ML19290E111
| ML19290E111 | |
| Person / Time | |
|---|---|
| Issue date: | 02/14/1980 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8003040282 | |
| Download: ML19290E111 (76) | |
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U N IT E D STATES N UCLE AR REG UL ATORY COMMISSION in the m atte r of:
CONTINUATION SRIEFING ON EFFECT OF SIG REPORT ON ACTION PLAN
(
Piace:
Washington, D.
C.
Dote:
February 14, 1980 Pcges:
1 - 74 INTERNAT1CNAL VERfAT1M RE?CRTERS. INC.
499 SCUTH CAPITCL STREET. S. W. SUITE 107 WASHINGTCN. D. C. 20002 202 434-2 0 8003040
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PAGE NC.
I f
i UNITED STATES OF AMERICA 2
I NUCLEAR REGULATORY COMMISSION 2
A J
In the Matter of:
5 CONTINUATION BRIEFING ON EFFECT:
i 7
0F SIG REPORT ON ACTION PLAN 3
9
\\
10 Commission Conference Room 11 Room 1130 1:
1717 H Street, N. W.
13 Washington, D.
C.
14 Thursday, February 14, 1980 l
15 l
14 The Coccission met, pursuant to notice, for 17 Presentation of the above-entitled matter, at 10:00 a.m.
13 Victor Gilinsky, presiding.
19 BEFORE:
20 VICTOR GILINSKY, Co=missioner 21 i
RICHARD T. KENNEDY, Commissioner C
I JOSEPH HENDRIE, Commissioner
- 2 PETER A. BRADFORD, Co=missioner i
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COMMISSIONER GILINSKY-We will come to order.
i Continuing our discussions of the action plan.
I wonder 7
before we go back to where we left off whether you could 4
address how you see what we are doing here relating to I
the other activities in connection with the several plants 6
l that are proposed for at least intially for low power testing.
7 We seem to be on parallel tracks here.
3 This is supposed to be, at least the NTOL items 9
l the pre-requisites for licensing of plants for operation.
to j
We are on another track of coming close to i
)
authorizing at least a low power phase of operation.
Could ji g
you say something about the relationship of the two efforts?
I MR. MATTSON:
It has been the operating assumption g
that the two matched completely that they were not on divergent g
l paths and what was required of the near tern OL's was to meet i
the near term OL licensing requirements contained in the action plant and approved by the Commission a week ago today.
l I
I j
It was necessary, but not sufficient.
Sufficiency, i
implicitly at least being decided case by case, Sequoyah 19 being the first case.
20 On Tuesday of this week when you considered Sequoyah Il i
and what you heard was in some instances Sequoyah meets the fuel load requirements as specified in the list of NTOL i
l requirements and in some instances, it does not, but the j
- 4 i
Director of NRR proposes that in most of those instances i
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what they have is in his judgment sufficient.
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l The best example being the one oc expanded criteria f
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and scope of examinations for operators.
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Harold's people reported to ycu Tuesday, that although I
i they did not meet the specific letter of the action plan, I
2 i
l they did have many hours of simulator train'ng, more than i
6 were required.
I 7
They had testing and retesting and they had the 3
l trend and some of the testing underway exactly in conformance l
9 with the action plan; and in their judgment, that was g,
sufficient.
That would allow some plant-by-plant tailoring I
s of the specfic near tern OL requirements.
Said tailoring to be acceptable, if I understand the decision process as l
g t
1 it is working today to both the Director of NRR and to the I
,,w Commission for the these near term OL requirements.
That
,4 is, both have to reach a finding that what is done case-by-case, is adequate in light of these newly adopted licensing require-i
,6 ments.
17 COMMISSIONER GILINSKY:
So, they are either met or found -- specifically found -- to be not necessary for 19 some initial phase of operation.
- o MR. MATTSON:
Yes, thdre is really two ways in 21 which you can go about it.
i i
You could say, well, it is not met met specifically f
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the way it is stated, but wht: is there instead is acceptable.
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That would be similar to the way the staff does the licensing review against them and they do not insist upon one particular A
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l set of design requirements if an neceptable alternative can 2
be proposed by an imaginative designer.
Or you can say, wei I
will split the fuel load stage into two stages and there was 4
some discussion of that Tuesday.
3 The zero power stage and the testing stage.
One 6
might say that since not all of the fuel load requirements 7
I are met specifically to the letter, they maybe met sufficiently 3
l well that you could let them load fuel but not begin to l
9 l
conduct tests.
g I think, for example Sequoyah, the full safety review f r the tests themselves has not been completed.
11 COMMISSIONER GILINSKY:
As far as I know the i
snall break analysis has not been completed either.
Is that i
what you are referring to?
,a MR. MATTSON:
No.
15 C0FSIISSIONER GILINSKY:
Two things, right.
I MR. MATTSON:
That is just factor reunion in a UHI, l
17 the upper head injection aspects of the small break analysis.
COMMISSIONER GILINSKY:
Right.
Now, are the ly I
people involved in the action plan also involved in the 20 l
licensing of these plants or are' these two distinct efforts.
I 21 MR. MATTSON:
They are two distinct efforts but 4em there is in a few instances some overlap.
a.
I Let me give you an example.
Nobody on the steering 04 group has been involved in the licensing.
But, the steering group has some task =anagers responsi' ale for various parts twrproeancunaa. VD'EAflas EEi e i m l '.C me 23UTW CAFTCl. f7WEET. $. *F. SuffT 187 wase.a.c""Dar.1 *.1:nc2
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parts of the plant.
I Let me give you one example where there is some 2
j overlap.
One of cur task managers is Rod Saderfield, the 4
I Branch Chief of the Instrument and Control Systems Branch.
I He has the section of the action plan dealing with control 6
room design.
i i
7 He also is the responsible line official, responsible a
branch chief in the division of systems safety for the l
9 review of the control room at Sequoyah.
i to Okay, so the action plan has a near-tern OL 11 requirement of a review of the -- a double check review --
7 I think we have described it of the control room in response is j
to Rogovin and the person who puts that in the action plan is Saderfield and the person who administers that review l
or as a branch chief supervises that review is also Saderfield.'
So, there are few instances like that.
COMMISSIONER GILINSKY:
Well, what I en getting at is in those instances where the requirements are not met, or at least, not strictly met, have the individuals 19 responsible for licensing come back to you and said, what j
20 l
did you intend by this; or is it just clear what you intended.
21 So, that if scue alternative is proposed or it affect the temporary exemption as being granted, it is at least based j
I on a clear understanding of why that item was put in there.
l
- 4 i
MR. MATTSON:
Yes. I think there has been a lot i
i of that interaction through the last nine months.
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One of the short term lessons learned, for example, j
2 all of which are near term OL requirements.
There has 3
been a steering gr up established comprised of members I
4 l
of the lessons learned task force who developed most of l
I l
those short term requirements involved in the implementation i
6 of those requirements on operating reactors and another 7
set of people also containing "x" members of the lessons i
3 i
learned task force involved in their implementation of 9
operating license applications including Sequoyah.
10 i
From time to time, difficulties have arisen in 1
agreeing on what the criteria need for application of either
);
Those differences have been brought forward to l
management or brought back to people who were on the task
,s force for resolution and that kind of thing has happened l
as a matter of routine for the last four or five months.
- d There has also been an occasion for the managers of the review of Sequoyah to interact with the managers 18 of the action plan where there were cases of uncertainty.
19 I don't think there is a problem of understanding 20 what is required.
Ed, is that a fair judgment?
21 l
C0100:SSIONER GILINSKY:
Where were we?
C l
MR. MATTSON:
I think we were at 1C, operating 22 procedures.
24 COMMISSIONER HENDRIE:
As far as I was concerned, i
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I think we completed IC.
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MR. MATTSON:
I think that is right, that is
,i 2
where my line is drawn at the end of 1C.
3 COMMISSIONER KENNEDY:
As I look forward to this, I
4 l
I made a brief proj ection linearly, of course and concluded 3
that by this time in 1981 we should have reached probably i
6 section four which should give the industry, I think, some 7
considerable comfort knowing that it should not be more l
3 than another year before we will finish going through here i
l to decide what the action plan should comprise but that 9
of course will not have anything to do with having done 10 l
- )
i anything about it yet.
COMMISSIONER GILINSKY:
Does that crystal ball
- 7
- 3 l
have the Dow-Jones average?
I COMMISSIONER KENNEDY:
No, I think the industry is capable of handeling that themselves.
i l
COMMISSIONER HENDRIE:
Onward with D.
There is a series -- in this section -- there I
is a series of B category items, one C category under research and an A which is is a technology transfer conference 19 that has already been accomplished.
You can leave it in 20 the plan and then mark it done or put it in the Appendix 21 and mark it done.
COMMISSIONER KENNEDY:
If we have anything done, I would certainly urge keeping it here.
24 COMMISSIONER HENDRIE :
Could we print this.
This 1!
section on colored paper style, or something like that?
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The B items are design review for control room 2
l safety parameter consoles, safety systems status, monitoring f
and designing standard.
For myself, I think the research 2
4 that is proposed here is a good idea and it is a C and 3
I just say fine, get on and do it on a schedule appropriate l
4 to resource availability on the pressure of what may be j
7 l
some more urgent items.
3 i
On the first three, the design review NRR is 9
going to require the licensees to look at their control to l
rooms to identify and correct design deficiencies.
It i
says you are going to formulate review guidelines and then g
l develop evaluation criteria for the staff to use in judging g
the acceptability of the reviews performed and while this i
general task is in accord with things we all recognize need to be done, I would comment that in putting together g
j the review guidelines and in the so-called evaluation
,4 1,,
criteria for the staff that we try to keep in mind that
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the aim here is not to compel all rhe control rooms in the sub-standard design.
l 1
Since that probably can't be done as a practical i
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matter and is likely to be not c'ondusive to safety and i
21 i
carried at all to accesses, but you would like applicants
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to do, or licensees to do, is to go and think sensibly
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i their concerns and identify places the operators aoout 24 point out as giving the problems one way or another and
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to do reasonable things.
So, my plea is for only reasonablenesst 2
l here but the task itself is obviously one that has to be I
I done.
4 COMMISSIONER GILINSKY:
It is hard to argue with rea.sonableness, but aren't we in effect pushing towards e
i standarization of scue sub-set of control room functions?
6 COMMISSIONER HENDRIE:
I think as time goes on 7
and we get some of the efforts in the general technology g
l area settled down and codified into some standards, then 9
I it seems to me that plants at such a stage in design and i
1 construction that they can work it off to as much as
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possible go toward those standard configurations.
I think in the long run, a fairly standard config-l
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uration that have been carefully thought about from a human u
engineering standpoint at least within a given vendors i.!
I line, are desirable.
