ML20236X460
| ML20236X460 | |
| Person / Time | |
|---|---|
| Issue date: | 12/03/1987 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1628, NUDOCS 8712090220 | |
| Download: ML20236X460 (124) | |
Text
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4 UN11ED STATES NUCLEAR REGULATORY COMMISSION
.=================.===================================================
IN THE MATTER OF:
DOCKET NO:
332nd GENERAL MEETING i
LOCATION:
WASHINGTON DC PAGES:
1 - 104 DATE:
DECEMBER 3, 1987
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j Heritage Reporting Corporation Official Reporten 1220 L Street. N.W.
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1 PUBLIC NOTICE BY THE kJ 2
UNITED STATES NUCLEAR REGULATORY COMMISSION'S f
3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
5 6
7 The contenta of this stenographic transcript of the 8
proceedings of the United States Nuclear Regulatory 9
Commission's Advisory Committee on Reactor Safeguards (ACRS),
10 as reported herein, is an uncorrected record of the discussions 11 recs _ded at the meeting held on the above date.
12 No member of the ACRS Staff and ns: participant at 13 this meeting accepts any responsibility for errors or 14 inaccuracies of statement or data contained in this transcript.
15 16 17 18 19 20 21 22 23 24 25 Heritage Reporting Corporation l
(202) 628-4888 J
1 1
'UtJITED STATES NUCLEAR REGULATORY-COMMISSION 2
ADVISORY COMMITTEE GN REACTOR SAFEGUARDS 3
)
In the Matter of:
)-
4'
')
332nd GENERAL MEETING
)
5
)
6 Thursday,.
December"3, 1987 V
L Room 1046:
8 1717 H Street, N.W.
j Washington, D.C.
20555 i
9 The above-entitled matter came on for hearing, pursuant to notice, at 8:30 a.m.
11, BEFORE:
DR. WILLIAM KERR l
12 Chairman Professor of Nuclear Engineering 13 Director, Office of Energy Research University of Michigan O-
'14 Ann Arbor, Michigan 15 ACRS MEMBERS PRESENT:
16 DR. FORREST J.
REMICK
. Associate Vice-President for Research 17 and Professor of Nuclear Engineering The Pennsylvania State University 18 University Park,- Pennsylvania 19 DR. DADE W. MOELLER Professor of Engineering in Environmental Health 20 and Associate Dean for Continuing-Education School of Public Health 21 Harvard University Boston, Massachusetts 22 DR. CHESTER P.
SIESS 23 Professor Emeritus of Civil Engineering University of Illinois 24 Urbana, Illinois
- 25 O
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'l MR. CHARLES J.
WYLIE Retired Chief Engineer 2-Electrical Division Duke Power Company 3
Charlotte, North Carolina 4
MR. JESSE'C. EBERSOLE Retired. Head Nuclear Engineer 5
Division of Engineering Design Tennessee Valley Authority 6
Knoxville, Tennessee 7
DR. HAROLD W.
LEWIS Professor of Physics 8
Department of Physics University of California 9
Santa Barbara, California 10-MR. CARLYLE MICHELSON Retired Principal Nuclear Engineer
'll Tennessee Valley Authority Knoxville, Tennessee, and 12 Retired Director, Office for Analysis and Evaluation 1 of Operational Data 13 U.S.
Nuclear Regulatory Commission Washington, D.C.
14 MR. GLENN A.
REED 15 Retired Plant Manager Point Beach Nuclear Power Plant 16 Wisconsin Electric Power Commpany Two Rivers, Wisconsin 17 DR. PAUL G.
SHEWMON E18 Professor, Metallurgical Engineering Department Ohio State University 19 Columbus, Ohio l
20 DR. MARTIN J.
STEINDLER Director, Chenical Technology Division y
21 Argonne National Laboratory Argonne, Illinois 22 MR. DAVID A. WARD 23 Research Manager on Special Assignment E.I.
du Pont de Nemours & Company 24 Aiken, South Carolina 25 I
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1l ACRS COGNIZANT STAFF MEMBER:
2 Raymond Fraley, Executive Director 3
NRC STAFF PRESENTERS:
4 Bill Kane Wayne Houston 5
6-
.7 8
9 10 11 12 13 14 15 16 17 18 19 20 21
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23 24 25 O
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I H D_ E X
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. Items Discussed Page 3-Chairman's Opening Remarks 5
4 Peach Bottom Nuclear Power Station-11 5
- Quantitative Safety Goals 52
.6.
NRC Safety Research Program 105 7
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14 15 16 17 18 19 20 21-
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1 P R O C'E E D I N G S (f
2-CHAIRMAN KERR:
The meeting will come to order.
This 3
is'the first day of the 332nd meeting of the ACRS.
During-4 today's. meet'ing, the Committee will discuss the Peach Bottom 5
Nuclear Power Station restart, the TVA nuclear power 6
activities, quantitative safety goals, and NRC safety research 7
program, quality assurance, ACRS future activities, and.
8 integrated safety, the integrated safety assessment program as 9
well as some discussion of future ACRS functions and 10 activities.
11 Copies for Friday's meeting are listed on the s
12 -.
schedule posted on the bulletin board outside the meeting 13 room.
The meeting is being conducted in accordance with the O
14 provisions of the Federal Advisory Committee Act and the 15 government and the Sunshine Act.
Ray Fraley is the designated 16 federal official for the additional portion of the meeting--as 17 he steps out the door.
18 I call your attention to a change in the agenda of 19 the Friday meeting.
First item, which was to have been the 20 discussion that was to be contributed to by ENCO 21 representatives has been postponed until the January meeting
-22 because of unavailability of those who were to participate.
23 We will shift the subject matter scheduled for three to about, 24 as much of it as we can, three to 6:15 p.m, to that slot.
()
25 This means that thor,o of you who may have agreed to prepare HER'JAGE REPORTING CORPORATION-- (202)628-4888 i
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1 draft letters for that three o' clock slot or 3:30 slot should'
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2-be giving some thought to the possibility of you might have 3
them prepared, that you may be try to have a draft ready by 4
that time.
5 I also report that the Commission has' formally 6
decided on the 25th of November to tell the hearing board to.
7 go ahead with consideration of the low power license for r.
8 Seabrook.
This, of ' course, does not give Seabrook a low power 9
license, but does remove a stay which had been decided upon 10 earlier from further consideration at that time.
That I guess 11 the stay on the part of the person responsible for granting 12 the low power license, the board presumably will now go_ ahead 13 with hearings on, in preparation for the consideration of the O
14 low power license, including of course,. consideration of an 15 emergency plan.
16 The Commission has also approved a full power 17 license for Palo Verde No.
3, which had been operated earlier, 18 and low power permit.
19 (A discussion was held off the record.)
20 MR. EBERSOLE:
Bill, your observation about Palo 21 Verde going head, I presume Committee members ought to know l
l 22 they are going ahead with the cracked shafts, and I wondered 23 if the Committee would be interested in that and the relative 24 positions of the cracked shafts and the CPC calculation, and
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25 they also, of course, are a party to the Pan American diesel l
HERITAGE REPORTING CORPORATION-- (202)628-4888
7
-1 groblem brought out in one of the papers.sent to us in the
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2 last month in'.the thing called the Shoreham saga, which for-3 the first time I found out that the Transamerica valves were
~
4 driven into overloads, knowingly apparently, and it has been 5
apparently the root cause of why they have had so'much 6
trouble.
7 MR. WYLIE:
Are you speaking of the Shoreham 8
machine?
9 MR. EEERSOLE:
Yes.
10 MR. WYLIE:
Thac's not typical of the other plantc, 4
11 though.
They are a different machine.
12 HR. EBERSOLE:
Are they?
13 MR. WYLIE:
They are Transamerica valve, but they-O 14 are different machines all together.
15 MR. EBERSOLE:
That doesn't reflect then the 16 other --
17 DR. SHEWMON:
Electroplate over cracks than the ones 18 in the other plants.
19 MR. EBERSOLE:
Same phenomena.
20 MR. WYLIE:
No.
The Shorsham machine was a 21 particular, well, first of all, it was a small machine.
As I 22 recall, it was around 2500 horsepower or something like that, 1
23 kilowatts, and they upgraded that machine to something over I-24 3000 by increasing the speed of that machine, and they didn't
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25 go back and do their research, and the machine had resonent l
1 HERITAGE REPORTING CORPORATION-- (202)628-4888 L
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vibration problems and the fatigue and it was, it was a, just
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a bad application.
3 Now the other TDI machines are big machines.
4 MR. EBERSOLE:
But they came from the same design:
5 rationale.
6 MR. WYLIE:
It was't a redesigo.
Those machines 7
were a machine that'has been in service'for many customers.
8 They are slow speed, 8,000 kilowatt machines, with a. lot of 9
experience in those machines, were not redesigned.
They are 10 entirely different 11 DR. SHEWMON:
At least one of these, they had had
-12 undercutting someplace and then had electroplated over it and 13 electroplate is inherently a low ductility product, and then O
14 were surprised when they got fatigue cracks going through it.
15 It sounds like anybody that would use that sort of 16 manufacturing technique, that isn't very bright or something.
]
.]
17 MR. WYLIE:
Well, I agree that there were problems 18 with the TDI machines, a lot of which were theoretical l
19 problems.
For exv ple, they went back and looked at those 20 machines and using non-disruptive testing techniques that had 21 never been used on diesels to find cracks, and every time they 22' found a crack they would say it was a failure.
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23 How in fact, those machines would run with those 24 cracks, and they do run with those cracks, and I think if they
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25 went back and looked at Code or any of the other machines with HERITAGE REPORTING CORPORATION-- (202)628-4888
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9
-1 the'same1 degree of exactness they would find the same thing on 2
ma'ny-of'those machines.
3 Now I would be the first to say'that the quality.
4-control at TDI was-very poor.
No question about that, from:
'5' the casting all the-way through, but the problem that Jesse is 6
talking'about with the Shoreh'am machine is an entirely 7
different problem.
That was just a misapplication and miss-8 design problem.
l 9
DR. SHEWMON:
Let me return to this Palo Verde main 10' pump shaft.
Those things come out of Germany and presumably 11 is reasonably close to what the Germans are, KWU was over 12.
there.
Did you every hear of why we were having more trouble 13 than the Gern=ans do?
O 14 MR. EBERSOLE:
I understand we know that we had
'15 cracks, and the interesting part to me is the CPC calculator, 16 the analysis of the effect of the cracks has been made on the 17 bcsis of it's the same or not as bad as locked condition.
18 Locked condition is picked up by the CPC calculator instantly 19 as a loss of flow.
And the failure mode by these cracks that 20 we, though we might have below the point at which they count l
21 shaft RPM costly, the CPC detector would never know you had 22 stopped earlier.
What that means in the context o; core 23 damage'I don't know, but that's the current study that they 24 have taken a comparison to the locked condition which is --
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25 MR. MICHELSON:
I looked into that once, Paul.
At HERITAGE REPORTING CORPORATION-- (202)628-4888
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that time the story wes that those pumps were redesigned,.the
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2
~ impellers redesigned for more flow and more head and there was 3
a, therefore more load on the system, but the same basic shaft 4
size.and so on, but that was a rumor at that time, and I
.3 haven't since verified it.
6 MR. WYLIE:
It is a KSB design: pump, right?
And'it 7
was built here, was it not?
8 MR. MICHELSON:
I don't think cc.
9 MR. WYLIE:
I thought they were built in New 10 England, in a factory built specifically by CE for that pump.
11 MR. MICHELSON:
I had hvard they came from Germany, 12 too.
13 MR. WYLIE:
They are German design.
No question O~
14 about that, but I think that CE, that's my impression.
They 15 were built in factory here.
16 CHAIRMAN KERR:
It seems to me it would be 17 appropriate for your subcommittee to get further information.
18 MR. EBERSOLE:
In fact I am going to do that.
19 CHAIRMAN KERR:
Other comments on this or other 20 general topics?
That brings"us to the item on the Peach 21 Bottom nuclear station.
22 We asked the staff if they would be willing to 23 discuss with us the criteria that we, are going to be used in 24 deciding on when and whether this plant could be restarted.
I
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25 think we have a representative of the staff here who is going 1
HERITAGE. REPORTING CORPORATION-- (202)628-4888
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to give us some information.
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2 I should, by the way, acknowledge the presence of 3
Mr. Tony Cappuci with us for the first time in an official 4
capacity representing the NRC.
We know him from previous 5
incarnation.
I want to welcome him back in this capacity.
6 MR. KANE:
Thank you very much, Dr. Kerr, For most 7
of you who were--some of you who don't remember me, I have 8
been down here a number of times over the years to talk to the 9
ACRS as a project,nanager f or a number of plants.
I am in 10 Region I, and I am director of the Division of Reactor 11 Projects, and I have with me today members of the staff who 12 will also participate.
13 (Slide) 14 MR. KANE:
Before we get into some of the things 1
15 that I know you are interested in, I would like to talk about 16 some of the activities that we have been involved in.
As you 17 are aware, that the plants were shut down by order on March 18 31st of this year, and in early April, we came down to, Dr.
19 Murphy and I came down to brief the ACRS on the background of 20 the reasons that led to the shutdown, and then following that 21 neeting, we went up and briefed the Commission.
22 Since that time, we have brief ed mar.y other people 23 on the status of the plant.
We have met with the State of 24 Maryland.
In early May we sat down and had the first real
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25 meeting with the licensee on the status of their HERITAGE REPORTING CORPORATION-- (202)628-4888
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. investigation.
Obviously they had a big problem in terms of
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2 trying to understand the depch and scope of the problem from 3
their perspective while we, of course, were going at it 4
independently with our Office o.C Investigations.
5 We spoke to the State of Pennsylvania, briefed them, 6
and then had a number of meetings with the licensee.
7 Subsequent to that, we briefed Harford County as the closest 8
county in the State of Maryland that had an interest in the 9
restart of Peach Bottom.
We have issued bi-weekly status 10 reports on the plant which go into basically what is happening 11 at the plant, and these were made public so that everyone in 12 the~ area who has an interest can appreciate what is going on 13 down there.
We have had, all the meetings with the' licensee O
14 have been public meetings except for the first one.on May 5, 15 which dealt with investigation matters.
16 We have also taken a special initiative to get 17 public input into the process, and maetings have been held in 18 September and October and November in Harford County, in York 19 County and Lancaster County to get the public input on the 20 PECO plan.
21 CHAIRMAN KERR:
What sort of input did you get?
22 MR. KANE:
Of the three meetings, there were about 23 70 speakers, and they ranged I would estimate from one third 24 in favor to getting on and restarting the plant quickly, to
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25 two thirds who expressed some problems as you can appreciate HERITAGE REPORTING CORPORATION-- (202)628-4888
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inta wide range.of areas, not all necessarily related to the J-2 shutdown', but management issues, the enforcement history of 3
the' Peach Bottom facility, and the'need for modifications to 4
the MARK I' containment, which is current issue as~you.are 5
aware having to do with the ability to vent the containment in l.
6 severe accidents.
l 7
We also had comments from both of the states, 8
Maryland and Pennsylvania, Maryland principally focusing on 9
corporate management issues, some A issues.
State of 10 Pennsylvania agreed with the, a lot of what we were doing, but 11 were concerned with the drain on resources that may have been 12 caused by the start-up of Limerick, making sure that the 13 changes had all been evaluated before the plant was allowed to O
14 restart.
They had a concern that the Commission through its 15 inspection process was unable to detect the sleeping that had 16 occurred, and they had just recently filed a 2206 petition for 17 public hearings on the process, 1
18 MR. EBERSOLE:
Let me ask a question.
To what 19 extent have the PUCs been involved in this in the context of 20 whether the operational losses will be suffered by the 21 stockholders or the rate payers?
22 MR. KANE:
I am not, I am not really prepared to 23 discuss that.
I am aware that there have been some 24 discussions.
Anybody here able to--
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25 MR. EBERSOLE:
Seems that would be absolutely root HERITAGE REPORTING CORPORATION-- (202)628-4888
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focal point.
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2 CHAIRMAN KERR:
You have to use the mike.
3 MR. EBERSOLE:
Right.
You go right to the roots 4
which is always the pocketbook, and I don't see how we can 5
miss that, as to wh ;her these are valid operational losses to 6
be suffered by the rate payers, or managerial losses which 7
seem to be reflected in that, impact on corporate profit.
8 MR. KANE:
I am sure that is being considered, but 9
it is certainly not a focus of our, of our review.
10 DR. REMICK:
What office represented the State of 1
l 11 Pennsylvania?
What state office?
12 MR. KANE:
Well, as I understand it, they put 13 together a committee, and I--the name escapes me right now, O
14 but it was, the comments as I understand it, were to take all 15 of the comments from all of the affected state offices.
Stan 16 Maingi from the State of Pennsylvania, could you help us out 17 on that one?
Did I capture that correctly?
18 MR. MAINGI:
That is correct.
There was a task 19 force formed which consisted of the Department of 20 Environmental Resources, with the Bureau of Protection and 21 then also Energy Conservation and Pennsylvania management 22 agency, and the Governor's Office of Policy and Planning, and 23 the task force, the comments were sent under that issue Mr.
24 Ebersole is concerned about.
And PUC was not involved,
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25 because they would be briefed independently doing their own HERITAGE REPORTING CORPORATION-- (202)628-4888
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thing, and the question you raise is really a good.one.
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2 CHAIRMAN KERR: 'Would you identify yourself, please,
'3 for.the reporter?
~4 MR. MAINGI:
I am Stan Maingi from the State of 5
6 CHAIRMAN'KERR:.Thank you.
7.
(Slide) 8 MR. KANE:
This is our approach to how we are going 9
to review the plan, and it's very similar to the one that we 10 have put in place on Pilgrim.
As you can appreciate, the, 11 there is extensive involvement-in the, by various offices 12 within the Commission that led to +.he shutdown.
There, of O...
13 course, is the Office of Investigations.
