483rd Meeting - June 8, 2001
Official Transcript of Proceedings
NUCLEAR REGULATORY COMMISSION
Title: Advisory Committee on Reactor Safeguards
[483RD ACRS Meeting]
Docket Number: (not applicable)
Location: Rockville, Maryland
Date: Friday, June 8, 2001
Work Order No.: NRC-251 Pages 260-310
NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers
1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005
(202) 234-4433. UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
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ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS)
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JUNE 8, 2001
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The Committee met at the Nuclear
Regulatory Commission, Two White Flint North, Room
T2B3, 11545 Rockville Pike, at 9:00 a.m., Mario V.
Bonaca, Vice Chairman, presiding.
COMMITTEE MEMBERS PRESENT:
MARIO V. BONACA
F. PETER FORD
THOMAS S. KRESS
GRAHAM M. LEITCH
DANA A. POWERS
WILLIAM J. SHACK
JOHN D. SIEBER
ROBERT. E. UHRIG
GRAHAM B. WALLIS
GRETA J. DICUS
ACRS STAFF PRESENT:
CAROL A. HARRIS
JOHN T. LARKINS
HOWARD J. LARSON
JAMES E. LYONS
I N D E X
Agenda Item Page
Opening Remarks, Vice Chairman Bonaca. . . . . . 263
Opening Statement, Commissioner Dicus. . . . . . 263
Discussion . . . . . . . . . . . . . . . . . . . 264
Adjournment. . . . . . . . . . . . . . . . . . . 309
VICE CHAIRMAN BONACA: It is a great
pleasure to welcome Commissioner Dicus who is here
today to discuss some items of mutual interest. We
understand that first you have some remarks to make
and then after that we will open the floor for
discussion. So without much ado, I will turn the
meeting to you.
MEMBER KRESS: George wanted me to remind
you that he's really sorry he couldn't be here.
COMMISSIONER DICUS: I spoke to him
yesterday. His daughter is graduating today.
MEMBER KRESS: That takes priority over
COMMISSIONER DICUS: That absolutely takes
priority over everything.
I really don't have any prepared opening
comments other than I do very much appreciate the
opportunity to come down and discuss whatever items
that you have on your mind that you first -- well,
MEMBER POWERS: Hi.
COMMISSIONER DICUS: I didn't think you
would make it.
MEMBER POWERS: We were in discussing
plans to handle the steam generator tube probe problem
in the future and we snuck in a quick briefing here.
COMMISSIONER DICUS: Very good. You had
prepared and I had met with Dr. Apostalakis earlier
and did you have something in particular in mind you
wanted to talk about, what was the particular interest
that the Advisory Committee had and he brought in an
outline of some topics to go over, so those are the
topics that I think we might be interested in
If you had a particular priority on those,
I sort of have my own priority, but obviously it would
start out with the health physics issues that you
identified particularly, any needs in research with
regard to actinides, toxicity, metabolism in the body
and then what are we ever going to do with the LNT.
I can start with those items and then we can go on to
some of the technical issues.
MEMBER POWERS: Yes, I think we've got
some specific -- we need some specific guidance in
connection with the actinides and the toxicity issue
because we have this MOX facilities staring us in the
face here and some of that stuff takes some lead time
COMMISSIONER DICUS: Right. Let me start
with that. With regard to plutonium oxide and uranium
oxide issues, there currently is no research that I'm
aware of at least being done. Quite a bit of research
has been done in the past. The only thing that is
on-going is some epidemiological work with the Joint
Coordinating Committee of the Radiation Effects
Research, the JCCRER work that I'm involved with in
the bilateral with Russia. The Russian workers did
have significant uptakes of plutonium in the early
days of their activities there and we are looking at
it from an epidemiological point of view.
The Russians have identified what they
characterize as plutonium pneumoschlerosis which is an
interstitial lung disease that leads to lung
deficiency in capacity. The x-rays show basically
fibroschlerotic lesions in the lung of the Russian
It doesn't take very much. Basically, the
uptakes are almost in micro curie quantities, so
you're not talking about a great deal of uptake, but
the doses range anywhere from 500 to 3700 rem dose
equivalent for these workers.
This contrasts with the American workers
in the Manhattan Project that had uptakes, those that
did have uptakes, had uptakes in the nanocurie range,
very, very small uptakes and the doses, effective dose
equivalents were somewhere between 10 and 720 rem and
we have not identified this issue of plutonium
pneumoschlerosis that the Russians have identified,
but we're talking about a lot higher doses in the
The work that was done with beagles you're
probably aware some years ago a tremendous amount of
work was done with beagles and at doses of around 800
rad. They did identify what they called radiation
pneumonitis in the beagles, but again, we haven't
identified that in any of our workers, but again, we
have relatively low doses of the workers in the
Our annual limits of intake of plutonium
oxide and uranium oxide is taken from ICRP document
number 48 and the modeling from ICRP document number
30 and we use those documents. Those numbers continue
to stand. I don't know, to my knowledge, the ICRP has
not determined that they need to go back and re-look
at these numbers. Not that it might happen at some
point in the future, but it has not happened yet for
the plutonium uranium.
I have in front of me a memorandum that's
dated October 6, 2000, an NRC memorandum. It is from
Eric Leeds who is the Acting Chief of the Special
Projects Branch, the Division of Fuel Cycle Safety and
Safeguards in NMSS and Cheryl Trottier who is the
Chief of Radiation Projection, Environmental Risk and
Waste Management in risk analysis and applications, a
branch of research and the conclusion from this
memorandum is that the NMSS staff concludes that the
annual limits of intakes published by the NRC in Part
20 and other available information on plutonium oxide
and plutonium oxide, uranium oxide radiobiology would
yield conservative dose estimates were they to be used
to prepare license application for MOX fuel
fabrication using weapons grade plutonium.