I l
14 i
COMMISSIONER GILINSKY:
But, I woula think that 17 there would-be a certain anount of backfitting on existing la plants standardizing control rooms because, as you say, j
19 that is a pretty large task --
i 20 i
COMMISSIONER HENDRIE :
You know, tearing the 1
whole thing out and re-instrumenting and re-building the l
control room is two, three years work.
COMMISSIONER GILINSKY:
One is going to require
- L that certain standard instruments.
We are in other parts f
- C
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of the plan requiring cartain --
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I COMMISSIONER HENDRIE:
Well, what we are going l
f to get on in a minute --
1 2
MR. MATTSON:
I think I have something here that j
might help.
4 The second item, the s.sfety parameter console 6
is the thing that people have begun to talk about about 7
for standardizing for backfitting.
3 That is the set of three or four dozen key parameters l
9 indicating the status of water level in the core, the primary coolant boundary, the containment isolation, the few para-je meters --
- )
CONMISSIONER HENDRIE.
It is just about the data links, isn't it?
i w
COMMISSIONER GILINSKY:
That is right, I was going to mention that.
We have not approved of that, but
,d l
implicit in that proposal is a certain degree of standardiza-tion of data --
17 COMMISSIONER RENDRIE:
To the extent that the 18 system safety state vector disply constitutes an addition 19 to control rooms you have an opportunity then to see that
- a l
that conforms to human engineering standards and could 21 be pretty well standardized, at least within vendor lines.
C COMMISSIONER KENNEDY:
As I understand Vic's l
i interest, it is not standardization of a piece of hardware, j
- a it is rather is a standardization as to the output of char hardware it is that data that is being produced and ratained.
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l COMMISSIONER GILINSKY:
Well, I don't want to l
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entirely dismiss the hardware here because there are certain 2
i functions which we are going to say can't be on the back 4
I panel and they ought to be on the front panel or got to I
be in the center or something like that.
6 MR. MATTSON:
There is a tendency -- this is 7
an area where industry is really devoting a lot of resources 3
and key talent.
NSAC is working very hard in this area i
I 9
i of control room backfit.
to We may be about to receive advice.
- Remember, i
i 11 I told you that the AIF and NSAC were bringing some people.
- 7 to town to look at resources and priorities from the industry's i
point of view of the things that remain in the plan to be approved, that is largely, the B decision category items l
that apply to licensees, some 40 or 50 items.
g We have been interacting and explaining what t o, i
some of the various elements of the tasks mean to us.
Some of this is pretty short hand with those people in the last few days just as we have with you; and one gets the feeling 19 that it may be possible to achieve more with this item two than it is with item one under control room design 21 and in fact, you can achieve item two quicker than you
^
can achieve item one.
lI Now, that is counter to the thinking that is j
- 4 reflected in the plan.
The plan presently says, do item one first while l
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you develop some criteria and do some further thinking 2
about the console and then maybe do it a year, two years I
down the road.
4 I think, however, the thinking on the console 3
has been driven by the nuclear data link, by people saying l
the safety state vector for the nuclear data link is something 6
7 I
like, if not identical to, the safety state vector in the i
3 l
onsite technical support center; oops, that is abnost identical 9
to, if not identical to, the safety state vector in the 10 j
control room; cops, that is the safety monitor console.
i l
Starting from one end they driven back, right back into the control room to the console and people are starting to make statements that it may be possible to standardize i
L, at least purchase specifications, that is functional performance la i
requirements for a safety console faster than one can derive i
13 I
backfit criteria for a control room generally.
l I
14 i
i Now, if that decision came, and it will probably come in the next month or so, you would have to make some la finding about booby traps.
i The control rooms have been looked at for booby
- 0 traps.
21 Now, to a certain extent the operating reactors already have by work that we require with short term lessons i
l learned, the vessel water level indicators, the direct 24 indicatton of safety and PORV position, some things like that are the obvious booby traps that we learned about i
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l The function of item one under control room design l
1 3
l was to look for more booby traps.
I do not quite know how that is going to sort out and it is something that l
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as we decide the standing and flexibility of this action 6
plan, we need to bear in mind that that kind of thinking i
7 is still going on in some of these things and the expert 3
technical judgment is not in yet as to which is the correct 9
one to put the most priority on.
10 l
We have to save some flexibility in the plan l
today, and six months from today to accomodate changes 11 1:
in technical opinion.
1:
COMMISSIONER HENDRIE.
I really think you need y
to stay very close to where the lead industry groups think l
they are able to go in this area.
l l
Let s talk a minute about, let's see, the state 16 l
i vector is going to turn out to be the data link, essentially, g
the data link parameters aspect.
la i
MR. MATTSON:
That is my judgment.
COMMISSIONER RENDRIE:
Maybe with reduced number
'O I
of radiation monitoring inputs.' I do not know.
But, it seems to me likely that the process variables and the data 3
j i
link list will be what you will want to see on the console.
O i
One of the proj ections about now to hang that l
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up, that is, you are going to go for -- if you are going J
to have to display 60 of those things on hardwired siescically l
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l qualified readable meters of that size, why you are going 1
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l to have quite an animal in there, and anybody proj ected 2
what this thing looks like?
i MR. MATTSON:
There is a big steering group, 3
I hate to use the term, but I think that is what they have f
called it of knowledgeable, technical experts in this field 6
7 being formed now.
3 I think their initial meeting is late February 9
to address the questions like that.
to l
COMMISSIONER KENNEDY:
What relationship is there j
i with what has been done in the Haldeman experiment?
11 i
- 7 l
MR. MATTSON:
Well, that kind of thing is being factored in.
There are several schools of thought.
The people 9
I who are big on micro processors, push micro processors.
The people who are big on computer print outs, g
push computer print outs.
i The people who are big on cathode displays, push cathode displays.
i i
19 l
Some were in there, the regulators need to made 20 some decisions on seismic qualifications for instruments 1
on the onsite technical support center.
So far, we have i
a said, it does not need to be seismically qualified because 4
you always have a fallback position for a big earthquake
- 4 of the control room, which is seismically qualified.
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Those things are not sorted out, but I think 2
they are being paid attention to.
I suspect that people with cathode tubes are 4
probably win out, that seems the most efficient way to I
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display things with some kind of computer storage so that 4
i you can recall information to do trending analysis on an I
I onsite technical support center or in an NRC regional office Il i
- i or headquarters, less recall capability in a control room, l
9 because you do not have time for it there and you do not to l
have all your engineers there now that you created the II onsite technical support center.
4 IO COMMISSIONER GILINSKY:
Are the industry groups l
really taking a real fresh look at this?
1:3 14 j
MR. MATTSON:
Oh, yes.
13 COMMISSIONER GILINSKY:
I wonder if that isn't i
I id something we might want to hear about?
- 7 COMMISSIONER KENNEDY
I think that they would is be delighted to have the opportunity.
It may be a little l
19 early.
MR. MATTSON:
I have letters from both EPRI and
- g
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NSAC people who are involved with pushing ahead with this.
I know some of the NSAC things were spoken about j
in the technology transfer conference with the high triple E folks --
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- 4 i
COMMISSIONER GILINSKY:
But is this something that has real utility involvement, the EPRI people would m % v-m.
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i expect to be thinking ahead with things but the utilities i
have been pretty slow about changing control room design and are pretty fixed in their ways.
4 MR. MATTSON:
Well, when you asked the question, 3
I was responding for EPRI and NSAC.
I do not know of a 6
utility that has come in and said here is the way that i
7 I want to backfic.
l COMMISSIONER GILINSKY:
Yes, but does it look i
9 as if the EPRI efforts really have the support of some 10 substantial segment of the industry.
t Is this something that is likely to take as --
11 1::
well Joe was saying that we ought to stay pretty close to what the industry is ccming up with and the question y
I
- 2 is are they really ccming up with these things other than i
an industry think tanks.
i l
g 73 In other words, it is something which is really --
COMMISSIONER HENDRIE.
I think the effort has 7
very strong support in the forum committees.
In the utility
,8 grouping that are supporting that.
I expect that there is distribution that there is some utilities are the ones who are more aggressive f
about trying to be out in front and understand what the current thinking is or be on the board pretty much and l
2 there would be others that would have to be urged to climb 24 on the wagon before it goes past.
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i MR. MATTSON:
The only indication I have, I 2
have not asked the people from NSAC or the people that
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are listening to it, maybe I should.
s I have an indication that there is broad utitlity e
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support because the AIF steering group, the ad hoc group 6
of Vice Presidents from utilities and AE's and vendors I
has changed titles and are in the process of changing titles I
and Byron Lee has become Chairman of a similar Committee 9
with similar membership that sits in oversight of NSAC l
and controls the direction of their research and study 10 11' l
which since NSAC is doing this kind of work implies to 12 me that yes they are getting strong support and motivation l
from the utility indut 13 I
la l
COMMISSIONER KENNEDY:
I think Mr. Hendrie's l
1.5 point has to be kept in mind.
There is obviously some 14 distribution.
Scme of them are going to be a lot more l'
interested, more committed than others, and that is just
- g i
inevitable.
79 MR. MATTSON:
Well, and some of them are going to say wait a minute, we have good control rooms, and scme 0
of them do.
g COMMISSIONER KENNEDY:
Some of them don't and they say we do have good control rooms.
MR. MATTSON:
Well, then I guess that is our 24 i
role, right?
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COMMISSIONER GILINSKY:
We do not have to arrange it now, and others may not agree, but I would like to hear about this at some point if it can be worked out, but anyway, please proceed.
I l
COMMISSIONER HENDRIE:
On the status monitoring, i
6 remind me what 147 reg guide, 147 says?
7 MR. MATTSON:
The philosophy of reg guide 147 3
was show the functionability of safety systems in the control 9
room.
10 l
There are those that claim if not implemented 11
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poorly, and all it does is show the position of valves a
n:
and the discharge pressure of pumps and does not end up 13 with good synthesized information or easy descrimination i
2 and understanding by an operator.
I.5 The first plant to be licensed with a finding i
by the staff that it meets reg guide 147 I belive is Sequoyah.
14 That is something you can get from Ross.
I believe that 7
is the lead plant for implementation of reg guide 147.
,8 i
l COMMISSIONER EENDRIE:
Are those bi-stable state 19 indicators down there in the central part of that?
MR. MATTSON:
I do not know, Dr. Hendrie, whether i
21 it is a distributed system or not.
l 1
i COMMISSIONER HENDRIE -
Well, Sequoyah is the a
only place I have seen it but they have got a set of sub-
- 4 I
panels under the ennunciators which give the status, the l
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i position of each bi-stable.
You have got four redundant channels and then two out of four, while you can sit there 3
l and look at where the bi-stables are in each of those four i
channels and it is all splendid information, you can also I
t go cross-eyed looking at all of that.
6 MR. MATTSON:
This was a lessons learned recommendation.