Should start out'
- 14 with Region I, of course, which, which was involved in the
'15 activity that led to the shutdown, but there is the Office of l
16 Investigations that is involved.
The Office of Enforcement, 17 and many of the issues that bear on whether this plant can l
18 restart are within the Office of Nuclear Reactor Regulation 19.
obviously, so what we decided to do was to put together a J
l 20 panel to coordinate the staff review of the licensee plan and 21 develop an evaluation report to support a restart decision, 22 and the panel is comprised of representatives, and I will get 23 into that later, representatives from NRR as well as the 24 region to make sure that we have a coordinated approach to, to
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25 the review.
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We, of course, met shortly after the-report came in
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2 from PECO, and as in the process of trying-to keep people 3
- informed, we have. issued weekly list of activities to brief 4
'all of the senior executive team.
These are internal reports.
5 On August 2nd and September lith, we developed the first. set 6
of requests'for information.
It'was a rather large package of 7
material that the utility had provided.
It was a, the initial 8
cut I might characterize sort of a laundry. list of various 9'
activities that they felt they needed to accomplish prior to 10 restart.
Some of those had to do with, with the reasons that 11 we issued the shutdown order and some were additional things 12-that they thought they wanted to accomplish.
13-These requests were sent to the licensee and'we held O
14 our first meeting'with them on August 26th to go over the.
15 responses, and the initial reaction of the staff to the 16
- 11censee's responses was that they had missed what we 17 considered to be a fundamental point, and that was the ability 18 of their corporate processes to identify and get to the senior 19 management the issues that were going on at the plant.
20 The Philadelphia Electric's plan was aimed 21 principally at what I will call three root causes, which were 22 the culture at.the Peach Bottom plant,'the effectiveness of 23 the management at the plant, and also at the inability to, to-24 get additional operators licensed, but our review, we felt
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25 that it wasn't solely a plant problem, that their needs to be HERITAGE REPORTING CORPORATION-- (202)628-4888
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17 1-a significant change in the oversight of the corporation at
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2 that facility in orderfto, to understand what was going on.and 3.
.effect the necessary changes, and I guess I liken that to, 4
somewhat to a defense in-depth as quality assurance is, 5
although I don't like that' term.
I like assurance of quality.
6 It is a mechanism to make sure that you are being able to 7
identify by various approaches the bad news, the problems, and 8
bring them up through a system and get them resolved.
Thus it 9
was not acceptable that simply the plant was simply not 10 getting the information up to be resolved.
There had to be 11 other mechanisms in place to cause that, and in our view,. they 12 were ineffective.
So that was the major, I would say the 13 major stumbling block at that point.
O 14 We.also looked at their plan in terms of the task 15 that they felt needed to be completed prior to restart. 'They 16 were divided up into, as I recall, three groups--one set that 17 had, could be coinpleted prior to restart, another set that i
18 could be completed after restart, and another set that were 19 much longer term.
So we needed to, we had some serious 20 problems with several of those which we can get into if you 21 would like.
22 And what we were trying to do is to get to a point 23 where we could make a decision on the acceptability of the 24 plan.
And we briefed the Commission on the plan on the 15th (f
25 of September, We laid out the specific problems that we had I
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with the plan, and the Commission then responded back to the h()
2 utility explaining that'they had in their view a lot more work 3
to do and.they were concerned with, with the lack of corporate 4
involvement and-the need to see some results.
I think.there i
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5 were some other concerns expressed about the size of the C
maintenance backlog.
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MR. EBERSOLE:
It seems that the matter of corporate 8
involvement would involve two possible roots -- one, corporate 9
information was simply unavailable to corporate management or 10.
they didn't, the information they were in trouble never did 11 get upstairs where they could do something with it.
That's 12 one course.
The other course is the information flow was all 13 right but corporate management didn't know what to do with.it O
14 when it got there.
Which was this?
15 MR. KANE:
Well, I think where we are, what we have 16 seen so far, is that you can look at a, at this flow as being 17 in two directions.
One, I guess I like to think of it as if 18 you have a viable operation, you have got problems being 19 developed from the very bottom of the organization, in this 20 case perhaps the operators themselves up through that system 21 through the plant management and then on to corporato 22 That's one path.
But that's I think subject to 23 single failures at times, and it, I think that's, I think 24 that's what happened here, but there also are other mechanisms
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25 which corporate needs to have in place to make sure that HERITAGE REPORTING CORPORATION-- (202)628-4888
19 1
through, through either QA or through some, the variety of
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2 mechanisms that people use, that licensees use, but they need 3
to have independent mechanisms which is assessing operations 4
to understand what the problems are.
If you have a, what I 5
would call a well-operated system, both of these are working.
6 The information is getting up through line management, also 7
getting around.
This was not happening, and this was the 8
focus of our concern.
Neither of those two mechanisms was 9
working effectively.
10 MR. EBERSOLE:
Did they in fact have both mechanisms 11 to go down as well as go up?
12 MR. KANE:
They did, but again it is a question of 13 how effective those mechanisms were.
I think it is not a O
14 matter of blocks on a piece of paper and reporting schemes but 15 really, really hcw well it is work working at the individual 16 levels.
It was not obviously, and in response following the 17 Commission meeting, we sent back a letter to the licensee 18 Aeally deferring review of the plan until they were able to 19 address what we considered that fundamental root cause of 20 being able to self-identify their problems, bring them up 21 through their system and get them resolved, and in response to 22 this, the licensee has now submitted this plan which is called 23 Section 1 corporate action.
It was submitted on the 25th. and 24 it is intended to address the corporate issue.
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25 Along with this, there has been a major HERITAGE REPORTING CORPORATION-- (202)628-4883
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reorganization within the corporation to pull all cf the
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2.
~ nuclear activities.under one senior vice' president'.
That'is, 3
that is.a change, a significant change in.the way that'they 4
have operated over the years so that-all-nuclear activities 5
will be brought under, under one individual.
That will 6
include engineering services and the operation of both plants 7
as well as the quality assurance or. assurance of quality 8
function.
9 There have also been--
10 MR. WARD:
Bill, could I ask you a question on that?
11 It seems to-me most utilities have moved toward that sort of 12 organization in the last five years I guess, five, eight 13 years.
Do you have any idce c' what fraction.of nuclear O
14 utilities actually have that sort of organization now?
15 MR. KANE:
Let me think.
In Region I, I think it 16 is, I think it is almost, almost all.
I can't, I can't give.
17 you that answer nationwide.
I can give you in Region I, 18 Region I, general public utilities has the type of 19 organization that, similar type of organization to the one 20 that Philadelphia Electric had.
Obviously no two are 21 identical, but that's the only one that I can recall at this 22 point.
Ed or Bruce?
23 CHAIRMAN KERR:
If you don't have it readily, you 24 don't know, we can get it.
()
25 MR. KANE:
They are certainly in the minority.
I HERITAGE REPORTING CORPORATION-- (202)628-4888
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would say that.
2 DR. REMICK:
What is the-proposed < highest level l
-3 person.for: Peach Bottom?
I 4
MR. KANE:
At-the site there will be a vice l
5 president on each of the sites, vice president of Peach Bottom 6
site, and a vice' president at the Limerick site.
So reporting-7 to the senior vice president will be those two vice i
8 presidents, the vice president for services, nuclear services, 9
and a vice president for engineering.
Have I missed any?
10 DR REMICK:
Senior vice president would be at 11 Philadelphia?
The others would be at, vice presidents would 12 be at the, each site, Limerick and Peach Bottom?
13 MR. KANE:
Right, and the other two vice presidents, 14 of: course, for engineering and nuclear services would also be j
1 15 in. Philadelphia.
11 6 There have also been some other enhancements that 17 they have made, the principal two of which would be an 18 expansion of the Nuclear Review Board and reporting level.
19 Nuclear Review Board will consist of three individuals from 20 outside the company.
As I recall, the individuals are Jack 21 Calhoun, formerly of PP&L, Bill Corkeran, formerly of CE, and 22 Roger Mattson, who you probably all know.
23 DR. REMICK:
Doesn't Philadelphia Electric have an l-24 arrangementarrangement with PP&L where they exchange corporate
-()
25 safety people, one representative of PP&LP that is on the HERITAGE REPORTING CORPORATION-- (202)628-4888
22 ho 1
Philadelphia Electric and vice-versa a?
I'th' ink we were told
.(}.
'2 that about a year ago on the subcommittee.
3.
MR. KANE:
.I believe that's the case.
l i
4 DR. REMICK:
Which I thought was a good idea in 5
general.to.have utilities have other utility people on their 6
review committee.
7 MR. KANE:
Tom, do you recall?
8 UR. JOHNSON:
I think there is an. agreement with 9
PSE&G.
10 MR. KANE:
Not with PP&L?
11 MR. JOHNSON:
I am not sure.
12 MR. KANE:
Next slide I will put up quickly here to 13 show you how we are organized to review the plan.
Bruce Boger O
14 from NRR will be the vice chairman of the panel.
Bill Regan, 15 also of NRR, will be a member of the panel, and obviously 16.
because of the, some of the things I will get into later, will 17 play a principal role in the review of the adequacy of the 18 operators for the restart of the plant, and then Ed Wenzinger 19 who is chief of one of my branches, Jim Linville, section 20 chief, and Ron Bellamy, from one of the other divisions in 21 Region I, and also principal advisors to the panel would be 22 Tom Johnson who is the senior resident from Peach Bottom.
23 Tom, why don't you hold up your hand?
And Bob 24 Martin who is the project manager for Peach Bottom who was
()
25 formerly the project manager of Limerick.
HERITAGE REPORTING CORPORATION-- (202)628-4888
23' 14 DR. LEWIS:
That is'all chiefs and no Indians.
How
(
2 many Indians are working?
3-MR. KANE:
Beg pardon?
4 Int. LEWIS:
The group is listed as all chiefs and no 5
Indians, so --
6 MR. KANE:
Well, no, I don't want you to-get,that 7
impression.
8 DR. LEWIS:
That's what I am trying to avoid.
9 MR. KANE:
This panel is not intended to be the 10 complete review authority for the plant, and I will go into 11 how we do this, but-it is, because of the diversity of issues, 12 the many organizations involved, we felt we needed to get a 13 group together who could serve as a force and function for
! ()
14 identifying issues that needed to be resolved and to get them 15 resolved.
16 I have the responsibility in the region for 17 directing the inspection effort, so that when there is an 18 issue that involves the assignment of inspection resources,
.j 19 that's something that we can do.
And headquarters, it may
]
20 involve, for some of our review teams which I will get in here i
21 later, we need to have technical specialist from NRR to be on 1
22 those teams.
And the idea of this approach is to make sure 23 that we can identify the resources that need to be involved, l
24 and through Bruce or myself cause that to happen.
()
25 DR. LEWIS:
I just want to follow, I really am HERITAGE REPORTING CORPORATION-- (202)628-4888
24 1
trying to find out whether there were~ dedicated resources or
(
2 whether you regarded all of NRC as the resources for, that 3
these chiefs had.
4 MR. KANE:
No.
We do not have dedicated resources.
l 5
DR. LEWIS:
Just use NRC.
l 6
MR. KANE:
We use the people available in the region 7
who are familiar with the issues; the same thing at NRR.
8 CHAIRMAN KERR:
Mr. Kane, I hope somewhere in the l
9 presentation you will give us some idea of how you are going i
10 to decide when the plant is ready for restart.
You have given 11 us very interesting and valuable background on what has 12 happened up to now, but I would, I am interested in how you 13 will know when to decide that yes, they can restart, or no, O
14 they will never be able to restart, or whatever the options 15 are.
16 MR. KANE:
Okay.
Let me just get into-the-next 17 slid and describe the process and who is involved and how it 18 is going to be done.
I will go quickly through it.
i 19 (Slide) 20 MR. KANE:
We, as I said before, will continue ~to be 21 involved with the states in getting those issues up front, but 22 the staff review and inspection activities will be, will be 23 focused primarily on the first issues there, which is assess 24 licensee, licensed operator attitude and performance 1 ()
25 improvement program.
That's a principal issue that is ongoing HERITAGE REPORTING CORPORATION-~ (202)628-4888
25 1
right now.
(( )
2-CHAIRMAN;KERR:
How will you decide when-the 3
improvement has-reached a level that you consider 4
satisfactory?
5 MR. KANE:
Okay.
The big concerns I think are:that 6.
we have--and I will also ask Bill Regan to get into this 7
little bit, of what we have done so far.
The big concern that' 8
we had was the, was the cultural issue or the, if you can 9
imagine a system where you can have an entire crew of 10 operators asleep at one time--as we talked about before, we 11 are not talking about an individual issue.
We are talking 12 about a group issue, if you will a cultural issue; the 13 program--
0 14 CHAIRMAN KERR:
I recognize that you can see 15 somebody who is asleep.
My question is how will you know when 16 the operator attitude has been changed sufficiently?
You 17 know, feel reasonably comfortable with, on whatever the 18 problem is, it has been corrected?
19 MR. KANE:
Let me have Bill describe a little bit 20 the program that they have in Bill's place and the one that we 21 are reviewing and how we are going to get to the end.
22 MR. REGAN:
We are currently reviewing--
23 CHAIRMAN KERR:
Please identify yourself.
24 MR. REGAN:
My name is Bill Regan, I am a member of
()
25 the Peach Bottom panel.
HERITAGE REPORTING CORPORATION-- (202)628-4888
26 1
We are currently evaluating the rehabilitation
()
2 program which Philadelphia Electric has put together, 3
evaluating that for adequacy both in terms of review of the 4
materials that are being presented and also by observation, L
observations of the training session themselves.
6 We are supplementing this by interviews with the 7
operators both during the, during their training, and when the 8
training is complete.
We will be conducting additional 9
interviews to--these interviews are by trained psychologist to l
10 assess whether or not there has been a change in attitude, and 11 really what we are talking about here is an attitude problem 12 on the part of operators.
There has beer no question at all 13 concerning their technical competence.
O 14 Based on the evaluation of the training program 15 itself, and if it is adequate, and evaluation of whether it 16 is, has had the intended effect on the operators through 17 interviews with the operators, we will make our, who--
18 CHAIRMAN KERR:
If the trained psychologist felt 19 that the attitude changed sufficiently, that is the way you 20 would decide?
21 MR. REGAN:
That will be certainly an element in our 22 decision, ma]or element.
23 DR. LEWIS:
I am confused because if indeed the 24 issue is attitude, why does the review panel consist of
()
25 nuclear engineers?
HERITAGE REPORTING CORPORATION-- (202)628-4888
27 1
MR. REGAN:. Well, the review panel, the' review
( )-
~2 panel, the review group itself' includes more than nuclear 3
. engineers.
4 DR. LEWIS:
Does it have a psychologist?
5 MR. REGAN:
Yes--not on the panel itself, but I am 6
the representative on the panel which has available to me in 7-my branch a group of psychologists.
8 DR. LEWIS:
But they are the dominant people in-9 determining the decision because determining attitude any 10 psychiatrist can tell you is really not very easy.
11 MR. REGAN:
We agree.
12 DR. LEWIS:
So this, the dominant group, the group 13 of psychologists that you have available, is going to in the O
14 end determine whether this plant can restart?
15 MR. REGAN.
That element of it.
16 MR. KANE:
Let me just make a, caution that that's 17 one aspect of it, and again, we are not looking at, we are not 18 looking at any one specific feature that's, that's going to j
j 19 dominate pass / fail.
We have to do the very best job we can at 20 all of these areas, in one, understanding whether operator 21 attitudes have changed and getting the best judgment that we 1
22 can get on that; secondly, understanding whether command and I
23 control of shift activities is in, has in fact been changed, j
24 is another important aspect of it.
()
25 CHAIRMAN KERR:
What I am trying to find out is how i
1 i
HERITAGE REPORTING CORPORATION-- (202)628-4888
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28 l
1 you decide when indeed'you have reached the appropriate level?
()
2 I understand that you.want to make some changes, and at some-3 point you are going to have to decide it seems to me the 4
changes have now been made-or they have not been made.
I am 5
'trying to understand the decision process.
What I have' heard 6
up to noN, that is that there is a group of trained 7
psychologists, they will determine operator attitudes, and 8
presumably their recommendation will be given great weight in 9
determining whether the operator attitudes have changed.
10 What other things will be used as a measure of an 11 adequate or inadequate level of competence?
12 MR. KANE:
With respect to attitude?
13 CHAIRMAN KERR:
Whatever; see, you have I think 14 based on the action that has been taken', one of the more 15 serious problems that has occurred at any plant.
I mean 16 action taken, one of the more drastic actions that have been 17 taken.
I am not being critical of the action.
What I am 18 saying is given this serious problem, how do you decide if the 19 problem has been sufficiently solvad?
20 MR. KANE:
I think it is, there aren't any what I 21 would call hard and fast rules that you can lay out and 22 pass / fail.
What I am saying is that on the first --
23 CHAIRMAN KERR:
But there has to be a pass / fail if 24 you are ever going to let the plant start because you have to
{
()
25 at some point decide yes, it has passed.
HERITAGE REPORTING CORPORATION-- (202)628-4888
c 29 1
MR. KANE:
We have to make a judgment.
()
2 CHAIRMAN KERR':
I am trying to understand how you 3
lmake a judgment.
Is it'just going to be that this group gets i
4
'together and says-well, we have.seen enough now, we think they 5
are okay?- O'r are you, are there. going to be.some more 6-
. tangible criteria that someone else could look at and say yes, 7
they have set these criteria and we agree that they have been i.
8 met?
!=
l 9
MR. REED:
I will comment, were the operators.at l
10 Peach Bottom originally, the original operators, aptitude 11 tested.by such as the Minnesota Multi-phasic Personality exam?
12 MR. KANE:
yes, sir, they were.
In fact, you asked 13 that question last time we were here, and Tom, do you have-the O
14
' details on that?
15 MR. JOHNSON:
Good mcrning.
My name is Tom Johnson.
