ML19308D005
| ML19308D005 | |
| Person / Time | |
|---|---|
| Issue date: | 01/31/1980 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8002130067 | |
| Download: ML19308D005 (80) | |
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i UNITED STATES N UCLE AR R EG UL ATORY COMMISSION l
l In the matter of:
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CONTINUATION OF DISCUSSION OF l
POLICY, PLANNING AND PROGRAM GUIDE f
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Place:'
Washington, D. C.
Date:
January 31, 1980 Pages:
1-79 i
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I INTERNATIONAL VsnsATiu REponTrns, INC.
408 SOUTH CAPITOL STREET, S.W. SUITE 107 WASHINGTON, D. C. 20002 l
202 aan.m 8002130 (N7
1 UNITED STATES 2
NUCLEAR REGULATORY COMMISSION 3
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x 4
In the Matter of:
5 CONTINUATION OF DISCUSSION OF I
6 POLICY, PLANNING & PROGRAM GUIDE :
7
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x i
8 9
Room 1130, Eleventh Floor 1717 H Street, N.W.
10 Washington, D.C.
11 Thursday, January 31, 1980 12 13 The Commission met, pursuant to notice, for 14 presentation of the above-entitled matter, at 1:30 p.m.,
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15 John F. Ahearne, Chairman of the Commission, presiding.
16 BEFORE:
17 JOHN F. AHEARNE, CHAIRMAN 18 JOSEPH HENDRIE, COMMISSIONER I
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VICTOR GILINSKY, COMMISSIONER lj[
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PETER A. BRADFORD, COMMISSIONER hj!j 22 r
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PROCEEDINGS 1
CHAIRMAN AHEARNE:
We have a quorum.
2 So, the purpose of it is to continue on with
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3 our progress towards -- and all the glowing words can 4
be inserted for the record.
5 We really come this afternoon, I think, to 6
address the planning section of the guidance document.
7 MR. HANRAHAN: If you recall the last session, 8
we made it through the policy section with some direction 9
from you for additions and changes.
We have made those 10 and hopefully correctly --
11 COMMISSIONER GILINSKY:
Can you remind me again l
1 12 in your view, is this planning section differ from the 13 policy section only in the level of detail, or is it 14 quantitatively different in some way?
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s 15 MR. HANRAHAN:
The Chairman' explained it j
16 eloquently at the last meeting.
However, in my humble 17 fashion I will try.
I view the policy statement as a 18 statement of principle.
The planning section as a 19 statement of course of action that follows from that jy 20 principle and the programming section would be the II3 21 detail of how that course of action would be carried geg I:.
22 out.
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So, it is a progression 24 in specificity --
11
- 2:
25 MR. HANRAHAN:
So, it is a progression of more
1 and more detail.
So, going from a statement of principle 2
to a course of action to the implementation plan for 3
that course of action.
I 4
CHAIRMAN AHEARNE:
And also less permanence 5
to the -- you get more detail, more specifically --
i 6
COMMISSIONER GILINSKY:
Well, obviously, 7
MR. HANRAHAN: Well, the policies could indeed 8
have an everlasting life --
1 9
COMMISSIONER GILINSKY:
Now, where do you feed 10 in the fundamental assumptions which underlie some of 11 our instructions.
In other words, we assume that there 12 will be so many reactors one has to deal with, or so l
13 many applications or something of this sort.
i 14 MR. HANRAHAN: Well, I think that could be in 13 planning.
16 CHAIRMAN AHEARNE:
I think there are two kinds 17 of -- they are truly fundamental assumptions ought to 18 be in'the plan.
That is right.
19 COMMISSIONER GILINSKY:
You mean the laws of j g 20 nature --
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CHAIRMAN AHEARNE:
Well, no --
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22 COMMISSIONER HENDRIE:
Those are policy.
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23 CHAIRMAN AHEARNE:
Good.
Another convert.
3I:a 24 gg COMMISSIONER HENDRIE:
I just wanted to inquire 2 8 25 if you are now ready to stop fighting this concept
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that the rest of us have been pushing for so long.
2 Is that what I infer from your request?
3 CHAIRMAN AHEARNE:
I am glad of that.
4 But,.you are right to the extent that for example, 5
if it is a major determinant of the staff resources, 6
like how many applications are they aiming at?
7 COMMISSIONER GILINSKY:
In what Joe calls the 8
golden days.
I remember Ed and I used to put in twenty-9 five application CP's per year and ten OL's per year --
10 COMMISSIONER HENDRIE:
Right.
11 COMMISSIONER GILINSKY:
-- that then translated 12 into how many people Joe had.
13 MR. HANRAHAN:
We said twenty-five, he said 14 thirty-five, if I recall.
15 CHAIRMAN AHEARNE:
For those that are a major 16 determinant of staff resources that ought to be inclined.
17 MR. HANRAHAN:
Let me ask Norm, if we are 18 at all in the programming costs --
19 MR. HALLER:
I would think a major element --
jg 20 CHAIRMAN AHEARNE:
Why don't you join us, Norm?
Ij 21 lg There is plenty of room.
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22 MR. HALLER:
I would believe that major elements l3
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24 that drive staff resources probably should be put into I I 25 the planning guidance.
There would also, however, be
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lesser assumptions which are unique to individual programs 2
that, in the program section, with each program write 3
up, one would have assumptions that would go along with 4
those particular programs.
5 COMMISSIONER GILINSKY:
Well, are there assumptions 6
here, for example, about numbers of new applications 7
one might have to deal with over the next several years 8
or --
9 MR. EALLER:
I believe at one time, in an 10 earlier draft of this we had inserted some assumptions, 11 but if I recall it was something to the effect that there 12 would be no new applications for several years.
13 I am not sure what happened to that in the 14 process, but --
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15 COMMISSIONER GILINSKY:
Because I presume that 16 then has. implications about your ability to use persons 17 who would otherwise be employed in that period.
18 COMMISSIONER HENDRIE:
It sets the programming 1
19 from there on up.
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20 MR. HANRAHAN: That was in the first draft 6
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that came up from Norm's office and was removed and I z,. e 22 I g.,
am at a loss to say for what reason it was removed in
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I don't really recall.
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COMMISSIONER GILINSKY:
Are there any other 2
such assumptions, and I assume that there are --
3 CHAIRMAN AHEARNE:
Well, there was once also 4
another type of I think major planning assumption. which I 5
intended to bring up but I don't recall seeing here 6
when I read it through last night as on waste management i
7 what will drive part of their program assumptions as on 8
when a repository application will be made, like a I
characterization plan.
How many sights?
That is a 10 basic planning assumption which will drive a large 1,
segment to their resources.
12 COMMISSIONER HENDRIE:
It unfortunately changes 13 from time to time and not necessarily in a time pattern 14 which is convenient for our development of our policy l,
15 documents.
16 CHAIRMM AHEARNE:
No, but Vic's right because 17 those are the planning tools that the guys preparing 18 the budget is going to start using whether we put them 19 in here or not, so ve ought to just say here it is --
f3 20 COMMISSIONER GILINSKY:
Yes, and you would l1[
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like those to be uniform --
22 CHAIRMAN AHEARNE:
Yes, right.
1si 23 COMMISSIONER GILINSKY:
-- throughout the agency.
1: 1 24 CHAIRMAN AHEARNE:.That is right.
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- 5 COMMISSIONER GILINSKY:
It occurs to me that
7 1
in the mi11 tailing area, it is not obvious whether j
2 all the States will comply with the new requirements, 3
the grievance states, whether all of those activities 4
will continue to stay regulated.
There is another 5
area where we may have to make an assumption about what j
6 fraction of them will continue to be State regulated, 7
and so on.
There must be a whole host of these, and 8
I would think that we would want a portion of the 9
document devoted --
1 10 CHAIRMAN AHEARNE:
That is right.
11 COMMISSIONER GILINSKY:
-- to some of these 12 fundamental assumptions that drive, you know, the 13 amount of work that needs to be done.
14 CHAIRMAN AHEARNE:
And, in particular, the sooner l
15 we could, as a Commission, focus on those, the better 1
16 off we are, because I would much rather focus on l
17 Number 4 of that budget cycle comes to its end rather 18 than in the middle of a budget review find that we have i
19 a fundamental disagreement on the assumptions that underlie 11 20 how they were put together.
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MR. EANRAHAN: Well, I think those assumptions ita I
tjg 22 are absolutely essential for the budget formulation and
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23 will be necessary for the fiscal guidance that is given js!
ri' 24 to the staff --
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- .I g 25 CHAIRMAN AHEARNE:
Yes.
8 1
MR. HANRAHAN: -- if they are not in planning, 2
they have got to be in the fiscal guidance.
3 CHAIRMAN AHEARNE:
Well, but they -- to the 4
extent that they can and particularly the large ones 5
ought to be in planning.
6 MR. BECKERLEY:
There is another series we 7
have got oh, about a month ago I guess, we got a report 8
from DOE on what they estimated they would be asking 9
what safety reviews they will be asking of NRC during 10 the next several years, and those certainly underlie 11 some of the plans.
12 COMMISSIONER GILINSKY:
The reason I was asking 13 about all those planning and programming is that I 14 think the way, I know that when these three levels s
15 of specificity from policy to programs, I guess the 16 way I would have done it is to have policy which translates 17 into programs and planning being another category which 18 contains the basic assumptions of the sort we are talking 19 about here.
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20 CHAIRMAN AHEARNE:
The reason I would urge us t'
l-21 to use the planning programming side is that after we a :.g 22
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have established the basic policies, and I think we really i5!
5II 23 still have a greater level.of involvement in planning 24 because there still are Commission level guidance and I
'3 the programs there is a lot more that has to be developed i
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9 1
by the staff.
2 COMMISSIONER GILINSKY:
But, at any rate, there 3
are two kinds of planning it seems to be --
4 MR. HANRAHAN: Yes.
5 MR. HALLER:
Yes.
l 6
MR. BECKERLEY:
Yes.
7 COMMISSIONER GILINSKY:
-- the final planning 8
assumptions and the planning --
9 MR. HANRAHAN:
The programming portion which is --
10 COMMISSIONER GILINSKY:
-- translating policy 11' into action.
12 MR. HANRAHAN: The programming portions is Part 13 3 of this on that list in the back being developed by i
14 the staff under Norman's direction and the pieces of 15 it have already been distributed to the Commission i
16 to those which have been completed.
17 To what extent of those, and I don't remember 18 if they are premised by some other types of assumption?
II MR. HALLER:
Well, there are planning assumptions 20
.l in each of these program write ups.
It is hard for me 21 e%l to characterize them as exactly whether they are big lk*!.
ones or small ones, but I would like to go back to the I
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Sfl principle for a moment.
I think the very large planning 23 1..
i lf assumptions that would drive overall staff resources, 24
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number of applications, for example, would be a good one,
10 1
the waste management data.
That sort of thing might be 2
very worthwhile to be brought up into this planning
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3 guidance up front.