7 COMMISSIONER EENDRIE:
I have some question whether 3
l you were an operating plant but the staff is shaken down i
9 on it and it has been operating for some years; do you 10 l
really want to go out and run a hundred thousand miles j
11 of wire into the control room and put up another hundred n:
square feet of things for people to look at in order that g;
they can see where all the valves are, I wonder?
ja MR. MATTSON:
Over a hundred complete loss of l
- 3 safety function and safety systems in operating nuclear i
power plants in the United States in the last ten years.
- g COMMISSIONER HENDRIE
Would this system have g.
i saved --
MR. MATTSON:
Three Mile Island was one with 19 l
its aux feedwater system, 20 j
l COMMISSIONER HENDRIE:
Yes, would this system
- 1 have saved them?
MR. MATTSON:
Well, we said no.
COMMISSIONER RENDRIE:
There was after all clear
- .L indication on the the TMI-2 control boards that the aux 3
l s
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i feedwater blocked valves were closed.
Now, goda=mit you 2
i are not going to cure that situation by putting another 2
i i
indication on some place.
If there is anything we have 4
got too much of in control rooms it is bells, gongs and 3
enunciators.
6 MR. MATTSON:
That is the difficulty with that 7
kind of indication.
It is not system function operation, 3
it is cceponent by component and there are so bloody many i
of them, nobody can keep track of them.
l If instead, there is an integrating device that 10 II l
says the aux feedwater system for reasons known to me, 12 and if you want to know, I will tell you the details, but i
13 take my word for it, the aux feedwate. s'fstem does not i
1 14 work.
I 13 COMMISSIONER HENDRIE:
You haven't got that in l
i 14 l
the Sequoyah control room.
17 MR. MATTSON:
Well, that is because reg guide tg 1.47 was nice in concept and not very good in implementation.
If I understand it.
19 COMMISSIONER GILINSKY:
What goes in that category g
21 f hundred that you --
MR. MATTSON:
Pardon me?
l COMMISSIONER GILINSKY:
What goes in, do you --
l l
what was it?
i 24 MR. MATTSON:
Over a hundred complete loss of i
I larforceam '/preATime Zw. m leeg et M CAP'PCE. FfD12*. S. e. RJfTT '87 I
- A1p=GT"Dae.1 1 m
t 8 ACZ No.
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i 1
safety function in an operating nuclear power plants in 2
3 the last ten years.
l COMMISSIONER GILINSKY:
And what sort of things --
4 MR. MATTSON:
Complete loss of emergency core t
cooling, complete loss or, loss of containment, loss of 6
emergency feedwater, loss of emergency power through human i
i or design errors, for varying periods of time.
3 COMMISSIONER GILINSKY:
How many systems?
9 MR. MATTSON:
One complete safety function.
l There is no ECCS or there was no emergency feedwater or 10 loss of the containment, or there was no emergency AC power, 11 I
1:
over a hundred.
is COMMISSIONER GILINSKY:
These fall into how many i
- 2 categories?
It MR. MATTSON:
How many different kinds of systems?
l I
COMMISSIONER GILINSKY:
Yes, roughly,
- g i
MR. MATTSON:
I think a dozen or so safety functions 7
required by the regulations.
I do not have a specific I
number.
19 COMMISSIONER GILINSKY:
That is okay.
MR. MATTSON:
There is some documentation of 21 those things that come from a not thorough going, but sufficient,
];
in our judgment, review of the LAR's from the last ten years to demonstrate those things by plant.
4 We did for lessons learned, which was the basis l
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l for the recom=endation for the loss of safety function limiting condition of operation rulemaking which was in I
the short term lessons learned report.
4 Mr. Kennedy, this was an item that we cocmunicated e
with you on several occasions in the course of the su=mer.
6 We said, having looked at this, that doing something 7
like reg guide 1.47 tried to do may not have completely 3
l succeeded was not enough, we wanted more than machine verifica-i 9
tion and we also wanted human verification of safety functions, 10 i
and that is part of the basis from the onsite safety engineering; l
group, it wasn't what the group was called, but when we 11 1
made the recommendations some months ago --
1 COMMISSIONER KENNEDY:
Well, my concern ran to f
the point which you made just a few minutes ago which you l
- 2 l
1e got literally hundreds of components all of which are being l
tracked but the inter-relationship in the system is, and 4
it was that which you were trying to get to.
MR. MATTSON:
It is clear that we have put too l
- g l
much information in some of these control rooms and one of the things that caused there to be too much were regulatory
,0 requirements to put more and moEe valve and pump and pressure and temperature indicators.
Reg guide 1.47 tried to come to grips with that and talk about safety function status, a simple integrated I'
advisor to the operator as to whether the sta;us was there larT1ptedf*,Csede, V CPGADtis 18eC.
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or not, for reasons known to the advisor, be it a computer, 2
i a micro processor, or whatever that cinched valve positions l
and pump readiness and that sort of thing.
s COMMISSIONER HENDRIE :
I would be cautious about 5
this one, on a fact basis to control room.
6 The only other comment I have on this section 7
is that some of the implementation schedules look to me 2
be intrinsically impossible, and I recocaend that examination l
to be made on the design standard to get straightened out IO l
on these other things as reflected in the documents of l
11 l
the agency, the researches useful enterprise.
12 Any other comments on this section?
l I
13 One E, we have done one.
i l4 COMM1CuIONER KENNEDY:
Have we?
l I
Well, I know the box is on the chart the question 4
is where do we stand?
17 MR. DIRCKS:
We have a new Director and I guess is they have established the office now under Jack Hildemus, pp has established some basic criteria for the new Director 20 t
approve, the work is ongoing in there and a lot of the
- 1 approval of the criteria and the operating philosophy of the office we are waiting for that new Director to appear i
and to indicate whether he is going along with it or how he wants to change it, but it has not been standing still.
l COMMISSIONER KENNEDY:
All right we have criteria, i
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meanwhile, what are they doing?
l COMMISSIONEF GILINSKY:
Criteria, for what?
l l
MR. DIRCKS.
They are looking once enough data 4
will be collected, how it will be analyzed and what sort i
e l
of signals will be thrown up for further cetion, how a i
6 foul up will occur.
i i
I l
COMMISSIONER KENNEDY:
How many people are there 3
physically onboard?
9 MR. DIRCKS:
Well, the people there -- about i
l a dozen that have been detailed from other offices right l
10 i
i 11 l
now.
1::
COMMISSIONER KENNEDY:
A dozen and they are l
there full time?
1:3 I
14 MR. DIRCKS:
They are there full time.
!=
COMMISSIONER KENNEDY:
And how long has that 14 been so?
l 1;.
MR. DIRCKS:
That has been so for about the past 1a month or so, at least.
I know I have had people from NASS l
over there.
g MR. MATTSON:
There have been another of people j
l there for three or four months since Jack Hildemus was i
cade the acting Director.
_a COMMISSIONER KENNEDY:
These are people for the cost part on detail.
There is no permanent staff yet.
I MR. DIRCKS:
Not yet.
I think the philosophy
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was to allow that new Director to have maximum flexibirity.
2 i
He may very well keep on those people who are i
l there.
He may also want to send them back and hire new i
people.
COMMISSIONER KENNEDY:
Okay, now I will come 4
back to my other question.
i i
Specifically, what in cerms of analysis are they i
3 l
now doing?
I 9
MR. DIRCKS:
Kevin, do you have any idea?
10 l
MR. CORNELL:
My understanding is that in terms l
of going into the LAR's and actually analyzing LAR's, there 11 12 is not much of that doing now.
What they are trying to f
l i
13 do is to decide how are they going to sort the score of I
12 these multi-thousand LAR's that currently exist and what
!=
kind of process they want to set up for it.
- 4 COMMISSIONER KENNEDY
Do we have some bench mark that tells that at some given date this outfit is
- 7
- g literally going to be in business or will it continue as f
is so often the case for such institutions to organize 79 itself until it is no longer needed?
.'O l
Let me just tell you that I for one, am unsatisfied
,1 i
with what has haopened in that peration and I believe thy t
.c reflects a lot of talk on the part of management l
sut
.: t very much attention.
That is my view.
24 t
COMMISSIONER GILINSKY:
When is Carl Michaelson I
coming?
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MR. DIRCKS:
He was due in this week, I believe l
l l
l and I still think today was the date I assume.
Oh, next l
Tuesday.
COMMISSIONER GILINSKY:
Well, perhaps he could j
after he has had a look around present a plan to the Commission.
6 COMMISSIONER KENNEDY:
I would like to have a i
l date in which I know that somebody is reviewing the LARs I
l 3
l because nobody is, in the context that we set this thing 9
up and went to work on this proj ect, and my recollection 10 is a long time ago.
11 COMMISSIONER GILINSKY:
I agree with you I feel 1:
this is the most important, if not close to that item 13 l
in the whole response to Three Mile Island.
l
- 4 COMMISSIONER KENNEDY
Certainly.
l te COMMISSIONER GILINSKY:
I think we ought to give i
j Crrl a chance to look around after he has arrived hera 14 I
and perhaps he could then give us a brief paper on how g,
he plans to proceed.
COMMISSIONER KENNEDY:
I do not think, and let 19 I
me just reiterate, I do not think that up to now what has
,.0 been done has received the kind'of management support as
,1 4
contrasted with talk that gets a job done, and I am hopeful
_a that starting this morning we are going to take a different 22 view of that and really put people to work and that means,
i
- 4 of course, getting Carl Michaelsen to focus hard and quick.
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MR. MATTSON:
We put up some awfully good people --
2 l
COMMISSIONER KENNEDY:
1 understand that.
2 l
l MR. MATTSON:
-- into that organization in a 4
1 short term, Commissioner.
e COMMISSIONER KENNEDY:
I understand that.
I
~
6 am fully aware of that.
I t
MR. MATTSON:
That is systems people in the agency --
I I
COMMISSIONER KENNEDY:
I mn fully aware of that.
9 I will be more comfortable when I see something, see a f
date in which something is going to happen, rather than 10 i
II we talk about it.
That is all we have gotten up to now.
I 12 Now, that is management.
l 13 COMMISSIONER GILINSKY:
I think something that i
14 we might also want to hear about is whether we are aiming i
i 13 high enough in organizing our efforts and whether we need l
14 to look for a larger operation than is currently planned.
17 MR. CORNELL:
Are you talking about the number i
13 of staff?
l COMMISSIONER GILINSKY:
Yes, that at least we
- 9
.o l
may want to have a larger operation there.
Perhaps that 3
is something that you will probably want to take a little longer to think about that.
i MR. CORNELL:
There are a number of things that go into that.
For instance, there is an office now under
,4 1
MPA which collects the LARs and processes them.
That function j i
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' remains, just does most of the paperwork.