16 I am senior' resident inspector at Peach Bo'ttom.
17 The information we have is that Philadelphia 18 Electric does aptitude test all their people prior to hiring.
19 The specifics of that testing, I don't know the name of it.
20 We are trying to find that out.
But as far as aptitude 21 testing, I have been told that they do, you know, personnel 22 are aptitude tested prior to hiring them, the employees.
23 MR. REED:
The reason I asked the question is 24 because I saw some written statement recently, and I have a
()
25 copy of it, I probably can't find it, to the effect that this HERITAGE REPORTING CORPORATION-- (202)628-4888
(
30 1
new class--both the words were strange.
Said something about
, ()
2
.the._first ' lass to be aptitude tested, and I;just. wondered c
3
.about whether or not they had been.
Now let-me go on a little; 1
4'-
bit more.
It seems to me that what has been in the public l
5 print mostly is--
6 CHAIRMAN KERR:
Mr. Reed, I would sort of like to 7
get a response if one exists to my question because I think we 8
have sort of interrupted in the middle.
'9 MR. REED:
May I get around to my--
10 CHAIRMAN KERR:
Sure.
Would you continue, Mr. Kane, 11 telling me how the decision is going to be reached?
1 12 MR. KANE:
I'm sorry?
13 CHAIRMAN KERR:
Telling me how you are going to-0 14 reach a_ decision finally that the plant is or-is not ready to 15 upgrade?
16 MR. KANE:
I think it is a, it is a multi-part, it 17 is a multi-part issue which I think we have to, unless you 18 want me to continue on, on the rehabilitation testing--
19 CHAIRMAN KERR:
I am less interested in the 20 organization than I am in the criteria for your, if any exist, 21 that are going to be used for decision-making.
22 MR. KANE:
- Okay, l
23 CHAIRMAN KERR:
Maybe the criteria could be just a I
24 good judgment of the panel.
I) 25 MR. KANE:
That's what it is going to be, based on, HERITAGE REPORTING CORPORATION-- (202)628-4888 l
31 1
' based on who we'have, and there are more than simply
([
2.
psychologistsfinvolved in this, in this decision-making 3
process.
I think!on the team that we have out there, we do in
~
4 our_own region have former licensed operators at nuclear power 5
plants who are also part of the team.
It is not, it is not 6
completely psychologists, so we are trying to draw on--and we 7
also have an individual who is, who is a, been involved in-training of operators so that we have taken a, an integrated 8
9 team, and that team will look at basically what the utility 10 has done to satisfy themselves that the operators have 11
. basically changed their attitude and we will also through 12 interviews, and involvement in the programs, make our own 13
.-judgment, but in the final analysis, it will be a judgment
'.O 14 based on the best experts that we can bring to bear 1on the 15 subject.
16 CHAIRMAN KERR:
Just let~me make one comment.
The 17 reason I am asking these questions is because unless I 18 misunderstand, the NRC organization was unaware of this 19 problem beforehand, and therefore it seems to me one of the 20 questions that one has to ask is, is this problem fairly 21 prevalent across the industry?
We didn't'know about it 22 before.
And hence the determination of when the attitude has 23 changed is something it seems to me that has a much more 24 far-reaching impact than just on this plant.
It may be that
'( )
25 the same criteria, the same investigations ought to be going l
l i
HERITAGE REPORTING CORPORATION-- (202)628-4888 l
+
32 1=
on' universally.
If you tell me that the decision is going to f}
'2' be left up to the, just this one committee, then I'll,~you'can 3
tell'me something different.
I thought that's what I heard, 4
that it'was going'to be the judgment of this committec 5
finally.
6 It seems to me that one might wonder if different
- 7. '
committees would reach rather different decisions at other 8
plants.
And I, I am a bit concerned about a problem this 9'
serious and apparently the lack of criteria, objective 10 criteria, for determining that either the problem has or has 11 not been' solved.
That's the reason I am asking these 12 questions, because I, it seems to me the problem has much more-13 far. reaching applications than this one plant.
14 MR. KANE:
I agree, but let me just add that there
'15 are'other factors.
I don't think in licensing of plants, it 16 has never been at least in my experience with the NRC, where 17 we rely on one factor alone in making a decision on the 18 acceptability of any decision on either restart or on the 19 licensing of a plant initially, so--
20 CHAIRMAN KERR:
I am not suggesting that you rely on 21 one factor.
I am trying to understand what factors you are 22 relying on.
23 MR. KANE:
To me, it is defense in-depth and there 24 are other factors.
The second factor I think that's extremely
<t
()
25 important here is the, is the command and control of the r
HERITAGE REPORTING CORPORATION-- (202)628-4888
33 1
shift, and the' ability of the shift managers--you probably
( ).
2 know about, Philadelphia Electric'has gone to a degreed-shift
'3 manager concept.
That is, the plant, the shift 4
superintendents who were formerly in charge of the shift, have 5
been replaced with degreed shift managers, which is a, which 6
is a basic cultural change to the philosophy of operation at 7
that plant.
8 But there is another concern, and that is the 9
ability of the degreed shift managers to command the respect ~
10 of the shift and control the shift.
That's a very important 11 part of our evaluation process, and that's-the next bullet 12 that you see on the slide, which is to conduct an evaluation 13 of the shift crews on the simulator, to understand again the
~
O 14 attitudes of the operators vis-a-vis the shift managers, the 15 ability of those folks to control operationm.
Obviously--
16 CHAIRMAN KERR:
This judgment will be made by 17 psychologists or nuclear engineers?
18 MR. KANE:
Will be made by combination of both.
19 Could you go through the review team again?
20 MR. JOHNSON:
Tom Johnson again--senior residents at 21 Peach Bottom--the process Me are doing that Bill was talking 22 about, we are evaluating the shift crews at Peach Bottom one 23 at a time.
This is at the Limerick simulator, and we are 1
24 evaluating the shift manager, the group constitution, the
()
25 command and control ability of the shift manager and the crew, HERITAGE REPORTING CORPORATION-- (202)628-4888
34-1-
the communications within the crew,' and what we do is we, on
'2 Friday afternoon we go up to the Limerick simulator,-and run a
~
3 bunch.of-pre-set scenarios or events, that Philadelphia 4
Electric has made, they made the-Limerick-simulator Peach-5 Bottom compatible.
6 The team that has put.together the, that evaluates 7
these. scenarios'are'a group of NRC licensed operator 8
examiners, and some. resident inspectors, and we evaluate the 9
shift crew and the ability of the crew to communicate.and the-10 shift manager to command and control, and we will give him a-11 pass / fail grade.
To date we have done.one of the six crews, 1.
12 and they did get.a passing grade.
We did feel that the shift 13 manager's command and control function, the crew interactions 0
14 and communications was adequate.
l 15 The next one that is scheduled is for' tomorrow.
I 16 was personally involved in the first one and I will be up at
-17 the Limerick simulator tomorrow observing the second crew.
We.
18 are going to do all six crews so this.is certainly one of the 1
i l
19 criteria that we will use.
It will be documented in the 20 Region I inspection report, and it will be available for the 21 panel to review the findings.
'22 CHAIRMAN KERR:
Thank you.
Mr. Lewis?
23 DR. LEWIS:
I want to follow the same track because 24 1 may have misunderstood.
I'm sorry, I missed your name.
Not
()
25 you, Tom, but the previous speaker.
I may have misunderstood HERITAGE REPORTING CORPORATION-- (202)628-4888
,.i l
35
~
a l'
you, but I thought you said earlier that there was no question
()-
2 of the technical competence of the peop.e, but that was, it 3
was only a matter of' attitude.
Did I misunderstand'you when 4
you said that?
5 HR. REGAN:
No.
That is what I said, and'I'would i
I 6
like to, I'would'like to correct perhaps one--
7-DR. LEWIS:
Why are we testing the technical?
I'm-n I
8 sorry.
G o <nt.
9 MR. REGAN:
I would like to correct one, perhaps 10 misconception that I left with you.
I didn't mean to imply 11 that psychologists were driving this review and we are going 12 to make the final decision.
I was speaking principally.of the 13 operator attitude aspect, and attitude is a very difficult O
14 thing to judge under any circumstances, and what I was trying i
15 to imply, that we did not have nuclear engineers trying to l
16 evaluate attitude changes, but rather we had appropriate 17 professionals focusing on that, on that aspect.
As Bill has 18 indicated, the team evaluating the rehabilitation program is 19 much broader than that, including in addition to 20 psychologists.
21 DR. LEWIS:
I am having a disconnect.
I understand 22 what you are saying and I appreciate it.
The place I am 23 having the disconnect is that I see us looking for the, at the i
24 lamp post.
If there is no serious question of the technical (f
25 competence of the people, the plant will shut done for HERITAGE REPORTING CORPORATION-- (202)628-4888
36-1 attitude reasons, of course,.then'I am'not'quite clear why we
~
(({
2 have an elaborate? program for testing the technical competence 3-when the' issue is one_of attitude,'and you know, it really-4
.is--of course, one expects, if your judgment is that their 5
technical competence is adequate, one expects them to pass, 6
nobody has a problem with attitude when they are taking the f
-7 exam on which their job depends.
It is what happens after, l
8 what happens after the inspectors go away, and so I have this 9
terrible memory of Three Mile Island in which an accident
'10 occurred for some reason, and people seized that opportunity 11 to test everything else and change everything else they can 12 think about.
13 MR. REGAN:
What technical competence were you 14 speaking of, Dr. Lewis?
15 DR. REMICK:
Referring to the simulator.
That's really to evaluate the command 17 and control aspects.
They reorganized the operation to 18 manager leading the crew, and perhaps Tom should be speaking 19 to this rather than me, but--
20 DR. LEWIS:
That was the subject that came up after 21 the shutdown, command and control?
22 MR. REGAN:
Yes.
Well, that was certainly part of 23 the, part of.the problem because not only was, were the 24 operators inattentive, but apparently it was being condoned by
.( )
25 management up and down the line, including management in the HERITAGE REPORTING CORPORATION-- (202)628-4888
37 1
control ~ room.
{.h 2
DR. LEWIS:
That was because.of' management attitude?
1 I
'3' MR. REGAN:
Yes.
l 4
- DR. LEWIS:
So we are entirely on attitudes?-
i 5
MR. REGAN:
Still on attitudes, but --
6 MR. KANE:
Let me just interject,-as I said before, 7
what;the utility did was take those supervisors, in other 3
words, the entire line from the operators on up at. Peach 9
Bottom has been replaced.
That is, the shif t : superintendents, 10 the operations engineer, the operations manager, and the plant 11 manager have all been replaced.
That entire line from the 12 operators up.has been replaced.
11 3 The decision, and let me, I will try to say this all 10 14 in one breath this time because I' keep waiting to get in the 15 third point.
I-think there are three principal things that we
!q
~
16
'are trying to accomplish with respect to that function.
- One, 1
17 the operator rehabilitation; can we in fact use, can the i
18 utility in fact use the operators that were there under some 19 other conditions, that is, with a new plant manager, with a 20 new operations engineer, with a new operations department 21 manager, and with new, what I will call new shift management, 22 that is, the shift managers, new people?
Will this work?
And 23 we saw it as several pieces.
One, the operator's basic 24 attitude to change.
That's important.
()
25 Two, can the shift managers control the operators?
l HERITAGE REPORTING CORPORATION-- (202)628-4888 q
L i
38 1
That's the command and control issue.
And the third issue, is le( )
2
'there a mechanism in place, a viable mechanism in place, to 3
detect problems if problems are occurring in the future?
4 Those three things are all essential to the decision on 5-restarting that plant.
6 DR. LEWIS:
Not one of them can be tested by 7~
simulation testing, not one of them.
8 MR. KANE:
Not one of them, I agree with you.
But--
9 DR. LEWIS:
Thank you.
10 MR. KANE:
But what we are looking at is a review 11 process that will, that will get the very best understanding 12 that we can.
You Obviously can't get a complete understanding 13 of how a plant is going to operate until it operates, but we 14 need to look at those three factors in arriving at.our 15 decision as to whether or not to allow the plant to restart.
16 All three of those are essential.
17 CHAIRMAN KERR:
Mr. Ward?
18 MR. WARD:
It is really just sort of a related 19 question or comment.
I recall that when we first heard about 20 the Peach Bottom problem, we were told that the operating 21 crews at Peach Bottom had a couple of characteristics.
- First, 22 they did seem to be technically competent.
They tend to do 23 well in training and on exams, and second, they seemed to have I
24 the ability to look good for inspections, that is, when the t
()
25 visiting admiral or commissioners or whatever were there, they l
HERITAGE REPORTINO "ORPORATION-- (202)628-4888
39 1
c,ould look good.
And that's, you know, how are you going to lll 2
protect against that is the question?
3 MR. KANE:
Is the third--
4 MR. WARD:
It is a, really a tough problem.
You are 5
in a new area.
I mean people shudder around this table even 6
when we talk about psychologist.c, but if that's the problem, I 7
mean there continues to be a strong tendency to work on things 8
we now how to work on rather than things that need to be 9
worked on, and I really see that in this program.
10 CHAIRMAN KERR:
Dr. Remick?
Go ahead, Glenn.
11 MR. REED:
My concern is now developing that, and I 12 have seen it in the media reporting, that the real problem at 13 the outset was sleeping on duty, and that got a lot of media 9
14
- splash, 15 Now I have to assume that maybe then the real 16 attitude problem was an attitude toward sleeping, and 17 apparently no one is den;ing that, but I am concerned now when 18 I hear you say that you might disqualify all these people with 19 all this continuity and experience qualifications and plug in 20 at the top I will call them 90-day wonders who really know 21 nothing about how the plant was built and where the bucket was 22 and where the skeltons are and where the bolts and the 10,000 23 valves are.
24 In my opinion, in emergency operations, you want lh 25 people that don't sit down for an academic consultation to do HERITAGE REPORTING CORPORATION-- (202)628-4888
40
>1 something, but they know where every. damn valve is that'will-('J 2
cause some action to take place, and I am very worried that 3'
you are plugging in and causing this utility to plug in a-degreed operators'and inexperienced and unqualified in-depth 5
people at this. facility and'if-I was at that facility, I would'
- 6 be writing.up a contract or an agreement with the NRC saying 7
that the NRC is responsible for the conduct and handling of 8
any. future accidents.
9 MR. KANE:
I will respond to that.,
10 HR. JOHNSON:
Can I address that?- The shift 11 managers that Philadelphia Electric has put in place'are all 12 experienced engineers that have been at the site'for as few as' 13 maybe six or seven years, at most maybe 13 years.
They have O
14 been in positions, engineering positions, outage management 15 maintenance positions.
A number of them have had licenses for 16 as many as eight years or so, so it is, I guess I don't agree 17 with your 90-day wonder.
18 MR. REED:
All right.
You say they are qualified 19 more than 90-day vonder, but they have be.en there that length 20 of time, and never been promoted into the job.
What was wrong 21 wa with them?
22 MR. JOHNSON:
Typically enginer.rs at the station 23 will come up, be hired right out of school, be a system 24 engineer for a few years, maybe spend some other jobs at the
().
25 site, and maybe after four or five years, go through the HERITAGE REPORTING CORPORATION-- (202)628-4888 I
- - _ _ _ - _a
41 1
. licensing process, get a senior operator's license, Lnd then.
().
2-be put in senior engineers positions at the facility.
3 MR. REED:
Now'did you have these peoplefgiven 4
supervisory leadership examinations before you move them into 5
their jobs as managers?
6 MR. KANE:
Yes, they have.
7 MR.-REED:
Particularly since engineers are not so 8
good in supervisory leadership positions.
L 9
MR. JOHNSON:
That is true.
l l
10 MR. KANE:
That is part of the program was 11 supervisory training for these individuals.
12 MR. REED:
Were they tested, evaluated for their 13 supervisory.and leadership ability?
There are tests, you O
14 know.
15 1;R. LINVILLE:
I am Jim Linville, project section 16 chief,' responsible for Peach Bottom.
17 They had a pool of twelve candidates for the shift l
18 manager program, all of which who were, had a substantial 19 amount of on-site experience, a number of which who had 20 experience, including the SGAs, as assistant operations 21 engineers, number of other positions.
They evaluated them.
22 The plant manager evaluated them for their leadership 23 experience.
They were evaluated by a group of psychologists 24 for their ability to fit into that role and they went through
( )-
'25 a six-week, three-week training program on management i
HERITAGE REPORTING CORPORATION-- (202)628-4888 l
42 1
supervisory skills in addition.
Then they took the best of E !
)'
2 that a, _that. group that was available with that, with-that 3
experience and the leadership abilities to_ fulfill that role.
4 MR. REED:
Well, I listened _to all that 5
conversation,'but'_quite frankly, as a person who has been in l
6 charge of nuclear plants for many, many years, I would hate to 7
.give up what I see as seasoned, long-term, in-depth shift 8
supervision for people who are qualified later on.
9 MR. LINVILLE:
In the shift crew as the licensee has
'10
. proposed at this time, in addition to the shift manager, there 11 is another licensed SRO who has been there as a shift
~ 12 supervisor under the shift superintendent so they are not 13 totally removing all their prior experience.
'14 MR. REED:
How many people did you disqualify or 15 what?
16 MR. LINVILLE:
We didn't disqualify anyone.
The 17 licensee decided not to return the shift superintendents to 18 license duties.
They do plan to return to, shift supervisors 19 who was the other licensed SRO sn shift, to license duties 20 when they restart.
So they hav3 got a mix of management 21 experience and leadership capabilities, as well as retaining 22 the technical expertise of some of the people that have had 23 licenses for a long period of time.
I I
24 MR. REED:
Well, that sounds encouraging.
()
25 MR. KANE:
That is part of what I--I want to try to HERITAGE REPORTING CORPORATION-- (202)628-4888
43'
~1 correct a statement that you made.
We. haven't forced.the 1( )
2.
licensee toido anything specifically.
The licensee has taken, 3
taken-these actions, and you know, they may be curious, but 4
the--
5' DR. SHEWMON:
Don't make us laugh, please.