For this reason, NMSS staff does not
recommend that the proposed research proposed -- and
there was a proposal for research -- necessary for NRC
to reach a safety conclusion on the construction and
operation of a MOX fuel fabrication facility. So the
staff has concluded research is not necessary.
MEMBER POWERS: The contention that's come
to that particular memorandum, it seems to me, to
revolve around the issue of in vivo dissolution of
this plutonium uranium dioxide mechanical mixture and
whether that, in fact, you get a conservative estimate
from those because the biological uptake might be
different and different not only for the plutonium,
but because of the americium decay in the plutonium
and what not.
And in my looking at it, it really came
down to how confident this Commission thinks we ought
to be when we go about attacking this, the challenge
of licensing this MOX facility.
What we have basically is a plausibility
argument in the memorandum that we're going to be
conservative and not a proof and so it's one of these
subjective decisions. I have to admit I haven't
looked at the length and the breadth of it, but it
really basically is how confident do we want to be
that we are, in fact, reaching a conservative decision
here because of the biological uptake problem. It
looks, I mean it seems pretty plausible that you would
get a different biological uptake with a mechanical
mixture than what we have based on the sought
COMMISSIONER DICUS: Now when you say
uptake, well, let's back up. The memorandum also, as
well as other information that I have read, discusses
the issue of transportability. Once the radionuclide
is in the body, all the research that we know can to
take on what we have in front of us states, indicates
that the uptake, the organs of concern, obviously the
lung through inhalation, that's going to be the
pathway and the thoracic nodes.
The data so far indicate the
transportability irregardless of form to other organs
in the body is essentially nil.
MEMBER POWERS: Nil.
COMMISSIONER DICUS: That it does stay in
the lung and the thoracic nodes and there is where the
dose is going to be received. Transportability other
ways whatever class is used and they looked at Class
W transport and Class Y model parameters and still the
transportability doesn't -- so I think that's
MEMBER POWERS: If you're not going to get
any transportability, then I don't care whether --
what the dissolution rates and what not are because
COMMISSIONER DICUS: Right. Any other
questions? I think we always have to keep our minds
open and be sure some new piece of data -- we're
always finding new things, that we have the
possibility that at some time it would have to be
relooked at, but I'm comfortable because I really
believe the transportability, the studies on
MEMBER KRESS: Aren't these
transportability rates and the solubility though --
COMMISSIONER DICUS: Say again?
MEMBER KRESS: Aren't they dependent on
each other? They're not independent variables?
COMMISSIONER DICUS: Yes.
MEMBER KRESS: So it's hard for me to
separate the two.
MEMBER POWERS: I think it's dribbling
down to a plausibility argument that you've got to
inhale first. And then it's got to dissolve from the
sites that it deposits and go into blood stream or
something like that in order to move on.
MEMBER KRESS: Which means it has to
transport across the blood vessels.
MEMBER POWERS: Yes.
MEMBER KRESS: But that's the function of
solubility, to me.
MEMBER POWERS: Right.
MEMBER KRESS: Once it's soluble, so I
have trouble separating the transportability out from
the solubility. If it's not soluble, it's not going
to be transportable. But if it is highly soluble, it
ought to be transportable.
COMMISSIONER DICUS: I think it's more --
I think the solubility is not that good.
MEMBER POWERS: It's low solubility.
MEMBER KRESS: I would think it's very
bad, yeah, and that's the saving --
MEMBER POWERS: The americium is going to
be a little more soluble than the plutonium which is
a little more soluble than the uranium. The uranium
is bottom of the list here.
MEMBER KRESS: It seems to me like if we
know that, then their conclusion that you're
conservative and don't need any more research is
MEMBER UHRIG: Are these studies
independent of the isotope involved, whether it's 241
COMMISSIONER DICUS: I don't know the
answer to that question.
MEMBER POWERS: Most of the --
COMMISSIONER DICUS: They did look at the
americium, etcetera. They looked at others, but what
isotope of plutonium, it was 239 to my knowledge --
MEMBER UHRIG: 239 would probably be the
COMMISSIONER DICUS: Right.
MEMBER UHRIG: But when you get into
things like isotopic generators you get into 238 which
at least my impression is that it's more of a problem.
COMMISSIONER DICUS: I don't know the
answer to that.
MEMBER POWERS: It has a much more rapid
decay rate. For the facility itself, the facility of
interest here, it's only the 239 and it depends on
what -- where the database was generated. In the
United States, most of our data comes from the 239.
That's a small amount of the data. The European data
actually comes from the 240, 241s.
MEMBER SHACK: You were quoting data from
the Manhattan Project, but we must have vast amounts
of data on people working with plutonium since those
days in terms of the weapons -- are the limits --
COMMISSIONER DICUS: I don't have that
MEMBER SHACK: Does DOE have that data?
COMMISSIONER DICUS: I hope they do. I
have my fingers crossed. I could find out that for
MEMBER SHACK: I just wondered how these
limits, whether they were consistent with --
COMMISSIONER DICUS: Why I used the
Manhattan Project is I was relating it to the Russian
workers shortly after that. That's why I use the
Manhattan data. Modern data certainly exists.
VICE CHAIRMAN BONACA: Any other questions
on this? If not, I would like to start with one issue
that clearly is interesting to us which is the impact
of national energy policy on the Agency and the
country. Last Monday and Tuesday we had a workshop,
as you know, that was reviewing new reactor designs
and clearly, there is a stirring of interest on the
part of this committee and the whole community
regarding this issue and the ties to this on national
energy policy. I wonder if you could give us your
COMMISSIONER DICUS: Sure. I'd be happy
to. Of course, the new energy policy, we're still in
the process of reviewing of what the real impact might
be on this Agency, but the obvious impact is new
energy policy underscores the need for additional
power plants to provide additional energy and that
nuclear will remain a viable part of the energy mix.