That function j
remains in MPA and the LAR, the operational data office 3
1 j
does not have to perfore that routine function.
So, there
~
i 4
are a lot of things that go into how many people you physically e
j want to have in that office as opposed to line or INE and
~
i 6
l other offices t-ao some of the collection of the data.
COMMISSIONER GILINSKY:
Well, anyway, we will 3
be looking forward to hearing from Carl, good.
9 j
COMMISSIONER RENDRIE:
In the rest of this item l
lE, the B and C category items, one can hardly be against 10 i
11 l
coordination of programs.
f COMMISSIONER KENNEDY:
Except when it is done 1:2 to the exclusion of work.
t
- 4 MR. MATTSON
Now, wait a minute, that is more i
te l
than coordination, that thing says that you have to worry i
about conflicting guidance on evaluation of operating experiences,
ja I
there are so many. people evaluated and we should not have
- g j
NSAC telling an operator one thing and the NRC telling the same operator the next morning to do something else.
79 Pumps on, pumps off from two different sources
,0 would be even worse than pumps on, pumps off from one source.
,1 4
COMMISSIONER KENNEDY:
The relationship between C
I i
the operational analysis office and NSAC and whoever else 22 is doing this --
24 MR. MATTSON:
You have a nationwide real time t e m voenameO h le
.f aus SOLITW f.Apr?ta. N. L w. Surft TF
pacz sc.
i system today using computers to feedback operating experience 2
i i
to operating plants and then we have a nationwide, not 2
i quite real time system for feeding back information to 4
i l
operating plants.
3 l
Somebody should worry about whether they are l
6 giving them conflicting advice.
I i
COMMISSIONER KENNEDY:
I agree.
i 3
i COMMISSIONER HENDRIE :
There are several elements 9
in here that have to do with data collection.
That data 10 analysis, the task seems to have research determining the l
II l
failure rates from the LAR data and I see the NPRDS has i
12 l
reared its ugly head here again in Number Five and then I
IU l
there is reporting requirements study in Number Six and i
I4 so on; and I wish I had a better feeling that it all 13 fell into a reasonable place.
l 14 COMMISSIONER GILINSKY:
What is going to happen 17 with NPRDS, are we going to study whether to make it mandatory?
13 i
COMMISSIONER HENDRIE:
Well, it says we are going 19 to do a rulemaking and do a study, apparently we are going
.o to do the rulemaking and then we will do the study.
MR. MATTSON:
It is our understanding that you 73 I
issued a proposed rule?
COMMISSIONER KENNEDY:
As a matter of fact, don't I
we have a proposition saying that?
l I
FEL. MATTSON :
You issued a proposed ruling, as larvtmaah Vtpuanne 0.7,,
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1 I understand it.
The day that the steering group decided 2
i j
that nuclear NPRDS ought to be removed from the action l
1*
I plan and delayed two years, and I think you approved it.
i 4
COMMISSIONER GILINSKY:
Who suggested it ought to be brought from there?
e
~
6 l
MR. MATTSON:
We were about on the verge to say l
a person on it since we are going to improve the LAR system i
I and we got all of this operating experience evaluation 9
we are really going to work that approach and try to improve l
things.
NPRDS maybe ought to be thought about a little 10 s
11 harder for a couple of years and give thet other stuff l
i 12 a chance to work.
That is, we would have put it in the l
Appendix, as it was suggested last Monday, about the time is 14 we were getting around to that decision, the Commission I
- e put out an advance notice of intent to proceed with the i
14 rulemaking on NPRDS so we just tried to reflect that in i
- 7 the action plan and forgot about the suggestion.
la We w uld be willing to suggest it again, if you j9 l
would like.
COMMISSIONER GILINSKY:
But doesn't this deal
.A with different sorts of data chan the LAR systems?
g COMMISSIONER HENDRIE:
It is an attempt to i
develop failure rate and failure mode data on a component l
I basis for the industry.
There are some difficulties with 24 it.
There are some utilities that are participating in
$6h YNDM 54
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l it and there are some that are not.
2 l
It is a voluntary program under, I guess it is 1
9 EEI's got it at the moment.
It has got some problems with
~
1 it in the sense that it takes a lot of engineering effort I
t l
to characterize the base. point for the several thousand 6
components that you are going to track in the plant and j
tracking runs somewhere I believe the least number is about 7
i' 3
fifteeen hundred or some participants that are up close 9
to five thousand it seems to me.
10 It trbes a lot of engineering time to characterize i
l each one of these components for the base line and it is 11 l
a substantial investment in engineering time to prepare 12 this stuff, send in the reports, tabulate it; and I must
- 2 say it is not so clear to me that we are getting value i
received out of this stuff.
- e i
l I w uld like to have a much clearer idea of what 16 is it we do with all of this stuff when it is collected g
then is the case at present.
- g I
Particularly, if we are going to have an expanded LAR system.
Later in this action plan there is talk about
,0 other reporting requirements, efficiency reporting requirements
,1 l
under INE's auspices.
I These things need to come together in some rational i
22 fashion.
- 4 MR. MATTSON:
One could argue that we just l
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put this one back in what you would call the Appendix on 2
I Monday, since it was ongoing work of the agency before 3
i l
Three Mile Island, and it is not clear how it fits in given 4
i j
the more urgent need to get on with better evaluation of e
operating experience expressed in LARs.
~
6 COMMISSIONER KENNEDY:
That is not inconsistent t
7 with the notice of proposed rulemaking.
3 MR. MATTSON:
It is not inconsistent at all.
l 9
It is the normal work, otherwise has resources scheduled 10 to it and we do not lose accountability it is still in i
11 l
the document.
12 COMMISSIONER GILINSKY:
Wait a minute, everyone 13 seems to be saying that we ought to make greater use of f
14 l
all these risk assessment techniques.
Don't they iltimately U5 rely on the source of data?
COMMISSIONER HENDRIE:
If I thought this data 14 1-was feeding through in a useful way and was what the risk gg assessment people needed, I feel a lot better, I talked 1
a number of times to people about it and don't come away 79 with a very clear idea that the risk assessment people 3
are in fact getting what they need from, or would get what g
they needed from NPRDS, and that bothers me because I can't 4
see much use for NPRDS except in the risk assessment data base.
i
'4 1
MR. MATTSON:
There is a little theology involved I
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here I think and it depends on whether you are a believer 2
l that you will ever do absolute risk assessment or not.
l l
If you are, then you need this kind of reliability 4
data.
If your theology is that it will never happen in i
your lifetime, then you attach more importance to systems 6
interaction studies and relative reliability studies and i
7 I
evaluation of complex operating experience looking for i
8 recoursers and that sort of thing.
9 That seems to be the philosophical difference i
10 between those who support it and those who can't support 11 l
it.
i 12 COMMISSIONER GILINSKY:
I agree that we ought I
is not gather if if we are not going to use it.
I was under i
l the impressiot; that this was important data for all these la 13 risk assessments that we were so enthusiastic about.
14 MR. DIRCKS:
There was another reason when Bill p
l Mcdonald was here who is a big proponent of the NPRDS, h
he was trying to gather pedigree data, failure rate data, jg i
l on componen::: so that he could track a pattern of maybe
- 9 failure that you can go right back and isolate it to 3
i a particular manufacturere or to a particular run.
3 i
COMMISSIONER KENNEDY:
QA syndrome.
l l
MR. DIRCKS:
It is abnost like that, yes.
That 22 was the reason that he was advancing for that concept,
,1 has that dropped out, or is it a minor aspect of it?
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There are still a few components that are the same in nuclear power plants that might I
l have been a more valuable thought when you were going to build more than you were going to build now.
f I
COMMISSIONER GILINSKY:
Well, you say you are I
6 never going to have significant statistics.
i I
7 j
MR. MATTSON:
Yes, that is the same thing.
3 COMMISSIONER GILINSKY:
Well, it seems to me 9
that we ought to hear from the risk assessment people, 10 the utility of this sort of data.
i 11 l
MR. MATTSON:
Well, what you ought to decide 12 today is whether you want to do this planning in the context l
- 3 j
of TMI actions or in the context of normal work and a normal l
line.
i I
COMMISSIONER GILINSKY:
Well, where have we put
- 3 i
increase use or risk assessment?
Is that in the TMI context, id i
or is that --
1.,
MR. MATTSON:
Yes, the IREP program.
COMMISSIONER GILINSKY:
Well, that is in the 19 i
TMI context and getting the data aught to be in the TMI 20 I
~
context.
II MR. MATTSON:
We ought to think about if the risk assessment people if it isn't worth anything we can i
22 put it in the Appendix.
22 COMMISSIONER HENDRIE:
It is a recommendation I
2 l
in the action plan and note that tha system has serious l
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studies in view of the accident will undertake this re-r 2
study and then there is also advance notice of the proposed 2
l rulemaking to make it mandatory.
I think that before we 4
make it a mandatory action it should be at least a majority l
of the rest of you would be willing to go with the rulemaking 5
i 6
notice to get comments on it before it goes mandatory 7
l if that is the way it goes.
The context is it is set up 3
to supply the risk assessment efforts with really useful l
l material and is it overdone for that purpose, if it is, 9
i
- o it is just chewing up important manpower resources without i
good yield and it ought to be fixed and I recommend that g
we go with that re-study would be done and I suggest because i
it is sort of the work of the r,ency and we ought to straighten l
out quite a part from Three M.le Island, I recommend that it go to the P-cubed G -- well, go to the Appendix of the j
i l
action plan that could be regarded as normal with the agency.
COMMISSIONER KENNEDY:
Which does not in any sense affect the concern which you express if the data is of some use or is essential to whatever it is that the 19 l
risk assessment people propose.
20 So, we will know that,' but you do not have to 21 l
deal with it in terms of the action plan at this point.
{
i j
COMMISSIONER GILINSKY:
I do not know that i j
23 l
l feel particularly strongly about whether it is in this 24 document or some other document.
2 MR. MATTSON:
We have a proposal to make on how i
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we do that Appendix, this might be a good time to do it i
l because I think it will make you feel better and maybe i
Mr. Hendrie not feel as good on this thing and we ought i
I to get the proposal on the table.
3 Our proposal is not to create an Appendix, but i
6 i
to create another decision group, call it D, as in dog.
l 7
Under resources and schedule we would not put a schedule, f
we would not estimate precise resources.
3 i
9 l
We would instead say some standard words which 10 l
I had but I think I lost.
Bob, have you got them?
i COMMISSIONER HENDRIE:
Could this be referred 11
- q to as purple prose?
f MR. MATTSON:
We would simply say under NRC actions
- 3 I
- 3 schedule and resources, this is a decision group D item, i
that is, schedules and resources are to be developed in i
e
- 3 l
context of routine agency, budgeting process.
Those words g
i to you should mean PPPG.