6 KANE:
I'm sorry, but that's'.that's a fact.
MR.
7 DR. SHEWMON:
Bring me a rock and'that's the wrong 8
rock, then.you haven't fired enough people or whatever.
9 MR. KANE:
With respect to the issue of corporate 10 oversight, yes, that is true.
We have not been satisfied, but 11-the decision to, to replace the shift superintendents was made 12 by the, by.the company early on based on the, on their own 13 investigation.
O 14.
DR. SHEWMON:
Okay.
15 MR. KANE:
And quite frankly, I personally think 16 that that was an appropriate approach in light of this' command 17 and control issue.
Obviously you did net have people who were 18 in command and control of shift operations.
What we are 19 trying to do now through our review process is to make sure 20-
.that the individuals who are in place to repla.
- he former 21 shift superintendents do have one, knowledge, and do have the 22 ability to command and control the shift, and that's what we 23 are observing primarily on the Limerick simulator.
24 CHAIRMAN KERR:
Mr. Kane, I realize that your
()
25 stretching this out has been because of our questions, but we HERITAGE REPORTING CORPORATION-- (202;628-4888 i
44 1L are going over some--I am going to try to give you after these 1
({ '
'2 two questions a chance to continue.your presentation without 3
major interruption, but I would like for us to get back on 4
schedule.
Mr. Siess?
5 DR. SIESS:
Do you have now, will you have when you 6
have finished'this process a basis for deciding when some 7
other nuclear power plant should be shut down because of 8
problems such as those you have found at Peach Bottom?
9 MR. KANE:
That's a tough question to answer.
I 10 would have to answer no.
I think we, I think we, we have to-11 evaluate each situation that comes before us on its merits, 12 and I might say that there are a number of--
13 DR. SIESS:
When will they come before you then?
O.
14 MR. KANE:
I'm sorry?
15 DR. SIESS:
When will they come before you?
16 MR. KANE:
They do routinely.
They do routinely.
17 DR. SIESS:
Peach Bottom came before you routinely?
18 MR. KANE:
No.
Other instances of sleeping, you get 19 observations of fire watches, of security guards, and we have 20 of operators as n il.
Those have to be decided, investigated 21 on their merits.
22 DR. SIESS:
I have seen about half a dozen of those 23 recently.
How have they been treated?
I haven't seen any I
24 plant shutdowns.
()
25 MR. KANE:
That's right, but when we were down here HERITAGE REPORTING CORPORATION-- (202)628-4888
45<
~
1 before,.. we told you that you, the reason'that Peach Bottom was-
-(}
2 shut down.is that one, it'wus widespread.
Two, it was 3
long-standing, and'three,.it was pervasive..And we.had,.we 4-had~ evidence of that.
And that is unique to.any situation 5
that we are aware of thus-far.
6 DR. SIESS:
You do have criteria for shutting them 7
down?
You do have a basis?
8 MR. KANE:
Yes, we do.
9 OR. SIESS:
That was my question.
Long-standing, l
10 pervasive and widespread, and it seems slightly. redundant.
11 MR. KANE:
Excuse me--and with knowledge of 12-management.
13 CHAIRMAN KERR:
Mr. Ebersole?
14 MR. EBERSOLE:
Most of the emphasis has been on the 15 operator sleeping, but I gather that this is symptomatic of 16 relaxation.of discipline and a general looseness in other 17 areas such as maintenance.
Am I correct in making that 18 assumption, that you also are looking in those areas?
19 MR. KANE: 'Yes, sir.
We do that, we do that 20 routinely, and I think the, the important, the important 21 elements of this review will be one, to make cure that, that 22 sufficient management changes have taken place to solve 23 problems that extend beyond near operations, and two, the 24 oversight processes that exist to detect other problems are
()
25 sound and viable, and will be brought to the attention of HERITAGE REPORTING CORPORATION-- (202)628-4888
__ _ _ __ _ _ _ _ A
'd 46 1
senior management so they can be' dealt with, so I think the,
()
2 the corrections to this.particular problem canfbe' applied 3
. universally to plant operations.
4 CHAIRMAN KERR:
How much more presentation do you.
5 have, Mr. Kane?-
6 MR. KANE:
I wanted to complete this slide, and two b
7 more.
8 I'want to make sure that you understand the process-9 beca2se when the panel, which is, which is charged with-10 developing an overall evaluation report, will have to'be 11
! reviewed by senior staff management, that is, the senior 12 management of the offices, and as well as the EDO, of course, 13 and then there will be a Commission meeting for which'the 24 Commission will get a review by both the utility and by the 15 staff'on the basis for restart.
16-DR. REMICK:
Who has the authority to allow the 17 restart?
Does the Commission take this on themselves or still 18 the director of NRR have that authority?
19 MR. KANE:
Well, the plant is shut down right now by 20 Region I, I'm sorry, by an order that was' signed by the EDO, 21 if I am recalling correctly, so it would at least be at that 22 level.
i 23 Bruce, do you have whether the Commission is going 24 to vote on that?
I am not sure that's clear, but they will be
()
25 briefed on it.
HERITAGE REPORTING CORPORATION-- (202)628-4888
e 47.
f 1-
_HR. LINVILLE:
Bill, I think'the order gives the
([
2 authority to-the' regional administrator to--
3 MR. KANE:
To relax the order, i
4' MR. LINVILLE:
Relax it or --
5' DR. REMICK:
You indicated the State of Pennsylvania 6
.had a petition for hearing, and is that'before the Commission 7
or before a hearing Board?
8 MR. BOGER:
Bruce Boger of NRC staff -- we just
-9 received it in about a week ago.
It comes to the Commission, 10 and it gets handled by the director of NRR.
11 DR. REMICK:
It is a what kind-of petition?
12 MR. BOGER:
2.206 petition.
13 DR. REMICK:
I see.
O 14 MR. KANE:
Okay.
Let me just get to the last slides 15 unless you have any questions.
I think we have been through 16 the major issues.
17 (Slide) 18 MR. KANE:
And the criteria that we plan to use for 19 the restart will be to assure that there is defense in-depth 20 at all of the levels that broke down, that led to the problem.
21 We will assure that, that each of those levels is, is 22 addressed, and to the best of our reviewability to make sure 23 that, that they are strengthened effectively.
24 Independent corporate oversight of operating
()
25 activities is certainly one that is essential.
The second one HERITAGE REPORTING CORPORATION-- (202)628-4888 i
I 48 1
is strengthen alignment of~ operating activities, which goes
(
2 right down to the shift manager level; improved operator 3
attitudes and performance through training and disciplinary 4
action as appropriate.
5 Our actions prior to restart'are to, of course, 6
review and approve the licensee plan.
That, that's a 7
continuing process.
Verify implementation of each of the 8
actions through our inspection process, and following restart, 9
if that's decided through our inspection processes which will 10 be tailored to the restart, to satisfy ourselves during 11 operation that the appropriate corrections have been made.
12 Thank you.
13 CHAIRMAN KERR:
Questions?
It would seem to me if 14 my understanding is correct, that this problem of widespread, 15 pervasive has been occurring for sometime, that one would want 16 to look and see how one could be certain that similar 17 widespread, preventive and long continuing problems did not 18 exist at other plants.
Apparently this was something that was 19 not identified by an NRC organization.
It was some outside 20 information.
21 Second, it appears that these operators were 22 operators who have had no difficulty passing the existing 23 licensing examination, yet their performance was serious 24 enough that the plant had to be shut down.
You know, it would
()
25 seem to me one would want to look really carefully at HERITAGE REPORTING CORPORATION-- (202)628-4888
)
l
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49 1
existing; at the existing licensing process.
If'there is
()
2
.something this. serious that the existing process simply does 3
not look at at all, it may be that one would want to 4
re-examine the licensing process.
5 MR. EBERSOLE:
You have learned how to pass the 6
. test, but that's it.
7 CHAIRMAN'KERR:
Yes.
I think we have, the licensing 8
process has been in development for a long time.
Presumably 9
from what-I gather these operators were well qualified in the 10 sense they had no. difficulty passing the licensing exam and 11 yet their performance was such that it was felt that to be 12 completely unacceptable.
13-I don't disagree with the judgment that was reached.
O 11 4 I am not being critical of that because it seems to mn that 15 under those circumstances, one would want to look and==v, you 16 know, is the process we are now using adequate?
17 MR. REED:
I agree with you, and of course, you have 18 heard my old refrain on personality as well as IQ and logical 19 reasoning, mechanical comprehension, all these things that 20 make up a good operator.
21 I sometimes wonder as I listen to this Philadelphia 22 Electric case, and knowing something about the culture, you 23 have some Philadelphia Electrical people, I am wondering if it 24 wasn't, isn't more to this case than just sleeping on duty.
I ()
25 That-has been announced many times in the meetings.
I am l
HERITAGE REPORTING CORPORATION-- (202)628-4888
50 l' '
wondering if there isn't an attitude problem,Llet's.say, some 3
{)
2 clashes'between NRC and its many activities and Philadelphia i
3 Electric ~and its employees?
So the attitude problem might not i
E4 be, might be one of non-submissiveness 'at the outset, not 5
' knowing the full strength of the NRC.
6
-CHAIRMAN KERR:
Mr. Wyle, you were holding up your 7
hand.
8 MR. WYLIE:
I wanted to ask'a question.
Following 9.
the morning reports over the last so many months, am I wrong 10 that there seemed to be more problems with Philadelphia 11' Electric plants, say Peach Bottom, in regard to personnel
-12 problems and drug use, abuse, and this kind of thing?
I 13 noticed just the other day the maintenance people.
Is that 14-true, or is that just a misinterpretation?
15 MR. KANE:
There have been a relatively high 16 incidence in the morning reports.
I would not try to 17 characterize !. as being unique, and there are some other 18 consider ations that I, that I would like to not get into at 19 this meeting if I can possibly avoid it, but I think that 20 there are within Region I, if you read the morning reports, we 21 have a philosophy, as does every region, of reporting.all such 22 incidents, and you know, in going back over the last couple of 23' years, it would be, the numbers would be high, but I am not 24 sure that they are unique.
()
25 DR. SHEWMON:
Clarification on that -- when you say HERITAGE REPORTING CORPORATION-- (2021628-4888
51
~
1 here high, does that mean they are high relative.to the1 region;
'().
2 out in the Midwest, or high relative to Oyster Creek, anotner 3
one in the same region, or high what?
4-MR. KANE:
High relative to the other plants in the 5
region.
6 DR. SHEWMON:
Okay.
7 CHAIRMAN KERR:
Another question--
8 MR. KANE:
I would not--hesitate to, to leave it 9
there.
I:would not attach that much' significance to that 10 statement.
11 CHAIRMAN KERR:
Mr. Kane, we thank you and your 12 colleagues.
I certainly think this is a difficult problem 13 that, with which you are dealing, and I hope you won't O
14 interpret our comments as criticism.
We are trying to 15 understand the process which it seems to me is particularly at 16 the heart of the operator licensing process, and we may,.if we 17 are facing something which is this hard to detect by our 18 existing procedures, we need I think maybe to look carefully 19 at what we are doing.
20 MR. KANE:
I,think I support your. comments, and I 21 think one thing that has always been difficult to Gssess for 32 us in the licensing process is really the command and control 23 issue.
It comes.up perhaps best in simulator examinations, 24 and of course, all plants do not have simulators, but it is,
()
25 it is an issue that, that can be developed through that HERITAG3 REPORTING CORPORATION-- (202)628-4888
y 52
'l process, and again that's why we are attempting to use, even
-()
2 though there is not_a Peach Bottom simulator per se, using the 3
Limerick simulator to try to get an understanding of this, of 4
this command andLeontrol issue, as well as the, as well as the 5
attitude issue.
It is a mechanism that we see that is.
6 available that will help us get a better understanding of 7
these two issues.
8 CHAIRMAN'KERR:
Again, thank you.
9 MR. KANE:
Thank you.
10 CHAIRMAN KERR:
I am going to suggest we take a 11 ten-minute break at this point.
12 (A brief recess.was taken.)
13 CHAIRMAN KERR:
Gentlemen, as you know, we have been-0 14 engaged in four score and seven years I think on the TVA 15 plant.
16 A discussion was held off the record by the 17 Committee members regarding the TVA issues.)
18 MR. WARD:
Going to the meeting, I didn't really 19 know whether the Committee would want to make, whether we have 20 an obligation to follow this at fairly detailed level, and to 21 comment when we think comments are appropriate.
Pardon?
22 DR. LEWIS:
Only then?
23 MR. WARD:
Well, if we can restrain ourselves!
24' Going'into the meeting, I had thought that it might, it might
()
25 be timely for us to comment at this meeting after the HERITAGE REPORTING CORPORATION-- (202)628-4888
53
- 1 subcommittee' meeting yesterdayfand then hearing a summary of' t-()
'2 :
the : status of' the plan from Mr. Houston here at theffull
.3
-Committee meetingitoday.
!~
I 4
After the subcommittee _ meeting was finished, I guess.
L 5
I came'to the conclusion that it, it is not necessarily--I
.6 think there are a number of things that we could say, but I 7
think the plan is still, there are a lot of difficult areas l
L l
8 and it~is still in a fairly preliminary state, and it might be l
9 better for us to wait two, three months before the Committee j
l 10 attempts to make some more formal comments, but when you hear 11 Mr.. Houston's summary today, you can, you know, decide what 12 you think about that.
13 There is another milestone of sorts coming up in O
14 that the staff is obligated, is on a schedule to have some 15 written description of what I guess it is that the plan itself 16 or, he will tell us by the end of January, and it might be 17 timely.for the-subcommittee to then review that written 18 material and have another subcommittee meeting and then come 19 back to the full Committee maybe in March, and the full 20 Committee would then be in a better position to make some 21 formal comments, but if after hearing Mr. Houston's 22 presentation today and the discussion, you think there is 23 something that we should call out right now with a letter, we 24 will include that letter with some, you know, limited, of
.( )
25 limited scope at this meeting.
i HERITAGE REPORTING CORPORATION-- (202)628-4888 i
54 1
There were a number.of other members at the-()
2' su'bcommittee meeting yesterday, and I invite them now to make 3
any comment they.would like to before going to the staff.
Al?
4 DR. LEWIS:
Just one point of information -- the 5'
package that, of copies of the vugraphs that were just passed 6
out, I think is.the same one you used yesterday, is that
~
7 correct??
8 MR. HOUSTON:
About a third Of them.
l 9
DR. LEWIS:
About a third of them, I see.
Very 10 good.
I was' going to ask how you were going to do in one hour 11
-what it took you six hours yesterday.
12 MR. WYLIE:
Talk fast.
13 DR. LEWIS:
Only two hours in one hour.
O 14 MR. HOUSTON:
That's up to you.
15 MR. WARD:
So.I present to.you Mr. Houston, yes, it 16 is Mr. Houston; Wayne, we have had one suggestion that we can 17 look~at the first page,~and see what is on that and.you can 18 just go ahead and pass the schedule to the next one.
19 MR. HOUSTON:
It is a pleasure to have the 20 opportunity once again to discuss the subject of safety goal 21 implementation and the staff's plans therefor.
22 We have actually had two meetings with the 23 Subcommittee on Safety Philosophy, Technology and Criteria I 24 believe is the correct name for it, in early October, and
(-
25-yesterday for about five and a half hours.
And it has been HERITAGE REPORTING CORPORATION-- (202)628-4888
55 1'
-very,_from our point of. view, it has been very fruitful to
('Y 2
have had-that opportunity to interact wich the members of the v-3 subcommittee with respect to our ability to gain clearer 4
- understanding of what was intended ar.d what in: fact is said-in 5
the ACRS letter.
6-DR. REMICK:
That only took five and a half hours?
'7 MR. HOUSTON:
It wasn't entirely devoted to that a
quescion or clarity of what you said.
I must confess that.
9
.There is some major points that I would like to make 10 in summary fashion which, two of which I think are, in ny
-11 mind, really highlight perhaps two of the most important 12 things that came out of the meeting yesterday.
13 And I hope to do that in short order.
One of t'.le
'14 things that I would like to make clear in that we are embarked-15 upon an effort to revise a previously existing plan, which was 16 basically the thing that had motivated the ACRS comment letter 17 and dated May-13th 18 This is the, so it is the second item here that I am 19 referring to, the preliminary staff implementation plan which 20 is the subject of a memoranda addressed to the Commission 21 dated January 2nd of this year.
22 The safety goal policy statement itself, of course, 23 was noticed and became official as it were in August of 1986, 24 and our present planning effort is based upon that being taken
()
25 as a given, and I mean that in the following sense -- although HERITAGE REPORTING CORPORATION-- (202)628-4038
56
- 1..
I think one can' recognize that the staff has an option, an
...()-
2' opportunity-to at any time to perhaps recommend to the
~
3 Commission that perhaps some changes in policy statements 4
might be in order based upon new understandings or new 5
knowledge, new information, that is not our' intent at the 6
present time.
7 We are attempting to build,. rebuild a plan that is 8
based upon the starting peint of the Commission's safety goal 9
policy. statement.
It appears to.us that the ACRS position 10 could be said to be the same.
That~is, there is nothing in 11 the letter that, in the letter.itself, reflecting the-12 collegial opinion if I may of the ACRS that would differ from 13 that, so that.at least we start out I think with the same O-14 basis of taking the safety goal policy statements as a given, 15
.and commenting on necessary changes perhaps in the staff plans 16 for implementation.
17 Since the first meeting with the ACRS subcommittee 18 in early October, we have received seme additional guidance 19 from the Commission with which you may be familiar.
It is by 20 memorandum dated November 6th, which asked the staff for a
.I 21 number of things, part of which have been alluded to in Dave 22 Ward's introduction.
Highlighted here are some option papers 23 that they have asked for that deal with certain elements of 24 the hierarchy of safety goal objectives, performance and test, j
'f) 25 particularly one dealing with the large release guideline, the I
l j
HERITAGE REPORTING CORPORATION-- (202)628-4888 i
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t.
