Re: NRC on Realism

[Charles Pennington <cpennington@nacintl.com>]

Ted



Sorry for the late response - have been traveling.



You are correct that this is something that fits well within what we as an

industry should be doing, indeed what we should have been about for at

least the last generation.



In my small area of spent fuel storage and transport, I interpret this

concept of "conservative realism" to include or even subsume my preferred

approach to demonstrating relative safety, what I call "comparative hazard

assessment", in which it can be conservatively demonstrated that nothing

can happen in spent fuel storage or transport that even approaches the

annual U.S. population/worker exposures delivered by unregulated,

non-nuclear industries, such as building design/construction, farming,

resource extraction, masonry construction, flying, fertilizer production,

waste processing of natural materials, etc.  (This is also true of the

worst reactor accident that can occur for a western reactor design.)



Further, the man-caused dispersion of the natural radionuclides that

produce such exposures have higher cancer mortality/morbidity risk

coefficients (by the EPA's own accounting) than those most feared in spent

fuel (e.g., 137Cs, 239Pu).



Finally, thanks to the good efforts of Dr. Bernie Cohen and others, it can

be shown that high man-caused exposures from 222Rn and other nuclides

result not only in no discernible negative health effects, but in potential

health benefits.  This means that nothing can happen in spent fuel storage

or transport to threaten radiologically the health and safety of the

public.



Two weeks ago, I made this pitch to the management of NRC's Spent Fuel

Project Office at an NEI meeting (they have "appreciated" this approach, in

previous discussions), encouraging them to include comparative hazard

assessment considerations as part of their Vulnerability Studies on spent

fuel storage and transport casks.  I have also made a similar pitch to the

National Academy of Sciences' Committee on the Safety and Security of

Commercial Spent Nuclear Fuel Storage, both in writing and in person.

Their classified report to Congress is due at the end of June.  How these

bodies will respond to such "encouragement" is not yet known, but we have

to start and keep at these efforts.



Finally, I have written articles and made pitches in a variety of venues

over the last several years with this message.  It works where it's heard.

I am also trying to encourage license applicants to begin to include

comparative hazard assessments in their licensing documents (FSARs)

submitted to the NRC, to show the relatively benign nature of spent fuel

storage/transport event outcomes and of cask operations exposures to

workers.  This gets such comparisons "on the record".



This is my view of being conservatively realistic, and you are absolutely

correct that all of us need to do something along these lines, using our

own individual strengths.



Charlie







                                                                           

             "Ted Rockwell"                                                

             <tedrock@starpowe                                             

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                                                                   Subject 

                                       NRC on Realism                      

                                                                           

                                                                           

                                                                           

                                                                           

                                                                           

                                                                           









Friends:



NRC Chairman Nils Diaz is "walking the walk" when it comes to applying

realism.  He recently defined what he meant, in a talk before the Japanese

Atomic Industrial Forum, April 21 in Tokyo:



"The regulation of nuclear power plants in the U.S…is in a transitional

phase…We need, and we are constructing, a regulatory program that better

meets our present needs…I have said many times: “Regulation must result in

a

benefit or it will result in a loss.”…It is frequently too easy to do a

little more “regulation,” to appear a bit more “protective,” and to add

another ounce of “conservatism.”  More regulation can appear enticing…The

NRC is not in the business of zero risk…Zero is not an option, it is a

disruption…We are learning how to define adequate protection in more

precise

terms…that make sense to the American people…We have the opportunity to

change the future, and I submit to you that we have the obligation to do

so…



"I am convinced nuclear regulation now needs to be anchored in realistic

conservatism…if we are to avoid the twin pitfalls of under-regulation and

over-regulation…I use “conservatism” in the sense of preserving adequate

safety margins, and I use “realistic” in the sense of being anchored in the

real world of physics, technology and experience…When engineering margins

are applied to input parameters, they can distort our understanding of what

is truly important.  Safety margins are better discerned when they are

applied at the decision-making stage, rather than at the analysis stage."



He then went on to apply this to a real and significant physical issue:



"Two major steps…are close at hand, and they are important, practically and

philosophically.  I am talking about 10CFR50.69 and 50.46.  The technical

information and analytical methods are available and the will to change is

strong…We have a sufficient understanding of the probabilities and

consequences to be able to progress to the next rational level of

regulation…Effectively, the current Large-Break LOCA would not be a design

basis accident…The commitment to go forward with 50.46 is fully formed and

the NRC Staff will develop proposed rule changes…The re-definition of the

Design Base LOCA is just one step, but a very important step, in the effort

to revise the regulatory requirements to be more risk-informed and more

broadly coherent."



Going a step further, he recently issued the following news release:



"--NRC HAS ADDED A "FOR THE RECORD" SECTION TO ITS WEB SITE. A May 13

notice

on NRC's home page said the section "provides NRC responses to inaccurate,

misleading or false information in print, on television and radio, and in

large write-in campaigns in order to provide the public with accurate and

truthful information." Items initially posted include NRC responses to

letters received regarding nuclear plant security and a proposed

independent

spent fuel storage installation at Indian Point. The commissioners said in

an April 28 staff requirements memorandum that "when research reports are

misused and quoted out of context, the staff should respond promptly." The

NRC web site is at http://www.nrc.gov.";



This is something I have never convinced our own people, in nuclear

utilities and labs to do.  If the Chief Nuclear Watchdog can do this, can't

we Nuclear Advocates follow suit?  There is no reason to shy away from

being

realistic.



Ted Rockwell