Given that information, coming out of the
energy policy and if that policy does finally see the
light of day for Congress and becomes the national
policy, I do anticipate that the Agency will be
impacted through additional renewal applications, by
possibly most of the plants, not all the plants,
coming in for renewal applications, hopefully not all
at one time. I hope they will pace themselves
But we do anticipate a strong potential
that we will get an application or a new reactor
perhaps in the next two or three years. Whether it's
going to be the pebble bed or not, who knows? That is
the decision for industry to make and decide what kind
of reactor, decide if they want to build a new reactor
and then what kind of reactor they want to build.
The challenge to the Agency, the
challenges to the Agency is if it's a pebble bed to
have the technical expertise to be able to do it and
be in front of the curve on that and I have a
confidence at this point that the staff is acutely
aware of this and I know staff has been to South
Africa following the activities there, getting up to
speed on the pebble bed.
There's going to be a challenge to the
Commission. We're going to have to address some very
interesting policy issues of the pebble bed reactor.
For example, containment. What are we going to
consider with regard to containment? I mean it
doesn't have one. It's a new breed of reactor.
Defense-in-depth is another issue that we're going to
have to come up and look at our policies on
defense-in-depth. Emergency planning becomes a policy
issue that we're going to have to look at because the
industry came in to talk to us about the pebble bed
and indicated, for example, a 2 mile EPZ, that is the
10 mile EPZ we are accustomed to. That's just off the
top of my head. Those are three major policy issues
for the Commission to deal with, so we have policy.
We have issues.
MEMBER KRESS: They outline several other
policy issues at our workshop. For example, how do
you deal with multiple modules on a given site. Is
that treated as one facility or several? And then
they had the whole list of financial kind of things
that I don't know whether it's in the purview of NRC
or not, things like the Price Anderson Act and --
COMMISSIONER DICUS: Yes. How much Price
Anderson money do you put aside for how many modules
MEMBER KRESS: But then there's the
question of the fees also, how do you --
MEMBER SHACK: That particular question,
is that an NRC question or is that a congressional
MEMBER KRESS: I think that's
congressional, the Price Anderson.
COMMISSIONER DICUS: The Price Anderson is
congressional, but the fees --
MEMBER KRESS: The fees I think you can
COMMISSIONER DICUS: Fees, we can deal
with, but the Price Anderson consideration would be
I think one thing, in some ways, I think
the Commission is a little bit disappointed that talk
isn't about coming in with one of the designs that
we've already approved. We get all this work and
these things are sitting on the shelf collecting dust
and come on, people, it's not one of those off the
shelf. All that hard work we did, was it worth the
time and effort that we put into it.
MEMBER KRESS: That occurred to us.
COMMISSIONER DICUS: It could be very much
an application, an interest is growing in the AP1000
nuclear plant and so --
MEMBER POWERS: We haven't certified that
one yet. Look at the System 80.
COMMISSIONER DICUS: We haven't certified
the AP1000. At any rate, it creates for us some very
interesting things. One of them is the resource
impact. If we got one or more applications and that's
one of the things on your list, can we deal with more
than one application and it's a resource call, with
all the other things that are on our plate and we have
to convince Congress that we've got to be in front of
the curve. We can't wait to have the application on
our desk and then start trying to hire the people. We
need the people a year in advance or so.
We have a little bit of leeway in our FTE
space that we could do a little bit of advanced
hiring. We're talking about this in terms of human
capital now at the Commission level. How do we
prepare ourselves for a variety of situations,
including the fact that approximately 40 percent of
our staff could retire don us and walk out the door
tomorrow. What are we going to do about that? How
are we going to replace these people from the pool out
there? It's not that big to find people.
MEMBER WALLIS: Well, maybe working on the
new reactor might encourage some younger people to
apply. It might be more exciting than the old stuff.
VICE CHAIRMAN BONACA: One concern that I
thought about is the thought that NRC has a lot of
talent and vendors will need talent to design and
implement these new reactors. That may be an
attraction for personnel, so there's also an issue of
totally retaining knowledgeable staff.
COMMISSIONER DICUS: That's one of the
human capital issues that we're addressing and some of
the fixes that may be possible will require some
legislative action to be able to do. We have the
issue that if there is, indeed, an upswing in the
nuclear industry and if the industry is going to be
competing for these people --
VICE CHAIRMAN BONACA: Absolutely.
COMMISSIONER DICUS: It's going to be a
very attractive situation, so we're very concerned
about that. There is perhaps a little bit of an
upswing. Students are beginning to show an interest
in nuclear engineering and associated fields. Texas
A & M University, their freshman class almost doubled.
MEMBER WALLIS: I wonder how many of those
are actually studying phenomena relevant to new
reactor design, whether the professors are stimulating
them to do that, whether the professors are still
teaching the old stuff?
MEMBER KRESS: With respect to the
technology related to the pebble bed reactor, it's my
view, you can become up to speed in a hurry on that
one, so you've got enough bright people that with a
little homework, I think you could cover that one.
Some of the other concepts may be a little more
difficult. I hope I'm still on the ACRS when you have
to wrestle with this problem of the defense-in-depth
and the need for containment because I'm really
COMMISSIONER DICUS: You can tell which
ones are on my mind. That comes around a lot. The
financial issues are there, as well. Those are all --
they're different. When we start talking about
defense-in-depth, containment and things like that
from a policy perspective --
MEMBER POWERS: It's real simple. Just
tell them they have to have a containment.