57
- 1
' question'being largely one of how does one,'how-does the staff
~
()
2
. propose;to define-a large release, and what basis, what 3
options are available to do that?
4.
And secondly, options that may be available and 5'
under consideration by the staff with respect to plant 6
performance objectives such as core melt frequencies, and 7
containment performance' objectives.
8 Finally, we have been asked, and we have proposed, 9
there has.been a response I should say to the November 6 memo 10 from the EDO to the Commission which reorganized what'they
- 11 were asking for, but essentially producing the same 12 information to the Commission and the same timeframe, and what
- 13' we, what we have promised the Commission is a proposed revised 14 staff implementation plan to be sent to the Commission for 15 their review and consideration by the end of January, and that
' 16 I think was the date that Dave Ward was referring to.
17 (Slide) 18 MR. HOUSTON:
I would like to spend some time now 19 summarizing some of the discussions that we have had, some of 20 the, what we understand to be the ACRS views and the staff 21 views which for the most part are really very similar, in.
22 spite of some of the discussion yesterday in which it was, 23 seemed at least clear to me that there was something in the 24 nature of a communication gap between us.
().
25 Whether it is totally a communication gap or l
l l-HERITAGE REPORTING CORPORATION-- (202)628-4888 1
58 1
something, or something else of.more fundamental distinction I
(
2 think remains to be seen.
3 Let's talk a little bit about the first element, and j
4' what I would like to preface these remarks with, it is the 5
staff's intent ~in preparing a revised staff implementation 6
plan for. safety goal policy to in effect adopt essent'ially the 7
recommendations of the ACRS in the manner that'has been 8
endorsed by the Commission.
9 The primary goal of the staff's plan would be to.
10 address questions.of adequacy of rules.and regulatory 11 practices, and that includes existing rules and regulatory 12 practices as well as proposed changes in the rules and 13 regulatory practices from whatever source.
i
(:)-
14 Stated in that fcshion,.that is a, what I would call 15 a rather global scheme of an effort, and so that, of course,.
i 16 one of the problems in carrying out a plan will be to try to 17 translate that overall goal or objective to one that is 18
'wo-kable over a reasonable period of time.
Workable over time 19 I should say because some of the elements of that kind of 20.
objective could, of course, take years and years to 21 accomplish, but nevertheless, it is the. intent of the staff to i
22
. work toward specifically the goal, the objective of using 23 safety goal policy and subsidiary objectives if I may, in the 24 hierarchy, proposed a hierarch a1 structure to address the
()
25 question of adequacy of rules and practices.
When you say the HERITAGE REPORTING CORPORATION-- (202)628-4888 l
59 p
s 1
practices,.you are talking about an awful. lot of additional
()
2
. things in the regulatory' process itself.
I will come back to 3
some of the specifics that are examples of things that can be 4
attacked if you will, by you the use of the safety goal-l 5
hierarchy.
6 One of the perhaps in a sense, perhaps one of the 7
most important points of our discussion yesterday,' revolves 8
around this recommendation on the'part.of the ACRS, and from 9'
my vantage point I would have to'say that there may be a
'10 misunderstanding on the part of the, some of the members of h
11 the subcommittee on what I was attempting to say, and there l
l 12 may not.
I may have been guilty in trying to rephrase in lo 13 different words what I said earlier--we are taking the safety 14 goal' policy statement as a given.
I 15 Now in that policy statement, word for word, as well 1
t 16 as in the more recent Commission guidance letter, one finds 17 the following statement -- the Commission concurs with the 18 Recommendations made by the ACRS to apply the safety goal 19 criteria in judging the adequacy of regulations rather than 20' making plant-specific regulatory judgments.
21 However, if information is developed that is 22 applicable to a particular licensing decision, the Commission 23 endorses consideration of that information as a factor in the 24 licensing decision.
And what I was trying to say yecterday is
()
25 no more, n>or less, tnan what that statement means.
HERITAGE REPORTING CORPORATION-- (202)628-4888
l 60 l
1 MR. EBERSOLEi May I ask a question?
Isn't'there a 2'
missing' ingredient in that first statement,.as to rules and
~
3 regulatory practices, what.that means as fitted'to the using 4
' agencies, which--
5 MR. HOUSTON:
Pardon?
6 lMR. EBERSOLE:
That must be fitted to the agencies, 7
the structure which is using those rules and regulations 8
because always there is a degree of interpretation.
In rules 9
and regulations there has to be fit.
Conservative.cperation 10 will produce a different result than non-conservative one..
11 With the same cet of rules and regulations, you know, you will 12 have differences in managerial structures in the utilities, 13 widespread, so the ingredient not shown up there is the using O-14 structures, which are the utilities, the way they are 15
. presently configured anyway.
16 MR.' HOUSTON:
Well, I agree.
I believe I understand 17 what you are saying, and one of the points that I have 18 attempted to make also which I think addresses your question, 19 is that to this effect--what we are talking about here is the 20 use of the safety goal policy and the hierarchy by the NRC 21 staff, but nothing in that plan, it is our intent that nothing 22 in that plan should inhibit the use of safety goal I will call 23 targets or objectives and the use of probabalistic risk 34 assessment methodology for their, by their own initiative for
()
25 their own purposes.
I don't know whether that--but we are not HERITAGE REPORTING CORPORATION-- (202)628-4888
61'
'1 attempting to address in this. context specifica11y'how they (f
- 2 shculd'do that and how they might adapt that to their own 3
various organizations.
l:
4 MR. EBERSOLE:
I am only saying we can.use the'same 5
set of rules'and regulatory practices,'then say the industry 6
is. improving and we are getting better results from -thera 7-
'without changing the rules and regulations as a result of the 8
education, and improvement'in the using groups.
9 MR. HOUSTON:
True.
10 MR. EBERSOLE:
That's not mentioned up there.
11 MR. HOUSTON:
It'is not mentioned in the ACRS 12 letter, is it?
13 MR. EBERSOLE:
Well, no, it isn't.
O 14 MR. HOUSTON:
This is my rephrasing of what appears 15 in the ACRS letter, 16 DR. LEWIS:
I think that there is an extremely 17 important question here on which you ought to solicit the 18 Commission guidance, because the ACRS letter as I understood 19 it, others can correct me, said that you should use the safety 20 goal, period, in terms of license decisions on individual 21 plants.
22 What you said yesterday and what you alluded to 23 today is that still information developed during it in doing 24 the PRA use will be used.
Yesterday we talked about
()
25 probability.
I have now looked at the Commission guidance on HERITAGE REPORTING CORPORATION-- (202)628-4888
62.
1-this point, and it is ambiguous.
That is to say, the
()
2 Commission concurs with the recommendations made by the'ACRS 3
to apply:the criteria in judging the adequacy of regulations 4
rather than making plant-specific regulatory. judgments.
Theyo 5.
go on to say, however, where informationinformation is 6.
available that is applicable to a particular-licensing 7
decision,'the Commission endorses consideration of that
'8-information as a factor in the licensing decision.
9 Now in doing the analysis, one can develop 10 information about the design of a plant.
We often say that's 11 onelof the most important parts of doing a PRA.
It forces you 12
.to look at the design of a plant.
I believe that it is that 13.
' kind of information that the Commission intended might be 14 useful in a licensing decision, and I believe'that the 15 Commission's intent was that you should not use the
.16 probabilities measured against the safety goal in any way, in 17 a licensing decision.
Certainly that would be my 18 characterization.
19 Now since the Commission's wording is ambiguous and 20 since this is, was an important issue yesterday, and will be i
21 an important issue as we go along, I believe that rather than l
22 running looce--and don't tell me you are not going to use.it i'
l 23' as the sole basis for licensing because that's an empty i
24 comment.
You are not going to use anything as the sole basis
()
25 of licensing.
It seems to me the question of whether you use HERITAGE REPORTING CORPORATION-- (202)628-4888 l'
63 1
'it.at all, the.probabalistic information measured against the
"()
2' safety goal is one on which'you should seek Commission 3
' guidance because I believe.you-have misread what the 4
Commission guidance was.
That's not a question.
It is a 5.
speech.
6' MR. HOUSTON:
Perhaps the lack of--and I don't know 7
whether we agree or disagree.
The, my response to'your.
8 comment isLthat it was never intended.certainly on my part, to
- 9 suggest.that the staff. intended to use the safety goal objectives per se, that is, the modified numbers, with respect 11.
to particular licensing decisions on plants.
I thought'I-12 actually ma'de that even clearer statement back in October, 13 eomewhat different framework.
O 14 What I am trying to say I think is that, just 15 exactly what you say, it is not, it is not, so it may be that l
l 16
. what we should be saying is that we want to use, we want to be 17.
able to review PRAs on specific plants, and forgetting about o
18 safety goals-if'you will, perhaps make judgments based upon l
19 review of a PRA, looking at the internal details of it, but i
20 you are faced with the fact that the PRAs will have some of.
21 the bottom line numbers, and you are faced with the fact that 22 if objectives are published, publicly availabic, they invite a 23 comparison.
I am just saying you can't ignore that fact, but 24 that, that comparison is not relevant to what I am saying, but
()
25 it is difficult to get that point across to a lot of people.
HERITAGE REPORTING CORPORATION-- (202)628-4888
64 1
IMt. LEWIS:
Well,-I believe that.you,did not'get it
()
2 across to me becauseEI thought you said yesterday that when 3
you:look at these probabilities you could not bring yourself-4 to ignore them because they were there, but now you say~you 5
can. bring yourself.
6 HR.. HOUSTON:
Let me put it this way..I'still would.
7-stand-by that statement.
I mean you know, you can't close 8
your eyes when you come to that point in reviewing a PRA and
.9 pretend that you don't see it.
And the comparison will, you 10
.know, will-pop.out of the page.
And in that sense you can't 11 ignore.that it is there.
If, for example, an objective or a
'/
12' core. melt frequency let's say for just an example of ten to 13 the minus 4th, some sort of target, we will get to the 14 question of what that means, or may mean or should mean, and a 15 PRA has a ten to the minus 2, now that will sort of pop out at 16 you as a question--why is it that high?
On the other hand, if 17 it were ten to the minus 6th, it might stretch the bounds of 18 credibility.
Why is it that low?
And I didn't mean to imply 19 that it would be just one-sided.
20' DR. LEWIS:
Well, I believe, you know, let me use a 21 nicer word.
I believe that this is ambiguous, and that what 22 you are in effect saying is that you are going to measure the I
23 individual plancs against the safety goal in view of the PRA, 24 and we are now haggling about the extent to which you are, and
{)
25 since the ACRS. letter was written precisely to avoid that as a HERITAGE REPORTING CORPORATION-- (202)628-4888
65 1
Dichotomous decision and'now;you are sayinglwell, it is not
(
lL
'really dichotomous, it,is just one of the things we are. going 3
.to take into. account, I really.believe, and this is again'not-4 a, question that requires.a response, I really believe you 5
- should seek. Commission guidance because I think it is a very 6
important question.
I have very little doubt that in the end, 7-plants will be licensed or not, whatever the obfuscation is,
'acco' ding to whether or not they meet the safety goal, and 8
r 9
that's precisely I believe what the ACRS letter was written to 10 prevent.
11' MR.' HOUSTON:
Now let me turn it around if I may in 12 a sense.
The other important--there are two, I mentioned I
13 earlier I think there were two most important outcomes of our 14' interaction, our discussion, and we are now beginning to focus 15 on what I think is the second one that relates to the first.
16 The ACRS, this was one of the distinctions in which I 17 guess at least in my mind had not been entirely clear but it 18 came out pretty well yesterday, it was in terms of a, the 19 point one or ten to the minus one figure as a minimum i
20 containment' performance objective, but it also was clarified 21 that the ten to the minus 4th core melt frequency was also 1
.l 22 intended as a minimum.
23 Now if, when that.is stated in that fashion, i
24 although your letter is quite clear and your position is quite
()
25 clear, that'you still mean that in the context of are the HERITAGE REPORTING CORPORATION-- (202)628-4888 1
66-l' regulations adequate to give reasonable assurance that such a d
)-
2
. target should be met if the regulations are met, and I think
'3 that is what the ACRS meant, that.also_ invites an 4
interpretation which could be said to be ambiguous in spite of 5
the langutge that you have used in the-letter.to the contrary.
6 So I think what I am saying is that I agree with you that'we
'7 all have a problem of ambiguity or potential ambiguity.in 8
dealing with these targets.
9 DR. LEWIS:
I didn't say I had a problem with 10 ambiguity.
I am unambiguous in what I believe.
11 MPd. HOUSTON:
I will apologize then.
Others may 12 perceive it as ambiguous.
I believe that's correct, and you 13 have suggested that we seek further. guidance from the 14 Commission.
15 CHAIRMAN KERR:
Why don't we leave a little bit of
.16 ambiguity and go on to the next one?
17 MR. HOUSTON:
I think it is an important point, 18 though.
19 CHAIRMAN KERR:
I do, too.
20 (Slide) 21 MR. HOUSTON:
With respect to the hierarchial 22 structure, let--I have a few more vugraphs on the hierarchial 23 structure, but not the complete set that I used yesterday.
24 (Slide)
()
25 MR. HOUSTON:
The top part of this vugraph simply HERITAGE REPORTING CORPORATION-- (202)628-4888
67 1
identifies:what.was identified in the ACRSlletteri. starting
( )k 2
with'the qualitative safety goals themselves, one dealing with 3'
accidental, basically risks associated with accidental death
'4 or. accidental' injuries, and another one associated with'the, L
5 with' risks of really health-related risk, and get translated 6
when coming to the level 2, also a part of the safety goal 7
policy statement itself, into two separate and distinct 8
quantitative health objectives, one of which deals with risks 9'
to an individual of a promptHor early fatality due to 10 excessive radiation exposure, and the second one dealing with 11 the risk of a late event cancer fatality, again due to 12 radiation exposure, the two goals recognizing that if 13' radiation exposures are sufficiently high, they can result in O
14 deaths to individuals within a matter of 30 to 60 days.
15 The level 3 in the hierarchy was adopted, adoption 16 or adpation if you will of a proposed so-called 'orge release 17 general performance guideline and sometimes referred to as ten 18 to the minus 6 overall mean frequency of a large release, and 19 the focus of, one of the major focuses of staff efforts in the 20 recent past was to try to come to better grips with 21 establishing a basis for defining what is meant by a large 22 release or threshold value, and then going on to a level 4 23 performance objectives which in the ACRS letter are identified 24 with essentially a target, a subordinate objective,
()
25 subordinate to the above, with respect to accident prevention HERITAGE REPORTING CORPORATION-- (202)628-4888
68 1-objective core.meltLfrequency target which is let's say (h minimally acceptable, as well as.a containment performance 3
.terget which.uill be. minimally acceptable, andLfinally, the 4
level'5 view of the-hierarchy was.the. body of rules and
~5 practiccs, and the ACRS suggested in its letter then certain
-6 what I will' call linkage. criteria that tie this together in 7
some logical fashion, suggesting that each subordinate-level 8
is, ar one moves down the hierarchy from the top down, that 9
there be an element of consistency as you proceed in'this 10
' fashion.. There has to be an element'of simplification
'11 involved in it, and in any event, the hierarchy itself should 12 be linked in such a manner as to assure that the safety goal 13-objectives are met.
We get problems when we talk about 14 objectives here and we talk about I think a broader sense'at 15-the bottom.
16 One of the, one of those apparent objectives stated j
17 in the safety goal policy statement which came:up for some 18 discussion yesterday, for example, was again at the risk of 19 paraphrasing, the Commission's intent that they really wanted 20 to minimize or virtually eliminate the risk of a core melt 21 accident occurring in the United States during the lifetime of 22 the present operating plants.
That's a paraphrase.
That's 23 not an exact statement.
And the question did arise how is, 4
24 the staff is going to deal with this.
()
25 (Slide) l i
HERITAGE REPORTING CORPORATION-- (202)628-4888
69 P
i 1
1 MR. HOUSTON:
One'of the most~ interesting and in a-
}
2.
sense, one of.tne more. difficult < problems, that is more-from a 3-technical point:of view I'think than a policy point of view, 4
is the. matter of' establishing a basis for defining a large i
5 release.
There has been'no dirth of suggestions made by 6
- various parties that have an. interest in this process, and 7
what I am listing here are three that are essentially 8
different ways that one can approach a basis for it.
9 Now at the bottom, I list the, I indicate that.in 10 the previous staff plan, the January 2nd, 1987 version of 11 staff plan or proposed staff plan for implementing safety 12 goals, it.was proposed that a large release be defined as, 13 simply as one that resulted in one or more early fatalities.
/'.
14 Now that, of course, is not defined as a release, 15-and one of the principal efforts that the staff has been 16 engaged in in the past several months has been to try to find 17 a way of defining a release as a release.
That is as a source 18 term into the environment if you will, and of course, that 19 statement does not match that.
20 In addition to which being expressed in terms of 21 health effects and objectives, that is, as prompt fatalities, 22 it tends to come into conflict with the level 2 quantitative 23 health objective which it addresses the matter of the 24 frequency if you will or the risk to individuals of early
()
25 fatalities.
HERITAGE REPORTING CORPORATION-- (202)628-4888
.m 70' 1
Nevertheless, in.the process of trying to get a
]
2' grasp uponLa reasonable definition'of a large release, of a
~
3 threshold value'for a large release as a release, this'still r
4-could bet one of the bases that'.one might attempt to use.
That 7:
5-is, it'is a. translation of that concept into a-release.
6 I should I guess, perhaps I should have said 7
previously to apply a. criteria of consistency one can also do 8-the, attempt'to do the same thing with respect to the 9
quantitative health objectives themselves.
What we have found 10 is that with both the early fatality quantitative health 11 objective and the late event cancer fatality health objective,,
12 you cannot really logically define a large release in a 13 fashion which I would say-is totally satisfactorily consistent
~#
14 with those quantitative. health objectives.
15 The large release definition and the frequency, the 16 overall mean frequency specified for it automatically-is more 17 stringent than the quantitative health objectives themselves.
