're saying here. When I read I 24 think what they have written in the SECY document 25 endin; in 202, I guess it's 89-102 or 88-102, and I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) N WASHINGTON, D.C. 20006 (202) 2324 8)0

m v 20-3, r+adind ron: of the transcripts ~ from our meeting with [ 1 -you-they.heve the' opinion we're saying you'have=a top f ev:: force fit of safety. goals. on individual 4. regulations, see if they. meet the safety goal. That 5' is not what.ve're saying. 6 I think Dave has just indicated what we had 7 in mind,-and that is that from our perspective, and of ?- course we like. to act like lawyers, we think that 9 adequate protection is compliance with the' .10 comission*s regulations. But how' do ' you know that 11 the regulations are providing plants that are 22-adec a bly se.fe from the public health standpoint? We it

say, "Well, if you find using the safety goal that a

- 14 preponderance of the population of plants out there 15 meets that safety goal, what_you say is safe enough, 16 then presumably the regulations must be adequate." 17 But suppose you find that that population of 18-plants is generally not meeting the safety goal. Then 19 you have to ask yourself the question, "What is it 20' about our regulations? Are there additional systems 21 for decay heat removal or what is it the* we must do? 22 Must we improve training and so forth so that we do 23 increase the safety of that class of plants? 3 1 L 24 So, that's how we're saying you would use [L g W-25 the safety goal to judge whether those regulations are l t NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 2M WASHINGTON. D.C. 20006 (202) 232 6

21 o I d in; th-jcb that you think they're doing. ( I. svMMISSIO!ER ROGERS: It's sorae kind of a i sense of a rean then? j 4 p DOCTOR REMICK: Yes. I'll look to our E statistician if that's a proper use of mean in that I cau 7 DOCTOE LEWIS: The point is, I think, we're E all ir agreement on this general point, but we have cd'fe ent erphases. The way I try to keep it straight 17

*; ou head, not very successfully of course, is t'=t

• S safety gos I think of as more a tool for the 12 Cer iscie than r. tool for the Commission staff.

That 13 is, the Co: mission staff is involved in a regulatory (i 14 process which is necessarily a deterministic process. 15 The; can't look at everything they do and ask, "Well, if does the bottom line mean meet $1,000.00 a man REM or 17 doesn't it ?" We've had people stand up in front of us i 1 E, and sey "This one loses because it's ten percent 19 over," and of course that's no way to regulate an l 20 industry because those numbers are good to a factor of 21 ten anyway. 22 But for the Commission to look at the way in t 23 which the -- not only the written regulations but the 24 irpl e:'+ n t a t i on of the regulations as applied to the 25 industry and how it provides an industry which is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE N W. (202) N3 WASHINGTON, D.C. 20005 (202) 232-6600

22 l

• t-c-J 1; eifety, that's what the safety goal,. in ny o

k 19 for. The probler is that the Commission doesn't i, 4 hevr t'e resources. except through the staff, to do r E 'his job. And therefore, the staff has this double C j '. - of evaluating itself on behalf of the Commission, 1 7 but also doing its job. They mix them up and I'm not F surprised. I would too if I were in that job. O Fo that's, I think, the confusion we're i grcT ng wit'

round here.

'^ '1 CHAIRMAli ZECH: Well, that's why we call on ys t your views, of course, to try to give the 13 balance to that -- 14 DOCTOR LEWIS: Gee, I thought you had to. 15 COMMISSIONER CURTISS: But on that point, I 16 gr ess I understood the staff's discussion a little bit l' differently When you say the safety goal would be 18 used as a rechanism for defining the mean or it would 19 be used against some benchmark. As I understood the 20

staff, their concern with that was that the safety 21 goal in the ACRS' vision would be applied to define 22 adequate protection or the benchmark or mean that you 22 would use would be the statutory standard.

Whereas I 24 understood then to say that it would be used as an 25 adjunc' to the back-fitting process. That leaves the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoOE ISLAND AVENUE. N W. (202) N WASHINGTON, D.C. 20005 (202) 232 6 ) 1 ______)

23 q.--t2:n of hw you define adequate protection. ( ht is there a difference between the two of ~ l y the* p:4in-? I 4 V: WAFD: Here's what we said in the ? letter "We believe that the safety goals should play 6 an uportent but indirect role in defining adequate 7 protection. Ideally, compliance with the Commission's E regulations is a suitable surrogate for defining 9 adequSte protection of the public.

However, we 1^

believe that the adequacy of regulations should be 11 judp d fro: the viewpoint of whether nuclear power class, licenced under those regulations, 12 plantc H 2 13 meet the safety goals." (.: la I'm just saying the same thing again. 15 DOCTOR REMICK: That isn't what the staff 16 svys me're s al ing, as I interpret what they're saying 17 ve said, but that's what we mean. It's an indirect 18 use to judge the effectiveness of the regulations. 19 COMMISSIONER ROGERS: I think they are 20 saying that now. I think that is very close. That's 21 why I wanted to hear from you because I think that's 22 what I did hear from the staff the last time. 23 DOCTOR SIESS: I think the biggest t 24 difference between the staff and the ACRS on the issue 25 cf adequate protection is that the staff has lawyers NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE N W. (202) 234-4433 WASHINGTON D.C.20305 (202) 232-6 &30 1

t 'l 24 1 a: ' we den *t l (" I ^ CHAIEMA'J ZECH: That the staff what? ~ DCITOF REMICK Has lawyers. DXTOP LEWIS: Of course we've asked for ther, but we'vs been denied them. A COMMISSIONER ROBERTS: You don't know when ~ you're well off. E CHAIEMAM ZECH: In defense of the lawyers, ? 1s~'e juet say that sometimes the lawyers make a very 20 va:uable contribution to this Commission. So, we 11 appr+ iatt-your thoughts, but they do help us. 12 DOCTOE EEMICK: Incidentally, you remind me 13 of s o" e t hing too. We say the staff and we differ with 14 ther, but the last year or so, Wayne Houston from the 15 staff has been heading up the efforts and he has 16 interacted exceedingly well with the Committee. He's 17 spent hours and hours with us, and which at times it 18 gets testy and so forth, but he's taken it and he's 19 been very receptive and he's tried. 20 CHAIR!!AN ZECH: Good. 21 DOCTOR REMICK: Of course he isn't the 22 entire staff, but really, I respect the effort he did 23 with the Committee. 24 I CHAIRMAN ZECH: I'm pleased to hear that. 2F Commissioner Rogers, anything else? I NEAL R. GROSS j COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W. (202) 2N WASHINGTON, O C. 20005 (102) 232M

(.. s 25 I COMMISSIONER ROGERS: No, that's fine. h 4_ r.e.2 r.M A N Z E C H : Commissioner Curtiss? 6 3 ~ COM'IISSIONER CURTISS: Just one othe'r 4 question. Would you read the'.large release in the 5 core da. mage guidelines that the-staff has proposed as '6 . implying a -containment performance standard or is 7 there still a shortcoming in that regard? 6 MR. WARD: No, I don't think it does because 9 that --. conceptually you could'have a plant thatwould 10 t w thet requirement without having a containment. '11 DOCTOR REMICK: That's right. 12 MR. W A P.D : That's a problem with those 13 things. f 24 DOCTOR LEWIS: I should mention the other 15 agency. This came up at another agency and produced a 16 brouhaha because if you define a large release in-17 terms of a prompt fatality at the plant boundary, 18 Chernobyl was not a large release and I don't know. 19 anybody who believes chernobyl was not a large 20 release. 21 So, it doesn't help to put the definition of 22 a large release several layers down. Why not define 23 the large release as a large release? It makes a kind 24 of sirplistic sense. 25 COMMISSIONER CURTISS: I guess I -- go l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) N WASHINGTON, D C. 20005 (M) 232 0000 )

9,, 26 -1 ahed. 2 ME, CAEROLL: It also -- which is something I the* you really wer. to get away from. '4' COMMISSIONER ROGERS: If'you do it in terms .5 of fatalities. .E MR. CARROLL: Yes, right. COMMISSIONER CURTISS: One other-que'stion.on [ E the issue of distinguishing between existing. and 9 f u t ur e. plants. A number of initiatives going on 10 around here that make exactly that distinction, and li' based upon what I think is a fact that the level of 12 s r.f e t y is - increasing, that we've discovered new ways i' to-do things. There's kind of a logic to that, to say 14 that.the safety goals for existing plants might 15 inherently be different given the state of the art 16 that's developing for future plants. 17 What's behind your statement on that? 18 DOCTOR REMICK: That goes to the question of 19 -- the Commission has said they have expressed what 20 they think is safe enough, and I don't think that is 21 conditioned upon it's this type of reactor or today's 22 reactor or the reactor ten years from now. I think 23 the Commission has spoken of what they think from a 24 public health and safety standpoint is safe enough, (6 25 and you've expressed that. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVENUE, N.W. (202) N WASHINGTON, D.C. 20005 (202) 232 6

= m w - x-- = .w '1-27. . ce ~ -Why would it be' conditioned that you would l' lowe: th6t in the (future, unless you felt that that f v =. t ' inadec.uate hesith and safety for the public? I i don't think you believe that. So what's the reason 5 for-changing the answer.of how' safe you think.is safe 5 encugh fror. a regulatory standpoint for future plants. 7 COMMISSIONER CURTISS: That may go. to the 8 dis'.inction that the staff drew at the meeting where 9 I*r sure they would define how safe'is safe.enough in II ter'e thet align i t' as closely ' with adequate 1 *. protection, that all the plants existing in future 12 would e v. that standard. But as we learn new things 13 and develop new designs, that inherently these new 14 plants wi31 be safer without saying that existing 15 plants don't meet the statutory standard. 16 DOCTOF. REMICK: I think that the future 17 plants will be safer. But the question is, just -16 because they can be safer, do you regulate that lowest' 19 level all the time or do you answer what we think is 20 safe enough and then let economic considerations and I 21 other things enter in to individual licensee's 22 decisions on how far they go beyond those. 23 But I think there is a natural reaction out 24 in industry. Every time they improve something, the ( 25 C onx.i s s i on coring in and wanting them to regulate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) N WASHINGTON. D.C. 20006 (202) 232-8000 i

28 P' seen ' hat in the accreditation process, t' k

• ei nt ere nce and so forth.

The natural tendency es 1 ' r. ;. inprcve to want to come in and place a limit, b 4 3 :: s. ires that kills the incentive to try to improve. E So, I think it boils down to the question, G d. yco third that the safety goals express adequately 7 how safe is safe enough from the standpoint of nuclear E pcw r plants in this country? If you don't, then e rel_ it should be lower in future years. 10 CHA FMAN "ECH: The Commission consistently err s+C tlc inclusion of averted on-site cost and cost anelysis and it's been debated for some time, b g 13 that issue. Do I understand correctly that the ACRS (;. :- 14 supports the inclusion of on-site costs if a safety 15 cc+t benefit analysis is done? '6 ME WARD: Yes. 17 Do you want to elaborate on it? 18 DOCTOE REMICK: Basically, we're saying that 19 giving credit for averted on-site costs against the 20 other costs is economically acceptable type of thing 21 in a cost benefit analysis, if you do a cost benefit 22 analysis. We're separating that from safety goal, but 23 saying if you do cost benefit analyses, whether it's 24 unda DFA or whether it's under -- {. 2? CHAIEMAN ZECH: Yes, I see. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234.4433 WASHINGTON. D C. 20005 (202) 232 6600

29 DOCTCF F.EMICE. rule or whatever, we do k ~ fiffer ' _ *

• the staff's view, and apparently OGC's g

h h b=isically subtracting that from the total il h ccots of the proposed modifications, we think that's r-cceptable. 6 CHAIEMAN ZECH: In a cost benefit analysis i situation, but you do differ from the safety goal F itself as far as that's concerned. You're not l 9 considering that? 10 OOCTOR REMICK: We've associated a cost j l '_ b e r.. I i *

• n: lysis --

2? CHAIEliAN ZECH: Yes. 23 LOCTOR REMICK: -- as a part of a safety (... 14 goel. 15 CHAIRMAN ZECH: Right. Okay. I understand.