Whereas, the things back in the back 4
are more like, we will complete a certain objective by 5
FY 82 or FY 83.
l 6
COMMISSIONER GILINSKY:
I am talking about the 7
first category and I think what we have done in the past 8
is that it is good to make them explicit.
I mean they 9
are obviously in there somewhere, because otherwise you 10 couldn't come up with numbers --
l 11 MR. HALLER:
Yes.
12 COMMISSIONER GILINSKY:
-- but otherwise it is 13 good to make them explicit and to make sure that everybody 14 is using the same numbers.
15 MR. EALLER:
Well, that can be done, it is a 16 matter of when it would be appropriate to do it in view 17 of the pace in which you proceed on this now.
l 18 In other words, that may be something the staff 19 could come back to you with or we could work separately l<
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MR. HANRAHAN:
Well, I don't see any reason i l*. g
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Recognizing that that is another
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"I 25 MR. HANRAHAN:
That could be a piece inserted into 2
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2 CHAIRMAN AHEABh?E:
Well, let us see it.
3 Do you want to just walk through these pages?
4 Page 6?
5 MR. HANRAHAN:
I have the January 9th draft 6
of it.
Now, if you have the memo of last night, you 7
could work from either one.
It doesn't make a difference.
8 CHAIRMAN AHEARNE:
Do you have the one from 9
January 9th in front of you marked up, Joe?
10 COMMISSIONER HENDRIE:
We are going to go through 11 enclosure--
12 MR. BECKERLEY:, Page 6 to start.
1 CHAIRMAN AHEARNE:
There is the one of the 14 Draft 1-9 with marks and then there is the Draft 1-9, 15 there is the 1-28 which --
i 1d MR. HANRAHAN: I would use the 1-9 where I don't
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see there have been any changes have been made from what l'
- 8 you looked at before.
19 COMMISSIONER HENDRIE:
Why did we lunge to Page j;
20 6?
et 21 i *. [
CHAIR N AHEARNE:
Because prior to that was
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the policy guidance, he thought picking up the changes 2
that have been made.
go.jf 24 MR. HANRAHAN: I will circulate around your offices l
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to get your agreement to that rather --
1
12 1
CHAIRMAN AHEARNE:
Anybody have any questions 2
on Page 67 3
COMMISSIONER GILINSKY:
Well, I was wondering 4
what somebody was going to make of all this.
So, what 5
does this do for people at NRRR, what do they say?
6 MR. HANRAHAN:
Well, it gives them at least 7
four areas of priority that, well three areas of 8
priority and the fourth one acquiring accountability.
I COMMISSIONER GILINSKY:
Now, are these in order 10 or priority?
11 MR. HANRAHAN: No.
12 COMMISSIONER GILINSKY:
No.
13 MR. HANRAHAN: They are essentially of equal 14 priority.
But, it involves some policy statements which --
15 COMMISSIONER GILINSKY:
What does the last i'
i 16 one mean, requiring accountability of individual licensee 17 employees and management for important safety function?
18 MR. HANRAHAN:
Well, we have discussed this 19 on a number of occasions about making individuals responsi-l 3j bility of the executives of the licensee, the operators, 20 i-s fl 22 that there is not just a corporate entity that has e:a 2
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responsibility.
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'3 COMMISSIONER HENDRIE:
But, more particularly, I;i 24 jj in the past when we had taken enforcement action of some YI 25 l
kind, it is typically directed into a letter to the l
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13 1
utility or a fine against the corporate management.
2 There is a feeling that we do after all license 3
operators, and senior reactor operators and they all 4
are able to have the jobs they have, in part, because 5
they hold that license from us, and that license from NRC 6
is a, in effect, a certificate that they have fulfilled 7
certain training requirements and examination requirements 8
and I think the feeling also is, and I am inclined to 9
agree with it, that it also ought to be a certificate 10 which indicates a line of responsibility from that person 11 who holds that license to operate a line of responsibility 12 for the public safety that comes back to us, and not 13 just ends at the utility office, and that where a license'd 14 individual has done something that is wrong, there may very well be occasions that when we ought to take action fi 15 16 against the specific individual operator licensed holder.
17 COMMISSIONER GILINSKY:
Okay, you are talking 18 about license holders, and this talks of licensee employees.
19 COMMISSIONER HENDRIE:
Yes, but I think all l
}I 20 that we can reach at the moment are the licensed operators, i*
f.g but there is the proposition in discussion that may 21 I.
22 come before the House as to whether or not we shouldn't I
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23 be requiring some sort of NRC personal licensing of some I
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24 jg people on up in the operations and management exchange.
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MR. BICKWIT:
This was the long-term lessons l
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14 1
learned.
2 COMMISSIONER GILINSKY:
Sure.
3 COMMISSIONER HENDRIE:
Well, I guess this 4
goes on a little bit beyond that, but underlying it 5
is the individual accountability.
l 6
COMMISSIONER GILINSKY:
But are we asking them 7
to do something, are we asking them to develop an 8
approach that goes beyond dealing simply with the 9
operators; is that clear from this statement?
It wouldn't 10 have been clear to me.
11 MR. HANRAHAN: I would think so.
12 COMMISSIONER GILINSKY:
Okay.
r 13 MR. BECKERLEY:
Well, Marty Walsh spoke to this 14 about a month ago and he also, I noticed his copy he 15 put a question mark because we have always talked about j
i 16 licensees as an entity --
17 COMMISSIONER GILINSKY:
If that's what we 18 want to do, and it sounds right to me, I think we ought l'
19 to say it a little more clearly, and it really means l1 li 20 developing a new approach.
The other categories, it seems i:
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21 to me are continuing things that the staff is doing a :..
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and doesn't involve any new regulatory approach.
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S!l 23 going --
- !!j' 24 MR. EANRAHAN: That is correct.
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'5 COMMISSIONER GILINSKY:
certain recommendations, i
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15 1
Now, this really requires something new, and if we want 2
to develop that, 3
COMMISSIONER HENDRIE:
The lessons learned i
4 contain a lot of new thrusts and indeed Number 4 is in fact 5
is one of the lesson's recommendations, under the lessons 6
learned things, r
7 CHAIRMAN AHEARNE:
You might get there at least 8
partially by changing requiring to establishing to get 9
across the point that there is a change.
I 10 MR. BECKERLEY:
As to requiring presumes --
j 11 COMMISSIONER GILINSKY:
What about simply saying l
12 extending accountability beyond license holders?
13 CHAIRMAN AHEARNE:
Fine.
14 COMMISSIONER GILINSKY:
Is that got down yet?
15 Extending accountability for important safety l'
16 functions?
17 MR. BICKWIT:
Beyond current license holders.
.i 18 COMMISSIONER GILINSKY:
Beyond current license l,
i 19 holders.
}i 20 MR. BICKWIT:
Because one of the ways you might j
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[js 22 COMMISSIONER GILINSKY:
That is right, i
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l3 23 CHAIRMAN AHEARNE:
Well, let's see, it is a
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24 combination.
So, it is not only extending it beyond 11 Jy 25 the license holder, but it includes to a sense getting P
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1 across to some current license holders, mainly operators, 2
that they have a broader sense of responsibility.
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COMMISSIONER KENDRIE:
We got two, three--
4 thousand people out there that we have never taken l
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an enforcement action against.
i 6
MR. BICKWIT:
Well, okay, I didn't read that.
7 COMMISSIONER HENDRIE:
The most limited 8
circumstances.
9 COMMISSIONER GILINSKY:
All right, well, let's 10 say that.
11 COMMISSIONER HENDRIE:
I think there is a --
r 12 a thrust is toward a change in that.
13 COMMISSIONER GILINSKY:
Requiring increased I
i 14 accountability for those who hold licenses and extending 15 such accountability to those who do not presently hold l
16 it.
17 CHAIRMAN AHEARNE:
Right, right.
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18 Anything else on Page 67 19 COMMISSIONER GILINSKY:
Well, now let's see l
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Under I
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it repeats what is in the regulations.
I think if i *. l l
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we are putting it in here we ought to be saying something 15!
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I think things are fine as they are, or they
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25 2
CHAIRMAN AHEARNE:
Well, I think the idea was
17 1
to place increased emphasis upon the QA/QC Programs --
2 COMMISSIONER GILINSKY:
Well, then, let's say 3
it, it will place increased emphasis on it.
4 CHAIRMAN AHEARNE:
Well, you are right. The 5
first sentence is just a reiteration of it.
6 COMMISSIONER GILINSKY:
Now, one of the criticisms 7
that has been leveled at us here is that we only look 8
at paper.
Do we want putting greater emphasis on 9
QA/QC for our inspectors to do more inspection of the 10 actual hardware --
11 MR.. HANRAHAN: Yes, in the next --
12 COMMISSIONER GILINSKY:
Well, Joe is shaking 13 his head, I don't know.
Is that something that we want 14 to --
15 MR. HANRAHAN:
Yes.
j 16 COMMISSIONER HENDRIE:
Yes, but with a certain 17 amount of delicacy because of the research implications.
18 MR. HANRAHAN:
The next page covers that thought.
19 COMMISSIONER GILINSKY:
Oh, is that in here?
31 20 MR. BECKERLEY:
Well, this one was more in it ll 21 terms of the licensing people.
i '. a I j e, 22 MR. HANRAHAN: So, the next Page 7, item Number asi
>f 23 2, deals with the inspection program.
You might look 1 1 24 at one looking at NRR deals more with inspection --
'I CHAIRMAN AHEARNE:
Well, wait.
QA/QC program you j
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18 1
say that is more dealing with NRR.
2 COMMISSIONER GILINSKY:
NRC sets up the initial 3
requirements, don't they?
4 COMMISSIONER HENDRIE:
There is a QA/QC 5
program which is required which intent is to insure that 6
plants are built so that when our. work --
7 MR. HANRAHAN:
Well, there are two levels --
8 you review the proposed program and then you inspect.
9 COMMISSIONER HENDRIE:
You adequately protect the 10 health and safety so it is the statutory language, 11 CHAIRMAN AHEARNE:
It is the NRR that inspects.
12 MR. HANRAHAN:
The second item here deals more 13 with inspection than enforcement activity.
14 COMMISSIONER HENDRIE:
In B, if you wanted to 15 get a little beyond simple restatement of what is in 16 fact and has been for many years the law of the land 17 which might be useful, you might comment that the power 18 reactors under construction will be' directed at assuring 19 that these reactors are designed and constructed so as l
j; 20 to incorporate the lessons learned from Three Mile f!
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Island and to provide adequate public protection, et cetera
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That sounds good.
24 COMMISSIONER HENDRIE:
-- instead of just require ia II
- 5 QA give more weight or upgrade and something along the
19 1
line giving more weight to QA/QC programs to insure that 2
plants are built to achieve this objective.
L 3
COMMISSIONER GILINSKY:
Good. Yes.
Right.
4 CHAIRMAN AHEARNE:
On Page 7, what does C mean?