MEMBER WALLIS: Dr. Kress said with a
little homework they could come up to speed. Maybe
the ACRS could write some of those homework problems.
MEMBER KRESS: That's a thought.
COMMISSIONER DICUS: That's a thought.
MEMBER POWERS: It is remarkable to me
that given all the troubles that the industry has that
they would want to engage in a battle over either
containments or EPZs. It seems to me that those are
-- they're guaranteed to be provocative and their low
level fights compared to other things that the
industry has to contend with. And they bragged about
how good their existing plants are. Just look at TMI.
Nothing occurred because of a good solid containment.
Look how terrible the Russians are because they had a
lousy containment unlike ours and then they said we're
going to get rid of it. It's a very peculiar battle.
COMMISSIONER DICUS: The arguments will be
MEMBER POWERS: I think it's peculiar
economics on their part too because when I have looked
at containment costs as a fraction of plant costs,
you're talking about a 7 percent effect. And so if
you get rid of it totally, you change the cost by 7
percent. This doesn't look like a big change.
COMMISSIONER DICUS: Well, with the
Emergency Planning Zone it's likely, in my view, that
the first one or two to whatever design, if it's a
pebble bed, probably be constructed near or at a
distant site. Shrink it down.
MEMBER WALLIS: Well, you may plan for a
small zone, but if there's an accident, the population
in a bigger zone may think that there's an emergency
for them too.
COMMISSIONER DICUS: Right. That's true.
We do expect to get some applications in this year for
early site permits.
MEMBER POWERS: Are those new sites or are
they locating plants on existing sites?
COMMISSIONER DICUS: I don't know.
MEMBER POWERS: Okay.
VICE CHAIRMAN BONACA: During the
presentation from NEI, there was an interesting
vu-graph where they were showing that they expect to
have over 10,000 megawatts of electric coming from
uprates and of course we are involved now in reviewing
uprates as well as reviewing life extension.
I would like to have your thoughts about
-- clearly, there's going to be a challenge with not
only licensing new plants, but maintaining current
plants operating at a higher rating and for longer
periods of times and working safely and efficiently.
So I don't know if you had any thoughts on this issue?
MEMBER KRESS: To get that kind of power,
it's going to take substantial uprates to 20 and 30
percent type levels.
COMMISSIONER DICUS: I think we'll have to
look at that. We are uprating. Some plants are going
already, I can't remember offhand which ones for
fairly high. I think Palo Verde may be going for a
fairly high uprate, but doing it in steps and that
might be maybe the way to go. That gives us a chance
to look at what the issues really are. I'm not up to
speed technically on what those issues are going to be
for uprates and some of the --
MEMBER WALLIS: Well, the manufacturers
assure us that there are very few issues.
MEMBER POWERS: I mean the argument that
gets advanced is that the FSARs for the plants were
originally for a much higher power than what they have
been operating at and I happen to know it's because of
some recommendations made by this Committee, these
many years ago that they operated at the lower power,
but they seem to not recognize that there have been
some changes in the way things are done at boiling
water reactor modes -- the big power uprates are all
boiling water reactors, that weren't recognized in the
early FSARs. And I think of things like outwash
recovery actions. We're going to drop the level of a
coolant down, introduce SLIC and then we're going to
bring it up.
Now tell me about the lateral forces on
cool rods that you've operated at high burnups so that
they're nicely embrittled and the fact that the time
that you have to do this has decreased now because
you've been operating at a higher power. Those are
kinds of technical questions that I have not seen
addressed for these big power uprates and they're just
not incorporated in the FSARs because these things
have occurred since the original FSAR was written.
COMMISSIONER DICUS: Actually, I think one
of the things that you might consider doing is really
listing the issues that you see with these power
uprates. That would be useful to the staff in getting
that information because I hadn't heard that 10,000.
that's a lot.
I hadn't heard that figure. That gives me
a little bit of cause for concern that we're not just
beginning to run amok.
MEMBER POWERS: We have over a unit's
worth, over a thousand megawatt electrical on our
agenda right now, so 10,000 doesn't sound out of the
COMMISSIONER DICUS: No, it doesn't, but
still, you know --
MEMBER POWERS: It's a bunch of plants.
COMMISSIONER DICUS: It's one thing when
if we get this change in the future of nuclear power
is to be able to pace that change so that doesn't run
amok, say that we just suddenly there's a snowball
effect that -- then we have an error. We don't need
the error. That won't work for anybody. It won't
work for the American people. We're going to need the
energy. So I want us to be trying to look as far
ahead as we possibly can, pace this change. I think
the Committee -- it would be very, very helpful to the
Commission in thinking along those terms and trying to
identify the issues as you see them and keep this
process very mature and very capable of dealing with
change that may occur.
MEMBER POWERS: One of the things that's
snowballing, not a fair term, one of the things that's
moving along expeditiously nowadays is license renewal
and we're seeing increasing public concern, it seems
to me when they see on the one hand license renewals
being granted and on the other hand, numerous reports
of phenomena and processes occurring to the plant that
at least in their mind look like aging phenomena,
cracks in pressure vessel heads, cracks in nozzles,
that sort of thing. And they don't draw the
distinction between active components and nonactive
The question comes about is do we have a
public relations problem here or do we have rule
COMMISSIONER DICUS: I think we have a
public information problem. This is a perennial
problem. It's one of the things the Commission is
looking at as both our external and internal
communications has been tasked with dealing with this
issue, public relations, public information, public
We don't say and this is what we're not
getting this information out. I think when we go to
the sites and we have our public meetings and not
getting the information out, that we're not saying
that there will be no aging issues. Of course,
there's going to be aging issues. What we do in
license renewal is very carefully look at what the
licensee's program is to identify and deal with aging
issues, but there will be aging issues. If you've got
a vintage car, you work on it to keep it running
because it's going to have thing go awry.