A Good 17 Well, let me just say that this has been a 18 len; considered subject, I know.

I have, frankly, 19 felt that your consistent stance that the safety goal 20 should be a judge of our regulations rather than a { 21 plant specific measure is proper. I think I've also j 22 felt rather consistently that the safety goal is just 23 that, it's a goal. It's a goal. The struggle that 24 we've had and the staff has had, I know, that you have 25 helped us with is how do you implement a goal. It's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVENUE, N W. (202) 234 4433 WASHINGTON, D C. 20005 (202) 232-6000

30 b-e c e.t ; difficult. But I think your contribution ( =r. n collective thinking on this has been very a . : pf.1 tc trI to at least temper the effort on the pr: of the staff, which you're absolutely correct, to 5 tri to define things. I would do the same thing if I J E w;s on the steff, as Doctor Lewis points out, he would 7 too, because you want to know what specifically do I 6 have before r e and what are the specific guidelines? ? The safety goal doesn't lend itself 10 c ; t c '. e t e ly te that type of a formula. Therefore-- 1: and I don't think it properly should. I think that's ' _ ^ th- ;M position too. 13 Sc, I do feel that the goal is a goal. I h. 14 t hi n :- it's a commendable achievement on the part of 15 the Comission with the help of the ACRS and the staff 16 and taking the next step as to how we should implement 17 it is indeed worth the time we've spent on it, I 18

think, because it is before the Commission.

We'll 19 hopefully make the best decision that we possibly can, 20 Your input will be greatly respected and reviewed by 21 all of us, I'm sure, again carefully. 1 22 We appreciate all the letters that you've 23 given to us, all the time you've spent on this very 24 irportant subject. I think it's, frankly, been worth 25 the ti.me. I appreciate your willingness to work and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS j 1323 RHODE ISLAND AVENUE, N W. (202) N WASHINGTON, D C. 20005 (202) 232-6600

31 +5 rtaff's effort. The staff, "i think, has r, vie v ( (;rt ccrrendable job too. They are indeed coming at ^ 1 ~ .? f.0 little different approach. Again, that's 4 understandable 5 Eut think we have come together to the 6

oi

' t where perhaps the Commission can feel reasonably 7

confident to make a decision on how best to implement E th_' "M y irportant safety goal. E Sc, let me just rove onto the next subject. 10 E' h+for-we do, I can't help but say how much the 11 Co::._ s s ion appreciates the careful thought, the honest 12 t h ma ch ' e.n : I know some of the differences that you've 23 had arongst yourselves in order to come to the 14 recc-endations that you've brought to the Commission. 15 Fut we appreciate very much your contribution in this 16 irportant area. 17 DOCTOE REMICK: Thank you, Mr. Chairman. 18 The n e>:t item then is the maintenance rule 19 that we had planned to discuss. As you know, we have ) 20 provided the Commission with two letters on the 21 proposed maintenance rule. 22 We were made aware this morning of your memo

l 23 of 26 April to the other Commissioners and that places i

24 a little different color on what we had planned. We 25 had pi r.nn e d to ark Carlyle Michelson, the Chairman of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) N WASHINGTON, D.C. 20005 (202) 232 6

. ~ 4 32 3 -. c or r. t r e e on Maintenance Practices and ( + eer te summarize our letter to you of 11 I r.; ; _ _ Em I '- not sure if that's the appropriate way b / I

; :. o c t e f cr if you would prefer us to gv ahead in thrt " ode, er if you' just want to open it up for quee'.icans that you Fight have.

7 CHA:EMAN LECH: No, I think we ought to ask - arl if he vouldn't mind summarizing the approach. We ^ recognize we've given you a little different way to

n it ncv Eut perhaps you could weave that into tb thou; hts you have and I think we'd benefit from y c.v e

us i ? MR. MICHELSON: Well, first, I would like to h "a just go back and refresh your memory on the two memos 15 tha' we did send to you on the subject of maintenance. 1C T': first one was sent in September of 1988. 17 In that letter, we stated, I think quite 1E

clearly, that we did not support the proposal to lo establish a maintenance rule and gave two particular 1

20 reasons. The first * - a son we.s that the we asked 21 two irportant questions av ose were the reasons for 22 our conclusion. The first question was, does the 23 maintenance rule of nuclear power plants as now l 24 perforref pose a significant risk on public health and 25 safetyi The second one, would the existence of a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVENUE, N W. (202) 234-4433 WASHi*:GTON, D.C. 20005 (202) 232-6600

33 o - : :. t e n e.n : e r t.i t reduce that risk? Those were the two (

• J rd e tht-ve were groping with.

e r; the first question, we felt that there 1 4 was s er e indication that poor maintenance had cc.ntributed to plant unavailability and in some cases 6 tc the e:n s t e n c e of plant states that could be 7 interpreted as possible accident precursors.

However,

? we did not see any evidence to support the idea that th- + :-:i s t e n c e of a maintenance rule would reduce this 1^ n3 nor did we see any evidence that the existence l' cf a rule votid r'ake things any worse. ~^ It appeared to us that the maintenance 13 practices in the industry were improving and that the (v, 14 rule -ight be disruptive to the substantial industry 15 initiatives that had been developed to accomplish this 16 purpose. So, at that time we indicated we felt that 17 it was not necessary to have a maintenance rule. 18 Cn April lith, we sent you a second letter, 19 this ti e concerning the draft Commission paper 20 related to final rulemaking. In that letter we 21 indicated that our position remained essentially the 22 same. We still believe that good maintenance is a 23 necessary ingredient in any operational program that 24 seeks tc insure reliable and safe plant operation, but l 25 we fel-that that was really not the issue. We l NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W. (202) 234 4433 WASHINGTON. D C. 20005 (202) 232 6000

l 34 hel t' t h e_ issur was how to obtain good maintenance. (

c. s we see it, the industry's aggressive esis or the development of effective maintenance 1

4 prc gr c t-r ever the past several years has resulted in ret t. e d improvements in maintenance programs and E significerce progress towards reaching the industry's 7 objectives. 6

Further, the staff has told us that their 9

evticatior of a sample of maintenance programs 'F - ^2c+*t s -het only a few percent of the total 1 polulatic: of U.S. operating plants may have poor 1^ na:n':ntnce prograns. That conclusion was based on '3 exen.ining about 25 percent of the total plants. (., 14 Given an environment in which there is if already a scarcity of industry and NRC resources, we '6 brlieve that it is more cost effective to seek 17 improvements applicable to the few plants with poor 18 maintenance prograts by means of existing regulations 19 rather than burdening all plants with a costly program 20 of unproven efficacy. 21 The scope of the proposed final rule is also 22 a concern to us. The rule, and its accompanying 23 reguletory guide, appeared to be very broad in scope. 24 So broad that almost every facet of plant operation l 25 r.ight conceivably be under the scrutiny of the NRC on NEAL R. GROSS CoVRT REPORTERS AND TRANSCPJBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234 4433 WASHINGTON, D C. 20005 (202) 232 6 ______________________-__________________-___-_-______a

35 -*is c' its effect on maintenance. Such a broad ( s cer-coal ? be counter productive. ll Fect .5+ everyone involved believed that il h .rt(nsnce programs are improving and because the and Etry is co: :itted to additional improvements, we 6 recor r + nded that the staff continue to monitor the '~ industry's progress and not to intervene at this time. E Thc' v.=f the bo t t or: line of our second letter and thM*s where ve're at now. ^O CHATEMAI? ZECH: All right. Thank you very .t

T Are there any other comments frorn the group, 13 Co.vitLee?

Thank you. 14 Commissioner Roberts?

E Commissioner Rogers?

16 COMMISSIONER ROGERS: Do you think that the 17 industry efforts, which indeed have been significant 18 in tt. last few years and have made very important 19 differences in a number of plants, and are being taken 20 up by rest of the licensees in some form or another, 21 do you think those efforts would have come on at the 22 pace end intensity that they have if there had not 23 been an I'iF C initiative towards a maintenance rule? 24 ME. MICHELSON: You're asking me my personal C.. 25 view because we did not entertain that as a Comrritt ee NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234 4433 WASHINGTON. O C. 20005 (202) 232 6

36 cartin h s O!' MIS SIONER ROGERS : I think some of a ~ l ym -- yes, I guess -- anybody can answer. t li tG., MICHELSON: I will indicate my own views 5 and then the other members can indicate their views. 6 I believe that a lot of the activity 7 associated with improved maintenance had been going on ? before the real push for a maintenance rule. The o question then is would that level -- I think INPO was 10 one of the prime movers of trying to get some of the il r e.i n t e n a n c e going because maintenance clearly was shonng up in LERs as a significant contributor to 13 events of concern. h-14 The industry was picking thro-a INPO.

Now, 15 the question is, would they have continued to build 16 the momentum that I think they are now building if the 1"

NEC hadn't come through with a similar thrust from 16 their direction? My own opinion is I doubt that it 19 would have proceeded to the level that it is now 20 without some additional impetus from the NRC. But 21

clearly, there were significant programs underway.

22 It's a question of whether you could keep them up over 23 the long term. 24 DOCTOR REMICK: I agree with what Carl is ( 25 saying. Several of us -- I don't know how many years NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 234 4433 WASHINGTON, D C. 20005 (202) 232-6000

M

o 37 1

e.c : it vas n ce, but several ~of'u.s.in ACRS accompanied [.. 2 +>, IT C staff on'a bilateral visit to Japan. Harold l Denter headed up that effort and I know - we were so 4 . i.mpr e s s e d with what we.saw in Japan and ' saying now, -5

• Fhat do we do with this information?"