5 What is the significance of it?
6 One way of looking at it is we are going to 7
get their attention by flooding them with paper.
8 It didn't strike me very favorably.
l 9
MR. BICKWIT:
Why don't we just say that.
10 CHAIRMAN AHEARNE:
It strikes pretty hard.
11 MR. BECKERLEY:
Does this reflect, for example, 12 on the qualification of electrical equipment they went
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13 to a bulletin rather than waiting for a regulatory guide 14 to be sure that the licensees are aware of this staffs --
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MR. HANRAHAN: While it looks like paperflooded, i
i 16 the purpose is to increase the information base that the i
17 licensee has --
l 18 COMMISSIONER GILINSKY:
Well, is this regulatory 19 requirements that we are talking about here or also 11 20 making them aware of safety problems of their facilities.
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21 MR. HANRAHAN:
This is really just talking
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Do we talk about the t5.:
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jf other anywhere?
It seems to be one of the points that 24 5I 25 are --
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CHAIRMAN AHEARNE:
Do we release information l
2 notices on regulatory requirements?
3 MR. BECKERLEY:
The staff is generally kind of 4
lax about using the word requirement.
5 COMMISSIONER HENDRIE:
Here they really mean 6
regulatory requirements and information pertinent to 7
the operations?
8 COMMISSIONER GILINSKY:
Yes, I think so, and 9
I think that we ought to be weighing this on ourselves 10 saying that we are going to try to do a better job 11 of making them aware of.the things they ought to know 12 about.
13 MR. HANRAHAN: If you turn it around.
14 CHAIRMAN AHEARNE:
And I was -- what bothered me was also in addition to the paper flood aspect is l
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16 that primarily which sounded like there is an alternative 17 that this is pointing out --
18 MR. BECKERLEY:
Telephone calls -- the alternative 19 is the regulatory guard route.
I think that is what the l
li 20 staff is --
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21 MR. HANRAHAN: I would think so.
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!je 22 MR. BECKERLEY:
-- and it came up recently i4
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21 1
CHAIRMAN AHEARNE:
See, yesterday, you pointed 2
cut that the way to get the Commission involved in these
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3 issues was to get more involved in the red guides and 4
technical positions -- so they will do it by means 5
of these others.
l 6
COMMISSIONER GILINSKY:
Well, aren't we talking 7
in part here about things like -- In other words, the 8
purging out problem of whether we are assuring that we 9
don't sit around here withholding information that would 10 be useful for licensees to have.
11 CHAIRMAN AHEARNE:
So what we are really saying 12 is that the agency will insure much more rapid dissemination 13 of information to licensees through such use as these 14 things and that is the focus that we are really trying 15 to get at.
16 COMMISSIONER GILINSKY:
And will draw attention 17 to important information --
18 CHAIRMAN AHEARNE:
Yes.
19 COMMISSIONER GILINSKY:
-- then just get jg 20 circulated in current events.
t' 21 l
CHAIRMAN AHEARNE:
Yes.
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MR. HANRAHAN:
That would -- I think in ths vary 2
first sentence or two, which is regulatory requirements, sort
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3 of have those words about pertinent information.
4 MR. DECKERLEY:
It would be better and prompter --
5 because that was the whole idea of this big, fat vote on 6
qualification is the promptness of it.
They can get that 7
out in a hurry, whereas the rate guide, you know, you've got 8
to massage it carefully each time, that's all.
9 CHAIRMAN AHEARNE:
But, I think that also the 10 flavor that ought to be changed is that we will do a better 11 job getting information out quickly and calling attention to 12 important events, and cais seemed to be more -- we're going 13 to make sure that the licensees pay more attention.
14 Indeed, I guess I would drop the phrase " continue 15 to" in the third center line.
16 MR. BECKERLEY:
That's kind of self --
17 CHAIRMAN AHEARNE:
Yeah, that's seven.
Seven going 18 once, twice.
Gone.
19 Eight?
};
20 MR. EANRAHAN:
Item #3 deals with the idea of using t'fg 21 third parties for inspection, and what it asks here is g
er a 22 gj!
4 essentially to be looked at to see if that has any possibili-l3
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23 ties.
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24 CHAIRMAN AHEARNE:
Yes, that's where we came out il 5I 25 before.
l l
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23 1
MR. BECKERLEY:
Yes, this reflects your earlier 4
2 comments.
3 CHAIRMAN AHEARNE:
In Number 5 --
4 COMMISSIONER GILINSKY:
Wait a minute.
5 In Number 4 it says, "NRC staff will consider taking 6
a direct role in training and testing these key employees."
7 What does that mean?
Review the pluses and minuses of doing 8
this?
9 MR. BECKERLEY:
Where are you?
10 COMMISSIONER HENDRIE:
Does this one include the 11 operators?
I would think it would.
I 12 MR. HANRAHAN:
Yes, yes, included them.
l 13 COMMISSIONER HENDRIE:
Remember there's been these 14 discussions about our needing some way to establish clearly 15 that tie between this Agency, the public health and safety 16 aspect, the licensed operators who hold licenses from us.
I 17 Discussions of whether you could arrange a series of workshops 18 so that a group of operators in an area can gather for a day I
19 or two and have a series of discussions with the regulatory j
i jg 20 staff on recurring basis, once a year or something like that.
fi 21 COMMISSIONER GILINSKY:
What, are they supposed to jg d
gll 22 do now?
Or they're supposed to think about that?
Because 15!
>!g 23 it says, "NRC staff will consider taking --
{b.3' 24 COMMISSIONER HENDRIE:
I think it's in a planning 11 53 25 and discussion stage, as far as I know, at the moment.
But j
24 1
it's one of a number of this kind of contact --
2 COMMISSIONER GILINSKY:
What I'm asking is:
What 3
is it that we're telling them to do?
Are we asking them to 4
continue thinking about it?
5 COMMISSIONER RENDRIE:
Yes, I guess so.
6 CHAIRMAN AHEARNE:
I guess it should say, "NRC will 7
examine," because I think we've already --
8 COMMISSIONER GILINSKY:
I would take out the staff 9
part.
10 CHAIRMAN AHEARNE:
Yeah, yeah, right.
11 We've already made a decision on the testing of 12 licensed operators, we already did that.
The next question is:
13 I think we are directing them to examine the direct role in 14 the training and also in the training and testing of these 15 other people beyond operators.
16 COMMISSIONER GILINSKY:
By the way, do these numbers 17 track with policy numbers?
18 MR. HANRAHAN:
Yes, not in numbers.
19 CHAIRMAN AHEARNE:
Oh no, no not the numbers.
l jy 20 MR. HANRAHAN:
They can't go from number 4 to number l
=
i 21 40.
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22 MR. BECKERLEY:
No, but they track policy.
We've gsi
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23 tried cutting out and gluing together to see how they look.
b5 24 MR. HANRAHAN:
There is a policy statement that you 11 53 25 - can attribute the planning statement to.
l 1
l I
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i 25 1
COMMISSIONER GILINSKY:
I don't went to forco thia 2
on you.
In this document you --
k 1
3 MR. BECKERLEY:
Questions?
4 COMMISSIONER GILINSKY:
But it would seem to me it'd 5
be a good idea, at least in the future, have a consistent 6
number and so one goes from one to the other.
7 COMMISSIONER HENDRIE:
Well, it's very difficult, 8
because you've got a few policies, a lot of plans, and a 9
staggering number of programs.
t 10 MR. BECKERLEY:
Could we do it easier by just i
11 putting a parenthesis after say reference and give the number 12 of the policy that refers to its relevance?
13 MR. EANRAHAN:
I think that's just a chore for next 14 year.
There is a correlation between -- we've made that 15 check.
16 COMMISSIONER HENDRIE:
Listen, should number 4 have 17 added to it the thought not only the NRC would examine taking 18 a direct role in training and testing of these key employees and 19 in the need for some form of licensing of key employees not l
j; 20 presently licensed.
l I'I 21 CHAIRMAN AHEARNE:
In a way we've already said that l.l l*
l 22 in the first sentence but in a implicit way, because we've gl.i 23 said " key licensee employees including certain management and l!.
24 maintenance personnel" and we should make it explicit.
We've 11 53 25 implicitly said that the agency --
I l
i
26 1
COMMISSIONER HENDRIE:
We've said they had to be 2
adequately qualified but --
3 CHAIRMAN AHEARNE:
But we've included under, oh no, 4
you're right.
5 COMMISSIONER HENDRIE:
It's not licensed.
It's key l
6 licensee employees not key licensed employee.
7 CHAIRMAN AHEARNE:
Yeah,.I read it as --
8 MR. HANRAHAN:
But, what the thrust is that you 9
require the licensee --
t 10 CHAIRMAM AHEARNE:
No, but I agree to show them.
11 COMMISSIONER HENDRIE:
I think it's fair, though.
12 There are these propositions that people like the operation 13 supervisors and maybe even the plant superintendent ought to 14 hold some kind of a license so there is a degree of personal 15 responsibility back here.
It's at least worth --
i 16 COMMIrlIONER GILINSKY:
Like in the merchant t
17 marine.
18 COMMISSIONER HENDRIE:
Huh?
19 COMMISSIONER GILINSKY:
LI'ke in the merchant
.N it 20 marine.
21 COMMISSIONER HENDRIE:
Yeah, that's right.
He runs
,g E"d 22 his ship into somebody you pull his ticket.
It provides
!l!
e 15 23 fundamental personal economic incentives.
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24 COMMISSIONER GILINSKY:
In fact, someone might take Ie 3I 25 a look at that system.
I think we've ignored that.
I think i
j
27 I
we've looked at FAA and some other organizations.
I don't 2
know that we've ever looked at the --
3 MR. HANRAHAN:
There is degrees of licenses in the h
4 merchant marine.
5 CHAIRMAN AHEARNE:
Yeah, first, second, and third 6
class.
7 MR. HANRAHAN:
And a chief.
8 COMMISSIONER HENDRIE:
I once held what I believed 9
is the lowest grade of Coast guard license for a professional 10 carrying to operate a motor vessel carrying passengers for 11 hire.
There was six passengers and, you know, a small boat 12 and limited waters and --
13 CHAIRMAN AHEARNE:
I think he's volunteering to 14 study the merchant marine.
15 MR. HANRAHAN:
He's the only one that's really 16 qualified.
17 CHAIRMAN AHEARNE:
The staff has seen enough of his 18 credentials.
19 COMMISSIONER HENDRIE:
They probably have establish-jg 20 ing how poor they are.
21 MR. BECKERLEY:
Did you want to add to this, now?
l*1 22 MR. HANRAHAN:
Yeah, was your thought, you said iat
>!I 23 that so elequently here earlier?
c h 30
.Ia 24 COMMISSIONER HENDRIE:
Let's see.
After direct i1
.! I 25 role and training in licensing of these key employees and
28 1
what do we want to say some form or an appropriate form of 2
licensing for key individuals not presently licensed?