18 are.
This is most easity seen by comparing the large release 19 frequency specification with the translation of the late event 20 cancer fatality quantitative health objectives into an 21 individual risk number which is two times ten to the minus 6th l
L 22 as a risk to an individual per year.
Well, the release l'
'23 frequency one times ten to the minus 6th is already larger 24 than that number, and therefore, there is no way that you can
()
25 make the one times ten to the minus 6th large release equal to HERITAGE REPORTING CORPORATION-- (202)628-4888 o
.l
i.
71:
1 the 2 times ten to the.minus'6th risk of a late event cancer-r ()
2 fatality.
F 3
DR.'SIESS:
Did you'say ten to the minus'6th both 4
times?
5 MR. HOUSTON:
Yes.
6 DR. SIESS:
One times ten to the minus 6th was 7
larger?
8 MR. HOUSTON:
Large release frequency.
9 DR. SIESS:
Larger than one times ten to the minus---
10 MR. HOUSTON:
Comes about from a translation--
A1.
DR. SIESS:
I just didn't understand what you said.
12 I thought I heard you say that one times ten to the minus 6th 13
'was larger than two times ten to the minus 6th?
14 MR. HOUSTON:
No.
The other way around--two times i
15 ten to the minus 6th is larger than one times ten to the minus 16 6th.
I'm sorry.if I misstated it.
That's what I meant to 17 say.
18 DR. SIESS:
The one times ten to the minus 6th is a 19 more rigereus--
20 MR. HOUSTON:
Yes.
More stringent, t7e large 21 release definition at one times ten to the minus 6th is more 22 rigorous, more stringent goal.
23 DR. SIESS:
By a factor of two.
24 MR. HOUSTON:
By more than a factor of two.
- Yes, l
)
25 with respect to that quantitative health objective.
HERITAGE REPORTING CORPORATION-- (202)628-4888
- 72
. 1.
.DR. REMICK:
Don't forget the safety goals include.
)
'2?
routine operations.
I am not suggesting that's a significant 3
factor,.but it islnot just accidents.
4 MR. HOUSTON:
'I have, as a matter of fact, the next 5
vugraph I have will come to that point, yes.
That is correct.
6 By the same token, with respect to the quantitative health
'7 objective that deals'with prompt or early fatalities--I k'eep 8
using the word early because I like it better than prompt.
9 The individual risk target that the prompt fatality 10 quantitative health objective corresponds to is five times ten 11 to the minus 7th.
That represents one tenth of a percent of 12 the average accidental death risk in the United States. lNow-
]
13 this is smaller than the one times ten to the minus 6th, so I O-14 might put it that,one has a fighting chance of a, at least 15 making a, drawing some, providing some definition of a large 16 release which is in some sense consistent with it, but it 17 cannot be perfectly consistent for the following reason -- the 18 quantitative health objectives as specified in the severe, in 19 the safety goal policy statement are accompanied Inr 20 prescriptions as to how one should deal with what I will call 21 average individuals in the vicinity of a plant.
22 When one applies that prescription to the 23 quantitative health objectives, it inevitably has to take into
)
1 24 consideration the likelihood that individuals in the vicinity l
.( )
25 of a plant who will be in effect downwind when a release might l
k HERITAGE REPORTING CORPORATION-- (202)628-4888 i
- _ _ = _ _ _
73 11
' occur so that the risk number lthat one is looking toward has
()L
'2
'to take into consideration the, the average risk over;a year,
.3 of the averaging out if you will, the' weather and 14 meteorological-factors,'not to mention others.
And since the 5
wind rose'is variable in any given' location, given a large 6
release at'a' frequency of' ten to.the minus 6th, the risk _to 7
any individual in the vicinity of a plant will already be less 8
than five times ten to the'minus 7th regardless of magnitude 9
of.the' release, simply because of the wind rose, so that 10
-that's the,~ essentially the logic that is a associated with 11 the statement made earlier that the large release guideline is 12 already more stringent than the quantitative health 13'-
objectives.
14 Therefore, it is not easy to apply a consistency 15 criterion in going from the level 2 quantitative health a
16 objectives to the' level 3 of the-large release guideline at-
.17 that frequency level.
l 1
18 DR. SIESS:
Why should you be consistent in the 19 level 1 and 2?
20 MR. HOUSTON:
Because.the ACRS said that was one of 21 the criteria.
22 MR. WARD:
We want you to be.
l 23 DR. SIESS:
Ten to the minus 6th on either the level i'
24 1 or level 2 or anything else, that came out of somebody's --
()
25 DR. REMICK:
No.
I differ.
My view of the ten to HERITAGE REPORTING CORPORATION-- (202)628-4888 i
_ _ _ _ = _ - - _ _ _
74 1
the'minus'6th is for how many years ~the ACRS pushed for a l
2 containment performance and the concept of the~ safety goals, 3
you are, really on1y needed the public risk, but there was 4'
considerable concern if you don't anchor this,.you won't get' 5
defense in-depth.
Somebody will put all their eggs in the 6'
prevention' basket'or somebody you will in the-mitigation, so 7
that you want--
'8 DR. SIESS:
The number wasn't based on the --
9 DR. REMICK:
Let me--ten to the minus 4 was 10 something that, people felt that you should anchor core melt 11-frequency, but ACRS kept pus. ting that you also need a 12 containment performance, and the staff kept saying you can't
'13
.do-that, so I see the ten to the minus 6th was an effort by G.-
l'4 the Commission to get out of that argument and say by 15 combining the core melt and a containment performance in one 16 shooting for,something like ten to the minus 6th in 17 combination, that's--
18 DR. SIESS:
Incomplete; they combine the ten to the 19 minus 4 and the other one, they didn't go back and look at the.
20 one tenth of one percent.
21 DR. REMICK:
I think it was realized that would be 22 something that would be at least conservative, but relatively 23
' consistent with the health risk.
24 DR. SIESS:
A good round number.
()
25 DR. LEWIG:
We are functioning as historians now, HERITAGE REPORTING CORPORATION-- (202)628-4888 1 ' ~
75 1
but let me.say the'way~I remember the. ten to the minus 6th.
I
([
2 think that.I put the bug at the. late stage into the 3.
Commission's; head by writing a set of additional comments to 4'
the ACRS letter, and what I recommended that they.do was to 5
adopt the ten to the minus 6th and then adopt no other numbers 6
because in fact,.if.you adopt only one number,.there is no 7
issue of self-consistency that can be raised asuit is being 8
raised now, and I recommended that they make a declarative 9
statement that the way we think we are getting to the ten to i
10 the minus 6th now is ten to the minus 4 on core melt and ten 11 to minus 2 on--well, that was in my initial comment I 12 recommended that and ten'to the minus 2 on containment, but 13 the recommendation was that they simply adopt the ten to the
'O 14 minus 6th as the safety goal and let everybody else fall into 15
. place under that, and I think we are getting into this pickle
~
16.
now because we have got too many numbers.
17 DR. REMICK:
I agree with what you.are saying with 18 what went on, but'I can assure you that these other 19 discussions went on and I had a part of those discussions and 20 so forth, and so there might be many origins of ten to the 21 minus 6.
In fact, ACRS itself recommended something like 22 this, and the staff was considering something like that.
23 DR. SIESS:
No matter what the origin, the 24 Commission has made statements, official Commission documents,
()
25 that cannot be related one to the other.
They express their HERITAGE REPORTING CORPORATION-- (202)628-4888
R V
76 1
safety goals in different t'e r m, qualitative term, quantitative j]h
'2 terms', that,there won't be a~ core melt,.there won't he a ten.
3 to the minus 6'either.
i I
(
4-DR. LEWIS: :They listened to too many people.
5 DR. SIESS:
They are all nice statements and I. don't 6
know why anybody should be surprised that they don't all fit 7
together exactly.
8.
DR. LEWIS:
The way to be. consistent is to say one 9
thing.
That may not be particularly useful.
11 DR. LEWIS:
At least it is consistent.
!~
l 12 MR. WARD:
Well, I guess I can't help bu'. comment,
l L.
13-Forrest, I don't, you know, I am just disagreeing with part of 14 what you said because I don't see how the ten to the minus 6th 15 number is, has anything to do.withLthe defense in-depth of l-16 anchor.
I'mean that's why we went to the next level and why
~
i I
l 17 we wanted to put in the one in ten number in addition to the 18 ten to the minus 4, to provide some kind of basic anchoring of i
19 the two sides of the defense in-depth and of thic sort.
20 DR. SIESS:
Of course there is no way you are going l
21 to get ten to the minus 6th on cote melt on any calculation.
22 MR. WARD:
You might, Somebody might come in with a 23 new kind of reactor that--wait.
Let me finish.
Let me 24 finish.
That claims ten to the minus 6th on core melt and all
()
25 we had was the ten to the minus 6th.
The safety goal would L
I HERITAGE REPORTING CORPORATION-- (202)628-4888
~77 1
-permit that,'but_we, the ACRS, insisted that'that.should not 7( f
.2 happen,.'and'that in fact that the next-level we have~got-these 3
other numbers.
4 DR. SIESS:
I don't think'you can take our letter as 5
saying that we have already looked at fast reactors, liquid 6
. metal, and as-cooled reactors and we-won't accept a ten to the' 7
minus 6 on core melt without containment.
You were thinking 8
of light water reactors.
9 MR. WARD:
Well, we didn't say that.
-10 DR. LEWIS:
I ca n give you ten to the minus 6th 11 without containment.
I can. build you ten hundred million watt' 12 reactors.
It can be done.
I an-just saying'that's just a 13 feasibility demonstration.
'14' MR.' WARD:
I think that's the statement we' are' 15-making.
Mayba after we learn more about fast reactors, we 16-will say, well, we ought to change our mind.
We were wrong 17 about this or something.
18 DR. GIESS:
It is a different piece.
It behaves 19 differently.
Phenomena will differ, the uncertainty will 20 differ; already different places.
Can't pin yourself down.
21 All of our experience judgment is based on all the water 22 reactors we have been looking at and all these containments we L
23 have been looking at.
i 24 MR. WARD:
But as f ar as--I :nean I agree with, ycu
.()
25 know, Wayne there is a disconnect in the logic there.
When we l
HERITAGE REPORTING CORPORATIO!i-- (202)628-4888
_-_ -- _ - _ - _ _ _ w
78 1
put together, suggested this hierarchial arrangement, we kind
()
2 of took what was given in the. safety goal policy, and tried to j
3 assemble that into some logical structure.
Now that worked 4
pretty well, but right here, there is a, there is kind of a 1
-I 5
, logical disconnect.
You know, I don't, I don't know that it 6
renders the whole thing --
7 DR. REMICK:
I don't see a major disconnect at all.
8 MR. WARD:
Where the disconnect comes in this, that 9
we a3so said as kind of a principle that we' don't want, as you 10 go down the. hierarchy, you get to a lower level of 11 abstraction, and we are saying let's not, when we go to lower 12 level of abstraction, let's not introduce so much, I hate to 13 use the word conservatism, that we are in effect introducing a 14 de facto new policy.
'And I think that was.an important thing l
l 15 to say we wanted to say that.
I think it does happen, though.
16 At this step in the hierarchy, you do that, and I don't know 17 what to do about it.
We are kind of stuck with it.
I propose 18 that we go on.
19 DR. LEWIS:
We are nct necessarily stuck with it 20 because everything you have said is exactly right.
And if 21 indeed it is so, that this introduces a new level of 22 conservatism, then there are two things that can be done.
One 1
23 is to relax the ten to the minus 6.
The other is to relax the 24 core melt probability-I have always felt that the given core
()
l 25 melt probability numbers are deficient also and it is because 1
HERITAGE REPORTING CORPORATION-- (202)628-4888
79.
1
'in the public-and-inimany of our own minds a core melt is
(
-2 almost. identical with a major reactor accident, but it isn't L
3-really,Jand we know that'it isn't really, so we have to set 4
4:
standards for the public for core melt which in turn really 5'
are linked in people's minds-with the major accident and the 6
-fact that does. exist,-containment and.other things, means we 7
do the trick.
8 MR. WARD:
Well, I don't' disagree with that except I 9
don't think that relieves the logical problem because the
~
10~
logical problem-is going from the QHOs, the ten to the minus 11 6,
and you haven't even got that down to the core melt.
I 12 mean the logical problem is you deal with the, taking the 13' average statistics for the country and lay them in some 14 simplified way and then comparing that with the ten to the 15' minus 6th.
That's where the logic problem is.
1 16 DR. REMICK:
We have got to remember I would still 17 point out that this includes routine operation, and the risks l
18 we are talking about here, five times ten to the minus 7, if I 1
i 19 recall, had scratched out here in the back, is something like 20 20 millirem per year to the average individual, and that's not 21 too hard to imagine, and we start factoring that in and you 22.
start factoring that in with the risk of an accident, I'm not j
l 23 sure there is a major disconnect.
Individual risk is a pretty 24 low risk of exposure <SPOERS) for individuals.
. ()
25 MR. WARD:
You are saying when we go into this step HERITAGE REPORTING CORPORATION-- (202)628-4888
80 1L at.the point where we are kind of smearing out this other-
.2.
.. thing, little extra conservative?
'3.
DR. REMICK:
Doesn't hurt.
That's right.
4 MR. HOUSTON:
There.is a handout there and the 1
5 vugraph, the next one coming up, will', as I indicatedjearlier, 6
will sort of address the point that you are making, but.you 7
have got to recognize that 20 millirem per year as such-is not 8
.something that would produce an early and prompt fatality, so 9
there is a little bit of a question here of apples and 10 oranges.
11 DR. REMICK:
Five times ten to'the minus 7, that 12-boils down to'--
13 MR. HOUSTON:
But now what you are doing is focusing
~O-14 on.how are you defining risk?
Because the quantitative health 15~
objectives focus on prompt fatality risk and latent cancer 16 fatality risks.
You can also talk about risk of dose, risk of 17 exposure, which is, and this'is, and this is basically sort of 18 the thrust which I think that we are probably going in that 19 direction.
20 Let me continue if I may, as alternative bases for
)
21 defining a large release, one would be, by use of a reference 22 dose, and here is some examples that people have, various ones 23 have suggested.
Ten CFR 100 guideline, 25 rem, whole body 24 dose, for example.
ENO criterion currently around 20 rads or
()
25 something like this.
I don't know how actually it comes out HERITAGE REPORTING CORPORATION-- (202)628-4868
l 81 l
l
'l in the revised ENO regulations; protective action guide
]
q) 2 levels, five rem, commissioners, former Commissioner Aselstein l
I 3
suggested that might be an appropriate reference level fcr a y
4 large release definition.
And we are also considering an LD 5
50 value something like, LD 50 value 450 rem because this at 6
least brings it into the ballpark that creates an exposure 7
that has the potential for some early fatalitics, and in that i
8 sense, it would not be consistent with a quantitative health 9
objective that deals with ear 13 fatalities, so our leaning at 10 the present time, if we use a reference dose concept to define 11 large release, our leaning would be in the direction of using 12 something like an LD 50 dose.
13 DR. SIESS:
Why did you want to define the dose 14 process to get the meteorology in?
15 MR. HOUSTON:
What we want to do is, this is I
16 necessarily the next step.
17 DR. SIESS:
Population, presumably you put somebody 18 at the--
19 MR. HOUSTON:
At the level, at the level 3, the 20 large release concept, and I indicated we want to define it as 21 release, one thing that this does, we go back now to the 22 simplification criteria that the ACRS proposed, that is, as 23 you go down the levels of the hierarchy, it becomes in some 24 sense simpler, and what we are trying to do is associate these
()
25 levels in the hierarchy with different PRA level, types of PRA HERITAGE REPORTING CORPORATION-- (202)628-4888 I
82' jk'
' information Level 1 PRA goes to. the core-melt frequency.
)-
2-Level'2 PRA goes t'o the source term release question, and a 3
leve113 PRA, a; full 1cvel 3 PRA goes to the health questions.
4 DR. SIESS:
Now--
5 MR.' HOUSTON:
Because the whole focus, whole 6
initiative for the safety goal policy was to' introduce in some 7
fashion-in some controlled fashion, the use of PRA 8
information.in,the regulatory process.
9 DR. SIESS:
But the Commission warned you that they:
10 wanted large release defined so that it would be Include the
~I 11 Chernobyl.
12 MR. HOUSTON:
True.
13 DR. SIESS:
What are your reasons for not wanting to I
14 define large release in terms of a release?.
15 MR. HOUSTON:
I said that's exactly what we are 16
' aiming for.
17-MR. WARD:
This is how it is going to--
I 18 MR. HOUSTON:
Have to have a basis for doing it.
19 Have to connect it to something you can pick out.
20 DR. SIESS:
Probably as big at Chernoby1; the 21 Commission has told you that.
22 MR. WARD:
No.
j 23 DR. SIESS:
Has to be big enough.
24 MR. WARD:
He is going to get--
()
25 DR. REMICK:
Can I make a point?
I see 10 CFR, ENO HERITAGE REPORTING CORPORATION-- (202)628-4888 L_ _ _ _ __
i
/
83 1
lcriterie,.and I ee protective. action guides, thatLthe ACRS in d )-
'2 itsLwisdom'said these things-should be looked at in view-of 3:
_the safety goal and therefore consistent those are regulations L4
-end practices, and I would hate to see you. tic it to something 5
.that--I think you should tie it to the safety ; sal, and then 6
things like;those last three should be looked at for 7
consistency with the safety goal.
8 MR. HOUSTON:
All I am saying-is that others have, 9
as you well know, suggested these numbers.
As a matter of 10-fact, EPRI, in.the, in its executive summary of the ALWR,. the.
11 advanced light water reactor requirements documents-that they 12 are preparing, and you may-or may not be aware of this, have 13 suggested-a-definition of a large release which would beftled
.O
'i 14 to 25 rem as a dose..You know, this is not original with us, 15 and I am just, all I am saying here is that these are things, 11 these are doses which paople have suggested, and--
17 DR. RSMICK:
I am just trying to suggest the 18 philosophy.