I think all of 6 -ur felt if.we could somehow get U.S. utilities to.go 7-and see the maintenance practices and see the effects. ? I think back then people started, they did, and some ? u:ilities worked out relationship with individual 10 u t il i +. i e u. in Japan. ~1

then later on had an op'ortunity go along 12 v i t t, an INFO visit with Dennis Wilkinson and my 13 accrediting board activities, looking at training and (E'

14 so forth. Onc'e again, we were sincerely impressed. 15 So, INPO came back and put the pressure on for more of 16 this. Then I think the whole accreditation process 17 where maintenance programs now must be accredited so 18 that utilities have established formal programs and 19 have laboratories and they're looking at the qualities 20 of personnel and so forth, I think all of that has 21 helped. But, like Carl, I think the interest of the 22 Comnission and perhaps the threat of a rulemaking and 23 so forth probably has pushed that along faster than it 24 othenise would. But I think it started some years (b. 25 ago. NEAL R. GROSS COURT REPORTERS ANDTRANSCRSERS 1323 RHoDE ISLAND AVENUE, N.W. (202) 234 4433 WASHINGTON. D.C. 2002 QO2)2324000

t 38 uCMMISSIONER ROBERTS: Well, that may be. l f 4 ._onc agc v s. f it you went on that trip to Japan I'?F " That't b e + r- -- >l f l! DOCTOR REMICK: It's probably four years 5 arc l l 6 COMMISSIONER ROBERTS: Yes. 7 DOCTOR REMICK: And the NRC visit was before F the-It ves about two years before then. So, I 9 v:-' guess the NRC visit was '82, '83. There were '0 54". +1 ' are went along. But I think that helps -- COMMISSIONER ROBERTS: When did the notion

^

of ru'.e. ,.ing on maintenance arise? '. ? DOCTOR REMICK: That I can't answer. 1" MR. WYLIE: I think it's at least three 15 years ago. 16 MR. WARD: About four years ago, I think. 17 MR. WYLIE: I recall when it first came up. } 18 There were neetings with the staff and industry at 19 that t ir>e. That's at least three years ago. 20 MR. WARD: I think there's no doubt in this 21 and other

areas, the threat of rulemaking has l

22 sometires spurred industry, concentration of industry 23 action. I don't know that I like all the conclusion 24 one draws from that, but I think it's true. 25 DOCTOR REMICK: I think you have to point NEAL R. GROSS 1 COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W. (202) 234 4433 WASHINGTON.DC 20005 (202) 232 6

T 39 e t. dw side t c, all of that too. Just the threat (~ cf r u l e.r ak i ng has diverted some industry resources to r; t: ccanter that On the other hand, coming from i h 4 induetry a few years ago, I would comment that 5 aetually improving maintenance, at least in my 6 p.rspective, was one of the first initiatives industry 7 or INFO care up with along with training. I think C 'h ;;'ve been pushing that for a long time. C DOCTO? KEER: I'm reminded of one occasion e'. A ic? "+ri Twein said, "I was glad to be able to n a n w eu that c,uestion promptly and I did, I said I 11 ddA'- kn-1 DOCTOR LEWIS: Could I just add one little (.l. la bit to this? I think, if I remember correctly, that 15 one of the things that impressed people on the Japan 16 epascoe was a fundamental difference in terms of 17 frequency of maintenance and depth of maintenance. 18 There's a tradeoff about how often you test and 19 maintain things against how deeply you go into them. 20 There's something to be said for frequent observation 21 and something to be said for shutting everything down l 22 every s i:. years and taking it apart and putting it 1 23 back together. Of course, when you do that, that's l l 24 the ri c ' d est part of the operation, when you start it ( 2E up ag?in. You kn w that from your overhauls at Naval l l NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W. (202) N WASHINGTON, D.C. 20005 (202) 232-6600 3

1 40 sM pynrds I've been through that too. b One thing I always emphasize, and I would f r + ~. d creh c t if : didn't at this point on this, is a I 9+: there is a real well developed academic body of E ir.f or.ation that addresses this question, called the 6-theory of reliability. There are professors of 7 reliability. There are books about that, that deal B w: tF the general issue of how you determine what J ? rroper leve:s are. 1C W say that if you look at LERs, there are 11 t.; incidents that are caused by maintenance. There 12 ar-

sc r.any incidents caused by testing, by 13 excessive testing where maintenance is not necessary.

14 The trace there is one that cannot be made by sitting 15 around a table. You have to apply some reasonably 16 good doctrine. There exists such doctrine and I don't 17 mean this as a slap at the staff, but I have a feeling IS th6t it is better known outside the NRC than it is 19 inside the NRC. This is just an admonition to use the 20 best of the art out there in dictating this matter. 21 So, it's not just a matter of a maintenance rule, it's 22 what rult it is. 23 COMMISSIONER ROGERS: I know in one of your 24 letters you've commented on the -- that the proposed 25 rule reelly got into what amounts to management NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVENUE, N W (202) N WASHINGTON, D C. 20005 (202) 232 6600

41 T m tions and you were sensitive to that. I'll just k I a t-k the question in general. Doesn't all regulation nt el or ranagement? I don't think that you can J 4 hav+ regulatier without its being in some way partly a E, managenent function because those are the kinds of ) E 'hings thet a good management does. 7 So, I'm not sure that there is a clear line E of derarkatier between regulation and management. 9 W'6 ell like to think there could be and that we can 20 alvery star on one side of it, but I don't believe it a sharp line, that there's always a fuzzy 12 the: t 22 bo u r ':N ; there and that regulation is always going to 13 be intrusive on nanagement prerogatives because it (. 14 sets a different set of priorities than the management 15 might necessarily have. 1C So, I don't think you can totally divorce 17 regulation from management. We can't have that clean 18 a separstion. It's a question of how far is far 19 enough and no further. 20 DOCTOR KERR: But I think it's very 21 inportant that one keep the two responsibilities 22 clearly in mind because otherwise the regulators who 23 are generally not ri ponsible for management take all 24 ths' responsibility. Ci_ 25 COMMISSIONER ROBERTS: As usual, I agree NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W. (202) 234 4433 WASHINGTON. D.C. 20005 (202) 232-0600

i 42 wi-$ you. -( DOCT ? KEER: So, although I agree with you ~ tr* M-u n dl a : !% y be fuzzy, when you get far away from 2 bcundary, which one can do occasionally, that is 4 5 not always so fuz7y. 6 COMMISSIONER ROGERS: But I think it's just 7 not quite so simple, that it is a very sharp line 8 there. The very fact that you have regulation is S intrusive and it sets constraints on management that 10 menE2erent right not give the same priority to without l' regu2atior, in any industry, But it is true that ^2 re bletion should not at t erop t to manage because it 1? can't do it. It doesn't have the tools, it doesn't Cs:. 14 have the responsibility. So, there is a clear 15 d;fference in those two sectors, but there's an 2E overlap there as well. 1 17 DOCTOR KERR: It's for reasons like that 18 that one has an astute and wise Commission to make 19 decisions of this kind. 20 CHAIRMAN ZECH: We hope so. 21 Anything else? 22 COMMISSIONER ROGERS: No, that's fine. 23 CHAIRMAN ZECH: Commissioner Curtiss? 24 COMMISSIONER CURTISS: I do have one quick (. 25 quertion. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVENUE, N W. (202) 234g WASHINGTON. D.C. 20005 (202) 232-6000

43 % 've got the first batch of results in from h the mintena ce t ear = inspections and the staff briefed I I ~ l u y.cterday 7 those. I guess the thing that jumped b 4 cut at ne is that the utilities do a pretty good job 5 of pt.tting Liain t enan ce programs together. Of the 20 6 sites that were surveyed in the first batch, we had 7 pretty positive results on the formulation of E rrogre.r. but there was a clear break between the 9 forr.uir ion of the program and its implementation. I 10 6c 't ' ' I ' r. telling you anything new that you 11 pr:baM; haven't heard or seen in this country at 12 156 13 Given what you've seen, do you have the same 14 high degree of confidence on the implementation side 15 and would you counsel the same sort of " wait and see, 16 let the industry pursue it" as you've alluded to in 17 your two letters? 18 ME. MICHELSON: I think the first thing you 19 have to recall, of course, is that we have mechanisms 20 for monitoring the quality of maintenance, the SALP 21 process in particular. This is, I think, a very 22 strong process, very effective, and it's keeping up 23 with t h e. on-site maintenance, with or without a big 24 paper p ograr' behind it. '5 So, I would not personally have a concern NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W. (202) N WASHINGTON. D C. 20005 (202) 232M

.[ 44- ,:p- ~. - tht! poor. maintenance is going to. go on: even. though - L

isi nt enance Lprograns --look : good, because I believe the 3

S A 1. F plocess, the resident inspectorf process,. there 4-are sev6ral checks and-balances tha't assure-that'we're. E' still' watchin; ~ how maintenance is. being done. 'It's 6 just a question ' of the formality of the program and 7 it's in.its basis and regulation'that we're really'.-- 8 MR CARROLL: One 'of the things that - the d 9 staff presented to us at our request, I don't know if '. hey shoved it to you, was an attempt to correlate how 10 + 1~ vel: the; viewed the maintenance programs through the 13 spe me' teer inspections with SALP, engineering, ,- ~- 13 maintenance, surveillance and also performance F 14 indicetors that you might intuitively think have 15_ comething to do with how good a maintenance program 16 one has. I guess my reaction to that was that-the 17 correlations weren't very good. 18 COMMISSIONER CURTISS:

Actually, the 19 question came up yesterday and we asked them what kind 20 of correlation they had with the SALPs in the first 20 21 or 30 that they've done and the answer, I think, was 22 that there seemed to be a high degree of correlation, 23 at least with the SALPs.

I don't recall the answer on 24 the performance indicators. L 25 COMMISSIONER ROGERS: SALPs, on the other NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W. (202) 234 4 33 WASHINGTON, D.C.20006 (202) 232 9000

~ 45 hen / th: cther indicator is not so good. There seemed ( to be am>d answer there, just as we -- 3 1 MF MIMELSON: I think most of the -- see, ) in i the_ E't tement was based on these management E insp+ction tear results which I think are only now 6 coring in. That's a fairly recent process. So, 7 perhaps that wasn't reflected in some of their E observations, conventional performance indicators and ? so forth, although we did discuss SALP as well. D~~ TOE KERE: I have not seen the report to

• ^

v : c' y lefer Perhaps it's been looked at by one of om s ubcorr i t t ee s. I would want to look at it in 13 det+i1 'cefore drawing any conclusions. I think your (4:..

4 que stion it certainly well taken.

15 For

example, one could say that the 16 ir; l emen t a tion of the maintenance program is not very 17 good by looking at the details of the program itself 18 and going through detail by detail and finding that 19 some of the details are not being carried out.

l 20 On the other hand, one could look at plant 21 performance and see if it is improving. I don't know 22 what criteria were used in making a decision that the 23 implementation is not very good. I think measuring 24 in plen en t 6 tion is difficult and a number of criteria ~- i 25 could be used. I certainly think it is an area to NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W. 9 02) 234-4433 WASHINGTON, D.C. 20005 902)232-6000 l t.

) 46 l l l* v t :. ci the staff needs to give continuing attention. i r* I would say this

early, the measures for t'_

trr.inin; -- i CO!EISSIONER ROGERS: Well, one of the areas 5 thE' stood out was the poor engineering support for 6 mai:, t enence prograr.s, that somewhere between 25 and 30 7 percent of the programs that they've looked at had S rair.?enance overall programs, had a program but the ? 1rpl er.;e n t a t i e n of that was inadequate. That was one 20 of the ereas 11 S'TTCR KERR: Well, I don't know. I just-- 17 wit: e.11 due respect to our staff, which I think is 13 cor re tent, I'm not sure how many of them have a lot of ( 14 experience in running maintenance programs.

Well, 15 I've said enough.

I think the question you ask ought 16 to be examined continually. Il COMMISSIONER CURTISS: It's a fair question 18 cf what you look at to measure maintenance with 19 respect to the staff's approach. They did say, and I 20 think it's a credit to the approach that they've taken 21 with the tree that they formulated, but it covers many 22 of the same

things, maybe from a

different 23 perspective, but many of the same things that the INPO 24 evaluations cover. So, there does seem to be a 25 consersus at least between the NRC staff and INPO as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W. (202) N WASHINGTON, D.C. 20005 (202) 232 6

, ~' ~47

w,

-i -to-the' things.that are critical to'look at it. They 2 seer to be looking.at the right things,.I think. b.- 12.-MICHELSOU: Wil, it's encouraging'that 2 th- ~ SALP process, 'at least, is' kind of fitting with 5 th -- 6 COMMISSIONER CURTISS: Yes. I1 was ~ very 7 pleased to hear that ' because it calibrates both-the E SALF. process -- .9 HR. MICHELSON: That was 'one of the 20 c.u e s t i ons - t h a t apparently has now been settled. ^: DOCTOR SIESS: You know -- may.I? 17 CHAIRMAN ZECH: Please. 13 DOCTOR SIESS: It seems. to me that the - s. 14 evtlua tion of maintenance programs is' not : all that-15-ruch different from the evaluation of a QA program. 16 One thing you can do as a measure is to say, "Did you s 17 do what you said you were going to do?" That's fairly 18 easy for somebody to check up on. It might.be if we 19 had a maintenance rule, "Did you do what we told you 20 to do." 21 The other measure would be how reliably 22 and/or how safely the plant is operating because the 23 objective of maintenance is to provide a safe and 24 reliable plant. The objective is not simply to carry 25 out +11 the steps in a plant.