3 CHAIRMAN AHEARNE:
That's the sense.
4 COMMISSIONER GILINSKY:
Yeah, let's just not use 5
the word appropriate.
6 MR. HANRAHAN:
Yet, we wouldn't use an inappropriate 7
form.
8 MR. BECKERLEY:
Do you want me to go and say in 9
the merits of some form?
I mean this is strictly editorial.
10 They will examine --
11 COMMISSIONER HENDRIE:
Well, I regard the whole 12 proposition and if you want to do that, okay.
This is a 13 proposition is the exact --
14 CHAIRMAN AHEARNE:
When we examine we examine the 15 merits that are --
16 COMMISSIONER HENDRIE:
-- and not a mandated --
17 CHAIRMAN AHEARNE:
In Norm as a separate aside, 18 would you pass on to the people who are doing the examination 19 of these various licensed studies the point of taking up ja 20 for merchant marines?
ex 5
g,1 g Okay, in number 5 you have -- once you've struck the 21 E*)o.
22 femur and have put in now a facility what did you have in mind lEl
>dl 23 by an activity?
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3' 24 MR. HANRAHAN:
We struck femur because we were 11
- .I :
25 talking about the laws that that was not correct. It wasn't -
{
29 1
CHAIRMAN AHEARNE:
Wall, CO2 now you're talking --
2 the disapproval that you're referring is for nuclear power 3
plants.
I'm not sure what the word -- the phrase or activity 4
means.
5 COMMISSIONER HENDRIE:
It goes beyond power plants.
6 MR. BECKERLEY:
Yeah, it goes beyond the matures 7
licensees and so on.
Do you have a hospital or --
8 CHAIRMAN AHEARNE:
You see every facility or activity 9
will have an NRC approved emergency plan.
A NRC rulemaking 10 procedure has been initiated to require this approval for 11 nuclear power plants.
12 MR. HANRAHAN:
For nuclear power plants.
13 CHAIRMAN AHEARNE:
What are the activities that you're 14 talking about?
15 COMMISSIONER HENDRIE: Allactivitiesthatfitfull--l 16 MR. HALLER:
Transportation too may be an area, if i
17 you're transporting very sensitive nuclear materials.
This 18 was a concern that we had in mind when we thought about this.
19 CHAIRMAN AHEARNE:
Okay, so then this would be a jg 20 direction to the staff to leave documents in.
21 MR. HALLER:
Yes.
151 f j 22 MR. HANRAHAN:
That the limitation the rulemaking
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> ! ~l 23 now is strictly to power plants l1Ea 24 CHAIRMAN AHEARNE:
Okay.
Il 53 25 COMMISSIONER GILINSKY:
I just want to say an i
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t i
30 1
activity would be covered by an emergency plan.
2 MR. HALLER:
Yeah, that's fine.
i 3
COMMISSIONER GILINSKY:
But, what are you talking
(
4 about here when you say "it could pose some nuclear risks".
5 I assume anything that's licensed could pose some kind of a 6
risk, otherwise you wouldn't --
in other words --
7 COMMISSIONER HENDRIE:
Your licensing it in some i
8 cases as you get down into those low quantities of byproduct 9
materials simply because that was built into the Atomic i
10 Energy Act in '54 and the predecessor act and we should go in--
t 11 COMMISSIONER GILINSKY:
We should go in and inspect 12 some of these.
I would think if we just had to do it then 13 we didn't think there wasn't any danger involved at all we 14 wouldn't inspect.
i 15 CHAIRMAN AHEARNE:
From mostly a lot of those we
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16 built.
f 17 COMMISSIONER GILINSKY:
Why don't we go to where 18 there's a low frequency?
19 COMMISSIONER HENDRIE:
When you get down into the jg 20 level of radial pharmaceutical stock bottles in a nuclear l'I 21 113 medicine department of a hospital, I just don't think you 3 j 22
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need specific emergency plans beyond the normal sort of --
i lx i
>!f 23 COMMISSIONER GILINSKY:
Well, you may be right.
- But, l $ !'
24 I'm not sure the word "significant risks" is the right word.
11 II 25 We routinely have problems with this Administration of regular l
l
31 pharmaceuticals or whatever.
I mean that --
1 COMMISSIONER HENDRIE:
That's not the thing --
2 COMMISSIONER GILINSKY:
That's not what we're 3
talking about here.
4 COMMISSIONER HENDRIE:
That's not what we --
5 significant risks here means an accident that could reach out i
6 and have consequences in a significant way for a number of I
7 the members of the public and that it would be appropriate to 8
have some plan to try to get them out of your way or whatever.
g COMMISSIONER GILINSKY:
Yeah, I just think you have 10 to change the words or qualify it or do something.
11 COMMISSIONER HENDRIE:
Furthermore, we don't want 12 to have to go around to every minor material licensee and drag l
13 out an elaborate emergency plan.
14 COMMISSIONER GILINSKY:
Now, one of these fundamental i
15 planning assumptions it seems to me would deal with what we 16 expect femur to do.
We expect, you know --
17 CHAIRMAN AHEARNE:
Right, right.
We ought to have --
18 CHAIRMAN GILINSKY:
A certain part of this work 19 to be done by femur.
l Vy 20 CHAIRMAN AHEARNE:
We ought 'to be planning for ee EI 21 femur to be doing the review of the feasibility of evacuation iel fhl 22 around high density sites.
j!i
- jj 23 COMMISSIONER GILINSKY
Are they able to do that now?
j l[*
24 COMMISSIONER HENDRIE:
I think you better build into Ii 53 25 the language the time scale that recognizes that within the 1
32 1
planning period that this document covers why we're still 2
going to be in it for a while and then as they pick up speed
)
3 we can back out.
4 CHAIRMAN AHEARNE:
Well, I think they'll be able 5
to.
In a time period that this covers they will be able to do 3
6 it for some high priority sites.
We will be on factors or a 7
list coming up for our review before it being sent over to 8
femur saying here is the highest priority set.
l 9
COMMISSONER GILINSKY:
Well, I don't know what the i
10 right answer is but a planning assumption ought to deal with 11 this question.
12 CHAIRMAN AHEARNE:
Then there ought to be planning 13 assumption on this phasing over to their doing the concurrence i
14 on state and local emergency plan.
But Joeb right on it.
On I
15 that it ought to reflect the memo understanding we have.
16 MR. HANRAHAN:
Is the MOU for --
17 COMMISSONER GILINSKY:
Now, when you say a facility l
18 of current role is covered by a plan that is what?
Someone 19 supposed to do something by a certain date?
13 20 MR. HANRAHAN:
Is that your term?
No, it is not IIlg 21 explicit on that.
I think --
22 COMMISSIONER GILINSKY:
It covered the reactors.
1!,
SIl 23 MR. HANRAHAN:
Yes, reactors are covered.
8!!!j' 24 COMMISSIONER GILINSKY:
I think we ought to indicate 1.
8 3 25 what it is we expect in other areas or at a minimum we ought 2
33 1
to have someone lay out for us what could be done.
2 MR. HANRAHAN:
I think one would have to do the 3
latter.
I wouldn't feel capable of --
4 COMMISSIONER GILINSKY:
So, let's indicate that 5
that's what we'll expect.
Just so these things aren't left 6
as loose ends.
7 MR. HANRAHAN:
The planning assumption csks for a 8
plan --
9 COMMISSIONER GILINSKY:
Why don't you just follow 10 that up.
With saying the Commissioner would like to receive 11 a plan for carrying this out.
12 MR. HANRAHAN:
Okay.
13 CHAIRMAN AHEARNE:
All right, any other?
14 COMMISSIONER GILINSKY:
This is covered by this i
15 document.
16 MR. BECKERLEY:
It should say communication links I 17 guess, but they're already --
i 18 MR. HANRAHAN:
I think that there's something missing.
l 19 It would make more sense to me if it started with the word 8
j; 20 upgrading.
The first phrase seems to be out of place.
l'I 21 CHAIRMAN AHEARNE:
Well no.
It is really providing 1..-.1
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22 the communications and other equipment or the communication 15!
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23 links and other equipment required from prompt and appropriate
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hI" 24 response to emergencies.
il 5I 25 COMMISSIONER GILINSKY:
Now, what are we talking about l
l l
l
34 I
hOro?
2 COMMISSIONER GILINSKY:
You wanted the telephones, radios?
'7 3
1
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4 CHAIRMAN AHEARNE:
Well, I think it especially 5
.. has two phases.
It really has a determine what is 6
required for prompt and appropriate response to emergencies 7
and that the volume being equipment and communication links 8
required to do them.
9 COMMISSIONER GILINSKY:
Well, when we say that -- is 10 something in the works on this?
11 CHAIRMAN AHEARNE:
Yes, that's what we're going to 12 have initial briefing.
I think it's either next week or the 13 week after.
That's what we put in our budget, remeber a two 14 lumps of dollar.
One for development and planning.
The second 15 for initial purchase of equipment.
16 COMMISSIONER GILINSKY:
Is this the data ' business?
17 CHAIRMAN AHEARNE:
Yes.
18 COMMISSIONER GILINSKY:
Oh, is that what you're 19 talking about here?
j; 20 CHAIRMAN AHEARNE:
Yes.
21 COMMISSIONER GILINSKY:
Well, I'm not sure that --
l 1*l j$
22 CHAIRMAN AHEARNE:
Well, wait, that's what I lsi
>di 23 assumed it was.
Maybe the staff--
til
!!I 24 COMMISSIONER GILINSKY:
I thought it was, il jI 25 MR. HANRAHAN:
I read it as to my mind as communica-l 1
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I tion not the data language.
2 COMMISSIONER GILINSKY:
It's a good thing we're t
3 going over this.
4 I
MR. HANRAHAN:
The data length is not specifically 3
l mentioned anywhere in there.
No one could easily assume 6
that it is subsumed under the --
7 COMMISSIONER GILINSKY:
When we talk communication 8
that means to me people talking to each other.
9 CHAIhW.3 AHEARNE:
Yes, that's it.
10 COMMISSIONER GILINSKY:
You're talking about mas-11 sive movement of data that's kind of --
12 MR. HANRAHAN:
When you say massive movement you l know that's undetermined as yet, too.
IU I
Id COMMISSIONER GILINSKY:
Well, since I don't know 13 how it would come out on this question of data base, I don't i
14 think I would want to commit myself to upgrading, 17 l That's what in mind, if that's what you have in mind here.
I8 c
CHAIRMAN AHEARNE:
Upgrading area I have no i
19 problem with that dropping.
I think we ought to agree that 20 we're going to determine what is required.
I was lumping i
2I data under --
22 l
COMMISSIONER GILINSKY:
First of all, it means I 23 think that I think that you ought to put that in explicitly.
24 CHAIRMAN AHEARNE:
Yes.
I would interpret that 25 what you're looking at is you want both voice and data i.,,
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1 transmission between licenses and us.
You want to determine 2
what is required and then you want to make sure it's provided.