I don't think, I don't know that the
public is getting that message that yes, there are
some issues. We have steam generator tube issues.
We've got the cracking issues. We may probably are
going to identify some other issues, but the point is
being we can't identify them and the licensees have
this aging management program in place and the
wherewithal to deal with it. I think we have a public
MEMBER POWERS: I think the licensees may
not serve their best interests when they get surprised
by an event and then say oh yeah, but we can run six
more cycles with cracks and things. Somebody who is
not intimately involved, it's not obvious that you
ought to run six cycles with cracks in your cylinder
COMMISSIONER DICUS: Right. I'm a little
concerned about that.
VICE CHAIRMAN BONACA: And I think it's
kind of difficult to reverse that perception in part
because for so long we have licensed plants for 40
years. I mean we have a built-in perception that after
40 years these plants must be retired, otherwise why
with only 40 years. And to reverse the perception is
going to be very hard.
COMMISSIONER DICUS: Yeah, because the 40
years was picked out of the sky.
VICE CHAIRMAN BONACA: Exactly.
COMMISSIONER DICUS: It was a financial
VICE CHAIRMAN BONACA: Absolutely.
COMMISSIONER DICUS: Well, in 40 years
they'll have it paid for, so we'll just license them
for 40 years. It had nothing to do with plant
VICE CHAIRMAN BONACA: That's right.
COMMISSIONER DICUS: And we didn't that
message out either.
VICE CHAIRMAN BONACA: That's right.
MEMBER WALLIS: While we're talking about
public perception, this Committee has discussed there
are various kinds of public. One tends to perhaps
think of the public as being John Q. Public, but there
are actually some quite sophisticated technical people
out there and they need to see some technical evidence
in the form of reports or something that the NRC is on
top of these subjects technically.
COMMISSIONER DICUS: In January, I was at
a conference. It was sponsored by NEA in Switzerland
and it was public perceptions of risk and public
communications and so forth and so on and that was one
of the themes that came out of that conference. It
was an excellent conference. It was by invitation.
I think there were about 70 of us there from around
the world, mostly Europe. And there are many
different kinds of public and you've got to talk to
those many different kinds of public stakeholders,
including the ones, the technical people, the
nontechnical people. It was a really good conference.
MEMBER SHACK: One of the last times we
had a meeting with the Commission you asked me whether
I thought we were still making sufficient progress
towards risk-informed regulation.
COMMISSIONER DICUS: Right.
MEMBER SHACK: I just wondered, what your
COMMISSIONER DICUS: Turnabout is fair
MEMBER SHACK: When you first came here,
we were talking about low hanging fruit.
COMMISSIONER DICUS: Right.
MEMBER SHACK: We're still picking that
low hanging fruit which just doesn't --
COMMISSIONER DICUS: It may have fallen
off the tree.
I think we're moving. It's slow.
Progress is very slow in risk informing. I don't know
if it's the proper speed or not, whether we could move
a little faster or maybe we're moving at the right
speed because we're trickling over into such a new
arena for everyone, for us and for the industry itself
and whether or not the industry is actually going to
be able to use the risk-informed regulation.
We've stumbled over 5046. We hope to get
a paper some time, but we're not sure exactly -- the
staff is struggling with it, on how to do it and what
to do with it.
So we are dedicated to the concept we are
going forward. We do have issues. The industry has
issues with us. Sometimes we get criticism because
we're moving too slowly. Every once in a while I hear
someone say we're not sure we're ready to do, to go to
a risk-informed regulation. But I think we have to
leap out there, it may be a leap of faith, carefully
trying not to step in too many potholes as we go
It's going to be interesting when we get
some really good and working risk-informed regulations
out and see licensees make their decision if they're
going to use the risk-informed regulation or stick
with the old regulation because we will have two sets
of regulations which is going to be interesting, I
think, from the Commission's point of view and how the
staff is going to deal with that.
But one of the things that we talk about,
talked about -- my staff talked about it with Dr.
Apostalakis is the quality and value of the PRAs that
we have and how that's going to interact with the
risk-informed regulation. It doesn't keep us from
risk informing our regulations, but it may keep
licensees from being able to use it because if they
don't have a very good PRA, they're not going to be
able to use a risk-informed regulation and hopefully
before too long we will have a standard and then we're
going to have take a look at those PRAs that don't
meet the standard and the licensees are going to have
to start making some decisions, so I would -- I get a
little bit concerned that we get on, get busy with
getting our regulations risk informed and deal with
these two sets of regulations that we're going to have
for each one of the issues and then very few licensees
go risk informed, be sort of like all the work we did
on certifying designs and no one seems to want to use
I hope that doesn't happen.
MEMBER POWERS: It seems to me that the
regulations that we've considered risk informing up
until now, that includes to some extent the fire
protection regulation with NFPA who insists that's not
risk informed. The regulation is some hybrid, but put
it in that category and now 5046, I don't think you're
going to see licensees jumping at this. Where you're
going to see continued licensee use is Reg Guide 1.174
for plant changes.
COMMISSIONER DICUS: Right.
MEMBER POWERS: That is already proving
its use. And already we are -- we keep running into
the problem that the PRA quality may be an issue, but
the scope is even a bigger issue and I think with the
emergence of the results coming out of the IPEEE, I
don't know whether you've had a chance to look at
those or not, but those are illuminating to me that
risk from the so-called external events which includes
internal fires which is a historical thing that adds
to challenges I think the public has in understanding
PRA are really quite commensurate with normal
operational risks and until we have people coming in
with PRAs that say yes, I take into account all of the
risks, not just the operational risks during -- when
the plant has power, but also these things in fire
which is a risk that people have a very intuitive
sense about, that you're going to have two kinds of
difficulties, one, challenges from public and
challenges in using 1.174 to its full potential.