Now, if the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W.

(202) 234.4433 WASHINGTON, D.C. 20006 (202) 232 6

4 48

xi Lil relati.onship between that an a - QA ' program -isn ' t '

ob'cicus,lI'll explain it some other. time. COMMISSIONER-CURTISS: I think that's a' fair 4

point, They do have some very gross measures.of plant E

' performance. But' one of the things that' we found' 6 ' y e s t e r rl a y was th'at there's very-little viability-7 trending on key systems and components. The utilities ~ .E hav+ the paperwork, but-they really haven *t looked at-ii ? trending-that information. 10 DOCTOR SIESS: Like QA. 11 COMMISSIONER ROGERS:

Well, just on that 1^

poin+ though, you're absolutely right that if the , gl 13 plant starts to show all kinds of evidence of problems U 14 that one could trace back to maintenance, then you've 15 got'a sure indicator that you've had a bad maintenance 16 program, but you've also got a problem on your hands. 17 The idea would be to try to avoid getting to the point 1 18 where poor safety performance of the plant is the 19 indicator that tells you you've got a bad maintenance 20 program. 21 MR. WYLIE: Before we leave that, let me 22 make one comment. Carl spoke to it in regard to the 23 scope of the proposed maintenance rule and the reg. 24 guide. One thing that disturbed us was the broad 25 scope of both. The definition of what was to be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W. (202) N WASHINGTON. D C. 20005 (202) 232 6

49 irc:tCr? i r. the progran was anything that could cause ( e transiert that would challenge the plant's safety. W*t that broad a definition, there was just no limits 4 to the bounds of that rule or the reg. guide. 5 You could take it so far as to mean the 6 transmission lines that come into the plant would fall under that definition. DnrTOR SIESS: Of course one of the biggest 9 causes of plant transients is maintenance. I 'O COMMISSIOliER ROGERS: Surveillance. On line l' su2veillancer 10 CHAIRMAII ZECH: Well, let me just say, from '. 2 ry standpoint, I believe we need a maintenance rule, 14 bu' we need a good one. We need the time to make a '5 goof one. But I'm convinced that we need one. But 16 I'r not trying to get a maintenance rule in place 17 between now and the next two months while I'm here. I 18 th1nk it*s very important that we have a good 19 r:ain t en anc e rule, but I do feel we need the time to l l 20 make it right. l 21 We need, I think, as perhaps Doctor Lewis 22 pointed out, what rule it is. I agree with that. A 23 good rule is very difficult to make a maintenance 24 rule. Yes, it does have management connotations. I 2E acr-with Doctor Siess also when he says quality i NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l 1323 RHoDE ISLAND AVENUE, N W. (202) N WASHINGTON. D C. 20005 (202) 232-0600

w >p c 501 arsurance tscause.it does have'a' lot of:the'same kind. ..h N '.cf' thinking that goes into' quality' assurance..There's

judp ent-in that, 4-So, professional judgment -is a-big part of-

-5 it. We need'a good maintenance rule. I remember when-A .I first started looking _ at the, plants. One of 'my 7. first comments on the Commission toLthe chairman was S-at that tire that it seems to me we'ought to hear from o the industry on their maintenance program, and they 1 D_ c i c' 'They can e.and made a presentation to ' the il C oruti S s i on - The essence of their presentation - was- ~? that, "hintenance is excellent. You regulators ougnt l,;. 13 to stay out of it. We know what we're doing in the . :y 14-industry and maintenance is in very good shape." 15 I listened carefully to that. I didn't seem. 16 to have ruch support at the time for any interest in -17 maintenance, but I thought about it a. lot. I kept IS looking at the plants and wondering about it. But I 19 was not impressed. Yes, I think industry was at that 20 time even starting to focus on maintenance and I give 21 INPO a great deal of credit for the efforts they've I 22 made in that regard. But it's taken a long time for 23 the industry, in my judgment, to focus on maintenance. 24 I was disappointed in that first 25 presentation. I will say that I think maintenance is NEAL R. GROSS COURT REPOR1 E'4S AND TRANSCRIBERS 1323 RHoDE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON. D C. 20005 (202) 232-8000 i. l-..

'O.- 51 1 infieved .I've seen it improve. I've heard about it 2 .inprove fror you~ and from our. staf f and from' the' i Nh. s t r y. I've seen it.myself. It has improved. But 4 I'still.-think.it'has a ways to go. I don't think it's S- .-as good as it ought to.be. G I think thwic are good maintenance programs 7 .out there. I think in some' cases there.are excellent 6 2 maintenance programs out there. But I think there are 9 too rany plants that don't have a maintenance program 10 t h s.t vould reet the standard that I would want if I 11 we: e a utility executive. I can't say they don't meet 12 our' regulations at the moment or we'd take some severe 13 action to counter that. But it seems to me that p .V? 14 maintenance plays a very important role in safety. 11 Safety is our business. I think we have a right to 16 . insure that -- an obligation to insure that 17 maintenance has improved. 18 I think our staff has done an excellent job 19 in trying to come up with a maintenance rule'with very 20 little support or help from the industry. It's been a 21 big disappointment to me. I really do believe that if 22 the industry had helped us and the utilities had 23 helped us, we'd have a better maintenance rule than 24 the proposed rule we have. I: 25 Yes, you can ask questions like, "Did you do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOL ISLAND AVENUE, N.W. (202) 234 4433 WASHINGTON. D.C. 20006 (202) 232-8000

52 I t v: t c i c' you to do in maintenance and is that 1 ('. 1 s= _sfactory?" That's one approach, of course. You l d

e.

airo cay "Hev are they performing out there? Is II 9 4 i 2' sefe? If maintenance contributing to safety or E not?" 6 There are rany things that could have 7 happened that have not happened in my judgment in 8 helping us core up with a maintenance rule. So, I'm 0 not completely satisfied we have a maintenance rule 1C t '- t is geod enough. I hope in due time we would have cnr tbn.c end I'd hr pe that the industry would help 12 ur r : '_ : - 'he have. 13 Just a couple more points on my views on (:( 14 r;:ntenance. The plants out there now that are 15 conducting good maintenance programs in my judgment 16 does: mean they're always going to have good I '7 maintenance programs. We've seen plants change. 18 We'v. seen plants go from operating very well to 19 declining. We've seen it go the other way. We need a 20 standard, it seems to me, for maintenance as well as 21 ve do for operations. If maintenance contributes as y 22 much to safety as I believe it does, sometimes as much f 23 or sonetimes more than operations, then I think we 1 24 need so w kind of a standard. 2 r-I think the proposed rule is probably too NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVENUE, N W. (202) N WASHINGTON, D.C. 20005 (202) 232 6600

I 53' .m u O hroe6. _I thir' _I agree with.the'ACRSHcomment in'that (; 2 reger6 and 'that 's one reason Isthink it should be a 2 N ; '. e r - r u l e and e' stronger rule. 4 Yes, ve do not have here on_the NRC'all the 5 expertise in the world~on maintenance. 'That's a fair 6 corient. But we asked for-help and we didn't get it 7' al.a that's disappointing. . We may have to_get E consultants to help us. I-would hope we.would do'that 9 in the future if the industry doesn' t ' help anymore 10 than they have. 1: I think maintenance is-improving. No 22 question about it. But I think it needs-to improve-13 more. Maintenance does, yes, testing contributes. So 24-does surveillance. Mistakes are made. Maintenance 15 needs to be upgraded, in my judgment. It could be 16 _perhaps the most significant operational safety 17 improvement that can be made. We have improved 18 operators. We have improved training significantly. 19 We need~to do the same in maintenance, in my judgment. 20 When you talk about management and 21 maintenance and how they interface as far as 22 regulatory responsibility is concerned, I agree. But 23 I think management needs to get more involved in 24 maintenance. Those who are involved in it, in my 25 j udgrnen t, are running our better plants. Those who NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 2N WASHINGTON, D C. 20005 (202) 232-6000

i 54 are not..giving the attention to maintenance are not~, 2-in - r y' j u d g n. e n t, earryin~g out-their: ' proper .r e spon s i bil i t i e s. 1 4 I would prefer to.see the. industry do it all' { '5 for then.selves, but'we've been_ waiting a'long time for 6-that'. It s e e..s to me that a standard would be helpful. 7- ' t o..the. indus try. I'am convinced that at leastItwo-6 . third or rnaybe more of our plants, if. we had a-9 n.ain t enance rule, would already be meeting whatever. 10 maintenance rule we might have out there. It wouldn't 11 be anyl real problem-to them. But it would help those IT plante that are not perhaps - running 'as good a - c 13 maintenance program as they should. .g-14 It might even help them when they go-their 15 PUCs and help the CEO, the chief executive officer, 16 r'a ke his case for maintenance funds that he needs if 17-he is not getting perhaps the funds he thinks he 18 needs. I think some of our CEOs are experts at that 19 and can defend themselves extremely well. But perhaps 20 there are some who would be strengthened by a rule. 21 In any case, I hope we do move towards a 22 rule. I think we need one, but I don't think, in my 23 judgment, that we're ready at this time for one. I 24 would hope though that the ACRS would continue L 25 thinking about this. If my colleagues would agree NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W. (202) 234 4433 WASHINGTON, D.C. 20005 (202) 232 6 .__1

i l-55 j \\ ~ l ~. v +r +hinking on this, we will, at least for the i ( St in;, have a strong policy statement and c have a rule in place, but ~ ror.;nue to develop a cortinue to perhaps strengthen it and modify it. I l 5 wot: i hope that the ACRS as well as the industry would 6 rt least help us try to improve the maintenance in 7 nuclear power plants in our country. E Those are my thoughts. If anyone wants to o co rent, I'd appreciate hearing it. If not, we'll 20 ove on tc the next subject. 1: DOCIDE REMICK: If not, the fourth subject

T th:'

y' +ntioned was NUREG-1150, the severe accident 13 risk assessment for five U.S. nuclear power plants. (e. 14 I'r not sure how much advice we can r'tovide you today 15 on that It's our understanding that the Commission 16 wishes ACRS to provide views on whether the revised 17 version of NUREG-1150 is suitable for use during the 18 t i ni e that a peer review takes place. And in j 19 particular, could it be used as part of the IPE l 20 process. 21 We only recently received the revised 22 version. We have not had sufficient time to hold a 1 23 s ubc or.mi t t e e, Usually something of this depth we hold 1 24 a subcommittee meeting first. But we have scheduled i. Er two hours of discussion of the full Committee tomorrow NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) N WASHINGTON. O C. 20005 (202) 232-6600

56 up this topic. We're hoping that perhaps te 'av e ( after thet two hours and then with other thought, that l F 3 rn'ps m can provide you some views on interim use i a -- *';< m--ting, but we cannot guarantee it. 5 CHAI? MAN ZECH: Why don't we plan on doing 6 that now and then we look forward to hearing your 7 views on that We would appreciate them very much. E That's the by question we're asking you to address. C DCCOR REMICK: All right. ". O CHAIRMAN ZECH: So, if you're going to '1 a d d r ee s s thet tomorrow, we'd appreciate hearing from yet wr.n yca can en that matter. 13 DOCTOR REMICK: All right. Fine. (:.. 24 CHAIRMAN ZECH: Then we ask you to address 15 one last matter too, I think, the integrated -- IC DOCTOR REMICK: Oh, yes. You're right. 1 */ CHAIRMAN ZECH: -- approach. 18 DOCTOR REMICK: Yes. 19 CHAIRMAN ZECH: Please go ahead. 20 COMMISSIONER ROGERS: Would you care to 21 c onn:er. t on your opinions of the peer review process 22 that 1150 in being subject to? 23 DOCTOR REMICK: I look to our Chairman of ) 24 our Subcorr.ittee if he has any comments. I cannot add fi. 25 any at this time. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 232 6600

1 l 4 I 57 l l 1 DOCTOR LEWIS: I don't have any comment. h i

t's a fine list cf people.