/
I 1
('7 2
COMMISSIONER GILINSKY:
But, you know that doesn't--
l MR. HANRAHAN:
The critical thing there is 4
3 l
determining what's required.
I think that's the first 6
direction to the staff.
7 COMMISSIONER GILINSKY:
Sure, let's --
l 3
MR. HANRAHAN:
Rather than --
9 COMMISSIONER GILINSKY:
You're saying we're going 10 to hear about this next week.
I suppose that's not going 11 to be the end of it.
l 12 i
CHAIRMAN AHEARNE:
No, no,it's what they're going 13 to do is come in as far as I understand it, they're going l
to come in and lay out their preliminary approach.
They've I4 IS had a contractor working on it and here is the scope that 16 i
they see and they need some direction as to where to go from i
17 l
there.
18 COMMISSONER GILINSKY:
Can we clarify what our 19 role is in all that, because --
i l
20 CHAIRMAN AHEARNE:
No, one of the things is to clarify 1
21 l
that role, which is the reason I'm driving them to come in 22 because I want us to at least see what the range that they 23 have with the largest question that they're going to need 24 some guidance on is what do we want to intend to do with all 15 this information?
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COMMISSIONER GILINSKY:
Well, shouldn't we let --
j l
2 CHAIRMAN AHEARNE:
They're not going to be presenting l
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3 that issue.
We have to decide that.
COMMISSIONER GILINSKY:
I would not like the 4
1 3
l hardware options to drive what we end up doing.
We're doing 6
something because it's easy to do.
7 CHAIRMAN AHEARNE:
But, we end up deciding to do 8
will drive the hardware.
9 COMMISSONER GILINSKY:
Well, why don't we decide 10 that and then look at the hardware options for doing what i
11 l
we want to do.
You know, there are a lot of people who want I
12 to set up an electronic palace in Bethesda.
I just don't 13 think we ought to -- I wouldn't say that no matter how much 14 fun it would be.
Unless they've got the whole agency into it.
15 COMMISSIONER HENDRIE:
Not even if you had your 14 own console?
}
17 COMMISSIONER GILINSKY:
You know that was part of 18 I
the plan.
I t
l 19 CHAIRMAN AHEARNE:
Well, are you unhappy?
How about i
20 the rest of you, you're unhappy with that as a planning?
21 COMMISSONER HENDRIE:
Well, I'm not sure that the i,
22 j
precise words here are as elegant as they could be.
- But, j
the general proposition that we ought to be examining and 23 24 then implementing the terrible word again some appropriate 25 set of communications probations to approve our ability to i
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respond to emergencies I think is a fair proposition. Now, 2
all you're saying is you don't want to commit by agreeing to Q
3 some language here to, I don't know, $26 million worth of
\\i 4
autcmatic computer hook-ups nationwide.
I agree that's a 5
subject we get to in detail.
6 COMMISSONER GILINSKY:
If you're talking about 7
assessing our needs, we ought to have some words like consis-3 tent with our role we picked for ourselves.
9 CHAIRMAN AHEARNE:
Fine.
10 COMMISSIONER HENDRIE:
Yes.
i 11 l
CHAIRMAN AHEARNE:
I think the need for having i
12 this in here is to identify that we do believe there is a 13 higher priority planning on it.
I l
14 MR. BECKERLEY:
Would you want a limit to be IS that just determing what communications facilities and l
16 equipment are required for prompt and appropriate NRC i
17 response?
18 l
COMMISSIONER HENDRIE:
Once we determine what l
a reasonable and proper thing to do is, I think we ought 19 20 go ahead and do it.
I think we could say that here examine 21 and provide or whatever.
t U
CHAIRMAN AHEARNE:
Then put in consistent with i
23 the role as decided by the Commission?
24 COMMISIONER HENDRIE:
I think we've got to do 25 better than the telephone.
(smissentlessaa. Veseaftas RuPosmsesL 384:.
me scum carrTon. smuur. s. w. mars 187 m: 1
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39 I
CHAIRMAN AHEARNE:
Your footnotes to Mr. Gilinsky
)
2 gets a console.
3 COMMISSIONER GILINSKY:
I know that's back in f
4 program.
i l
5 CHAIRMAN AHEARNE:
That's in program.
i 6
COMMISSIONER GILINSKY:
It could come in right I
under my 4-wheel drive vehicle.
l I
CHAIRMAN AHEARNE:
All right.
9 On the things on page 9.
10 1
11 t
I 12 13 I
i i
14 I
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40 1
COMMISSIONER BRADFORD:
How would you feel about I
as opposed to Item G in that list to the effect that 3
it is speaking out of the point of being sure that 4
everyone along the line in an emergency response is qualified to, in fact, discharge the duties expected l
of him.
7 What I have in mind in particular is avoiding 8
situations of the sort alleged t.o have occur even though 9
and probably didn't in the North Anna situation where 10 you have somebody conceivably not appreciating the 11 gravity of what they are being told, and this is the 12 whole thrust of each of the points on emergency response 13 is somehow either procedure or hardware oriented and 14 it seems to be important to make sure that the right I
people are in place as well, both on the licensee's i
16 side and on ours.
It may be the clause that fits 17 into the items that is already there.
MR. HANRAHAN: Until you said the last phrase
~9 I
about the part of the licensee and ourselves I was l
l V-20 thinking of perhaps you were thinking in terms of Iil 2
Ii the whole response system which included State and t*!-
local people and I was wondering --
- i:!l 23 fia COMMISSIONER BRADFORD:
I don't agree.
1;i ll MR. HANRAHAN: It is either that --
53 3:
~
~~
COMMISSIONER BRADFORD:
Obviously -
l J
41 1
there are limits what we could do about State and local 2
but at least areas within our jurisdiction.
i 3
MR. BECKERLEY:
You mean contraying the qualifications-4 of the NRC people that are involved in this?
5 COMMISSIONER BRADFORD:
NRC and licensing.
l 6
CHAIRMAN AHEARNE:
Well, are you saying as 7
opposed to our other either regulations on the licensee 8
or our assignment of personnel in the agency?
I COMMISSIONER BRADFORD:
No, what I mean is f
10 that we are obviously looking at that qualification in 11 training and management in all areas in a way that we 12 didn't use to and suggesting that the clause appear here.
13 It is not a major item here --
L 14 CHAIRMAN AHEARNE:
The difficulty I am having 15 is that I don't disagree whenever we assign people in l
16 and throughout the agency we ought to try and make sure 17 we understand and have confidence in training them to 18 do their job, Commissioners aside.
II COMMISSIONER BRADFORD:
I will leave that aside.
$j 20 CHAIRMAN AHEARNE:
But I don't know why we l n;I[
2*'
call, what is the reason of this one place.
Id i
2 *')
jid COMMISSIONER BRADFORD:
I -- well, it isn't t*!
23 j
a different point than what one would make under say n..
24 l[
that under the heading of reactor operation, this just 25 seemed to me to be a very hardware and procedure oriented
.m.
42
}
1 set of points and in fact the human chain is every bit of l
2
(
importance. as the communications links.
3 Why don't I just try and see if I can rephrase it.
i 4
CHAIRMAN AHEARNE:
See if you can fold it into r
5 C.
l[
6 COMMISSIONER BRADFORD:
Yes, I was thinking that.
I 7
MR. HANRAHAN: Assuring that the training and
(
I the people understand the emergency action and function I
of their job as well as the normal operation function.
l 10 COMMISSIONER GILINSKY:
I would group these i
l i
items all differently, it seems F goes with A in developing i
12 emergency planning its own concept.
Also, I would put 13 the instrumentation item before the communication items --
i 14 MR. HANRAHAN: Yes.
15 COMMISSIONER GILINSKY:
As a certain actual
'6 progression.
Now, I am not sure what C means, delin~ eating t
t
'7 I
specific responsbilities of NRC persons and organizations, 18 is that where you deal with role, the respective roles j;
! i II of these items?
fl 20 MR. HANRAHAN: Yes, that is the role requested.
t-hl 21 COMMISSIONER GILINSKY:
Well, that seems to f
a!w*!.
me to be primary.
I would put that first under emergency 2
1-l:l planning and then data communications.
s 24 jj CHAIRMAN AHEARNE:
In Item 6, could we drop l
as this knowledge develops --
l l<
43 O
1 COMMISSIONER BRADFORD:
Let me make what may
(
2 be a parallel suggestion.or at least one which would 3
be an umbrella suggestion of Item 6.
I would go rignt 4
back and pick up the language from the Chilta gram of 5
January 19th a year ago on risk assessment which really 6
was quite forceful.
It is clear, though;I think --
7 CHAIRMAN AHEARNE:
It is something I misunderstood.
I COMMISSIONER BRADFORD:
So, I think no one got 9
it wrong, I think it is nonetheless clear that there 10 is an ambiguity at best in terms of establishing an 11 outside rules protection of.
I think it was said quite 12 forcefully.
I went back and looked at it just the other 13 day and what we ought to say here is that the Commission 14 continues, or the Commission reiterates this directive.
15 I
CHAIRMAN AHEARNE:
Well, you wouldn't say the i
16 Commission, because the Commission is saying this whole 17 thing.
18 COMMISSIONER BRADFORD:
Okay, well it's --
19 MR. HANRAHAN: Aside, from that what was
$1 20 your concern about?
6 11 l
jgj CHAIRMAN AHEARNE:
As this knowledge develops, E:e 2.,
gj.
obviously you are not going to use it until you understand t*!
23 jgol So, it just seemed to be a throw-a-way phrase.
it.
- i" 24 11 MR. HANRAHAN
Well, I think it was to counter 53 25 I
the notion that that technique was well established.
i t
44 1
MR. BECKERLEY:
Well, also, though, it gave I
~
r 2
the flavor that don't wait until you got the whole story i
3 on this assessment that when you get the pieces of it 4
use.them.
I thought that was the flavor of it.
[
5 COMMISSIONER BRADFORD:
Well, that is what the 6
Chilton gram says, it lays out this specific point.
7 CHAIRMAN AHEARNE:
Peter suggested it and we 8
will follow that.
I Joe, I assume silence is assent.
10 COMMISSIONER HENDRIE:
Yes, I don't remember i
11 the language, but let's see it.
12 CHAIRMAN AHEARNE:
Do you agree?
13 COMMISSIONER HENDRIE:
Yes, I would only like 14 to see it in the context of this document and see if 15 there is some addendum a year or a year later that if 16 you would like to add to it.
17 CHAIRMAN AHEARNE:
I guess all of you got 18 copies of the update.
I had sent down to the staff 19 asking and it is now a year later.
What has happened 13 20 and I don't think there is much that can be done
!l 21 whether it has to be.
22 p
MR. BECKERLEY:
This is a real data now, n
I3!
Ifl 23 CHAIRMAN AHEARNE:
That wasn't obvious either.
l;i 24 jj Okay, anything else on Page 9?