Getting back to the actual regulations,
you're not going to see people sweeping to those until
there's a much fuller set. One at a time, you're
going to have the out person do it.
COMMISSIONER DICUS: You are going to have
the out person do it and it may be that one of the
things, those regulations that tend to have a generic
approach or a generic basis may be -- if we can get
those out, then I think we can get wider use and I
think once a few plants or a few licensees really leap
off, take that leap of faith to get fully involved in
utilizing a risk-informed regulation, it will be like
license renewal. Once Calvert Cliff got the courage
up to take that leap of faith and thus tried to do
this, and it went well and Oconee went well, now the
flood gate is open. And I think the same thing will
happen, but it will take a while.
MEMBER POWERS: I think you will see 1.174
still being used a lot. It's proving to be an
attractive vehicle for making changes in plants.
MEMBER WALLIS: Can I make a connection
between the last two subjects, the public perception
and risk informed? We have a couple members of the
public here and they seem to be suspicious that
risk-informed regulation is a way to reduce the burden
on industry, whereas it seems to me that the drive for
risk-informed regulation really should come from the
public because this is where you actually face up to
the question of what is the risk and what's being done
about it and that's far better than some rather
arbitrary prescription. It's surprising that the
public can't sort of be better aware of the fact that
this is in their interest and perhaps they should be
more the driving force behind it.
COMMISSIONER DICUS: This is just another
example of whoever has the responsibility. In my RIC
speech, I'd put a burden on the industry. You people
should be out there talking about what you're doing in
the realm of safety. It's your responsibility to talk
about your safety records. It's not our
responsibility. It's our responsibility to ensure
that you are doing that, but you're the ones that have
to do it. The plant is your responsibility. And I
think what -- the words you just used, reduce burden
on the licensee, they hear burden, reduce burden.
They don't hear reduce unnecessary regulatory burden.
And the whole issue is that when we make essentially
everything the same importance, even if it's whether
or not how they signed off on a particular piece of
paper which literally has nothing to do with safety,
when we make that just as important as how well
they're taking care of their pipes and pumps and
everything else, then the same emphasis, they can't
put the emphasis and this is a message we're not
getting out to the public. They can put the emphasis
they should on those systems, structures and
components that are absolutely vital to safety because
they're having to spend time on something that is not
vital or even important to safety and what we're doing
is taking these things and putting them down here, got
to be done, but it's not as important as these things,
now you can put attention on here. We're not getting
that message out to the public. And the industry is
not getting that message out to the public. I don't
have an answer for that. But any time I can, when I'm
talking to the public, you know, and this question
comes up, you explain it, and then they do understand.
You don't discount the public that can't understand
these things. They understand them very well. If
they get the right information.
So it's a communication issue that we all
need to work a little bit better at.
VICE CHAIRMAN BONACA: The unfortunate
thing is that, for example in the case of South Texas,
there are a number of exemptions resulting from risk
information and but if initial exemption means that
you're going to have to do any more or something that
you had to do before, and if you are ill-disposed, I
guess the technology, you jump to the conclusion very
easily and this can be so easily instrumentalized and
that's one of the issues that of course, whenever you
remove burden, the word unnecessary doesn't come to
mind in that case.
COMMISSIONER DICUS: Does not come in.
MEMBER LEITCH: Further on this area of
public perception, since joining the ACRS I've taken
to reading the daily event reports and I'm struck by
the number of medical administration issues,
industrial problems, radiography problems, misuse,
loss of radio isotopes. I don't really have a
historical perspective on that whole area. Did an
increase in these kind of incidents over the years are
at least stable --
COMMISSIONER DICUS: I think it's fairly
stable. It may, in fact, have gone down just a little
bit, but medical administrations probably running
pretty well what they normally run. I don't have
stats in front of me. There might be hills and
valleys along, but there hadn't been what I would
consider a steady increase or a steady increase.
They're running about the same.
Lost or stolen sources, about the same.
One thing, I think we're going to see in the offering
source issue, I think we're going to see a real
improvement in the offering source issue because of
our registration program that we're going to put in
for general licensees.
That's going to make people start having
to really go out and find sources. In some cases,
they didn't even know they had a gauge in their
plants. It's sold two or three times and they're
going to be surprised when they get our letter saying
we have a record that shows you've got XYZ and they
say we didn't know we had this. And then they start
looking for them. But I think in two or three years
with that kind of accountability that we're going to
put in place, I think we will see a decline in some of
these gauges, etcetera, winding up in the public
So that part should improve. I think the
others run about the same. It was, I think, my first
speech that I gave at the RIC, first or second, at the
RIC. I talked about the fact that where we are
unnecessarily irradiating workers and members of the
public is through the radioactive materials side of
the house and not in the reactor side of the house.
And that's where -- that's not recognized that much.
We just had the issue in Panama. That's not a U.S.
issue, but several patients have died as a result, who
were having radiation therapy because of still trying
to ferret it out, but they received more radiation
than they should have. And reasons for that still not
real clear, other than their own parameters were put
in. But why it's still unclear.
It is, and we continue to have medical
administrations with our best efforts to prevent it.
MEMBER SHACK: One thing that comes out of
the new reactors as we look at them, they appear to be
much safer than our existing --
COMMISSIONER DICUS: They have the passive
safety systems, yeah.
MEMBER SHACK: Right. Do you think that
would increase pressure to rethink our notion of how
safe is safe enough? That would be out in the future
that -- would our safety goal be something that people
would actually have to achieve, rather than aspire to?