I don't know whether ^ l l 3 l they've all agreed to serve, but I think it's l: 4 I deli;htful that we're having a peer review, I think. E I c.on ' t think that the report has been improved as 6 ruch as the staff does, but I also defer to the peer 7 review E CHAIRMAN ZECH: Well, the Commission also 9 looks forward to the peer review group and I'm sure 10 t h.:; will ake a contribution to 1150. 11 DDITOE LEWIS: No, our position was simply 32 th? it shouldn't be used until that is done. 13 CHAIRMAN ZECH: Right. N. 14 DOCTOR REMICK: I'll address myself to the 15 fourth iten., the integrated approach to regulatory i 16 r+tters. I 17 CHAIRMAN ZECH: Yes. Thank you. 18 DOCTOR REMICK: The letter we wrote on April 19

17th, a fairly short letter.

I'd like to say that 20 we're aware that the Commission has worked hard to get 21 a hold on where this Agency is headed and to establish 22 priorities in order to bring some semblance of order 23 in the aftermath of TMI.2. 24 However, we still see many cases of items {. 25 which seen to crop up and which, regardless of their NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W. (202) N1 WASHINGTON, D.C. 20005 (202) 232-6600

L l: (. 7-58 s-1 l' ris). s i g n i f i'c a n c e, sometimes get pushed to the forefront.of Agency priorities. We ' f' eel.that this - ) p: > c e s ' considerable burden on the licensees. Whati 4 ongoing activity do they drop to undertake.the latest 5 . regulation?- What ' is. the relative. priority of f that ~ l' 6 natter compared to others? 7 We think -that from the ' licensee's-8 perspective, andL certainly at times f rom our 9-perspective, it appears that the Commission's efforts. 10 to es tablish ~ regulatory stability. are. not working ~ 11 c e r;p l e t e : S As 'your safety advisors, we felt .2 correlled to express those views to you, so we.sent (.~@ 14 concerns about. things. It just seems like this office 15 pops up this issue and this office pops up that issue 16 .and we're not sure that anybody's' weighing the 17 relative risk priorities of those various things and 18 so that there's some semblance of order of what goes 19 out of the Agency. 20 So'that's the general background. I look to 21 my fellow members to see if they want to add anything 22 to that. 23 Hal? 24 DOCTOR LEWIS: No, I think you've said it y 25 very well. This isn't a criticism of the Commission, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202).M WASHINGTON, D C. 20005 (202) 232 6000

-c_

• [

s' 59' .s. 1 3 'y rimply an expression of ~ state of affairs which a 3: -is not' uncommon among agencies, in-which'each element L4 of' % agency does what it honestly thinks 'is best. L ' 4 .Yet

. t somehow doesn't add up'to the best for the j

5 whole society. We've seen so many cases of it and we 1. L 'C - don't want to belabor each one. You've seen-it too. I 7-We'think there's something wrong.. Cures are .S another ratter. 9 CHAIRMAN ZECH: Right. Well, has the staff 10 discussed their approach to the integrated programs 11 'with the ACRS? Have you heard -- 12 . DOCTOR KERR: The staff gave a presentation e t. 13 on the SECY paper. .Q 14 CHAIRMAN ZECH: Yes. 15-DOCTOR KERR: I would characterize the paper 16 as e - -very good description of those programs that 17 needed to ' be integrated. I have not seen anything 18 that. tells how they're going to be integrated. 19 CHAIRMAN ZECH: Well -- 20 DOCTOR SIESS: Just the opposite. 21-CHAIRMAN ZECH: Yes, I think -- 22 DOCTOR SIESS: Mark I containment was 23 reintegrated. 24 COMMISSIONER ROGERS: Say that again, CL 25 please? NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W. (202) 234 4433 WASHINGTON, D.C. 20006 (202)332 6

} l 60 DOCTOR SIECS: Mark I containments was k reintegrated I i l ~ COMMISSIONER ROPERTS:

Well, I wouldn't i

4 l pr e 5-w e to put words in your mouth, but in your letter 5 you specifically mention the maintenance rule. Would f ycu put charging off with the Mark I so-called 7 improvements and simultaneously doing the IPE program f er e e ple of what you refer to in this letter? 9 DOCTOR REMICK: Yes. 1^ COMMISSIONER ROBERTS: Thank you. So would l '. 1. 1: ?' r. WARD: IN fact, we wrote a letter 13 specifically on that. C.:;r 14 COMMISSIONER ROBERTS: Thank you. 15 CHAIRMAN ZECH: Well, let me just make a 16 corment and then I'll ask for other comments from my 17 colleacues. 1E I certainly agree that integrating our many 19 different programs is extremely important. I've 20 mentioned this to the staff before and asked them to 21 take on this project to make sure that we start with a 22 safety goal perhaps and integrate the severe accident 23 policies, the Mark I containment, all the other very 24 important issues that bear on plant safety and that we f. 25 do integrate, that we make sure we have a thread of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W. (202) 234 4433 WASHINGTON, D C. 20005 (202) 232-6800 l

l I 61 _ F

• e r. c y floving through them.

I think l 2 c or ::e ptt n11 y, that's what we'd all like, we'd all want i ~hm h Again, it's true that parts of the staff, I f I'- sure well meaning, are going after their own f ptr'iculal prograr and doing it very professionally 7 and that's not a criticism of them either. But it is E irpo'ttat that at a higher level somewhere that we do 9 ardegrate thes" progr an:s. It's the same view I had 10 wht: I firs + started thinking about the necessity of a 1: buk-fi' rule. 1 I think perhaps after Three Mile Island, the 13 Conniseien, the staff, all of us or all of those who e; 14 were here,, ell meaning and taking issue after issue 15 and addressing it and issuing regulations and so 16 forth, probably every on by itself can be justified. 17 But integrating those things over a whole -- and 18 making ther' consistent, bring them together, seems to 19 me very necessary. That's why I thought some kind of 20 discipline to our system, such as the back-fit rule, 21 was irportant, so that we look carefully and with some 22 kind of an analytical process before we go ahead and i 23 make sore regulation that by itself may improve safety 24 in this area but may detract perhaps in this area. 25 50, ! think an integrated approach to all NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVENUE, N W. (202) 23 % WASHINGTON. D.C. 20005 (202) 232-6600

F 5 ). 62 7 1 r ps cur' regulatory notters is extremely important.- ItLis

lg[

l. 5, 2 e big' issue. I appreciate your letter. I appreciate 7 yoc _ views on it. I think they're very consistent I ' bi t' the' Commission's views. -{ 5 -On the other hand, what we've asked the-6 staf f to cone up w$th is a pretty tough' problem, I 7 suppose. But I do think it's worth a fair = amount.of E-thoucht. It's worth the Commission involvement, I 9

think, in attempting. to get integrated programs 10 b+eeuse t h el* sinply must contribute one to the other l '.

a v they' tust be brought together at some level. 10 So, I would hope that perhaps -- the staff, 13 I know, is trying to do this and it may be an 14 irrossible task we've given them. We'll have to think 15 about that. But I do feel that if the ACRS, in.your 16 good judgment and your experience, can assist us in 17. 'some way and perhaps assist the staff in taking a more' 18 Meteched view than' maybe they're able to take, it 19 might be very helpful to the Commission. 20 So, my approach would be to ask the staff to 21 'look at your letter and to see what they can come back 22 to us with. On ' the other hand, I'think if the ACRS 4 23 could, in due time, because I think this is another 24 difficult issue to wrestle with and we wouldn't expect 25 you to try to help us solve it overnight, but if you .NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE 15dND AVENUE, N W. (202) 234 4433 WASHINGTON, D.C. 20006 (202) 232 6

63 0 c.10 takt this on and see if there's some way from ( 1 2. different viewpoint that you raight be able to ht i, us vi *1 looking at an integrated approach, even I systematic or a philosophical approach, might / I f r o-r E be a good starting point, because I do think the 6 effort tc integrate these programs is very important. 7 Cor.missioner Roberts has a good point 9 bec % n -- and I think we all look at it the same way. 9 We recognize these various programs that we're 10 -ssin; We don't want to address them in '~ ". 1 isol: io: There is a tendency, I think, to do that 17 be. -. e s ym look at the logic and the good sense to 13 the progr a:: and such. But how does it integrate with 14 other programs? I think it's important. Perhaps the 15 ACFS can help us in that regard. I, for one, would ~. E ask you to take en that issue. 17 DOCTCR REMICK: There's several of us on the 15 Corrittee, of course, that work for licensees to the 1 19 NRC and have to read issuances from the Commission. 20 Sorm of us have to face students and talk to them 21 about the NRC and the regulations and so forth. It's 22 surprising trying to explain sometime the thread of 23 continuity and consistency that exists in the 24 regulations and what is going on. (; 25 CHAIRMAN ZECH: That's a very important NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVENUE, N W. (202) 2344 433 WASHINGTON. D.C. 20005 (202) 232 4800

64 e, u* ' t ai. i n g. It really is. It's a very, very big i (' l .. ee fur as concerned. I think you recognize 0 es wel: as we recognize it. It's a very I! e i ir,xr:ent issue. But if you could take that on one 5 and think about it some more, I think it would be very E helpful to the Co. emission. '7 Commissioner Roberts? ? DOCTOR LEWIS: I wonder if I -- C CHAIRMAN ZECH: Yes, please, go ahead. IT " TOR LEWIS: I just wanted to jump in 11 wh::- I'- net wanted. Coordination in an agency, you wouldn't run a ship by committee. If the k:,

?

ch m are down, somebody has to -- (0. l' CHAIRMAi* ZECH: Yes, you can say that again. 15 COMMISSIONER ROBERTS: You wouldn't run this 16 agency with s commission, would you? I '7 CHAIRMAN ZECH: One of the reasons I favored IE a single administrator as I'm sure you know. 19 DOCTOR LEWIS: And besides, I've also been 20 on a ship. But anyway, you wouldn't. You just can't 21 do it. In that sense, the trouble of coordination of 22 an integrated approach, you can't go a step below the 23 Committee that runs this Agency, which is you folks. 24 It's a little complicated. You can't go from there l 25 dewr the line to get an integrated policy. NEAL R. GROSS CoU: T REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) N WASHINGTON, D C. 20005 (202) 232-0600