25 COMMISSIONER GILINSKY:
I guess I put -- dealing i
45 r
1 with operational data before I deal with risk assessment, 2
it is a small point.
Also, how does this operational 3
data item relate to our earlier point, 2C, I guess.
4 This deals more with collecting, I suppose this is 5
overlapping of this area.
l 6
MR. HANRAHAN: There is quite a bit of overlapping, 7
- yes, 8
COMMISSIONER GILINSKY:
I think it is useful I
to have the data come before the risk assessments simply 10 because it emphasizes that the risk assessment ought 11 to make use of the data.
12 MR. HANRAHAN: Can we put that up as a policy 13 statement?
14 COMMISSIONER BRADFORD:
The phrase takes steps 15 to insure it has a threatening ring to it.
It is --
16 what could you say will insure, but if you have specific 17 steps in mind should we delaying, I am talking for example j
18 about the NPRDS --
II MR. HANRAHAN: I think that was the notion here V-0
.8 there is, you know, a proposed rulemaking and published 21 1 : *[
and put--
22 l l *.
CHAIRMAN AHEARNE:
I think what they are trying 23 to say in a different way, is that they will try as I;i 24 jj hard as they can.
53 3:
~~
COMMISSIONER BRADFORD:
Yes.
I ames ms. 46 o
e I
MR. BECKERLEY:
Do you have any feelings about 2
data being singular or plural?
3 COMMISSIONER BRADFORD:
That maybe in the category 4
of things that the Commission is being advised to stay l
out of.
On the other hand it's the kind of things that 5
4 Commissioners might get into.
7 CHAIRMAN AHEARNE:
Page ten.
Under the purposes j
3 of the enforcement program perhaps we should pick up on 9
your 1, 2, 3, to 4 point that we were making yesterday 10 to examine the possibility of certain enforcement actions 11 to be handled at the regional level.
l 12 MR. HANRAHAN:
And so that will be point number 13 l
four.
I 14 CHAIRMAN AHEARNE:
I would suggest that, since 13 that's I --
j 16 COMMISSIONER BRADFORD:
I would in that item i
i 17 8 drop the phrase the threat of.
18 CHAIRMAN AHEARNE:
Let me ask --
l 19 l
MR. HANRAHAN:
Through strong --
20 CHAIRMAN AHEARNE:
Well --
1 21 COMMISSIONER GILINSKI:
Deterience deals with l
22 threats, right?
l 23 CHAIRMAN AHEARNE:
- Well, 24 l
COMMISSIONER GILINSKI:
If you left the threat 25 in then I'd think you'd want to change correctives.
i-no v
= a=== i=.
as surrw carret spearr. s, e, surft ior i
w _._____.
3.C. EEEE
0 o
pass No. 47 I
1 MR. BICKWIT:
That's what I think.
The threat 2
I of strong enforcement.
l 2
i MR. HANRAHAN:
I think that's the --
l COMMISSIONER GILINSKY:
Well, maybe it's just 4
3 i
a sort of a distinctive reaction to the word threat but i
I 6
it seems to me that by --
7 COMMISSIONER HENDRIE:
It seems to me just through i
8 a deter of future non-compliance through a strong enforcement 9
program?
3 10 COMMISSIONER BRADFORD:
Yeah, and that is the 11 l
point is that it states the strong measures that are going l
12 l
to deter it.
13 l
CHAIRMAN AHEARNE:
Yeah.
The strongest threat i
14 i
is an example.
I 13 COMMISSIONER HENDRIE:
The awareness that the agency will react --
16 17 j
COMMISSIONER BRADFORD:
The point is that they i
is are there even if they aren't used.
One is prepared to i
l 19 j
use them.
20 l
CHAIRMAN AHEARNE:
I think Joe's phrase would l
pick up both, we say, to strong enforcement program.
21 22 The subject is programmed.
The purpose of the program -
23 COMMISSIONER GILINSKY:
The purpose in the enforce-24 l
ment program is to gain compliance to insure compliance, 25 the NRC requirements and the way this will be done is in Ti v
mmm a:
me gg.,Tse CANTOL STWWF. & W. suffE teF w _-
17-= (L C. M
C O
PAGE No. do Cf I
CHAIRMAN AHEARNE:
Well, I can say NRC's enforce-l' 2
ment program will obtain prime correction of licensees 3
weaknesses and and deter future non-compliance.
MR. EANRAHAN:
Through strong enforcement 4
3 management?
6 COMMISSIONER GILINSKY:
Yeah.
7 COMMISSIONER BRADFORD:
I would add a fourth I
8 subpart to that which said stated assuring that PRC Regula-9 tory requirements are enforceable.
I think we discovered, 10 in the course of the fire protection and electrical connector 11 matters that it isn't always clear, for example the failure 12 to have qualified equipment is --
13 MR. HANRAHAN:
Assuring that NRC Regulations i
la COMMISSIONER BRADFORD:
Well, it's more than U
15 regulations its --
l 14 I
COMMISSIONER GILINSKY:
Requirements.
17 MR. BICKWIT:
Requirement.
i 18 COMMISSIONER GILINSKY:
Now, do we want to say l
19 l
something about decentralization of the enforcement programs 1
20 l
or increased authority for regions?
21 MR. BECKERLEY:
Yes.
If I had a tape I'd play 22 it back and then I'll just read what I just --
23 MR. HANRAHAN:
We have two number four's really.
24 MR. BECKERLEY:
See I just said that I suggest U
l that we putting in and examine the possibility of certain 3
Is,rupneafscusas. Veseaff*8 REPONf88E I4 as son,ne carro6 svisuuf. s, s. surfe ist j
6-w;l
& C. BRIS l
l
o O
Paes No. _.49_,
1 enforcement actions be handled at the regional level.
g i
2 i
COMMISSIONER GILINSKY:
On the research item --
i 3
COMMISSIONER BRADFORD:
Does NRC want to size 4
research efforts that support the safety
-- I'm not sure i
l will re-emphasize?
What does that mean?
3 I
6 MR. BECKERLEY:
Well it was in our original 7
the re-was I don't know why we had the re-in there, I l
8 think it's superfluous.
9 COMMISSIONER GILINSKY:
Well, what does emphasize 10 mean?
{
11 MR. HANRAHAN:
Give priority to.
12 MR. BECKERLEY:
To give priority to, I assume.
13 COMMISSIONER GILINSKY:
Well, you're talking 14 about one of the statutory offices that has half the --
i 13 l
more than half the budget of the agencies, I know.
What
\\
(
16
)
are we talking about?
i l
17 CHAIRMAN AHEARNE:
Well, he goes on to say l
18 COMMISSIONER GILINSKY: We'11 continue -- I would 19 just say in carrying out the research efforts that support l
20 the safety operating reactors on operating facilities l
21 I
attention, particular attention be devoted to.
But, the 22 l
category seemed on to me.
After all, human factors and 23 l
all sorts of trancients, etc., etc. are rolled into reactor j
licensing.
This year will be kind of rough.
24 25 i,m
- v riu as-ross. x mesowtw c arres svuunt?.s.e. suresser
- a c. mama
'l
50 C
C puss.m
'f I
CHAIRMAN AHEARNE:
Well, this is now you're getting 2
at the list that bothers proposing.
3 COMMISSIONER GILINSKI:
That's a kind of funny a
list.
Unless he means something like a reactor liscensing whicR i
l is different he may mean longer range or larger programs 3
I 6
i in these other categories which aren't specifically tiad i
7 to licensing menis.
Confirmatory, and if that is what 8
he means then I think one ought to differentiate between 9
the two kinds of activities he might be carrying on.
t to l
MR. HANRAHAN:
He's made a suggestion for 11 a policy statement which he attempts to differentiate between i
12 confirmatory research explore areas where new concerns 13 I
may exist where existing regulatory approaches may be inade-I4 quate and research examining concepts.for improving safety.
1 IS l
CHAIRMAN AHEARNE:
But I would agree with 16 the fact, I think that you ought to go back to Bob and i
17 get some clarifications, otherwise reactor licensing either 18 covers a lot more than is smbedded in that word or else 19 it's the phrasing.
Some of it is reductant.
20 It's certainly true that we understand what i
21 I
we're saying --
U MR. BECKERLEY:
Doesn't he mean like all' the l
best way is to find 23 somebody composes some language, 1
24 l
the best thing to do is ask that person what they mean, 23
$ because if you accept their language and then give it back i,
- v v-am.a===.i =
as se,rie caarvin. stuurt. s, s. surve ter
__z
_ a 3. C. BRIE o
h 01 G.
?
P a e s m a.
I him, he knows what he meant and he's assuming you know
(,
2 what he meant.
3 COMMISSIONER GILINSKY:
Unless you really like l
it then you take it and run.
4 i
{
CHAIRMAN AHEARNE:
I didn't get that flavor here.
5 6
MR. BECKERLEY:
I assume he missed, for example, 7
the big program you had ECCS Calculations.
8 l
CHAIRMAN AHEARNE:
Now we'd better get specific --
9 l
Now his 9b then,.I guess, would follow, looks l
10 to me more like a paisely stick.
It seems to be -- it's 11 i
the same character of the research program I'll have two 12 l
pieces that yes it does, the first order of priority is 13 to have a tight link with the agencies regulatory needs, 14 but then it must have this longer term aspect to it.
i.
13 l
MR. HANRAHAN:
I think it would be appropriate 14 to add that to the policy section.
i 17 CHAIRMAN AHEARNE:
We agree with it.
l Are you going to go on?
18 19 COMMISSIONER GILINSK :
We're going to check 20 with Bob on that nine.
21 On ten speaker material licensees and you say 22 the risks associated with these are not sufficiently known 23 well, there is a whole spectrum of material licenses going I
24 all the way from --
23 COMMISSIONER HENDRIS: Furthermore, at least some i
i,m, rio vs rn. moemwin. te.c me 93nf7M CAMTCL ff15EET. L W. marM teF w--
ik C. m
52 4
e esas iss Op I
of those distinguished positions are in the licensees they 2
take some distress into -- and being implied that there
(
2 l
is risk associated with them and not only is a risk but 4
we don't know how much.
i MR. BECKERLEY:
It should be --
6 COMMISSIONER HENDRE:
Licensing activities are 7
not sufficiently known, well --
8 MR. EALLER:
I'd like to comment on that for 9
a moment.
l There is a point here that I think this paragraph 10 11 is trying to get at and that is that the whole notion of 12 the priority that materials licensees should take in NRC i
13
)
Regulatory activities is just not clear.
The thought is i
14 I
that you may be able to establish the priority by determin-
'I 15 I
ing the relative risk as compared to, for example, reactor 14 operations or fuel facility operations.
So, l'7 COMMISSIONER GILINS Are you talking here 18 i
about lumping everything in together, nuclear field mycle l
activities and hospital isotopes?
19 l
20 l
MR. EALLER:
Not really.
I think it is more i
21 l
the large number of small materials licensees that we're 22 i
talking about.