7 COMMISSIONER HENDRIE:
I would say the normal 18 t
i agency budgeting and so on.
I COMMISSIONER GILINSKY.
What was the wording --
COMMISSIONER HENDRIE. ' Routine.
21 MR. MATTSON:
The reason we wanted to do that is one, becar.ie o
'ogistics.
22 l
COME.~ G NER HENDRIE:
I have no problem with 21 it.
I i
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MR. MATTSON:
Good.
There is a couple reasons.
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COMMISSIONER HENDRI2-It is a reasonable way 2
l to treat it and it allows you to --
2 MR. MATTSON:
So, what it does is it leaves it 4
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here in a surmary description but says we aren't going I
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COMMISSIONER HENDRIE:
It means you don't have 7
l to do an enormous edit on that text.
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MR. MATTSON:
Figure out where all the references 9
attached at the end that is the biggest problem.
10 COMMISSIONER GILINSKY:
You know, quite a part 11 from NPRDS, we ought to be thinking about whether these 12 risk assessment efforts are going to have the data that i
they need to chew on.
13 ta MR. MATTSON:
Oh, there is a lot of research 13 l
under way, I shouldn't say a lot.
There is research underway i
14 to look at ways to collect that kind of data.
I
- 7 They have gone to some plants and used logging, la j
the logs, and reviewed the performance data available from i
logs to see whether that is useful for their reliability
- 9 studies.
0 They have looked at ways to derive that information 3
from LARs.
l They have looked at ways to require different 2
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l NPRDS got here for some reason, and it escapes me why, but it may have been the Kemeny Commission that i
had words to say about NPRDS.
I COMMISSIONER HENDRIE:
It is one of those things I
6 which the proposal, to make it mandatory is one of those i
7 things which has been intermittently picked up by assorted 3
groups who are looking around fot some quick set of.bandaids 9
to smack on the nuclear enterprise and here is a handy l
10 one; when you go around and ask people what about making 11 NRPDS mandatory, why the general answer is well, it may t2 not help much, but it probably could not hurt.
COMMISSIONER GILINSKY:
I think GA0 recommended i
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this thing.
g COMMISSIONER HENDRIE:
That GAO recommended it, i
the Presidents recommended it, you know, it turns up in g
every investigating report because it is the kind of thing g,
that people who are not involved in the business on a day-4 i
to-day business have some feeling of where it all fits 19 can pick up and say why haven't they done this, it sounds
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like such a good thing.
Well, it is an expenditure of resources I say out there and it may not be the best one, but I think in the context of looking at it again against the background 24 of these efforts, and its use in risk assessment why that
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l COMMISSIONER KENNEDY:
You adapt to this D item 2
concept very quickly.
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COMMISSIONER HENDRIE:
Well, I have been worrying 3
about the appendix, because I know you set up the action i
6 plan to try to put down all of the things in response through f
our own conclusions about Three Mile and all the investigating 7
s reports and while all of this eventually works into the 9
agency's program guidance documents, why I recognize a 10 l
need to keep for some time to come an enunciation in a separate package of our response to all these recommendations, l
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our own as well as other peoples.
l I have not wanted to throw out of the action
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but I did want some way to identify to sort of make some le.
i kind of separation between the things which are clearly b,
j specifically direct responses to Three Mile Island and 18 i
the the other things.
19 l
We are going to get to a specimen immediately,
- 0 if I convince you to come off lE and go to 1F.
- 1 COMMISSIONER GILINSKY:
Did we just do foreign i
sources.
I notice on some of the things it says letters 22 i
to each of the foreign agreement countries, re-emphasizing
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It seems kind of a long time.
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Haven't they sent them i
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1 COMMISSIONER HENDRIE:
They are waiting for i
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I think that one of the reasons --
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COMMISSIONER KENNEDY:
Could we give them that i
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9 COMMISSIONER GILINSKY:
I propose that we approve 10 that.
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COMMISSIONER KENNEDY:
I certainly second that 11 i
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if that is what they are waiting for.
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MR. MATTSON:
No, I think part of the problem i
l 14 is to get it coordinated with the AEOD, the experience 1.5 evaluation office and not ask for the wrong thing when 14 these letters are sent or say it improperly and get something different than what you expect.
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So, these are a more i
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detailed orders?
COMMISSIONER HENDRIE :
These are more detailed
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technically.
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l MR. HANRAHAN:
What I have seen so far that is j
j IP has compiled a book like that a history of information that has come over, but it is unsorted and undifferentiated 24 and they have something that one could put on the shelf, l
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but I don't see how it would be used because that is existing 2
and I think unless it is clear what you want to ask the folks overseas for in a fairly specific way with some A
i sort of criteria, you are going L end up again with big C
books of ten years of German reactor history which you 6
would have no use for.
7 MR. MATTSON:
Well, I did not mean to say details, 1
3 as you people said, what I meant to say is learn how to 4
9 l
ask a foreign government for operating experience so you 10 get the important stuff, differentiated from the unimportant Il stuff, that is not a trivial task.
It is hard enough 1:
when you all speak English and you are all in the same IU country, evidence, the LAR system.
Id I think that is why they are taking their time.
l IS COMMISSIONER KENNEDY:
Well, if that is the problem l
16 let me just say that we will be awfully careful because 17 I have talked enough with them on this very point to know 18 that by and large that perfectly prepared to deliver all 19 manner of material to you.
20 What they are not prepared to do is sit down 21 and devote their resources to sorting out the specific 22 information and arranging it the way you want it.
23 They figure it is your problem, they will give 24 you the data, that is your problem to how to resort it.
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2 COMMISSIONER GILINSKY:
I am surprise that we are concerned about getting too much.
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COMMISSIONER HENDRIE:
I expected that.
MR. MATTSON:
I just tried to explain a June 6
date, if you want more and if you want to spend the resources 7
to go through them more, we will tell them to go for S
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everything, I guess is what I am hearing.
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COMMISSIONER KENNEDY:
That is what you are likely 10 1
to get.
11 COMMISSIONER GILINSKY:
Well, we will get it 1
and j us t sort it out to the extent.
I MR. HANRAHAN:
I think that is a little --
MR. MATTSON:
You said 20 people a minute ago l ~'
I think you must have meant 40 people or 60 people.
M MR. HANRAHAN:
Well you will get the files dumped i
I7 you and I think that you can become easily overwhelmed I8 with information.
I9 COMMISSIONER KENNEDY:
Which would you rather 20 be, overwhelmed or under whelmed.?
Il COMMISSIONER GILINSKY:
I mean we are in touch 22 when important things happen, we let them know, they let 22 us know.
It seems to be a matter of re-emphasizing the 22 importance we attach to full exchange of information on i
23 safety and it is worth doing.
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I think the appropriate 2
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Additional i
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and experience includes the letters and re-emphasizing e
the importance of the time and regular change, et cetera,
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of other nations in NEA and so on for the exchange.
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10 and, in fact, the way that it is said here represents a U
fair emphasis.
12 It does not say run out and get every damn thing Id in every drawer --
M COMMISSIONER KENNEDY:
It says do what you have IS been trying to do and that comes back to Victor's question, t4 why June 30th and if that is only a question of somebody I7 waiting for us to say, bless you, get on with it, let's la just tell them, they just have been blessed.
19 MR. MATTSON:
We can flag that one and either i
20 get it moving faster or find out why if they are valid 21 reasons why for the June 30th.
22 COMMISSIONER HENDRIE :
Okay, duly prompted.
22 F on quality assurance.
24 Now, the objective in the quality assurance task I
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God, on the other hand, I would not have on the 27th of 6
March as I do today, as I would have five years ago, as 7
I would ten years in the future.
3 I think it is a D item.
9 COMMISSIONER GILINSKY:
Wait a minute.
I think to the thing might be dismissed so easily.
11 It seems to me that there are aspects of quality (2
assurance that we became sensitive to as a result of this i:;
accident and in those areas we ought to be responding.
g2 MR. MATTSON:
I con't agree, but I have been one who has not agreed with this part of the plant for r
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g a long time.
COMMISSIONER KENNEDY :
Why not, Roger?
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MR. MATTSON:
Well, because it comes at the problem 18 wrong.
What this is trying to address is the fact that
,0 there were pieces of equipment --
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COMMISSIONER GILINSKY:
Wait a minute, whose document is this?
O MR. MATTSON:
This is an agency document, not A
my document, NRR has been very strong on this.
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No, seriously, this 2
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MR. MATTSON:
The steering group has brought A
it to you from the line organization of this agency.
3 It is not a task force, it is not a dedicated b
office who thinks only about Three Mile Island, it is coordinating I
steering group --
3 COMMISSIONER GILINSKY:
Composed of --
4 MR. MATTSON:
Representatives of offices.
10 COMMISSIONER GILINSKY:
And items not in here 11 or fail to get in here on what basis?
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COMMISSIONER HENDRIE.
If they were proposed, i
is by a mine group why they got in and less majority of this i
14 steering group felt strongly enough --
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COMMISSIONER GILINSKY:
That is what I am asking.
I td MR. MATTSON:
Less we put a convincing argument l
17 in front of the line then the other office directors that la they should come out and we did put --
19 COMMISSIONER KENNEDY:
The office directors are 20 the people who would make that ultinate decision.
Not 21 you, not the steering group.
MR. MATTSON:
The removal of items has -- we i
have done ones where you could put them in with another l
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of two, or we go to the office and we say wait a minute IN% YNEW
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It does not come from Three Mile Island and if l
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I This particular one, there has been for some 6
weeks, difficulty on my part of what was in here but I i
7 understcnd the reason it is here --
3 COMMISSIONER GILINSKY:
This presumably comes 9
from NRR?
10
?
MR. DIRCKS:
And INE.
'l 11 COMMISSIONER GILINSKY:
And INE.
I:
MR. DIRCKS:
Can't you trace it back to the
- 3 recommendations that came out of the President's Commission i
- 2 report and the staff analysis report?
MR. MATTSON:
Yes, but it is the wrong way to t3 solve the problem.
y COMMISSIONER KENNEDY:
I recall Commissio:._rs 77, on one of them who, a long came back, expressed concern
.s i
that we were not emphasizing the QY, QC kinds of questions to the extent that we might.
i MR. MATTSON:
That is a different question whether we should do better on quality assurance, I do not quarrel with that a bit.
We should do better, but it is a category l
D.
This is the wrong way to solve the problem that it j
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tries to solve that does come from Three Mile Island and 15 t
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The way to come at that is systems interaction 6
and degraded cooling studies, not through more paperwork I
on more equipment under the quality assurance program.
3 Now, through systems interaction studies, if 9
you decide to scope a safety grade equipment it should IO reach more equipment, then you will do quality assurance l
on that equipment and that you do not need to decide it 1T i
through quality assurance, that is my argument against 1:
it.