COMMISSIONER DICUS: I don't know. But
it's a possibility.
Right now we're wrestling with safety goal
VICE CHAIRMAN BONACA: I imagine if the
number of new applications were many and the number of
reactors would be large numbers, then there would have
to be some important consideration.
COMMISSIONER DICUS: I think at some point
we would really have to relook at that and I think
that's the issue why there's some hesitation now on
the Commission's part to go further or at this point,
to add to a revised safety goal policy statement,
waiting to see more regulation is risk informed,
seeing what does, in fact, happen, whatever the
economics are that the nuclear power industry makes
decisions accordingly, and maybe at that point in time
we do need to take another look at the safety goal
policy statements, what we plan to do with them.
MEMBER POWERS: If the staff really runs
into a long-term hurdle in 5046, do you think they
ought to rethink their option paper to you?
COMMISSIONER DICUS: Yes.
MEMBER POWERS: I think so too. I mean --
COMMISSIONER DICUS: I think that's in the
MEMBER POWERS: Is it?
COMMISSIONER DICUS: As far as I know.
VICE CHAIRMAN BONACA: Just thinking about
these new reactors. We had presentations that speak
about the system and again I was thinking about the
comments from Dr. Powers regarding fire, external
events. I think it will be important for us as a
Committee to really pay attention to those external
events which really create comment mode failure and
because the focus has always been so much on the
plant, specifically, and those external events are
truly the challenge that is not fully appreciated in
the existing plants.
In fact, the IPEEE were going to review
them now, the results of it, but there isn't such an
understanding of their impact, really, on the safety
as there is for internal events.
MEMBER POWERS: And you get these
remarkable things. As we move toward more risk-
informed regulation in a different reactor oversight
program and we look at corrective action programs you
always find that. The oldest things on the corrective
program are the fire protection stuff. They don't
produce kilowatts so they come up bottom on the list.
And they're producing risks that are
comparable to the normal operations. This is real
risk information here that's just not being used, but
a licensee --
VICE CHAIRMAN BONACA: The reason why I
bring it up is that their own paper, they can really
design something which is for internal events,
significantly and clearly safer than current plants,
but if you don't pay attention to the external events,
in the siting, for example, and other issues that may
affect the plant, still you have this component which
is not fully appreciated which is really the driver of
common cause. If you have -- and we will have to be
very sensitive to those kind of issues, otherwise,
we'll have a perception of much better plants, much
safer and maybe the perception is not correct.
COMMISSIONER DICUS: And because of the
perception that may cause a lax attitude on things
that ought to be, as you said, given a great deal of
attention because they can create the unsafe situation
in this safe plant.
VICE CHAIRMAN BONACA: That's right.
MEMBER KRESS: At the risk of being a dead
horse with a red herring --
COMMISSIONER DICUS: Just got back from
MEMBER KRESS: How do you feel about the
need for a substantial improvement in the risk
assessment capability with respect to shut down risk?
COMMISSIONER DICUS: Well, everything that
I read, well, indicates to me that there are some
significant risks in low power and shut down from the
point of view that you may have some systems very
necessary for safety that are down. They're not
available to you, so if you have some event, external
or internal, that occurs that you need that system or
component, whatever, and it's not available to you,
then I think you have some element of risk. You don't
have the reactor running, okay, fine, but you can
still have something occur. That's what I read,
that's my understanding. Obviously, this isn't my
field and I'm very dependent upon what I learn
externally to understand these sort of things.
Now on the Commission, there are feelings
on both sides of the fence. There are strong feelings
that basically there are very few risks at low power
shutdown and it's just because the reactor is not
running. Everything can be handled because you have
time. Time is on your side. And that's true too,
probably. I just think -- I guess to make me have a
greater comfort level, I need it to be looked at and
if I'm sure that the answer is no, there really isn't
a great deal of concern here at low power shut down
situations because it can be handled and I've got
little bullet items to tell me how that's going to be
done and I will have a comfort level. Right now, I
just don't quite have that comfort level.
MEMBER POWERS: It's examining what's
necessary because you're right, time is on your side
here. But if you look at what we have to go on right
COMMISSIONER DICUS: We don't have much.
MEMBER POWERS: Well, that time has not
been factored in in any kind of realistic way, so
we're stuck right now with actually -- those people
that think everything is okay, don't understand.
We're making decisions based on information that says
things aren't okay because the original studies were
all very conservative. Examination of it is exactly
what needs to be done.
COMMISSIONER DICUS: Maybe we can put it
to rest one way or the other.
MEMBER POWERS: And you can and you have
to recognize there's a difference between scheduled
and unscheduled shut downs, that a scheduled shutdown,
I think the industry is doing a marvelous job with
scheduled shutdowns. And when we visited the plants,
it's only reinforced my view on how well they're doing
because they're very clever individuals.
The unscheduled shutdowns, however --
COMMISSIONER DICUS: That's different.
MEMBER POWERS: Don't have that kind of
planning. So it's really examining it. It's not
because you think that there's any imminent things
that have to be done, new regulations written. It's
finding out what the status is. It's really causing
a problem right now.
MEMBER FORD: As the newest and maybe most
gauche Member of this Committee, I'd be interested to
know what your views are for the longer term future,
for instance, right now we're proactively implementing
risk-informed policies. But what do you see happening
in five years? Ten years out, as far as what you'd
like this Committee to be focusing in, on that sort of
COMMISSIONER DICUS: I think a couple of
things immediately came to mind. Say 5 to 10 years
from now, hopefully, we do have a full range or almost
full range, certainly in 10 years, of better risk-
I think it's going to be incumbent on all
of us and especially this Committee to be sure that
we're catching everything we need to catch, that the
risk-informed regulation is indeed being focused on
what is really important to safety and we haven't
dropped something or we have something that we've
declared important to safety that may not be that
keeping in mind that this is going to be a living
document, quite frankly, a living process. And we --
five years, I'd like to see us begin in five years and
then in the 5 to 10 year range refine it. And fix any
little problems that we see.