I 23 CHAIRMAN AHEARNE:
That I can't identify --
24 MR. HALLER:
I think the real purpose here is 25 to try to get, like I say, a priority on how much activity larTWeseAT10 seat. VgggAT1M REPCHTERE lMC age ggWTM CAMTen. STREET. S. W. surft ter wT
_.ws A L nm
53 Q
O MGE NC.
i from inspection and licensee should be devoted to this 2
l part of the spectrum of things we regulated as opposed
(
i 2
l to these others.
A COMMISSIONER GILINSK :
I guess one has to be 5
sharpened up.
6 MR. BECKERLEY:
Here you're thinking of things 7
like the tritium problem, and so on.
l I
8 l
MR. HALLER:
Yeah, and also the mail order licensees.
I 9
CHAIRMAN AHEARNE:
Not to mention that --
10 Under waste manage one and I'm not sure what.
i 11 l
We will promulgate our criteri,a as soon as possible.
I 12 MR. HALLER:
I assume that's always true.
I 13 COMMISSIONER HENDRIE We've been saying that i
14 ever since August '77, practically the first thing I got 13 told to say when I got here was to promulgate our criteria, i
l l
14 it seems impossible.
17 i
MR. HALLER:
The kind of assumption referred 18 to earlier.
19 CHAIRMAN AHEARNE:
Yeah.
Let me just -- because i
20 the alternative is we will -- obviously, we will promulgate i
21 the criteria later than possible, or sooner than possible?
l 22 j
MR. HANRAHAN:
Better sooner than later.
We'll I
i 23 l
work on that basic assumption because I think that this I
i I
24 is one of the areas where it is really critical to.
23 CHAIRMAN AHEARNE:
That's right, that's right.
i,,r nan.6 vs n nummm =
- m. cumm. eraser. s.. sum =
.= w o. c. ams
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i
[
t I think what I would like to see in here is we
\\U i
2 I
will promulgate our criteria by -- as a planning statement
(,
3 we ought to be saying this will be done by --
l COMMISSIONER BRADFORD:
Is there a policy statement 4
i 3
on that that really reflects sort of an urgency as to waste 6
management?
7 MR. BECKERLEY:
Now, the process being particularly I
8 referred to protecting the future generations.
9 MR. HANRAHAN:
Yeah.
Policy Statement A2H, if 10 l
you will recall, the objective of NRC Regulation will l
l not only be to provide adequate protection of the health 11 i
12 and safety during the term of each licensee would also 13 provide adequate protection of future generations after I
14 l
operating licensee termination.
Then it goes on accordingly, i
f
!3 NRC will not license a facility unless the NRC is confident 16 that after termination of the operating license the level 17 l
of protection of the public health and safety from the 18 potential hazard of the Ccmmission facility itself, as 19 i
well as the associated waste over the period they present l
i 20 hazard will be adequate.
It is not specific then there's 21 l
also the statement, what general policy statement is about i
22 public health, i
23 l
COMMISSIONER BRADFORD:
How would you feel about l
24 saying something in the policy statute just to the effect 25 that the development of the licensing regiment for licensing
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es gentpe CMurf4E STIEEEF. t 8-SWITE 887
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55 o
e nez so.
I of the long-term disposal of nuclear power reactor waste
\\b 2
is clearly one of the most dirty tasks confronting the I
3 l
agency.
4 CHAIRMAN AHEARNE:
I don't --
i Joe?
6 6
COMMISSIONER HENDRI:
Yes.
A 7
COMMISSIONER BRADFORD:
I was just urging that 3
we do put something in the policy section to the effect 9
that the --
l l
10 CHAIRMAN AHEARNE:
Licensing, developing the 11 licensing.
I 12 COMMISSIONER BRADFORD:
Developing the licensing l
regimen-for the long-term disposal of nuclear reactor 13 l
l waste was one.of the most urgent tasks confronting the 14 15
)
agency.
That language is off the top of my head, but it 16 just seems to me that's an idea --
17 CHAIRMAN AHEARNE:
Things brought for a policy 18 statement.but to assist a're saying --
I i
l COMMISSIONER HENDRIE:
It sounds fine to me.
19 20 CHAIRMAN AHEARNE:
All right, anything else on 1
21 l
page ll?
k 1
22 i
Go ahead.
i I
22 i
24 l
l 23 terranianosnaa. V amanu Marzmp'E 18'c m soun curt, svuurr. s w. surft ist w2
- a-a c. asses I
3 /v\\ '
2 psex no.
1 2
MR. BICKWIT:
On safeguards, do you want to --
(
3 as I remember, at one point, we talked about putting some 4
l language into confine the effects of the NFS Erwin decision.
i l
3 l
Whether my memory serves me right or not --
l CHAIRMAN AHEARNE:
No, that's right.
4 7
MR. BICKWIT:
I think that wouldn't be a good 3
idea.
9 CHAIRMAN AHEARNE:
I think something similar 10 to the statements that were in the list memo to the staff.
l COMMISSIONER GILINSKY:
Let's see, what are you 11 12 proposing to say here?
13 CHAIRMAN AHEARNE:
Suspicion arises.
I ja l
COMMISSIONER BRADFORD:
We're limiting the Erwin t
13 Case to it's time, according to the staff.
14 CHAIRMAN AHEARNE:
Pointed out that there was 17 i
a concern to limit I think he's reflecting your concern --
\\
18 l
COMMISSIONER BRADFORD:
I think it was your concern.
19 COMMISSIONER GILINSKY:
Yeah, right.
No, I want i
20 to understand just what you're doing.
21 CHAIRMAN AHEARNE:
And he's saying that there I
- 2 f
was an interest in limiting that.
23 COMMISSIONER GILINSKY:
Yeah, right.
24 l
CHAIRMAN AHEARNE:
And so I was suggesting picking 5
- s up the language that was in the staff memo.
iwfusseatioseas. Vessea?'*8 REPO'fW'E I*'C i
me son, Tie casma. sTimuut, & w. wrTE tot w:_-
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4
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Pada No.57 I
COMMISSIONER GILINSKY:
Did that in fact do that?
2 l
CHAIRMAN AHEARNE:
I thought we all agreed to 1
3 it.
A COMMISSIONER BRADFORD:
Yeah.
3 COMMISSIONER GILINSKY:
I don't know that I was 6
involved in that.
7 COMMISSIONER BRADFORD:
There was a sentence 8
beginning nothing in this decision is to be taken to reflect 9
any decrease in the Commission's emphasis on the material 10 control and counting which remains or something like that, i
11 anyway.
12 COMMISSIONER GILINSKY:
Okay, good.
I think 13 that would be very helpful.
l 14 l
COMMISSIONER BRADFORD:
Thank you.
You'll have l
13 j
to adapt it somewhat.
16 I
CHAIRMAN AHEARNE:
Sure, S re.
17 COMMISSIONER BRADFORD:
We'11 put something in 18 here saying nothing in the Erwin decision.
l 19 i
CHAIRMAN AHEARNE:
I got him right.
Yeah, I s
i 20 would probably try to argue against that.
I 21 Anything else on page ll?
22 l
MR. BECKERLEY:
Thirteen is a little bit of a i
23 hodge-podge in the sense that it doesn't follow the format 24 of the others.
23 i
CHAIR N AHEARNE:
I'm not sure I like the word i,ms no-i. vvinn moem r e as soum c. antes. stueurr, t w. surrs ter wZ iin & C. BERE l
csas no.00 l
C
'?
l l
1 self-examination.
Did you have in mind here of these --
l 2
COMMISSIONER GILINSKY:
What do you say the staff 1
l 3
will - -
l 4
COMMISSIONER HENDRIE:
Now you're on to something.
t 3
COMMISSIONER GILINSKY:
Can we just drop the 6
first sentence?
7 CHAIRMAN AHEARNE:
Now, when you say it will 8
accelerate are you saying then it is your point that we 9
have committed in the press letter on the KIMNI Commission 10 and issue a review completed by
'84, that's what we're i
11 l
committed to.
Now, you are saying we will accelerate so, 1
12 l
you are saying we will do it faster than '84?
13 MR. HANRAHAN:
No, the discussion of the policy i
14 statement along these lines which contained the phrases 13 l
Commissioner Gilinsky pointed out belonged in the planning I
16 section.
So it would go in something like under "A" which 17 l
would say this initial review will be completed by 1984 and i
k 18 i
subsequent reviews will be made a five to seven year 19 cycle.
But under the regulatory requirement standards
{
would pick up the press letter.
20 21 CHAIRMAN AHEARNE:
I guess I am not sure.
22 l
MR. HANRAHAN:
To the five percent the '84 would 23 l
be --
i 24 CHAIRMAN AHEARNE:
You know, I would see it as i
23 a
statement saying that the following areas would be under in rio v
- m. numer== i,.c me so.,m carma. rn.aut. s. e. su,7s ter w_ Z u m ik C. M
59 1
examination and then each of those statements what I was 2
getting -- two things were bothering me but one accelerates 3
you got a schedule and you're saying accelerate which could 4
imply to me that you wanted to do it faster, and the second 5
answering such questions as -- meaning that there are others 6
that you didn't have.
Of course this planning document I 7
would think that you are just saying here --
8 COMMISSIONER GILINSKY:
But this is the whole 9
agency, so I don't see very much more than the agency would 10 examine itself.
I think you have to weigh out some course of 11 action.
12 CHAIRMAN AHEARNE:
Now if you -- take paragraph A, 13 the NRC will systematically review all safety regulations 14 for content and structure.
This initial review will be 15 completed by 1984 and subsequent reviews are made on a five 16 to seven year cycle that is the specific planning item.
17 MR. HANRAHAN:
Would you want the other three cast 18 in the same sort of way?
19 CHAIRMAN AHEARNE:
Well, I guess what you are saying jg 20 is that we should be directing the same kind of a comprehensive f!
jfg 21 review; without being a little bit more specific I am not sure e,
13 22 if the staff asks what did we really mean by that.
i!!
5dj 23 COMMISSIONER GILINSKY:
What are we supposed i5s I?i 24 to do?
11 5I 25
^
60 1
l A comprehensive review of all the regulations and 2
requirements is a big itam and we've got to say who's supposed 3
to do this, how's it to be done, is it internal-external 4
combination.
When is it supposed to be done?
5 CHAIRMAN AHEARNE:
And we get the research one, t
6 i
that's what Butness is supposed to be developing when he goes I
7 through his research plan.
Are there important areas that 8
require additional effort, which should be eliminated, which 9
should be reduced.
10 MR. HANRAHAN:
Do you want to limit this specifically 11 to the statement that was impressed for the 1984.
12 CHAIRMAN AHEARNE:
On the reviewing all safety 13 regulations for content and structure and I think that's a 14 specific that will be made.
15 COMMISSIONER GILINSKY:
And who's going to do
!r 16 that?
17 COMMISSIONER BRADFORD:
Standard staff.
18 COMMISSIONER GILINSKY:
Okay, well that's pretty i
19 substantial.