14 The argument on the other side is but here is f.e a process by which you can accomplish change quickly without 3
a lot of analysis and a. lot of study, study, study and it is appealing because of that.
- 7 COMMISSIONER GILINSKY
Maybe we ought to 3
hear that from a proponent.
g MR. MATTSON:
Do you want to try?
0 MR. O'REILLY:
This test action plant does tie
,1 6
in IREP with this and I think that it is a good argument j
and strong argument and I think the timing of this I think j
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could be delayed but there are a number of systems that l
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systems and the tanks, the pumps, that has never been really QA for the same degree of those items.
A COMMISSIONER GILINSKY:
Because they are not i
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MR. O 'REILLY :
That is correct.
7 COMMISSIONER GILINSKY:
Safety related triggers l
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the QA systems.
9 MR. O'REILLY:
That is correct.
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COMMISSIONER HENDRIE:
It triggers a certain II level.
II COMMISSIONER GILINSKY:
So, is the argument over i
13 what ought to be labeled safety related?
!.s MR. O'REILLY:
It ties in with IREP.
te COMMISSIONER KENNEDY:
But, that is one question.
t4 COMMISSIONER HENDRIE:
I must say that the way 17 to go about that is to think about the system interaction ta problem and about the definitions that we have established 79 for safety related and non-safety related and look at some
.g of the risk analyses things and see if we can find a better g
way to categorize the safety significance of plant components and then out of that in turn will flow a graded set of requirements which will include then the graded set of QA attention and then the QA organization implements that l
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Item Number Seven, increase the size of the QA A
staff, period.
C' mon, I recognize that every group with an interest in the agency will have wanted to see its 5
I particular piece in the action plan but you know, this 7
i one just does not tie in any real rational way to the 3
TMI directed thrust.
I COMMISSIONER GILINSKY:
Well, it sounds from to l
what you are saying that the thing isn't focused properly 11 but it does not sound to me like it ought to go out of 12 here.
13 MR. O'REILLY:
I think some of the types of things i
14 that you talk about here --
i 13 COMMISSIONER HENDRIE:
Well, we were trying to l
f4 improve QA before Three Mile Island, we will be trying 17 to improve QA after, you know it is --
ta MR. MATTSON:
If you are worried about that, 19 then what you do is give emphasis to Item 1 in the parenthesis o
on Page 1Fl.
COMMISSIONER GILINSKY:
Well, but in some sense 21 i
7 we were trying to improve operator training before Three j
i Mile Island, and we were trying to improve operator training after Three Mile Island.
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i You can say that for 95% of this stuff in here.
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But what was the experience from 2
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Three Mile Island that said our QA was wrong?
l COMMISSIONER GILINSKY:
Well, what seems to be i
1 coming out is that we have extended it to a large enough --
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That is not because our QA program 0
was wrong, it was because our definition of safety grade i
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r was wrong. Why was that wrong, because we did not understand 3
how systems interacted with one another in a degraded cooling
?
accident, not about how to apply --
10 COMMISSIONER GILINSKY:
It is not by the way 11 true that nothing in that experience raised questions about QA on the systems that it had been applied to.
12 Is MR. MATTSON:
Not to my knowledge.
14 i
ECCS was Qa and the equipment worked fine, te COMMISSIONER GILINSKY:
All right.
Assuming I
tg that is correct, the question is the extent of the QA system.
l
- 7 MR. MATTSON
The scope of application that is
- g the central substantive thing in this recommendation, there are some other things in here about who the QA person reports 79 to and that has been a question for ten years, how big the QA staff should be --
,1 s
COMMISSIONER GILINSKY:
By the way is that a general agency view that Three Mile Island did not lead j
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were in fact being applied?
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I do not think that is true because I think the INE special review group said QA was a problem but I think more for the reasons Jim has stated --
COMMISSIONER GILINSKY:
It is really the scope 3
of the QA systems.
l 5
MR. O'REILLY:
I think this action plan would i
7 cover the things that I think you identified except we 3
should clean it up a little bit.
This is a lot of d types 9
so we can clean up this item and focus on the IREP and to that type of interaction.
11 COMMISSIONER GILINSKY:
Well, maybe the whole t;
thing ought to be entitled scope of QA activities.
13 But, that does it seems to me flow from our l
- 2 experience.
- 3 MR. HANRAHAN
I think Roger is right in the l
- g QA approach i coming out at the wrong way.
You have to come at it from the -- the problem 77 is the systems engineering the question is not a QA and it requires looking at the way the machine operates at a system and all the inter-related systems to define which of those pieces of it that are important to you and therefore you need to pay more attention to.
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Either through QA or something C
else.
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The fundamental issue is taking 2
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a systems engineering approach, that is what you want to i
l focus on and not what I do as a result of that.
I COMMISSIONER GILINSKY:
Well, I am for QA and systems approach.
3 MR. HANRAHAN:
Well, I mean this comes out four 6
squares, Mr. Hendrie says for QA, I mean you could not 7
warrant that in a better approach.
3 i
COMMISSIONER GILINSKY:
But isn't that other l
7 aspect handled in other parts of the plan?
10 MR. HANRAHAN:
Yes.
I COMMISSIONER GILINSKY:
Aren't you proposing 11 j
that we review par s of this plan that we had not otherwise 13 reviewed, and so on.
g4 Well, this part of it deals with the QA aspect of it.
Having decided to review those other parts of the plant, we also want to b.e applying some level of QA undetermined--
73 MR. MATTSON:
Yes, but we would do that as a 77 matter of normal work, it goes without saying that this Agency has stood fer QA for sometime has applied QA for some time and has done a good job of applying it.
COMMISSIONER GILINSKY:
Yes, but what I hear 21 Joe saying is not necessarily true that you want to apply i
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system to these other areas that there are degrees of
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levels of QA attention --
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It gets rough.
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MR. MATTSON:
Well, he said maybe.
COMMISSIONER GILINSKY:
What you are saying is A
this deals with that problem trying to get that part of e
it straight having decided in some other part of the document 6
what systems it would be applied to to arrive at a rational t
I level of QA.
3 MR. MATTSON:
But, what you are saying is that 9
l you will do the QA after you do the systems interaction
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and IREP kinds of studies which are the next two to three 11 years, which means you won' t do this for two or three years i::
which means it is beyond fiscal year 1982, which means i:;
l it is category D, because that was the definition of
- 2 category D.
I do not know how to keep it in the plan.
g3 COMMISSIONER GILINSKY:
I think I put myself 74 on the on position in defending parts or this document.
- 7 I had nothing to do with the preparation against those who put it together --
- 3 COMMISSIONER HENDRIE
Out of the 12 sub-items 19 under here really the only one that I think is TMI specific
,.0 it ought to be an A item, you know, an approved action
,1 s
plan item is Number 1, the rest of them are what you do in fact in the normal course of business under QA review Jr and so on.
If what they want to do is to whittle it back
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I guess I would like I
l to hear from the offices who wanted this item in presumably it has the support of the Directors of NRR and INE Is that not right?
4 MR. MATTSON:
That is not what I said, I said i
7 the staff and the offices have not concurred in this plant.
3 COMMISSIONER GILINSKY:
I guess I am not clear l
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then how items got into the plant or not.
7 10 COMMISSIONER KENNEDY:
I am confused about what i
we said earlied.
I thought you said that if an office 11 i
r; director wanted it kept in here, it stayed and it could 13 not be taken out unless he said, take it out.
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MR. MATTSON:
Well, the office directors have 73 focused on it the way.you have focused on it, pieces at 14 a time and becuase this one was not a NTOL requirement r a short term operating reactor requirement they have 17 n t yet ade a concurrence on this item along with a number 18 of the cther items'that you are talking about.
COMMISSIONER GILINSKY:
I tell you, this process
,c mystifies me.
COMMISSIONER HENDRIE:
Plunge ahead with my y
recommendation.
COMMISSIONER GILINSKY:
I am willing to plunge
- A ahead.
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Yes.
I COMMISSIONER HENDRIE:
I think if you are going L
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i COMMISSIONER GILINSKY:
I wonder if we could i
6 focus on it?
7 I
COMMISSIONER HENDRIE:
Well, my suggestion 3
l either is the present draft is a D item or one focus down 7
I to the first item on the list if you are going to leave 10 l
it -- what do I call it?
I guess it becomes an A item j
because it becomes approved -- that is we end up here 11 i
12 with A's and D's.
1:2 COMMISSIONER GILINSKY:
I think we ought to i
ga l
get focused to our response to problems that became evident i
l g3 as a result of the accident.
i 73 COMMISSIONER HENDRIE:
Onward.
G, yes we ought t
have a look at the training during the low power testing.
l f,,
MR. MATTSON:
At this point, it is the only one 73 I know in Chapter 1 where we will be adding an item as a result of an investigation, and it concerns the scope I
,0 of the test program for low power testing and it is a minor
,1 addition.
l COMMISSIONER GILINSKY:
Is this essentially equivalent to what we are doing in Sequoyah?
j
- 4 MR. MATTSON:
Yes, Item 1 says do what you
)
are doing on Sequoyah.
ra m v a,u m = ~
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COMMISSIONER RENDRIE:
Is that what the criteria I
i are?
MR. MATTSON:
It says develop criteria case-A by-case over the next few near term OLs, issue those criteria for comment, and then Item 2 that is being added, go back 0
to reg guide 1.68 which specified pre-operational testing I
and factor in what we have learned is good to do by way I
of training and special pre-op testing in the course of i
9 these near term OLc.
f IO COMMISSIONER HENDRIE :
Roman II.
11 What is the status of our effort on siting policy, would somebody remind me?
I:
Is We have been moving toward --
r2 MR. MATTSON:
The paper pending in front of you, te from Tuesday.
74 MR. HANRAHAN:
It was on Tuesday, two more studies,
- 7 one on the site policy tests of sites and a very short decision memo from my office encouraged you to focus your 73 discussion on that' Tuesday.
g t
COMMISSIONER HENDRIE:
We had fairly extensive g
discussion about the citing policy task force report, back 1
4 about a year ago or something like that, do you people l
remember?
MR. FONTECILLA:
Last Fall.
- 4 i
COMMISSIONER HENDRIE :
Last Fall.
I do not recall i
w that we came to any conclusions'here at the table but that f arTUlsaanconaa. '#tyrmanas h f anc et E3tT%e N fTietIT. A e. surTE sf
- ^2 HG% 1" as
n ez se. u t
t the matter was to be recycl for further meetings and I
what happened then, we got involved I guess in the events i
of late October and thereafter.
.t.
t MR. HANRAHAN:
So, that comes to past Tuesday just to provide some guidance, direction for the rulemaking.
MR. MATTSON:
Staff is waiting for you to decide I
l on the direction proposed in 0625.