19 MR. HOUSTON:
We are leaning toward this one at the 1
l 20 present time.
This one is simply a possibility, Commissioner 21 Burnhall has been concerned about relationship of a large 4
22 release to ENO criteria, and there is another possibilty that 23 you can sort of forgot about if you will, the quantitative l
24 health objectives, par ticularly the early f atality one, not
()
25 necessarily the late event cancer fatality, but express a HERITAGE REPORTING CORPORATION-- (202)628-4888
84 1
1 concern:for contamination in the environment.
A post-accident
()
2 contamination,.and in principle, there is no--you could define 3
large1 release it is tied tx> a. post-accident contamination I
4 concern 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s-later, seven' days later, whatever.
And there 5-are ENO criteria which it-could be related to, and it.could be 6
expressed either as integrated dose over.a long. period of 7.
time, 30 years,.or it could be expressed as a dose rate.
All 8
I'am saying is that could in principle.be used as a basis.
.I 9
am not, I don't think wc are going to do that.
10 DR. REM 1CK:
Would this be consistent with the 11 health effects criteria?
12 MR. HOUSTON:
Not necessarily, although you might, 13 you would look for an element of consistency with the late
.O 14 event cancer fatality A objective, yes.
15 (Slide) 16 DR. SIESS:
Has the Comuission given you any clue.as 17 to what they meant by large release?
18 MR. HOUSTON:
No.
19 MR. WARD:
Individual commissioners have given some 20 hints about what they would like'to see.
21 MR. HOUSTON:
Commissioner Burnhall expressed 22 interest in relationship to ENO criteria.
He did not 23 necessarily mean use ENO criteria as a definition.
He was 24 concerned about, legitimately about the relationship.
And
()
25 Commissioner Asenstein had, former Commissioner Asenstein HERITAGE REPORTING CORPORAT]ON-- (202)628-4888
t 85 1-stressed some: views the other' commissioners.to the best'of my
,]
j 2
. knowledge have not, and certainly it is.a collegial decision.
3; DR.LSEISS:
At one: time one of them. suggested PAG, 4
didn't they?
5 MR. HOUSTON:
PAG.
6 DR. LEWIS:
I think we sometimes define
?
'ourselves--out of good sense, I see no need to define the 8
large. release because'I will know when I see one.
It is--we
~
9-don't define emergencies, but every now and then there is an 10 emergency and the President declares an emergency and that 11 makes it.an emergency.
I don't see why we can't.do that with
~
22 releases.
' 13 DR. SIESS:
When you cesign containment, you have:
14-
-got to have some limit on what the release can be before it is 15 designed.
16 DR. LEWIS:
Yes.
17 DR. SIESS:
Might be you are only interested in 18 probability, not the magnitude of it, see.
I don't know 19 whether the probability of a thousand curie release is going 20 to be this much different than the probability of a 10,000 21 curie release or hundred thousand or a million.
22 DR. LEWIS:
Probably not.
23 MR. WARD:
That is absolute principle.
l k
24 DR. SIESS:
Entirely a question of release size is
()
12 5 unimportant, it is only the probability we are worried about.
l
\\
l
{
HERITAGE REPORTING CORPORATION-- (202)628-4888 j
--x______
k
0 LU 86 s
l' MR. HOUSTON:
ILmust say not too long ago'there were-(
l 2:
quite a number of people on-the staff who' tended toward 3
exactly'that same point of view, that maybe the best thing to 4
do is not try to ' define it, but recognize that we will know :it
(
['
.5 when we see it, but that doesn't seem, but I think that's the h
6
' argument against it, at least.we are making the effort t6 try i
>l 7
to detine it.
Whether it flies, whether it is, serves a l
8 useful purpose or not, I think remains to be seen.
9-What I have'tried to do on this graph is to show 10 something about the impact of various possible definitions of 11
.a large release, that would be tied to some reference dose 12 value.
Eo what we have here is a, something that shows 13 relationship on a risk of dose basis.
That is a frequency.of i
14 an individual receiving a dose of a given magnitude, showing j
15 also at the ten to the minus 6th the frequency of a large l
16 release, so that, for example, if one were to choose as a 17 reference dose an LD 50 value of 450 rem say, that this point l
l 18 represents the likelihood that an individual would receive, 19 that is at ten to the minus 6th level, it would represent if 20 the point had any significance, it would represent the 21 likelihood of an individual in the vicinity of plant receiving 22 dose of 450 rem.
Similarly, at the 25 rem level, which is the 23 Part 100 level or PAG level, 5 rem would be a point on that i
24 curve, so it would be the risk of dose, the risk to an
()
25 individual of receiving such a dose.
l HERITAGE REPORTING CORPORATION-- (202)628-4888
^i
- ti 87
-l1 ;
Now--
2-DR. SIESS:
Thost points presumably on the dotted-3 lines, right?
4 MR. HOUSTON:
I tfill'come to the dotted lines in a 1
5
' moment, i
i 6
DR. SIESS:
Aren't points or horizontal line, l
7 horizontal line.is reference line?
8 MR. HOUSTON:
horizontal reference line; the 9
verticalLlines are reference line, just where the two 10 intersect.
i 11 DR. SIBSS:
Points'not on any line right now?
12 MR. HOUSTON:
Correct.
But the whole point of the 13 discussion is leading toward'a definition of a large release, 14.
a quantitative definition of a large release.
.It makes a 15 difference in terms of making such a quantitative definition 16
. whether you are talking about what I will call a maximally 17 exposed individual or whether you are tal? ting about a, some 18 sort of a process which averages individuals in the vicinity 19 of a plant, the latter being a prescription in the safety goal 20 policy statement itself.
21 When you do, when you do this averaging process, you 22 will get a different level of risk to en individual taking 23 into account, for example, the wind direction frequency.
Then 24 the right-hand scale, what we show is the frequency of dose to
()
25 an average individual in the vicinity of a plant as it might HERITAGE REPORTING CORPORATION-- (202)628-4888
88-.
1-
'be--the absolute location of the numbers are not intended to
-( )
2 lua precise,.but it is considerable.
That is the risk to an 3-individual, an' average individual, for a release of ten to the 4
minus 6th frequency, where the risk to an average. individual 5
would be, a' risk of receiving a dose of 450 rem would be 6
considerable, less than ten to the minus 7th, maybe five times 7
ten to.the minus 8th, which is then an order of magnitude
.8 below the target of the quantitative health objectives.
9 Another way to look at it is that if the frequency 10 were. increased-that is, if one were to' consider a large 11 release associated with an overall mean frequency of say ten 12 to the minus 5th, one would have a point up somewhat higher.
13 And then in that event, the risk to an average individual O
14 might be somewhat closer to the five times ten to the'minus 15 7th target taking into account the averaging process.
16 DR. GIESS:
The average individual, one on the left, 17 is the downwind person?
{
18 MR. HOUSTON:
That is downwind.
19 DR. SIESS:
Unfortunate enough to be--I have got a 20 string of people around, and he is the one that is downwind, 21 so his probability--
l 22 MR. HOUSTON:
it is conditional probability.
23 DR. SIESS:
Conditional problem probability, okay.
24 But then isn't this the one we are concerned with?
()
25' MR. HOUSTON:
Well, I'think that's the issue.
HERITAGE REPORTING CORPORATION-- (202)628-4888
)
89 11 DR. SIESS:
Somebody downwind.
).
2 MR. WARD:
That is' pot what the policy says about.
3 who the average individual is.
4 MR. HOUSTON:
Wnat I am saying is that you can't use
'5 the quantitative health Lbjective early fatality tenth of a 6'
percent, and the definition of an average individual given in 7'
the safety goal policy statement, and come up with a 8
definition of a large release at a ten to the minus 6th
'9 frequency level which is consistent with those two previous 10 things. 'They are just inconsistent with one another on their
.11 faces.
12 One way you can make them consistent is to increase 13 the frequency of the large release.
That is not I think a 14 viable option,.because.as you increase that frequency, you get 15 closer and closer to what one might perceive as an acceptable-16 value for an objective for core melt frequency.
And I don't-17 believe it would be acceptable to the ACRS in light of their 18 letter to'have a core melt frequency and large release 19 frequency be at the same frequency level, so it is difficult.
20 What I am trying to show with these dotted, dashed 21 lines which have no intrinsic meaning, they are deliberately 22-sketched in there as four degree lines, which represent 23 constant risk lines, where the major risk is dose, and we show 24 up here a point whica corresponds to the maximally exposed
-( )
25 individual limited by Appendix I consideration for normal l
HERITAGE REPORTING CORPORATION-- (202)628-4888
_-__-____.________.m
90 1
operational releases. 'Considering~that limit,.and if, if the (f
2
- regulations could be structured in such a way that you could-3.
'actually view the whole spectrum of possible releases and.so
!4 forth and'could show that-what you are trying to achieve is a 5
constant risk-level, Forrest mentioned like 20 millirem per 6
year, there would be ten millirem per year tied to this 7
Appendix I. number, the probability of.one certainly, ten i
8 millirems, so ten millirem per year inverse of slope of that 9
line you see would come down.
Here in the ten to the minus 10 6th level, on this scale, corresponding to a rather large i
11 dose, ten to the 4th.
12 DR. SIESS:
What is the significance of that line?
13 An individual getting ten millirem a year with probability of O
14
.the one.is the same risk as an individual getting' ten to-the 3
'15 or something probability.
16 MR. HOUSTON:
Yes.
Take the view that risk is I
17' probability times consequences.
And if you take that, if.you 18 were to say your objective is to make that product a co:stant, 19 which would be a constant risk objective, so that you don't 20 want to be, for example, over-stringent with respect to large 21 consequence events, compared with small consequences.
22 DR. SIESS:
I don't see consequences.
Where are i
23 thethe consequences on your plot there?
24 MR. HOUSTON:
Pardon?
The consequences is dose.
1
()
25 This is dose in this graph.
HERITAGE REPORTING CORPORATION-- (202)628-4888
91 1:
DR. SIESS:
Okay, but that is, just meets a 2
constant.
1 3
MR. HOUSTON:
It is a risk dose.
]
- l 4
MR. WARD:
That's what he is doing.
5 MR. HOUSTON:
You can define consequences any way 6
you want to,=as health effects typically or' fatalities, but 7
don't have to have an exposure--you.can talk about exposure, 8 ~
risk of exposure,. which produces a does, dose to individual.
9 DR. SIESS:
The commissioners chose not to.
10 MR. HOUSTON:
It is not in the safety goal policy 11 statement itself.
That is correct.
Again, let me emphasize 12 that I am, what we are seeking is a basis for a definition of' 13 a large release.
Let me add one more thing.
This is not an L) 14 easy graph I think to understand.
In actual, in actual fact, 15' the Appendix I limits are not closely approached from normal 16 operational releases, and although I don't have currently a 17 figure that I can' assert is from data taken, clearly the real 18 exposure that occurs to people, measured in terms of doses to 19 maximally exposed individuals, as a result of normal 20-operational releases, is clearly considerably less than ten 21 millirems per year.
And if one were to put on here not a 22 limiting value in the regulations, but rather a realistic 23 value of what people actually get, it would move this point 24 still at the certainty level problem probability, if one moved
()
25 it to the left, perhaps some place in this range.
Now if one HERITAGE REPORTING CORPORATION-- (202)628-4888
92 1
were to draw the same constant risk line down here,.it is i
_()'
2 interesting, this., it would come'down to about this same 450 3
rem point, at the ten-to the minus 6th large release 4
frequency..
And'that's one of the reasons why we are leaning 5
toward a. proposed. basis for defining a large release tied to a
[
6 reference dose of 450 rem to an individual.
7 DR. SIESS:
The risk increases as you go which way?
8 MR. HOUSTON:
The risk is constant.
9' DR. SIESS:
On your several diagonal lines, the 10 risk, they don't all represent the same risk obviously.
11 MR. HOUSTON:
Any one diagonal line representing the
.12 same risk; represents a different risk.
13 DR. SIESS:
Which way does the risk' increase?
o 14 MR. HOUSTON:
Going in this direction, 15 DR. SIESS:
Are you sure?
Greatest risk from 16 Appendix I?
17 MR.. HOUSTON:
Now wait.
If one, for example, were 18 to adopt a definition of a large release referenced to a 19 protective action guide level of 5 rem, you can see if you 20 were to extend this line down, it asks if one were to 21 experience larger releases, what sort of risk of early 22 fatalities are you associated, are you, of exposures of doses 23 which could result in early fatalities, and you can see you 24 are down at e. frequency level down below ten to the minus 8th,
()
25-so it is a much lower risk as you move down this way.
4 HERITAGE REPORTING CORPORATION-- (202)628-4888
.a
r 93.
'l DR. SIESS:
You've got the plot showing 2y
. probabilities and doses,.and you' keep' talking about releases,
~3 but they aren't on there.
1 4
MR. HOUSTON:
Correct.
l
'5 DR. SIESS:
And you know something I don't?~
6 MR. HOUSTON:
Well, because--
7.
DR. SIESS:
You said each diagonal line represented i
8 a constant risk..
9 MR. HOUSTON:
Correct, risk of dose.
10 DR. SIESS:
And each diagonal line represents a 11 different risk of dose?
12 MR. HOUSTON:
That is correct.
13 DR. SIESS:
And you said that the one up highest was.
14 the greatest. risk of dose?
'15 MR. HOUSTON:
This is greater than any of these, 16 yes.
And you move in that direction, the risk increases.
17 DR. SIESS:
How do I interpret risk of dose then in 18 terms of risk of harm?
19 MR. HOUSTON:
Look at, at a dose level of 450 rem, 20 you are talking about the possibility of early fatalities.
21 And dose levels below about the threshold value, you have 22 around 200 rem, you are not talking about early fatalities 23 anymore.
You are talking about latent cancer fatalities.
24 DR.'SIESS:
You see, my risk of getting the LD 50 is l-( )-
25 closer to the risk of background than it is to the risk of HERITAGE REPORTING CORPORATION-- (202)628-4888
94 1
PHE.
This'stwhat is-bothering me.
(
2' MR.' HOUSTON:
Well, look at it the other way.
If-3 you extrapolate this line up in this< direction, you would say, y
4 if you attempted.to set the risk from severe accidents at.a 5'
level'which is pegged to this point, and we are thinking in 6
terms'of that not representing.any risk aversion which is 7
another-thing which I think we are saying that we are trying 8
to get at, and extend that line up here in order for that to 9
' avoid havir.g that represent a strong risk aversion principle, 10 you would be talking about real exposures from normal 11
. operational releases which are down in the microrem level.
12 DR. SIESS:
Okay.
Go ahead.
13 MR..
HOUSTON:
So it is--
0 14 MP, WARD:
Let's see, Wayne and Chet, the Chairman 15 wants us to end at noon, even though we started late.
l l
16 CHAIRMAN KERR:
We started three minutes late.
17 MR. WARD:
I thought it was fifteen minutes.
18 DR. REMICK:
I can't resist one quick point, and 19 that is that also tells me that maybe Appendix I should be 20 reviced in light, and consider to be revised in light of the 21 safety goals.
l 22 MR. HOUSTON:
Maybe.
I don't think so, because I 23 think what we are going at is showing, is that--many people 24 will have objection to this--that we are dealing with a more
()
25 or less constant risk, that is, we are not overly-stringent or HERITAG2 REPORTING CORPORATION-~ (202)628-4888 Y
95 1
overly-risk averse with respect to our dealing with severe x
(
2
. accident consequences versus normal releases.
~
N
-.3 Now I believe -- I can't provide a' citation.
I L
4.
think the Commission is already on record of not being l'
5 sympathetic with the idea of risk aversion.
I am not certain-6 of that,'but I think this is correct.
7 DR.'STEINDLER:
Do.you believe the previous draft 18 represents' a continuum of risk., or do you draw distinction 9
between-early fatalities, and early harm?
10 CHAIRMAN KERR:
You are not using the mike.
We are 11 missing your statements which I am sure are profound.
12 MR. HOUSTON:
He asked a question about 13 distinguishing between the risk of early fatalities and early 14 harm, I believe early injury.
And we are not taking 15
' cognizance of early injury at this point.
16 DR. STEINDLER:
So.you believe then that this is a, 17 this series of risks lines.you have is a fairly smooth, 18 continuum?
19 MR. HOUSTON:
Well, I believe that realistically 20 there are, there is a continuum of possibility of releases 21 from very small to rather large.
22 DR. STEINDLER:
Even though in some cases one might 23 generally agree that there will be no early fatalities whereas 24 in other cases you might agree that there will be certainly
()
25 early fatalities?
HERITAGE REPORTING CORPORATION-- (202)628-4888
96 1
.MR.
HOUSTON:
Yes.
We.have had with the Chernobyl
()
2 experience, for example, there was a large release.
It did 3
not result in the'off-site early fatalities.
4 CHAIRMAN KERR:
Wouldn't want-to say you think risk 5
is really a straight line?
6 MR. HOUSTON:
We don't know what it is.
That's a 7:
hypothetical line.
8.
CHAIRMAN KERR:
It is not even a line except you 9
draw it between two points.
10 MR. HOUSTON:
You can draw it.
Its significance, it 11.
has no specific significance.
That is correct.
The only 12 reason for having it on there is to associate it with the 13
' constant risk concept versus a risk aversion concept and tying O
14 the occupation, the normal operational situation with the 15 severe accident end of the spectrum of releases.
That's why 16 it is dashed and not a solid line, the line I am showing on 17-this vugraph.
18 MR. WARD:
We better hold any more questions.
Just 19.
let Wayne go through the story.
j 20 MR. HOUSTON:
Just be a couple of minutes while I am 21' showing in this vugraph.
Here are-the results of some initial 22 calculations that we have done in terms of using a reference 23 dose of 450 rem, LD 50 value to define a large release as a 24 release.
