RE: NRC on Realism

["Ted Rockwell" <tedrock@starpower.net>]

Charlie:



Good for you!  The base of the msg is that nuclear power and radioactive materials are not some diabolical entity ("Faustian Bargain"), invulnerable to puny human efforts to control.  They are limited by all the same physics and engineering laws that we deal with elsewhere.  When we analyze their behavior that way, they are no greater menace than many things we have lived with comfortably for generations.



Keep up the good work, as an inspiration to the rest of us!



Ted Rockwell

  -----Original Message-----

  From: Charles Pennington [mailto:cpennington@nacintl.com]

  Sent: Tuesday, May 25, 2004 3:21 PM

  To: Ted Rockwell

  Cc: Bert Wolfe; Mandil, Harry; NN-BetsyTompkins; McNeill, Corbin; Connie ANS-Cherry; Starr,Chauncey; David Christian; Chapin, Doug; Don Hintz; Zebroski, Ed; NRC-FaroukEltawila; Stone, Henry; Taylor, John; Simpson, John W; Cohen, Karl; Foulke, Dr. Larry; Charles Pryor; Levenson, Milton; owner-rad-sci-l@WPI.EDU; RADSAFE; Rad-Sci-L; Schriesheim, Alan; Ted Rockwell; Todreas, Neil; Davis, Kenneth; Pate, Zack

  Subject: Re: NRC on Realism





  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@starpower.net>





                "Ted Rockwell" <tedrock@starpower.net> 

                Sent by: owner-rad-sci-l@WPI.EDU 

                05/16/2004 01:31 PM

       



              To 

              "NRC-FaroukEltawila" <FXE@nrc.gov>, "RADSAFE" <owner-radsafe@list.vanderbilt.edu>, "Rad-Sci-L" <rad-sci-l@WPI.EDU>, "Zebroski, Ed" <edzeb@sbcglobal.net>, "Bert Wolfe" <bertramwolfe@attbi.com>, "Todreas, Neil" <todreas@mit.edu>, "Taylor, John" <JJTAYLOR@epri.com>, "Stone, Henry" <HStone5190@aol.com>, "Starr,Chauncey" <CSTARR@epri.com>, "Simpson, John W" <jws@hargray.com>, "Schriesheim, Alan" <Schriesheim@anl.gov>, "Ted Rockwell" <tedrock@starpower.net>, "Pate, Zack" <ztpate@attbi.com>, "Mandil, Harry" <BMandil@aol.com>, "Levenson, Milton" <mlevenso@nas.edu>, "Davis, Kenneth" <wkdavis@aol.com>, "Cohen, Karl" <karlpc@earthlink.net>, "Chapin, Doug" <dchapin@mpra.com>, "McNeill, Corbin" <camcneill@wyom.net>, "Don Hintz" <DHintz@entergy.com>, "David Christian" <david_christian@dom.com>, "Charles Pryor" <mjinlynchburg@aol.com> 





              cc 

              "Connie ANS-Cherry" <ccherry@ans.org>, "NN-BetsyTompkins" <btompkins@ans.org>, "Foulke, Dr. Larry" <Larry.R.Foulke@verizon.net> 





              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