3 The Staff will then develop interim criteria 7
for use with pending cps and some plants under construction to i
while the rulemaking is underway for new cps, but that i
11 is essentially what the plant says on the site.
12 COMMISSIONER GILINSKY:
In other words, it is is up to us to deal with this staff recommendation?
t.t l
MR. MATTSON:
In the context of the NUREG 0625 13 deciding policy task force recommendations and not just 74 not the task force recommendations at this point, I think
- 7 they have come up with office endorsement, and when you 18 decide on the directin to proceed on the rulemaking that will trigger a staff issuance of interim criteria for 79 pending CP applicants and some plants under construction
.g the work on those interim criteria has perceived in the meantime, but is hard for them to write the specific i
requirements, alck of decision on 0625.
COMMISSIONER GILINSKY:
Let me just take you 24 back once again I did not fully understand what pertinent i
~3 i
i-% v-m.
_. _ i e j
.um -
i
~
I item in here or took it out.
There is a steering group 2
(-)
that reported what the executive director and it is in its i
I f
final stages at any rate --
A i
l MR. MATTSON:
Has for three months.
l
~
COMMISSIONER GILINSKY:
Right, they put this l
together and in Item -- and you are the chairman of the i
steering group?
i 3
MR. MATTSON:
That is right.
t 9
i COMFESSIONER GILINSKY:
And an item went in here 10 or did not go in here precisely on what basis?
11 l
MR. MATTSON:
We started with the letter from the Commission to the White House on November 9, the press is letter --
I COMMISSIONER GILINSKY:
Right.
t.t i
t.g MR. MATTSON:
And tried to develop a consistent rd and adequate response to. the recocmendations to the Kemeny
- 7 Commission with that as a base and guidance from our 73 Commission we factored in the President's decisions in early December, we have kept accountability with all of the ACRS 79 re mendations, trying to use, where possible, to use their 20 advice and guidance in specific recommendations where they were responsive to what we though the Commission concluded i
and of of course responding to the Kemeny Commission.
I We have kept similar accountability for all of
- 4 I
the internal NRC studies, the INE study, the NRR Lessons
,i me
&Y OH We n H j
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and now we are factoring in all of the Rogovin recocmendations.
i 2
( )
l When the steering group felt that someone had I
e l.
an idea that went overboard or missed the point, we were not bashful at telling them so and in some cases they 3
changed them and in some cases they did not.
6 We took draft one through the office directors 7
in early December, mid December asked for their concurrence 3
and they did not give their concurrence.
f They said they wanted to see some prioritizing, 9
10 i
as you did, they wanted to see some further refinements, as you did.
t; i
r; People have offered us guidance on how to make
- 3 those refinements and we have been trying to make them.
i At this point, you have not concurred in the plan, g
nor have the office directors.
Both of you, however, have g
concurred in portions of it, the short term lessons learned g
you concurred in before the plan was ever drafted.
The NTOL list you have concurred in last week, you also concurred in the category C decision items in the sense that you have not removed them.
20 You have removed a few of them to category D 21 when you do not remove them to category D you are implying a decision that you want to see them again in a separate
- 2 paper studying the alternatives and the pros and cons i
- 4 because you agree with the steering group that that is 2
l a subject highlighted by Three Mile Island warranting r.,,
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l further study.
l Now, the theory is when Draft Three comes through l
the line, after the steering group has taken your comments, and Rogovin and ACRS advice, put e.cgether Draft Three, the I
Draft Three will come to you with office director concurrence 6
or specific reasons for non-concurrence.
That is a full l
7 staff recommendation on how to approve or not approve the 3
action plan.
9 I
COMMISSIONER GILINSKY:
Now, in their review of bhataretheytakingit as given the parts of this are l
to j
11 approved or not approved by the Commission?
I:
MR. MATTSON:
They have the same information in gg front of them that you have in front of you.
- 4 Decision Groups A, B, C.
They know that the A's
- 3 are approved.
g COMMISSIONER GILINSKY:
And by the way how did you keep --
i MR. MATTSON:
Remember in December we talked about the problem with taking the time to do this because the office directors know that there are some things they have to get started and how they had to go out on a limb to get Il some of those things started without full concurrence that C
those were the right things to do.
O In scme cases that has worked well, in some cases, 24 l
it has not.
I think you saw one in the Sequoyah example the l
2 I
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other day as to whether the cperator licensing branch had r
2 l
begun to implement something in 330E.
The steering group had understood that they had i
L and what we found out Tuesday is that they hadn't when we thought they were going to do it.
6 We had it in here as approved and they thought 7
it was still pending.
3 There has been some minor instances of confusion i
9 otherwise the office directors can use it as a planning 10 l
document for understanding where they are with your concurrence.,
it i
COMMISSIONER GILINSKY:
Now, in the steering group, I2 did you work by majority vote or was --
I3 MR. MATTSON:
Yes, we did.
Il COMMISSIONER GILINSKY:
It was by majority vote.
13 Okay, should we run to a quarter tc twelve or --
id Do you mind if we go on with this?
l 17 COMMISSIONER KENNEDY:
No.
18 (Whereupon, Commissioner Kennedy pp left the proceeding at 11:30)
COMMISSIONER HENDRIE:
I think the number one here, g
21 the policy -- the siting policy rulemaking when we had this paper coming up and we clearly are moving in this direction l
=
and I have the impression that if we do not, the Congress 7
may anyway.
So, I think that is appropriate.
l 1
MR. CASE:
Well, just to expand a little bit on i
introu m Vara m u -,
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i shat Roger is saying because this is to be the example this
/
is one --
I COMMISSIONER HENDRIE:
Take yes for an answer.
4 MR. CASE:
It could have a profound effect on what we do in construction permits, depending on how the l
6 Commission grandfathers or does not grandfather this new i
7 siting rule.
l 3
l COMMISSIONER GILINSKY:
You are talking about 9
Part Two here?
10 l
MR. CASE:
I do not know what part it is.
COMMISSIONER GILINSKY:
It is a big number.
MR. CAEZ:
We have not been working on construction 12 13 permit reviews in light of this policy question, and in the l
light of other considerations too.
We do not have a lot I
of man power.
g COMMISSIONER GILINSKY:
Well, let's see, you are
,4 not hanging this entirely on this --
COMMISSIONER HENDRIE:
I hope it is the manpower and not because we have not acted on the siting policy task 19 force.
- o MR. CASE:
Some of each.
Il COMMISSIONER HENDRIE:
You better get ready to O
act on Tuesday, Vic.
2 MR. MATTSON:
The problem here is not acting on 24 the action plan, if 0625 were approved, the staff could move l
-e with the interim policy statement on siting, independent of l
mea.s va
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t of whether this point portion of the action plan was approved I
or not.
I I
8 MR. CASE:
I think I will take yes for an answer.
COMMISSIONER HENDRIE:
Under site evaluation, 3
once you know what we are going to do with what is it 0625 i
4 or something like that why you look at the cps and CP applications t
7 and it is clear enough about the application how far up the 3
line the plants in construction even accomplished this review i
9 of where to site a plant on which they already dug the 10 I
basement and have a lot of concrete poured.
MR. MATTSON:
Well, that is why this is a category 11 12 C item, they are going to develop an analysis and come up i
I
- 3 and make a proposal to you and let the Commission decide that
- 4 point.
We thought that was consistent.
l COMMISSIONER GILINSKY:
Well, it seems to me that g
in some sense you have to look at all the plants although i
g the standards you would apply would be very different depending g.
on how far along you are --
MR. MATTSON:
In some sense you have to look at it as standards may vary, the staff will do an analysis,
,0 make a proposal and --
COMMISSIONER GILINSKY:
We are looking at operating O
plants, at the site of the operating plants and we have said j
2:
l that we have not ruled out the possibility of shutting down l
- 4 8
operating plants if we find that the public can't be adequately 2
l
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(
l think we got to look at i
2 MR. MATTSON:
That this item two does is accomplish 1
a transition all the way from plants that have not yet started 5
construction to the plants on which we are considering shutdown 6
as one alternative because of their site, Indian Point design.
l 7
COMMISSIONER GILINSKY:
Obviously, the threshold 3
goes way up as the plant stage of construction goes up?
i 9
MR. MATTSON:
Yes.
In deciding the plan you do go not decide that issue, all you decide is yes, that is something you want the staff to bring back to you with the full analysis so that you can understand how to draw those thresholds.
i i
How to write those thresholds.
I,a i
l COMMISSIONER HENDRIE:
Item Two B of the first Three la i
I are things that are in the short term lessons learned and i.!
l have been going ahead with training of B item seems reasonable.
Five and Six are research and --
17 MR. MATTSON:
It is an 70L --
13 COMMISSIONER HENDRIE:
les.
19 I have no problem with either of those two things, 20 aside from commenting that there'are some fairly husky 21 dollar chunks associated with some of these research efforts
=
l Item Five is worth over twenty million dollars in l
w
~
fiscal '80 and '81.
22 So, you know, you are looking at some fairly good i
~
size of research programs.
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i The other comment on Six was that I seemed to --
f~
l let's see --
(Whereupon Commissioner Bradford walked in at 11:45) 6 COMMISSIONER GILINSKY:
Oh, is it time to quit?
i I
l COMMISSIONER BRADFORD:
I thought you might mean i
3 i
sit there and vote to adjourn.
9 COMMISSIONER HENDRIE :
I think he ought to be f
simply listed as present at this session and you know bear to I
11 i
responsiblity in the full measure.
t; COMMISSIONER BRADFORD:
The transcript's note the l
- 3 point of time of entry.
COMMISSICNER HENDRIE :
Let's see features to cope
- 4 i
with core melting.
t2 l
Well, this is what we are doing with Indian Point, f4 Zi n and so on.
17 The containment inerting.
Now, let's sec, haven't 18 we met this question before?
MR. MATTSON:
This is the short term lessons learned. !
- o l
I am sorrry, it is an NTOL requirement, you approved it last i
II l
Thursday, the paper has not reached you yet.
l COMMISSIONER GILINSKY:
Let's see the requirement 22 1
being what?
l
- 4 MR. MATTSON:
That NRR brings to you a paper describin'g L
lOM 'dNUllE I4 veawm as m2119e CAMTot. ff1ra? L s. sJrft :#
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an interim position on the hydrogen control matters for small j
containments.
I COMMISSIONER GILINSKY:
But we have never adopted any such positions?
3 l
MR. MATTSON:
No, the paper has not reached you.
6 COMMISSIONER GILINSKY:
Okay.
7 j
COMMISSIONER HENDRIE :
But we have said the paper i
3 aught to come up?
9 COMMISSIONER GILINSKY:
Yes, when is that coming to I
up, is this something that we ought to be thinking about j
in connection with Sequoyah?
i MR. MATTSON:
Yes.