-(:)-
.25-The release that we define here is specified in HERITAGE REPORTING CORPORATION-- (202)628-4888
,f 97 L
1
-terms of curies of one particular radionuclides, which happens i
(}
2-to be iodine 131'in this case.
The technique or the 3
methodology for doing'this has been discussed _with the.
'4 subcommittee.
I-won't take the time to describe what we did, 5
bu't it is conceptually very simple, and has some' unique.
6 advantages I-think.
7-In any event, if we did this, that is, used the 450 8
rem.as the reference dose to establish a basis.for providing a 9
definition to a threshold value of large release, we would get 10 somethingElike a number that is in the range of a hundred 11 millirem' curies of iodine 131, to say it very simply.
12 Now to establish that basis, one does need to make.
13 certain assumptions to relate a dose to a curie release..You
.g U
14 need the dose conversion factors which are not assumptions.
15 They are particular characteristics of the nuclides 16
'themselves, but you do need to make assumption regarding where 17 that dose might occur in the vicinity of a plant, such as a 18 half mile, one mile, mile.and a half.
Since we have picked a 19
-450 rem dose, we--our thought process in our calculational 20 process, it is reflected here.
We put an individual about 21 halfway between the plant boundary and one mile from the plant 22-boundary.
That's what this result shows.
I d
23 Secondly, you have to make assumptions about the 24 weather, the meteorology,-and what we have done here is
()_
25 calculate a release that might occur and could conceptually be HERITAGE REPORTING CORPORATION-- (202)628-4888
98 1
based upon an average meteorological circumstance.
)
2 Specifically in this case, class D wind speed of'six-3
.ciles.per' hour.
Other choices are possible.
This has to be 4;
part of the basis in' order.to tie a reference dose to'a curie 5
release.
Other one could.have made assumptions about low 6
probability weather releases, and you will get. lower values of 7
a release quantity if you do that.
8 In any event, the straight line reall'y represents' 9
nothing more than the manner in which one defines an 10' equivalent amount of radiciodine 131, relating a hypothetical
.11 release of that amount of iodine, to a dose that it would 12 produce with average meteorology one mile downwind from the 13 source.
That's-what this line represents.
It takes into 14 consideration exposure-from both the, a plume passage; which 15-of course is finite in time, and takes--and the major 16 contribution for this kind of release is from the ground 17 shine, from that which the activity that falls out of the 1
18 plume and stays on the ground and produces a ground shine to 19 an individual, but in that event, in order to'make the 20 probability tractible, you have to make some assumption to how 21 long an individual is exposed to that ground shining.
This 22 particular plot shows for an eight-hour period and then--
23 CHAIRMAN KERR:
I thought you said earlier half t
j i
b 24 mile.
()
25 MR. HOUSTON:
Half mile from the plant boundary or l
HERITAGE REPORTING CORPORATION-- (202)628-4888
99 1
roughly a mile from the reactor.
-( )_
2, CHAIRMAN KERR:
Okay.
Thank you.
3 MR. HOUSTON:
We do calculations based on distance 4
from the reactor, so it is,.it is a source.
i 5'
Also shown on this plot is how that definition would 6
compare'with some of releases that have appeared-in the
. 7.
literature.
For example, 1400,,Surry 1, the--no.
Excuse me.
l 8
BWR'1,'and the PWR 2, are 1400 releases; Surry 1, Peach Bottom 9
13, Peach Bottom'19, and Surry 8, are all related to the l
I 10-containment failure, bins releases associated with-containment-11 failure bins and draft NUREG 150 all except for Surry 8.
They 12 are all very'much larger releases than our potential 13 definition.of what a large release is as threshold value.
Now O
14 if the Chernobyl release were put on this graph--that is not 15 easy to do--it would fall down in this general range.
I 16 DR. SIESS:
That small?
'17 MR. HOUSTON:
We don't have--excuse me.
The 18
-information that we have from the Soviets on it identifies 19 like I think it is 18 or 19 different radiont';; d ies in the l
20 release-and they indicate that that's, they are probably good i
21 plus or minus 50 percent.
Even if you double those, it is
{
22 still going to fall down in this range.
23 DR. SIESS:
How much was in the containment field 24 by?
().
25 MR. HOUSTON:
In the containment?
I really can't l
l HERITAGE REPORTING CORPORATION-- (202)628-4888 i
100 il tell you.
I Enow veryllong'after that, the reactor, something I
2 like'wasn't it 50,000 curies of crypton or xenon?-
3 DR. SIESS:
Iithink there were a few megacuries-
]
4 inside containment.
.g 5
MR. HOUSTON:
In the atmosphere, in the containment i
6.
atmosphere.
7, DR..SIESS:
Being released, yes.
8 CHAIRMAh KERR:
The. atmosphere, it was ab'out ten 9
curies of iodine.
I don't know how much was in the water.
10 DR. SEISS:
I am talking about. released.
11 MR. HOUSTON:
I don't know the answer to your 12 question.
11 3 DR. SIESS:
There were a few million curies of' O
14' activity.
15 CHAIRMAN KERR:
Crypton, xenon.
16 DR. SEISS:
Some of it was iodine.
17 MR. WARD:
Just why don't'you roll ahead?
We can.
18 discuss this at lunch.
19 DR. REMICK:
I am not sure, I know what I would 20 conclude from that slide, but I am not sure I can tell 21 anybody.
Could you tell me what I conclude from that slide?
22 MR. HOUSTON:
The previous one?
23 DR. REMICK:
The curve.
-l r
i 24 MR. HOUSTON:
All we are showing here is the result
()
25 of preliminary calculations of staff effort to define release HERITAGE REPORTING CORPORATION-- (202)628-4888
101.
1 as a release,'specifically in terms equivalent number of
(}
2 curies of a particular radionuclides, in this case iodine 131, 3
but tying.that definition to a specification of a reference 4
dose of 450 rem, that is, it is a release which is big enough 5
to produce an early fatality in the vicinity of the plant, and 6
the conclusion is that, the inferencoethat one can draw from 7
that is that that's, our proposed threshold definition is such-8 that aiost of'the releases that one will calculate in PRAs are 9
going to'be large releases.
No question about it.
They are
'10 going to be larger.
11 DR. SIESS:
What you are saying is that any. accident 12 sequence in which the containment has zero effectiveness will 13 lead to a large release?
14 MR. HOUSTON:
If'you have, if you have core melt, 15 core melt pressure, loss of pressure, vessel integrity, yes.
16 DR. SIESS:
Containment doesn't work.
17 MR. HOUSTON:
Basically., yes.
18 DR. SIESS:
Well, I am afraid it is not much 19 help--if somebody wants to vent that containment and through 20 imperfect filters and only put out one one hundredth of 21 activity that is in it, that would be a large release.
I am 22 afraid when I look at this, and divide by a hundred, I still 23 get some pretty good sized numbers that says that will kill 24 somebody.
This is very simple.
This says take any PRA we
()
25 have got, with the core melt, and assume that containment HERITAGE REPORTING CORPORATION-- (202)628-4888
102 1
fails, it is a large release, by any standard.
()
2 MR. HOUSTON:
There was one, the Surry 8, category 3
war not quite at that threshold.
4 MR. EBERSOLE:
What if there is substantial core 5
damage but not melt, containment failure?
Like the valves 6
were open?
7 MR. HOUSTON:
All I will sa is analysis made, if 8
the analysis shows that there is release, and that is 9
calculated, one can make the comparison, and the question is 10 this a large release, does it include the threshold value that 11 we propose?
12 MR. EBERSOLE:
Could be a large release with 13 moderate core damage.
O 14 MR. HOUSTON:
It is possible, yes.
15 DR. SIESS:
It was pointed out earlier the reason 16 for this large release criteria and safety goal was to ensure l
17 that we have a containment effectiveness criteria.
What it 18 turns out from what I hear from you, is that you might just as 19 well go to the safe ten to the minus one on containment 20 failure, and not worry about large releases because any 21 containment failure is large release.
22 MR. WARD:
The ten to the minus 6th was to assure we 23 have containment.
I think this was a wrong statement.
I 24 think this is incorrect.
()
25 MR. HOUSTOH:
We are focusing here just on the HERITAGE REPORTING CORPORATION-~ (202)628-4888
103 1
definition of a lar'e release threshold.
The otherscompanion j()
2 part-of the. release guideline'is the ten.to the minus 6th
~
3
.overall mean frequency number, and what I am, and what one 4
.would do would'be calculations of the sort that were 5
represented on that graph--first of all, to determine the 6'
releases that are identified in PRA whether.or not they are 7
large releases or not, and if you sort those out, most of.t' hem-8 probably would be.
Some may not be.
And of those that are, 9
however, now you ask the question what is the overall mean-10
. frequency of that family of releases, of accident scenario?
11 DR. SIESS:
How would I go about designing a plant 12-to meet that criteria?
13 MR. HOUSTON:
You would have to do it in conjunction 14 with doing a PRA.
15 DR. SIESS:
The PRA tells me that if containment 16 fails, or leaks substantially, I have got a large release.
17 Now-I go backtand design for reliability on the containment, 18 not on the large release.
19 HR. HOUSTON:
It is through this, this is intimate;_
20 related with doing a PRA.
And but again, I think we go back 21 to your question, the thrust of the ACRS letter, and the 22 thrust of what we would be trying to do in a plant of this 23 nature, is to, from this kind of information, raise the 24 question are the regulations that we have and the regulatory
()
25 processes that we have in place considered adequate with HERITAGE REPORTING CORPORATION-- (202)628-4888 L______________._-_
r-104,
d l'
respect to the containment function?
And this is.a criterion
()
2 that one.would-use to answer that, answer that question.
It 3
might rasult'in different kinds of general design criteria.
o l
l 4
CHAIRMAN KERR:- You are cutting into Sis' lunch 5
hour.
I
'6 MR. HOUSTON:
I am willing to stop a: y time.
7_
HMR. WARD:
But Chet isn't!
8 DR. SIESS:
There has been a lot of emphasis placed l
l 9
on'the defining what a.large release is and magnitude.
I' l~
1'O think thefreal problem is defining the reliability of the 11 probability-of large re2 ease because any release is going to 12 be large and I think we have'put our money in the wrong place.
13 CHAIRMAN KERR:
Will you stipulate that?
We 14 stipulate that Chet's statement is true.
Are you finished?
15 Have you done justice to what--
16 MR. HOUSTON:
Yes.
EI will be glad to stop here if 17 you wish.
I was going to talk a little bit about some 18 applications of the type.
They are in your--
W l
19 CHAIRMAN KERR:
Since we are going to hear from you j
20 subsequently. I think we will stop at this point.
Are there 21 any comments or questions before we break for lunch?
We are 22 now broken for lunch without a gavel, and Mr. Lewis wants to 23 say a word.
1 24 (Whereupon, at approximately Noon, the meeting was
()
25 recersed, to reconvene at 1:00 p.m.
the same day.)
HERITAGE REPORTING CORPORATION-- (202)628-4888
m s
i 1-REPORTER'S CERTIFICATE
-c 2
}
4 DOCKET. NUMBER:
.4 CASE TITLE:
Advisory Committee on Reactor Safety 5
5 HEARING DATE: December 3, 1987 6
LOCATION:
Washington, D.C.
i 7
I hereby. certify that the proceedings and evidence
.g are contained-' fully and accurately on the tapes and notes 9
reported by me at the hearing in the above case before the I-10 I
i, 11 12 OM Date:
December 3, 1987 O= '/
14 l
15
.l
- 6 I
16 u v -J.
Jq Official Reporter
/
7 A
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, s:
O NRC STAFF PRESENTATION TO THE ACRS
SUBJECT:
PEACH BOTTOM RESTART REVIEW DATE:
DECEMBER 3, 1987 l
PRESENTER:
WILLIAM F..KANE O
PRESENTER'S TITLE / BRANCH /DIV:
DIRECTOR, DIVISION OF REACTOR PROJECTS REGION I PRESENTER'S TEL. NO.:
488-1229 O
,~
,\\k/
NRC STAFF ACTIVITIES FOLLOWING SHUTDOWN ORDER APRIL 10 BRIEFED COMMISSION AND ACRS ON STATUS OF PEACH BOTTOM APRIL 14 BRIEFED STATE OF MARYLAND ON STATUS OF PEACH BOTTOM MAY 5 MEETING WITH LICENSEE ON STATUS OF THEIR INVESTIGATION MAY 6 BRIEFED COMMONWEALTH OF PENNSYLVANIA ON STATUS OF PEACH BOTTOM MAY 15 MEETINGS WITH LICENSEE ON STATUS OF THEIR INVESTIGATION JUNE 17 JULY 15 JUNE 23 BRIEFED HARFORD COUNTY ON STATUS OF PEACH BOTTOM JULY 24 -
ISSUED BIWEEKLY PUBLIC STATUS REPORTS ON PEACH BOTTOM PRESENT SEPTEMBER 24 MEETING TO RECEIVE PUBLIC COMMENTS ON LICENSEE PLAN IN HARFORD O
COUNTY, MARYLAND AND YORK COUNTY, PENNSYLVANIA OCTOBER 15 RECEIVED WRITTEN COMMENTS FROM STATE OF MARYLAND ON INITIAL PECO PLAN OCTOBER 28 RECEIVED WRITTEN COMMENTS FROM COMMONWEALTH OF PENNSYLVANIA ON INITIAL PECO PLAN NOVEMBER 4 MEETING TO RECEIVE PUBLIC COMMENTS ON LICENSEE PLAN IN LANCASTER COUNTY, PENNSYLVANIA O
I
~ p V'
PEACH BOTTOM RESTART ASSESSMENT PANEL ACTIVITIES AUGUST 7
.PECO SUBMITTED COMMITMENT TO EXCELLENCE PLAN AUGUST 11 PANEL ESTABLISHED TO C0 ORDINATE STAFF REVIEW 0F LICENSEE PLAN TO SUPPORT DEVELOPMENT OF SER AND RESTART DECISION AUGUST 13 INITIAL PANEL MEETING AUGUST 17 -
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(~%
1.
BEFORE RESTART
\\#
2.
DEVELOPED BEFORE RESTART, COMPLETED AFTER 3.
NEEDED FOR EXCELLENCE POST RESTART SEPTEMBER 15 BRIEFED COMMISSION OF STATUS OF PEACH BOTTOM SEPTEMBER 28 PECO SUBMITTED RESPONSE TO STAFF REQUESTS OCTOBER 8 DEFERRED REVIEW 0F PECO PLAN OCTOBER 9 PECO ANNOUNCED CORPORATE REORGANIZATION NOVEMBER 20 MET WITH LICENSEE ON REORGANIZATION AND PLAN REVISIONS NOVEMBER 25 PECO SUBMITTED PORTION OF REVISED CORPORATE ISSUES PLAN I
(S) l l
I l
'a PEACH BOTTOM RESTART REVIEW PANEL CHAIRMAN WILLIAM KANE, DIRECTOR, DIVISION OF REACTOR PROJECTS, REGION I L
VICE CHAIRMAN
- BRUCE B0GER, ASSISTANT DIRECTOR, REGION I REACTORS, NRR MEMBERS WILLIAM REGAN, CHIEF, HUMAN FACTORS ASSESSMENT BRANCH, NRR EDWARD WENZINGER, CHIEF, PROJECTS BRANCH 2, REGION I ROBERT GALLO, CHIEF, OPERATIONS BRANCH, REGION I RONALD BELLAMY, CHIEF, RADIOLOGICAL PROTECTION AND EMERGENCY PREPARE 0 NESS BRANCH, REGION I jJAMES LINVILLE, CHIEF, PROJECTS SECTION 2A, REGION I
% Suus I
O l
1 v
PLANNED RESTART REVIEW ACTIVITIES 1
INVOLVEMENT WITH STATES OBTAIN WRITTEN COMMENTS FROM STATE OF MARYLAND AND COMMONWEALTH l
OF PENNSYLVANIA ON REVISED PECO PLAN STAFF REVIEW AND INSPECTION ACTIVITIES l
ASSESS LICENSED OPERATOR ATTITUDE AND PERFORMANCE IMPROVEMENT PROGRAM CONDUCT EVALUATION OF SHIFT CREWS AT LIMERICK SIMULATOR RECEIVE PECO SITE ISSUES PLAN REVISION (EST 1/15/88)
COMPLETE ACTION PLAN REVIEW PROCESS VERIFY COMPLETION OF CORRECTIVE ACTIONS COMPLETE DI INVESTIGATION ISSUE PANEL EVALUATION REPORT I
SENIOR NRC STAFF MANAGEMENT REVIEW BRIEF COMMISSION ON READINESS FOR RESTART O
i MAJOR ISSUES LICENSEE MUST PROVIDE COMPREHENSIVE RESPONSE TO SHUTDOWN ORDER i
ABILITY OF LICENSEE CORPORATE AND SITE MANAGEMENT TO IDENTIFY.
AND CORRECT PROBLEMS OPERATOR ATTITUDE COMMAND AND CONTROL OF SHIFT OPERATIONS LICENSEE RESPONSE IDENTIFY ROOT CAUSES OF PROBLEMS TAKE CORRECTIVE ACTIONS WHICH WILL FULLY ADDRESS EACH ROOT CAUSE O
O
- o CRITERIA FOR PEACH BOTTOM RESTART A DEFENSE IN-DEPTH APPROACH TO PREVENTING RECURRENCE OF THE PROBLEMS MUST INCLUDE AS A MINIMUM STRENGTHENED INDEPENDENT CORPORATE OVERSIGHT OF OPERATING ACTIVITIES STRENGTHENED LINE MANAGEMENT OF OPERATING ACTIVITIES IMPROVED OPERATOR ATTITUDES AND PERFORMANCE THROUGH TRAINING AND DISCIPLINARY ACTION AS APPROPRIATE NRC ACTION REQUIRED FOR RESTART REVIEW AND APPROVE LICENSEE PLAN VERIFY IMPLEMENTATION OF LICENSEE ACTION ASSESS EFFECTIVENESS OF LICENSEE ACTION l)
v I
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