The other thing, of course, we really will
be getting well into control of aging issues. Some of
these plants will in 10 years beginning to start their
second 20 years or their new life and I think this
Committee would serve the Commission very well that
you are really looking out there, 5 to 10 years on
what might happen next, so there aren't any surprises.
And we can give a heads up to the licensees that we
think you better watch this, this could become a
problem. So that is where I think I would like to see
you put a lot of your effort.
MEMBER FORD: Bearing in mind the public
perception acceptance is an important part of your
cornerstones. What role do you think we should be
playing in ensuring that there's not a problem
If there's another major problem offshore,
that's going to impact the public perception in this
country. Should we be, we the NRC, be actively
involved in helping regulation? I say that advisedly,
obviously, you're not going to politically, from a
technical point of view situation in Japan or Russia
COMMISSIONER DICUS: I'd like to give that
some thought. Now we are involved with several
countries through a variety of mechanisms to with
regulations, with exchange of information of maybe
from time to time we lend people to the IEEA on OSARs
and other kinds of reviews, regulatory reviews, so we
are involved. To what extent the ACRS has an
involvement, I don't know, other than clearly -- I was
surprised actually that the Tokamura accident didn't
get very much press in this country. The Panama
misadministration event, very little press in this
country. Something like Chernobyl, obviously, it
affected the world and it had an impact here in the
U.S. as well. That's going to get a lot of press and
a lot of attention.
We, through a variety of mechanisms,
mostly IEEE and NEA, like to see some of the unsafe
reactors that are in the former Soviet Union countries
not operate because we do feel that they have some
issues with them that the safety level is not what we
demand in this country and in other areas, but I mean
if you identified something that you think the
Commission must be aware of some place else, offshore,
as you mentioned, I think it would be incumbent among
you to let us know about that and then to what extent
we have an opportunity through the avenues that we
currently have in place to deal with that and I think
that would be valuable information and I would see it
from that point of view.
MEMBER UHRIG: There were a couple of
trends that were discussed in the advanced reactors
meeting we had this week. One of them is long-term
operation without shutdown, either through continuous
refueling like the pebble bed or in the case of the
IRIS, they're looking at an AE or fuel cycle,
something of this sort. And the other thing that was
discussed is automated operation for a minimum number
of operators involved where you have perhaps 10
modules, but only in the case of the South African
concept about three operators to handle all 10 of
I wonder if you could give us your
thoughts on this type of thing for do we need
additional layers of assured safety associated with
this type of operation or is the present regime of
COMMISSIONER DICUS: For the refueling on
line for both instances that you talked about, longer
runs or in some cases being able to refuel while the
reactors at some level of power and then other is the
pebble bed and --
MEMBER UHRIG: Pebble bed is the
COMMISSIONER DICUS: But less operators
with the pebble bed with more modules.
MEMBER UHRIG: Yes.
COMMISSIONER DICUS: So you want me to
address what I think our regulatory structure --
MEMBER UHRIG: There are two separate
issues here. One is manpower associated with the
operation and automated operation and the second one
has to do with long --
COMMISSIONER DICUS: I think we got into
-- I don't know if we need regulatory changes or not.
You get into reduced manpower and automated operation
might well be. Certainly, we're going to have to
address it from the safety point of view and the risk
point of view, so whether that would lead to a
regulatory change I think the study of looking at it
will tell us whether we need regulatory changes, might
well do with that.
As far as being, of course, the pebble
bed, putting that side as far as short -- longer runs
and being able to refuel, without total shutdown, that
is probably going to be a regulatory, something that
has to be done from that point of view. I don't know.
MEMBER UHRIG: The IRIS concept had an 8
COMMISSIONER DICUS: Uh-huh.
MEMBER UHRIG: And they would propose to
continue operation for 8 years before shutting down to
refuel. And this is unprecedented in any operation
that we've had in --
COMMISSIONER DICUS: I don't know. I
would have to get information on that. I just can't
answer the question at this point.
MEMBER UHRIG: Pebble bed was proposing,
I believe it was 7 years before they shut down for a
major overhaul, 7 or 8, something of this sort, so in
both cases, it was the order of 8 years.
MEMBER KRESS: It seems like it would
impact your ability to monitor and inspect and find
out if anything is working its way towards disaster.
Might call for more instrumentation, at least.
COMMISSIONER DICUS: That will just be
part of our learning curve and some of the things we
ought to consider as we get into that sort, get into
those kinds of reactors and our staff will have to
come back, look to you for a lot of information on it
VICE CHAIRMAN BONACA: It seems as if we
are out of questions.
MEMBER POWERS: I am running out of
ability to take notes here.
COMMISSIONER DICUS: You've been taking
MEMBER POWERS: I'm hanging on every word
VICE CHAIRMAN BONACA: We seem to have run
out of questions. Certainly, it has been a wonderful
exchange and very informative. We thank you for
coming and spending some time with us.
COMMISSIONER DICUS: Thank you. I
appreciate it. I know some of the issues because
they're really technical, out of my field. I'm not
quite up on the concepts and the policies and things
of that nature. I've enjoyed talking about them with
you. You've got your work cut out for you, I think,
in your next 5 or 10 years. There's a lot coming down
the pike and we're going to look to you for a lot of
advice being an advisory committee.
(Whereupon, at 10:03 a.m., the meeting was
Page Last Reviewed/Updated Monday, August 15, 2016