COMMISSIONER HENDRIE :
I think the paper is going r3 l
f gg to come up and say Sequoyah does ncs fall into the category l
of inert containment.
- 3 l
l MR. MATTSON:
Let me check if it was a fuel load l
,O I
or a fall power.
I7 i
COMMISSIONER HENDRIE:
What we are talking about I
is a small volume containment, 19 j
MR. MATTSON:
You decided last Thursday that l
- o you had to reach a cecision on what to do with small containments Il before you allowed a near term OL go to full power is how the near ters OL requirement is stated.
So, NRR has to bring you the paper which is close --
- 4 COMMISSIONER GILINSKY:
How close.
MR. CASE:
I would expect next week, I hope.
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I MR. MATTSON:
Then you reach a decision on what
(
i i
to do --
e t
COMMISSIONER GILINSKY:
I would at least like to A
see that before we act on Sequoyah even though we have tied I
l t
it to the full power authorization, even if we could have
~
6 a draft of that I think it would be helpful.
l I
COMMIS3IONER HENDRIE :
Well, let's see are you 3
looking for Commitsion action Vic or some chance to look 7
into personally?
10 COMMISSIvi ER GILINSKY:
The chance to just look at 11 i
it.
I:
COMMISSIONER HENDRIE :
If the paper hangs up is why ycv might get yourself a briefing as a way of knowing
- 2 what the staff thinking is on the matter.
l l
te COMMISSIONER GILINSKY:
Or perhaps they can simply tell us about it in the meeting insofar as it relates to 3
that particular plant.
- 7 COMMISSIONER HENDRIE
Okay, I understand, 73 The rulemaking on degraded cores is proposed as g
a way of dealing with what could otherwise be case-by-case
,0 litigation of soma of these issues.
I guess that is a reasonable way to go.
I MR. BICKWIT:
Yes, we do not regard that as l
a way to handle that problem.
Yes, that will not get you 04 l
out of case-by-case --
2 COMMISSIONER GILINSKY:
The rulemaking?
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MR. BICKWIT:
Yes. It is a proposed rule it has l
(
not binding effect on the boards.
t MR. MATTSON:
Even when you combine Item Seven and Eight?
A COMMISSIONER GILINSKY:
Let's see, what is it that 6
we are trying to do to keep from going on in individual 7
proceedings?
MR. BICKWIT:
I think it is a good idea to have 3
l a rule if that is the reason, if that is the reason you are g ing a ter it.
It w n't acheive that obj ective.
10 l
l COMMISSIONER HENDRIE:
If going to rulemaking on
,l i
a an item doesn't save you litigating that item in individual t,s I
cases, but only has the ultimate merit of putting on the l
ia i
Commission's books rule, why I find --
COMMISSIONER GILINSKY:
The final rule does it I.!
but a proposed rule he says does not.
It is only in --
MR. BICKWIT:
One of the purposes of going to 17 rulemaking is to achieve that objective.
fa The issuance of the proposed rule on its own 19 does not achieve that objective.
- c COMMISSIONER HENDRIE :
Is there a mechinism to 21 enforce it to achieve that obj ective, otherwise, you see if C
l there is not a mechinism to do that, what I am going to say i
is if we are going to have to litigate while we have got l
2 a proposed rule on the street and go forward ir parallel, j
~
I do not find much sense in that.
I just as soon in that f
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case litigate it on a case-by-case basis and after a year
/
or two use the experience of those assorted litigations f
to form a proposed rule, but I see no reason if we are 1
going to have to litigate 17 cases to go in parallel with e
a rule making which will also carry have the same material 6
in it, the whole point of the rulemaking as an early and I
aggressive effort would be to try to concentrote the i
3 l
litigation over these items into a generic proceeding.
7 COMMISSIONER BRADFORD:
Is this the kind of 10 issue you would be likely to have to litigate in 17 proceedings?
11 MR. CASE:
There is clearly a rule on the books on how much hydrogen so that is not lir.igab le.
There is f2 I
r3 implicitly rules on the books on degraded core performance.
ra COMMISSIONER GILI?iSKY:
Let's see isn't that a l
g3 matter --
MR. CASE:
Bec.ause we do not consider as part of g
the design basis --
7 COMMISSIONER HENDRIE:
But, Ed, you are going to la get an assault just as you have in TMI-l proceeding on the g
Commission's rule on hydrogen and the Commission's rule on
,.0 how much degraded core you take into account and I think the difference without instruction from the Commission one way or another I think the boards are going to find it very l
22 hard to say no, those are unacceptable assaults on the
- 4 Commission's rules.
i I
U l
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MR. CASE:
That is the purpose of our proposal
^
2 l
was to do just that and consider what can be done on the rule t
3 in the rulemaking --
4 COMMISSIONER EENDRIE:
What he is saying is that 5
f until you got a final rule which --
6 MR. CASE:
No, unless you have a rule --
7 MR. BICKWIT:
You got a rule now.
l 3
I gather the existing rule is subject to a number of interpre-9 l
tations and the staff would like to and those you can litigate to with respect to that interpretation, you can't go in there and say it is not litigable because this is our interpretation.
g Now, if you want to sanctify that interpretation to a rulemaking which I gather what you want to do and it seems i
37 a legitimate purpose that will achieve the objective for g
including litigation after the rule becomes final.
You make that rule i= mediately effective it becomes l
l final immediately and achieves the obj ective at that point.
MR. CASE:
I know a proceeding on the premise that under our present rules requiring emergency core cooling 19 systems and all that that any significant degradation of 20 the core is outside the gambit of our present rules.
- Now, 21 it is now all neatly written down in one particular section, C
but considering the regulations as a whole I think that is C
true at least the staff is proceeding in that assumption --
l
- 4 COMMISSIONT' GILINSKY:
But in the light of our
~
experience, how can we go on this way?
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MR. CASE:
I am not suggesting that we should not l
study as to what we ought to do about that and that is the I
purpose of the rulemaking but the question is that Glen is A
raising what is the position in the meantime?
t~
He seems to be saying that if it is not explicitly 6
l set down in some rule, than the present position is litigable.
MR. BICKWIT:
If the rule is on the books is subject 3
l to different interpretations, the parties can raise those I
3
~
interpretations in the normal --
10 i
MR. MATTSON:
But, I do not think they are subj ect II to different interpretations it says five percent metal r I2 reaction, not fifty.
l I
l MR. BICKWIT:
To the extent that they are not the I4 objective is achieved.
I.!
COMMISSIONER HENDRIE:
Well, as a practical matter, r4 you are going to have a-tough time convincing boards that 17 they ought to accept the contention from a party that the ta five percent rule needs --
- 9 MR. MATTSON
That is what we are trying to get 20 you to say is through a notice of intent to tell the board 21 y u want it held for rulemaking.
COMMISSIONER HENDRIE:
He is saying that that l
=
[
t notice of intent doesn't wash with the board and that won't g
keep it out of litigation.
3 MR. CASE:
He is not saying that --
f mewo
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i COMMISSIONER HENDRIE:
Yes, he is.
I I
MR. BICKWIT:
Yes he is.
COMMISSIONER HENDRIE:
See, ne is.
MR. CASE:
He is saying if there is a five percent t
on the books, then that is the Commission's rule --
0 l
COMMISSIONER HENDRIE:
No, he is not, da=n it, what 7
I am telling you is that rules about degraded core because 3
i of the Three Mile Island --
9 COMMISSIONER GILINSKY:
Order, order.
10 are vulnerable in spite COMMISSIONER HENDRIE:
ti of the fact that there are rules on the books.
t:
We have a procedure, we have a rule which says you r::
can challenge a rule of the Commission if you have a basis la to show in a given case that it may not be applicable and what I am telling you is that we have already seen TMI-l t.5 T4 go in that direction and we are going to see it in every other case that comes up on these matters of degraded core
- 7 and hydrogen.
g bo, what I am telling you is, yes, there is a g
hydrogen rule on the books, and it ain't going to keep you
,0 out of litigating hydrogen in every case.
,1 4
Now, what I thought was that there was a way j
to go forward with a rulemaking and try to concentrate that l
litigation on hydrogen in the generic proceeding.
I
- s What Glen is telling me is that does not sound I!
like it is going to wash with either.
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MR. MATTSON:
What if you put out interim requirements t
l for inerting some small containments as your interim approach as an ic=ediately affective rule while you were conducting rulemaking on what else you ought to do, that is the proposal 3
l on the action plan.
It has been the proposal for some time.
6 The primary concern is hydrogen and there is an 7
argument one can make and that is the paper that is coming to 3
you as to what you ought to do i= mediately about hydrogen l
7 why you conduct a rulemaking on the other secondary questions 10 over a longer period of time.
ti MR. BICKWIT:
It won't bind the boards.
COMMISSIONER HENDRIE:
I must say if it won't i
if ther is not reasonable or the Commission decides it does 73 not want to bind the boards to see these matters dealt with
,2 only in a generic proceeding, if they are going to be litigated g
possibly, most likely an individual proceeding then my view is the rulemaking is of considerably less importance and that we may as well go ahead and the staff make up its mind what
,8 6
its position is on these things and present that position in the individual case = as appropriate and after we develop 20 some experience, then it may become clear to us what we would il like to see as a rule and make a simple proposal and go after that.
Well, you know, if you don't like that then what 2
you do is everything I just said, plus, staff rulemaking beside !
i
~
it, you rather do that than the straight litigation?
Why?
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i MR. MATTSON:
No, I as agreeing that that is the 2
l only other alternative is to do them both sLnultaneously.
i MR. BICKWIT:
Well, if you have confidence in A
where you are going on the rulemaking, you can move the rulemaking quickly, meanwhile litigating the matter case by case.
I MR. MATTSON:
It becomes a question of resources 3
of the availability, of competent people to deal with this l
subject is not that high, you can't do it in rulemaking, I 9
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mean ten individual proceedings and a rulemaking simultaneously 11 you haven't the resources.
12 COMMISSIONER GILINSKY:
I propose we adjourn at l
13 l
this point.
t2 COMMISSIONER HENDRIE :
It seems like a good place te to adjourn.
I recommend some thought on it, you know, I t4 am not saying take the rulemaking out or make it a D or 17 anything else, I am just saying yog know if the counsel thinks we can't do what this thing was intended to do which is to
- g focus as a generic proceeding of th.se matters, then it
- 9 does not make much sense to me to hop forward and throw 0
the staff resource into doing it.
MR. MATTSON:
I agree with you.
COMMISSIONER HENDRIE :
We can run it like we did 2
fuel densification where we litigated in a major way and
,4 about two or three cases and after that it died down and
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those things stood as precedents.
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i We never did make a rule out of it.
Maybe that is the way this one ends up.
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A COMMISSIONER GILINSKY:
Okay, thank you.
6 (Whereupon the conference was i
I adjourned at 12:00 a.m.)
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