1 65-3. 1 CHAIRMAN ;ECH: le s.. Yes. h j DOCTOR LEWIS: In

fact,

'i n most i organizations, the integrated policy. comes f rom the 4. chief executive. officer. 5 CHAIRMAU 2ECH: Okay. 6 ' DOCTOR LEWIS: You know, you hire him and 7 fire him according to whether he can. accomplish that.. 8 Still.less can you get an integrated policy frorn the 9 advisory committee to the committee that runs ' the ~ 10 agency. 11 CHAIRMAN ZECH:

Well, I don't know if I l

12 agree with that. I agree that giving it to the staff (?v: 14 fair to let them hear their views on it because, 15 you're right, we have to make the decision. No 16 question about it. But it's helpful to have their 17 views, I think. 18 DOCTOR LEWIS: Oh, yes. 19 CHAIRMAN ZECH: And also, by the same token, 20 I'think that the ACRS, we have to make the decision. 21 It's our responsibility and we will make it. You can 22 count on that, I'm sure. But we want to make the best 23 decision we can. I really do believe that yoa and 24 your collective experience can at least give ycur (El + 25 thoughts to us and we will make the decision and we'll t NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W. (202) 234 4433 WASHINGTON, D C. 20005 (202) 232-6000

66 l s t+ke the responsibility for making it. k. But I think in our arriving at that 5:,.ctant decision to integrate the programs, it's a 4 littit bit in a sense like the safety goal and trying 5 te irpien.ent the safety goal. I think you have 6 s o.se t hing to offer. 7 DOCTOR LEWIS: Yes. It's just that in this 8 subject there is no enemy. There's nobody against = integration. 10 CHAIRMAN ZECH: Ho. Exactly. 11 DOCTOR LEWIS: That's what makes it so much h e r C +- : (.- CHAIRMAN ZECH: I agree. I agree exactly. I s 14 DOCTOR REMICK: We are in a somewhat unique 15 position. Other than the Commission, ACRS and a 16 couple of your senior staff members, many other people 17 don't see what is going on -- 18 CHAIRMAN ZECH: Exactly. 19 DOCTOR REMICK: -- the breadth of the 20 Agency. We see that breadth, not as much as you do-- 21 CHAIRMAN ZECH: But you do see that. so we are able to 22 DOCTOR REMICK: 23 cornp a r e. 24 CHAIRMAN ZECH: Yes. 25 DOCTOR REMICK: Sometimes when we work with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W. (202) N WASHINGTON. D.C. 20005 (202) 232-6600

a '. -67 + .1 ~ s t *. f f frce ons. ; cf fice, they're not at ' all where a - ~[ Is:ett'.progre in another of fice. ? CHAIRMAN ZECH: .Certainly. C - DOCTOR' REMICR: We see this type of thing 5 W art in a position sometimes where we -- 6 CHAIRMAN ZECH: Yes, I think you can make 7 a -- you can help us. We have to make the decision, I E agr n. 9 .Ccn.issioner Roberts? 10 COMMI?FIONER ROBERTS: Are we completing'the la neeting?- Have we finished the last topic? 12 CHAIRMAN ZECH: This is'the last topic and 12 we're asking colleagues questions on the last topic. I/%7,: 14 COMMISSIONER ROBERTS: I have no' questions. 15 on that, but 16 CHAIRMAN ZECH: We'll come back to you then. 17 ' COMMISSIONER ROBERTS: All right. Thank 18 you. 19 CHAIRMAN ZECH: Commissioner Rogers? 20 COMMISSIONER ROGERS:

Well, just that I 21 wanted.to say that you do have that vantage point 22 that's rather unique and I think you are in a special 23 position to be able to see where things seem to be 24 disconnected and t properly integrated.

25 I'd also ask you to think, if you could, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234 4433 WASHINGTON. D.C. 20006 (202) 232 6 L_-.________-

_m_--- 1. 68 1 dbcut' perhaps where there might' be'some problems 'due (. T tc a -lack of knowledge, that the: things.aren't-being ir t-ecr a ted because there is some question someplace 4 tha-someone f eels ' they need an. answer to that they F don't have that sets an. improper priority on the work L6 in some wal. I think you would also. be in a.very 7 special position to be able to point out to us where 6 there are - roadblocks to integration because of-a lack i 9' of knowledge, important knowledge. 10 DOCTOR KERE: I'm sure you are as aware, as '1 those of us who come from academic backgrounds, of the ': 0 c o r.p a r t r. e n t a l i z a t i o n that takes place within ic 13 -universities. I think things are equally .gb 14 compartmentalized in this organization, for good or 15 ill. 16 CHAIRMAN ZECH: Commissioner Curtiss? 17 COMMISSIONER CURTISS: No comments. 18 CHAIRMAN ZECH: Commissioner Roberts, you 19 had a comment to make? 20 COMMISSIONER ROBERTS: Well, I don't want to 21 get into an argument over semantics with my colleague, i 22 Commissioner Rogers. But I'll just tell you from my l b 23 point of view, it'is certainly -- back to our earlier q 24 discussion about management and regulation. Certainly a 25 the irposition of regulations can affect management, NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS l 1323 RHoDE ISLAND AVENUE, N.W-(202) M WASHINGTON, D C. 20006 (202) 232-6000 l i _________--__________.u-_-_________.___.._

m. .m Y ] s* r R4 16 ry Oiev they-are clearly separable - and:. when _t ther de tend to 'get ' fuzzy, we have' a L eompelling i cY;ication t o ' make them as separable as possible 4. becease I think-regulation and management are. two - different entities. r 6 That's all I have to say. 7 CHAIRMAN.ZECH: All right. Thank you. .? COMMIS SIONER - ROGERS : I won't rise to that t; 5 bait -In CHAITMAN ZECH: All right. Fine. 11

Well, let me thank the ACRS again~ for 12 another-v+ry fine presentation.

When will you come i.: 13 back to the Commission again? Do we have another, < ($ 14- -meeting scheduled? 15 DOCTOR REMICK: No, none scheduled at the 16 r o r.e n t. 17 CHAIRMAN ZECH: Well, it may not get back 18 before I leave. If that does take place and you don't 19 appear before us again, I would like to take this 20 opportunity, Doctor Catton, to welcome you again -- 21 DOCTOR CATTON: Thank you. to the Committee and I 22 CHAIRMAN ZECH: 23 would also like to welcome the other new member who 24 hasn't been here too long to the table, Mr. Carroll. j 25 It's a pleasure to have you with us. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVENUE, N W. (202) 234-4433 WASHINGTON, D C. 20005 (202)232 6

t. q( 70 e 1 Tc all of. you who I'v'e gotten to know so 2-r'; ch. bet t er than'the.new members perhaps, and to.' all 2 of you, I would like to of f er.you my own personal' 4 gratitude'for your competence, your intellect and.your 5 willingness ' to share 'our views and your-time, your-6 energy with this Commission. 7 I can'.t t111 you how much.it'means to me to 'S have had the benefit of your views. I think I can 9 ' s p e a '.. f o r all r.y colleagues - in this regard, but. 10 certain1r speaking for myself, I want you to know how 11 much I' appreciate working with you and I'll be 12 eternelly greteful for the way that you have assisted' '.C4? i 14 . colleagues in coming to these important decisions that 15 we'have to make. 1A We do make the decisions. We are the 17 Commission. We make the final decisions. We make the 18 beet ones we can. We have a lot of good advice from 19 the staff, a very competent dedicated staff who does 20 their best to give us the good advice. But I can 21 assure you that as far as I'm concerned the Advisory-22 Cormittee on Reacto'r Safeguards has in the past, over 23 the many years, and continues to make a very real 24 contribution to this Commission. I, for one, wish to 1. 25 thank everyone of you for the time you give and for NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202; 234 4433 WASHINGTON, D.C. 20006 (202) 232-6000

71 crec* contribution to our Agency and to our ( ^ ce " t :. ; ~ D O C T T,F REM': C E. Mr Chairman, we wanted also 4 t- -ypress our pleasure for the opportunity to work I with you during these past five years. You've openly 6 end repeated 2y expressed appreciation of our effort 7 and that's r.ade us feel very good, of course. But it ? else spurred us on to try to do the best possible job ? th' ve can in giving advice to the Commission.

^

You've been very receptive and attentive to '.1 cor

e t t.- r s.

We know that. Some of the ~_. 2 r e c er ~ e:. ",a t i on s you accept, some you reject, but we 13 understand that fully. We just provide advice, you 12 must make the decisions. But we want you to know that 15 ve've been extremely proud to have been part of the 16 Agency under your Chairmanship. We wish you very well 17 for the future. IS CHAIRMAN ZECH: Thank you very much for 19 those kind remarks. 20 Thank you very much, gentlemen. We stand l 21 adjourned. l 22 (Whereupon, at 3:36 p.m., the hearing was 1 i 23 concluded.) 1 24 .5 ^ NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVENUE, N.W. (202) 234 4433 WASHINGTON, D.C. 20005 (202) 232-6600

~' -( CERTIFICAT5 0F TRANSCRIBER This is to certify that the attached events of a meeting of the United States Nuclear Regulatory. Commission entitled: TITLE OF MEETING: PERIODIC BRIEFING BY ADVISORY COMMITTEE ON REACTOR SAFEGUARDS PLACE OF MEETING: ROCKVILLE, MARYLAND DATE OF MEETING: MAY 3, 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. 0&'d$t N (t G g Reporter's name: PETER LYNCH G NEAL R. GROSS COURT Rt90RTERS AND TRANSCRl0ER$ 1323 RHODE l$ BAND AYfWUE, N.W. j (202) 234-4433 WASHINGTON, D.C. 20005 (202) 232 6 o- ----

,y 'o UNITED STATES. g ./3 NUCLEAR REGULATORY COMMISSION o ADVISORY COMMITTEE ON REACTOR SAFEGUARDS { f WASHINGTON D.C.20666 o February 16, 1989 The Honorable Lando W. Zech, Jr. Chairman U.S. Nuclear Regulatory Comission Washington, D.C. 20555

SUBJECT:

FURTHER ACRS COMMENTS ON IMPLEMENTATION OF THE SAFETY GOAL POLICY During the 346th meeting of the Advisory Comittee on Reactor Safe-guards, February 9-11, 1989, and in meetings on October 6-7, December 15-16, 1988, and January 12-14, 1989, we continued our review of the NRC staff's plans for implementing the Safety Goal Policy. We had the benefit of a draf t paper for Commission approval, " Implementation of Safety Goal Policy," dated January 17, 1989, and of presentations by a member of the staff. We had previously comented to you on this subject in our letters of May 13, 1987, and April 12, 1988, following a number of exchanges with the NRC staff, including several meetings with our Subcommittee on Safety Philosophy, Technology, and Criteria as well as with the full Comittee. Although we agree with the general direction of the staff's recom-mendations, we have substantive differences about a number of issues. We urge the Commission to implement the policy after considering our recommendations.

Background

The draft paper proposes guidelines for the NRC staff to use in implementing the Safety Goal Policy. These guidelines include the structure of an. implementation plan, definitions, and quantitative objectises. The paper calls for these guidelines to be incorporated into the policy statement itself through an amendment., In addition, the paper proposes that potential averted on-site costs be used as an offset to licensee costs in cost-benefit analyses. And finally, the paper - asks the Comission itself to consider whether the policy should be amended to clarify the relationship of the safety goal and the statutory standard of adequate protection. \\ l

9f. [ HonorableLandoW'.'Zech,dr. February 16, 1989 I Before commenting specifically' on the staff p(aper, an observationPRA)andits about the use of probabilistic risk assessment to' the' safety goal is appropriate. Although it is frequently. said that "the bottom line is the weakest part of PRA," the fact remains j that the safety goal.cannot be implemented without the bottom line. Without this bottom line and a safety goal' to which it can be. com-pared, either explicitly: or implicitly, PRA becomes a never-ending' search for outliers. Although it is satisfying to some engineers and analysts L to identify' " dominant" contributors to. risk, especially those that can be eliminated readily, there is nothing necessarily less safe about a plant that has most of its risk embodied in one or two outlier sequences than a plant that has its risk distributed more or less uniformly over 20 sequences. Structure of-the Implementation Plan The draft paper describes a structure similar to that' suggested in our letter of May 13, 1987, but with some differences. We continue 'to prefer the structure we recommended, a hierarchical arrangement of five levels using the multiple goals in the policy statement of August 6, 1986. The staff's current proposal is consis' tent 'with our recommendations for Levels One and Two. Level One is the pair of qualitative goals and Level Two is the two quantitative health objectives. Our recommendation for Level Three would. be the general performance guideline that large accidental releases should occur no more fre-quently than IE-6 per reactor-year. The staff's Level Three proposal is similar, but differs in the definition of "large release." The staff proposal defines a large release as "a release that has a potential for-causing an offsite early fatality." We are still not satisfied with this definition for 'two reasons. First, it can or could be considered as little more than the quantitative health objective in Level Two, but at a level ten times more conservative. Second, this considerable additional conservatism is not accompanied by a significant simplification. The use of the word " potential" in order to encompass the release at Chernobyl will require the use of Level 3 PRA results with a suitable prescription or selection of potential meteorology and population distribution or location. Although this would be possible for specific plants, it would require f arbitrary assumptions if the safety goals are to be used to test the i sufficiency of the Commission's regulations or to provide a basis for i establishing design criteria for containments for future plants. We continue to believe that a definition in terms of the release L itself is preferable. It might be defined in terms of curies, leak l I

( ( Honorable Lando W. Zech, Jr. February 16,1989 v or. release rate, or fraction of the core or_ containment inventory. In any case, it should be independent of the site characteristics and should provide some criter.ia against which the design or performance of containments can be' tested. We urge you.to request the staff to continue seeking a means to define a large release that is ' not

significantly. more conservative than the Level Two health objectives and that focuses.the. mitigative function on containment design characteristics independent of site or population characteristics.

Our recommendations for Level Four. consisted of three specific performance objectives: (1) core melt probability, an ex the effectiveness of a plant's-prevention systems, (2) pression of _ conditional. probability of containment failure, an expression of the effective-ness 'of a plant's mitigation systems, and (3) an expression of how - well a plant is operated. (We use here the term " prevention" to describe those activities and systems intended to keep the reactor. core from melting, and " mitigation" to describc those ' activities and ' would be' released from a melted core.) public fission products that' Level Fou systems intended to keep away from the staff is.significantly different from what we recomended. -It would-consist of: only one of the three objectives we recomended, a limit -on core damage frequency. This loses the balance between prevention .and mitigation, one form of defense-in-depth, that.is inherent in our inclusion of a containment' performance objective. We believe this balance should be retained. The staff proposal for Level Four also omits the ACRS recommendation for a quantificatien or objective statement of how well a plant is operated. We called this a "plent performance objective." We have not been able to develop a workable definition for this, nor has the staff. In light of this, we rely upon the alternative recommendation made in our letter of April 12, 1988: 'If this cannot be done, a prominent caveat, e.g., a warning that PRA results do not tell the full story, should be made a part of the policy or of the implementa-tion plan." We recomend that such a statement be made an explicit part of the plan. Ir. our letter of May 13, 1987, we recomended a quantitative objec-tive of IE-4 per reacter-year for " core melt" as a part of the Level Four performance objectives. In our letter of April 12, 1988, we more carefully defined the event that should be associated with this quantitative objective as the " loss of adequate core cooling (core overheating beyond design-basis limits)." The staff proposal seems to agree with our recommendation. We caution, however, that compari-sons of this objective with some of those proposed by others under the description of core melt probability can be misleading. o

[ ~..,. \\ ,i Honorable Lando W. Zech~,' Jr. February 16, 1989 with the staff's proposal to use IE-5 per reactor-year as We disagree.for mean core damage frequency for future plants. the target. ~ This difference from the objective for existing plants - introduces an-arbitrary level of conservatism which conflicts with the criterion we suggested for. linking the hierarchical levels of safety goal objec-tives;.that is, that each subordinate level of the hierarchy should be consistent with the level above and should not be so conservative as to create a c.e facto new policy. Not only would the staff pro-posal introduce a major ~ inconsistency with the Level Two. and Three objectives, but it would result in loss of balance between prevention and mitigation because arguments could then be made that the higher levels of the safety ' goal hierarchy could be met readily without the i need for accident mitigation systems such as containment buildings. The Commission's safety goal should be the same whether considering the adequacy of regulations for existing plants or for future de-signs,.and whether for LWRs or other types of reactor plants. Definition of " Adequate Protection" The term " adequate protection" has importance in the legal areas of safety regulation. Although it is needed and used with apparent precision in' legal instruments,.its technical. definition is not precise. In general, it is cceepted as equivalent to the term "with no undue risk to public health and safety" often used in other contexts. Another term, "in full compliance with the regulations" is used as a surrogate, on occasion, for either of these. We believe that the safety goal should play an important, but in-direct, role in defining adequate protection. Ideally, compliance with the Commission's regulations is a suitable surrogate for defin-ing adequate protection of the public. However, we believe that the adequacy of the regulations should be judged from the viewpoint of whether nuclear power plants, as a class, licensed under those regu-lations, meet the safety goals. It is our understanding, following discussions with the staff, that the staff proposes the safety goal to be a sort of aspirational objective which would be sought but not necessarily reached. Pith the safety goal approach now proposed by the staff, a class of plants that meets existing regulations (therefore meeting a standard of adequate protection) would be obliged to make improvements up to the safety goal, if cost-benefit arguments so dictated. The imple-mentation plan proposed earlier by the staff would have used the safety goal as the minimum standard (i.e., adequate protection) and cost-benefit arguments could have been used to justify further l

1

l. '

'.g. l Honorable Lando W. Zech, Jr.. February 16, 1989 I i improvements, without other limits. fWe believe that neither of these approaches is a proper use of the Safety Goal Policy. We believe that the proper use of the safety goals is embodied in two a principles'which we have previously recommended: (1) The safety goal is a definition of how safe is safe enough. (2) At the present time, the safety goal should. be applied to judging the adequacy of regulations and regulatory prac-tices, and not to make' specific decisions about individual plants. l - The Commission has taken a bold and progressive step in. proclaiming the Safety Goal Policy. It is an attempt to place the regulation of safety in nuclear power plants in an appropriate context. relative to. other. risks in society. It is imperfect, but it is as useful a step as has been taken by any industry or regulatory agenc Using concepts of cost-benefit analysis or, even worse, ALARA '(y. as low as-reasonably achievable), dilutes the achievement and effectiveness of the Safety. Goal Policy. We believe that the safety goal.is a good present standard for "how safe-is safe enough." Further, as we have stated earlier, we believe that the safety goals should be used to judge the adequacy of the regulations from the standpoint of whether those regulations result in classes of nuclear power plants which can be and are operated in such a way as to meet the safety goals, and thus provide adequate protection to the public. A wide community of safety experts and policy makers has concurred, after extended deliberation, in accepting the Safety Goal policy as reasonable, based on present knowledge. It may be that_ future information about reactor risk or societal risk will cause a need.to adjust the safety goal one way or another, or to make different implicit allowance for uncertainty. Until that happens, we believe that the safety goal should be accepted as an unambiguous working standard for the regulation of nuclear power, along the lines we have suggested. Cost-Benefit Analysis The staff paper proposes that cost-benefit analyses made to evaluate proposed plant safety improvements should use averted on-site costs as an offset to the plant costs entailed in making such improvements. We believe that this is appropriate in making cost-benefit assess-ments, although it inevitably adds uncertainty to the results, However, as discussed above and as we stated in our letter of April p g E - - - - - _ _ _ _ _ _ _ _ _ _ _____ _

' 's Honorable Lando W. Zech, Jr. .6-February 16, i989 ~ 12e 1988,'we.believe cost-benefit analysis is not properly 'a part'of safety.goalimplementation(incontrastto"backfit". implementation). Incorporation of Guidelines Into the Policy b We ' concur.with the staff proposal to incorporate certain of the L implementation guidelines as amendments to the policy statement. We have no preferences or comments about the details of this, beyond the-reminder that the safety goal is a policy statement, not a regula-f tion. Coherence Among Regulatory Policies The Safety Goal Policy' has been in existence for some time and has, in fact, been an influence in recent regulatory activities. We believe a clear implementation plan is necessary to. ensure that it is applied comprehensively, consistently and unambiguously. Several major Commission decisions are. presently on the horizon regarding, 'for example, the Severe Accident Policy, the issue of Mark I con-tainment adequacy, certification of advanced reactor. designs, and evaluation of plant operations. In each of the these, the question "how. safe is safe enough" must be answered, either implicitly or explicitly. The safety goal can and should bring greater objec- ) .tivity, consistency and clarity to deliberations and decisions about f these issues. g Sincerely, orrest J. Remick Chairman Reference Draft Proposed Paper from V. Stello, Jr., Executive Director for. Operations, to the Commissioners,

Subject:

Implementation of Safety GoalPolicy(Predecisional)(receivedJanuary 17,1989).

-y rl UNITED STATES v o,, NUCLEAR REGULATORY COMMISSION f. c. { j' ADVlsORY COMMITTEE ON REACTOR SAFEGUARDS o wassmoTow, n. c.20ssa g April 11, 1989 The Honorable Lando W. Zech, Jr. l Chairman U.S. Nuclear Regule. tory Comission Washington, D.C. 20555

SUBJECT:

PROP 9 SED FINAL RULEMAKING RELATED TO MAINTENANCE OF NUCLEAR i POWER PLANTS During the 348th meeting of the Advisory Committee on Reactor Safe-guards, April 6-8,1989, we discussed the draft Comission paper related to final rulemaking for mair.tenance of nuclear power plants, including a draft regulatory guide. Our Subcommittee ca Maintenance Practices and Procedures discussed this matter with representatives of the NRC staff and the Nuclear Management and Resources Council during a meeting held on March 30, 1989. We also had the benefit of the document referenced. We previously comented on the. proposed rulemaking in a report dated September 13, 1988. In our September 13, 1988 report we did not endorse the staff's proposal to establish a maintenance rule. After review of the proposed final rule, including the public coments and a related draft regulatory guide, our position remains essentially the same. We still believe that good maintenance is a necessary ingredient in any operational program that seeks to ensure reliable and safe plant operation, but that is not the issue. The issue is how to achieve good maintenance. We were told by the industry that its aggressive emphasis on the devel-opment of effective maintenance programs over the past several years has resulted in a marked improvement in the maintenance programs themselves, and in significant progress toward reaching its objectives. The staff members with whom we conferred agreed that this is the case. Further, we were told that a staff evaluation of a sample of maintenance pro-grams, which included about one quarter of those plants now operating, indicated that only a few percent of the operating plants may have poor maintenance programs. Given an environment in which there is already a scarcity of industry and NRC resources, we believe that it is more cost effective to seek improvements applicable to the few plants with " poor" maintenance programs by means of existing regulations rather than burdening all plants with a costly program of unproven efficacy. The scope of the proposed final rule is also of concern. The Comission has the responsibility to regulate the operation of nuclear power plants in a way that ensures protection of the public health and safety, but

i e The Honorable Lando W. Zech, Jr. April 11, 1989 does not have the responsibility for managing plant operation. The proposed _ final maintenance rule. strains severely and may violate the boundary between -regulating and managing. 'The scope of the proposed final rule and its accompanying regulatory guide is so broad that almost every facet of plant operation would be under the continuing scrutiny of- { the. NRC on the basis of its effect on maintenance. This would be counterproductive. Because everyone involved believes that maintenance programs are 'in-proving, and because the industry is committed' to additional improve- ~ ments, we recommen.d.that the staff continue to monitor the industry's progress and not intervene et this time. The proposed final rule would introduce a major policy change extending NRC responsibility far beyond identified safety systems. We do not believe such a significant change in policy should occur in the guise of a: maintenance rule which deals only with maintenance' and provides no guidance on which systems deserve special attention., The ACRS' has in the past recomended more emphasis on the performance of'some nonsafety systems. For example, the Comittee recommended an evaluation' of the contributions to risk from failures of nonsafety-grade control systems. More - recently, the Comittee has recomended a reevaluation of the current set of regulations in the light of additional insights provided by risk-based evaluations of plant performance and the adoption of safety goals. We would endorse a well-conceived reevaluation of current regulations which would undoubtedly suggest that more regulatory en-phasis should be placed on some systems that in the past have been treated as balance-of-plant, and less on others. However, this evalu-f ation should be done in an integrated manner which would, on the basis of what has been learned about risk contributions, identify some systems for special attention. Sincerel i orrest J. Remick Chairman

Reference:

Memorandum dated April 6,1989 from Bill M. Morris, Office of Nuclear Regulatory Research, for Raymond F. Fraley, ACRS,

Subject:

Draft Comission Paper for Notice of Final Rulemaking For Maintenance of NuclearPowerPlants,"w/ enclosures (Predecisional) l

nceg UNITED 8 TATE 8 NUCLEAR REGULATCRY COMMISSION ,/ n ADVISORY COMMITTEE ON REACTOR SAFEGUARD 6 { l wAsHtNGTON, D. C. 20666 January 23, 1989 i The Honorable Lando W. Zech, Jr. Chairman U.S. Nuclear Regulatory Comission Washington,D.C. 20555

SUBJECT:

NUREG-1150: RESOLUTION OF ACRS COMMENTS We have noticed in SECY 88-337, a memorandum from the Executive Director for Operations (ED0) to the Comission, a misleading reference to the ACRS which we want to correct. You will recall that we reviewed the draft version of NUREG-1150, " Reactor Risk Reference Document," and sent you comments in a letter dated July 15, 1987. More recently, in a letter of July 20, 1988, which reported on SECY 88-147, we comented further: Reactor Risk Reference Document (NUREG-1150) plore "In our discussions with the staff, we exwill be used'in the resolution of the severe accident issues. Although we were told that the information in this document will. play a key role, we were unable to get a clear picture of just how. If NUREG-1150 is to play a key role It is important that its accuracy and credibility be established. We believe that subjecting the final version of NUREG-1150 to a thor-ough peer review is required as part of the process of establishing credibility." As the EDO reports in SECY 88-337, we did meet with him and with members of his staff on August 11, 1988. Much of our discussion had to do with what we see as a need for peer review of the final version of NUREG-1150 (renamed Severe Accident Risks: An Assessment for Five U.S Nuclear Powerplants). It is true that the staff's proposed uses of NUREG-1150 However, we declined to coment on the specific were presented to us. uses proposed for NUREG-1150 and instead recomended correction of the identified deficiencies and a peer review of the final version to establish its accuracy and credibility before publication in final form. Following our meeting with the EDO, we wrote to you in a letter dated August 16, 1988:

~ ( The Honorable Lando W. Zech, Jr. January 23, 1989 i " Reviews-by a number of individuals and groups were highly critical' of the original draft of NUREG-1150..In view of the extensive modifications that have been made in response to this criticism, the current version must be regarded as a new document. Also, since this document is intended to play a substantial role in the implementation of the Comission's severe accident policy, its quality and credibility are very important. We recomend that before publication in final form, the final version of NUREG-1150 be subjected to a thorough peer review." However..in SECY 88-337, the EDO p(roposes to publish a revise of NUREG-1150 without peer review. and.to publish the report of a peer review to be perfonned later as a supplement). Further, a statement is made in referring to the staff's proposed uses of NUREG-1150: "These uses were discussed-with the ACRS, which did not indicate any objection to them." This might lead to the conclusion that we had endorsed the use of the revised version for the purposes listed. We have not. We have not even seen it. Additional coments by ACRS member Harold W. Lewis are presented below. Sincerely, est J. Remick Chairman q Additional Coments by ACRS Member Harold W. Lewis j I believe the misstatement here is more serious and offensive than does f the Comittee. We often state that our letters speak for themselves. I and ask our own members to avoid interpreting Committee positions. The EDO, in effect, is telling you that we concur in his ?roposed use of a report we have repeatedly criticized in writing. We Tave not done so, and it is not only improper for him to tell you we have, it is disingen-uous. C_________________________.___._______.______

6 The Honorable Lando W. Zech, Jr.. January 23, 1989 Our written recommendation was for a peer review before publication. I believe that was a good recommendation, and that the comission should so insist. References 1. U.S. ~ Nuclear Regulatory-Comission, NUREG-1150, " Reactor Risk Reference Document," Draft for Coment, February 1987 2. SECY 88-147, Memorandum dated May 25, 1988, for the Commissioners from V.

Stello, Executive Director for Operations,

Subject:

Integration Plan for Closure of Severe Accident Issues 3. SECY 88-337,-. Memorandum dated December 8,1988, for the Connis-sioners from V. Stello, Executive Director for Operations,

Subject:

Plans For Future Review of NUREG-1150 f 1

I: + -[,pieCtt e i+ UNITED STATES g ' 3,, Ek NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS g p '-p o WASHINGTON, D. C. 20555 August 16, 1988 The Honorable Lando W. Zech, Jr. Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

REPORT ON NUREG-1150, " REACTOR RISK REFERENCE DOCUMENT" During the 340th meeting of the Advisory Committee on Reactor Safe-guards, August 11-13, 1988, we discussed the staff's plan for the development of the final version of NUREG-1150, " Reactor Risk Reference Document," with Mr. V. Stello, Jr., Executive Director for Operations, and members of his staff. We also had the benefit of the documents referenced. In our July 20, 1988 letter to you on the Integration Plan for Closure of Severe Accident Issues, we stated, "We believe that subjecting the final version of NUREG-1150 to a thorough peer review is required as part of the process of establishing credibility." Reviews ~ by a number of individuals and groups were highly critical of the original draft of NUREG-1150. In view of the extensive modifica-tions that have been made in response to this criticism, the current version must be regarded as a new document. Also, since this document is intended to play a substantial role in the implementation of the Commission's severe accident policy, its quality and credibility are very important. We recommend that before publication in final form, the final version of NUREG-1150 be subjected to a thorough peer review. Sincerely, W. Kerr Chairman l t 1 L_-_---_-.__---_______

m ii. The Honorable Lando W. Zech, Jr. August 16, 1988

References:

1. Memorandum dated August 10, 1988 from V. Stello (EDO) to R. Fraley (ACRS), " Plans for Review of Final NUREG-1150" 2. SECY-88-147, Memorandum dated May 25, 1988, for the Commissioners from V.

Stello, Executive Director for Operations,

Subject:

Integration Plan for Closure of Severe Accident Issues 3. Brookhaven National Laboratory Report, NUREG/CR-5000, " Methodology for Uncertainty Estimation in NUREG-1150 (Draft): Conclusions of a Review Panel," H. Kouts et al., December 1987 4. Lawrence Livermore National Laboratory Report, NUREG/CR-5113, " Findings of the Peer Review Panel on the Draft Reactor Risk Reference Document, NUREG-1150," W. Kastenberg et al., May 1988 5. American Nuclear Society, " Initial Report of the Special Committee on Reactor Risk Reference Document (NUREG-1150)," L. LeSage et al., Draft Report dated April 1988 l l

[pa arci,g'o UNITED STATES i NUCLEAR REGULATORY COMMISSION o ? I ADVis0RY COMMITTEE ON REACTOR SAFEGUARDS l waswiwovow. o. c. nosse j April 17, 1989 The Honorable Lando W. Zech, Jr. Chairman U. S. Nuclear Regulatory Comission Washington, D. C.'20555

SUBJECT:

INTEGRATED APPROACH ON REGULATORY MATTERS We are concerned that in a variety of matters, of which the proposed maintenance rule is only the most recent example, isolated subjects have been identified by the NRC as requiring additional regulatory attention, in the absence of any clear over,all guidance about integrating priorities. The ACRS has long advocated an integrated approach, based, at least in part, on the safety. goal and severe accident policies, but there is little evidence that the recommendations have taken root. The problem is that for each item considered separately it is possible for the staff to come to the conclusion that more regulation is necessary, but the overall effect is one of diluting the industry's and NRC's resources, thereby detracting from the overall quality of the effort. This is a subject that cannot be dealt with without clear guidance from the Commission. We think it important. Sincerel l orrest J. Remick Chairman w-

'g. 'o,, NUCLEAR REGULATORY COMMISSION UNITED STATES 8 o f ADVISORY COMMITTEE ON REACTOR SAFEGUARDS o WASHINGTON, D. C. 20656 March 15, 1989 i MEMORANDUM FOR: Chairman Zech FROM: Forrest J. Remick, Chairman, ACRS

SUBJECT:

CONTAINMENT DESIGN CRITERIA During the 347th meeting of the Advisory Comittee on Reactor Safeguards, March 9-11, 1989, we discussed our plan of action to develop containment design criteria for nuclear power plants, based on current knowledge, in response to the referenced Staff Requirements Memorandum. Containment performance in response to severe accidents is being considered by several groups within the NRC staff for existing nuclear power plants via the NRC Severe Accident Policy Statement as well as criteria for evolutionary light-water reactors. The Comittee will concentrate its efforts on con-tainment design criteria for future reactors, taking into account the work already being done by the staff and others. An initial subcommittee meeting has been tentatively scheduled for April 18, 1989 to consider this matter.

Reference:

Staff Requirements Memorandum dated July 28, 1988 from Samuel J.

Chilk, Secretary, for Raymond F.

Fraley, ACRS,

Subject:

Staff Requirements Periodic Briefing by the ACRS, Thursday, July 14, 1988 cc: Commissioner Roberts Commissioner Carr Commissioner Rogers Commissioner Curtiss OGC EDO GPA

.MNNNN6E6WhfVWWWWWWWWWWWW@g(tVcVgV;(;(AgVgypygggyggggg i TP.AHSMITTAL TO: Document Control Desk, 016 Phillips l ADVAfiCED COPf TO: The Public Document Room 5/Ad[f9 DATE: / fl - F 80M: SECY Correspondence & Records Branch E' N !l Athched ate copies of a Commission meeting transcript and related meeting i accument(s). They are being forwarded for entry on the Daily Accession List and i placement in the Public Document Room. No other distribution is requested or { required. Meeting fitle: k b [ W I Meeting Date: J'~/5//9 Open Y Closed

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