};
20 ge MR. HANRAHAN:
Well, let's just make thirteen 25 21 that one specific --
$i$
22 j!g COMMISSIONER BRAFORD:
Well, standards -- there's
$ll 23 g[a going to have to be a legal component to that somewhere i
24 ll I should think standards plus O.T.C.,
standards plus D.O.D.
II 25
.-pow W
61 1
CHAIRMAN AHEARNE:
Well, standards will need a 2
review.
3 COMMISSIONER BRADFORD:
But, Len, you've been an 4
advocate I think of going over the rules and regulations in any 5
case and not just from a technical content point of view.
g O
COMMISSIONER GILINSKY:
I would think we'.d want I
1 7
to have the general counsel invo]ved in this.
8 CHAIRMAN AHEARNE:
We ::ertainly get involved 9
since rules are going to get changed by --
10 MR. HANRAHAN:
Well, I don?t think at this 11 point that would be that specific.
12 You take that into the implementation and the 13 programming.
14 CHAIRMAN AHEARNE:
But on the others I don't know 15 about.
16 MR. HANRAHAN:
Limit 13 to that one specific 17 item.
18 CHAIRMAN AHEARNE:
Joe?
I 19 okay, page 14 -- oh, wait no 12.
Ij 20 MR. HANRAHAN:
There were a couple of suggestions here
[
that --
d 22 COMMISSIONER GILINSKY:
Can we drop the first k>j 3
sentence?
24 t
MR. BECKERLY:
You can drop this.
It's going EI 25 l
i l
62 n
e pass No.
I to a policy.
l 2
MR. HANRAHAN:
Now, what first sentence of what?
l 3
NRC's relationship?
4 COMMISSIONER GILINSKY:
They're important because 3
we serve the public and we receive oversight from the Congress 6
to support national policies of the Executive Branch.
7 CHAIRMAN AHEARNE:
I would be delighted to drop i
8 it.
There'll be no cries of anguish.
9 l
MR. HANRAHAN:
The first sentence of number one --
i' i
10 I'm sorry not the first sentence, the first two sentences i
i 11 l
have been suggested that those are really policy statements 12 and beginning NRC's dedicated to conducting its activities I
13 I
openly, consequently the NRC will make its deliberations l
14 i
on products readily accessible down to laws will be moved l
15 j
to the policy section and the planning guide follow along to la the end of that.
17 j
COMMISSIONER GILINSKY:
I would qualify that 18 a.little bit.
l
{
19 MR. HANRAHAN: I would too.
20 l
COMMISSIONER GILINSKY:
Appropriately inaccessible.
21 I think we want to think carefully about just t
22 what is open and what is closed.
Interpretations of the 23 Sunshine Act.
24 MR. BECKERLEY:
This makes it sound as if we 25 are going to open everything except to the extent that i,m, rio v -m. memm i=
t de apt #TM CAMTOL. STittTT. & w. Surft 107 w2 la G. C. BEE
n g
63 PAGE NC.
1 we are required by law to close it.
In fact that would 2
be a disasterous policy.
1 3
COMMISSIONER GILINSKY:
I think in some cases a
we may, in fact, want it closed meetings that we have pre-l viously kept open and particularly those dealing with intern-5 I
6 al. management.
7 COMMISSIONER HENDRIE:
Yes, ind some of the areas 8
where you are either in litigation or ' bordering on it, i
9 it's perspective.
10 l
CHAIRMAN AHEARNE:
Well, do you want to just --
l 11 COMMISSIONER HENDRIE:
There are all kinds of --
12 COMMISSIONER GILINSKY:
I think we ought to examine i
j 13 that whole area.
It's just --
14 CHAIRMAN AHEARNE:
Well, are you -- how about 15 j
we're dedicated to conducting our activities openly, or I
16 is that too far?
1 i
17 j
COMMISSIONER GILINSKY:
Well, I think what we i
18 mean by that is that we want to lay out a manner in which 19 the regulatory process is functioning and, certainly, pro-l 20 vide all information on safety matters and so on that we 21 can, but not necessarily--
22 CHAIRMAN AHEARNE:
Well would you propose dropping --
23 l
COMMISSIONER GILINSKY:
Open up all questions l
24 i
dealing with internal matters.
What we're talking about i
15 here is the interpretations of the variour exempt categories i-- vs
- m. moo-r===. x
.,, cumn,smust.s wrra=>
w a c.==s
64 1
under the Sunshine Act.
I don't think we want to commit 2
ourselves to having open meetings, you know, in every case 3
except where classified information is discussed or something 4
like that.
5 MR. BECKERLEY:
But I thought applicable law was 1
6 supposed to cover all those, you remember that first draft 7
tried to mention national security, proprietary and so on.
8 CHAIRMAN AHEARNE:
Well, no.
As Len pointed out, and 9
I think Joe and I and Victor at least agreed that under applica-10 ble laws you still have a band.
There are some that you -- we wil l
11 certainly open all that must be opened.
12 COMMISSIONER HENDRIE:
And close all that must be 13 closed.
14 CHAIRMAN AHEARNE:
Then there's a band there that 15 says in reason you have flexibility and there is, from what 16 I gather here at least among the three of us we would like to 17 begin to exercise a bit more of that flexibility for Commissione c 18 Hendrie at least preserve the flexibility and not commit --
19 COMMISSIONER GILINSKY:
Right, I think we'11 be f
3j 20 committing ourselves to not to use that flexibility to hold back 21 i ". [
information on safety matters to keep the public from learning.
a
! j e, 22 You better get the engineering judgment.
I5!
5!l 23 COMMISSIONER HENDRIE:
You'd better get this language
{b!'
24 j
straightened out for this meeting.
The Sunshine Commissioner
- i 25 JE will come back here.
65 9
raas no.
1 Good, onward.
2 MR. HANRAHAN:
Why don't we just drop those first 3
two sentences.
4 COMMISSIONER GILINSKY:
The only reason I was l
5 a little reluctant to say -- make some sweeping declaration 6
here is I didn't want to mislead anybody.
7 CHAIRMAN AHEARNE:
You're right.
8 Peter?
9 COMMISSIONER BRADFORD:
I think I can almost l
10 live with any outcome that is the -- don't seem to be the l
language that we had that was proposed would include our 11 i
12 l
deciding that some sessions can more clearly can more I
13 j
effectively be conducted closed, but I'm perfectly content I
l 14 to strike.
13 CHAIRMAN AHEARNE:
You want me to strike it then.
f COMMISSIONER BRADFORD:
I agree with a few basic 16 17 points that there may be some discussions of agency business.
18 COMMISSIONER GILINSKY:
Well, I'm not suggesting l
19 l
that we ought not address the subject.
20 CHAIRMAN AHEARNE:
No, I understand.
l 21 COMMISSIONER GILINSKY:
And I think maybe we l
22 ought to, but we ought to think carefully about what he's 23 saying.
24 MR. BECKERLEY:
Some of this first working point 25 we're not really sure what we're saying.
i i
no v
- i a somme castron. snaarr. s w. susTE 'et
.- a, c. muss i
66 n
c pass so.
1 COMMISSIONER GILINSKY:
Right.
2 MR. BICKWIT:
One possible way to phrase this t
2 if you want to say something would be to say limited only l
by policy considerations referenced inapplicable laws.
4 i
3 CHAIRMAN AHEARNE:
I'd rather when we do say 6
something say it more clearly.
7 MR. BICKWIT:
Say something that means something.
3 CHAIRMAN AHEARNE:
Yeah.
9 COMMISSIONER GILINSKY:
Let's see it are you i
10 going to be coming up with something?
I 11 i
CHAIRMAN AHEARNE:
I would guess that we have a
I i
12 l
to try to figure out something, yeah.
I 13 l
MR. HANRAHAN:
Quickly.
I 14 i
COMMISSIONER GILINSKY:
I think we ought to say 1.5 something about it, and just try to be as clear as we can, i
14 I
CHAIRMAN AHEARNE:
I mean if anybody should be 17 i
tasked, either us or --
f Item number two.which he also proposes to put 18 i
19 l
into policy.
20 l
COMMISSIONER HENDRIE:
What does the second sentence 21 l
mean?
l 22 COMMISSIONER BRADFORD:
I think it's dispensible 23 if that's what.you want.
24
[
COMMISSIONER HENDRIE:
WelL I think as far as i
23 the staff is concerned at least I read that _o mean the i,m, no v u.n numw
- s. x me sanw carma, smuxT. s, w. suers ter w _ _- _.- lL C. M
1 c
e l
puss no.
67 I
dissenting --
2 COMMISSIONER BRADFORD:
I guess I would bring 3
the staff dissent' out'and treat it differently.
4 COMMISSIONER HENDRIE:
Differently than this.
3 COMMISSIONER BRADFORD:
We would rather --
6 COMMISSIONER HENDRIE:
Does this mean we would 7
not give consideration to rendi.ssenting views?
No, I can't 8
hardly believe that.
9 How about views on something that doesn't have 10 significant potential impact but is still germane.
They 11 I
are not to be considered.
It's an odd sort of a sentence.
12 COMMISSIONER BRADFORD:
But it was the.~ dissenting 13 sentence, wasn't it?
I 14 COMMISSIONER GILINSKY: Well, then let 's deal 13 with that specifically.
l 16 CHAIRMAN AHEARNE:
Since we now have a policy, 17 at least, some general sentence of it that will be extractable i
18 from that,but that's okay.
19 COMMISSIONER GILINSKY:
It's the act of participa-l 20
. tion in the NRC Regulatory Process that an informed public 21 l
is beneficial both to the public and the NRC.
I 22 l
COMMISSIONER BRADFORD:
I thought the last seven 23 words could disappear.
24 i
COMMISSIONER EHNDRIE:
Yes, why don't we just f
declare it beneficial in a broad sense, 25 l
i
]mnopeak VWBBAMM N
as name c.antok sfuerr. s w. sJrts ist
- w. _Z _ _ _ in & C. 3sut
68 1
COMMISSIONER GILINSKY:
Now, what is the Commission 2
majority?
3 CHAIRMAN AHEARNE:
It should just say Commission.
I 4
That's the last time I'm going to say that.
5 COMMISSIONER HENDRIE:
No, no, no.
L 6
CHAIRMAN AHEARNE:
But Joe is the Commission.
l I
7 COMMISSIONER HENDRIE:
A misinformed majority 8
commissions the language which you want.
9 COMMISSIONER BRADFORD:
Well, I'm normally a 10 firm defender of the calling three members of the Commission 11 disadvantaged, though, doing it expressly here is that we -- I 12 think we're trying to e through this document without 13 acquiring dissenting footnotes.
14 CHAIRMAN AHEARNE:
Well, at some point, frankly, I
i 15 if it were required I would then try to ask the Commission 16 to approve that there be no dissenting footnotes allowed in 17 this kind of documenu.
It's the Commission speaking to its 18 staff in the sense of the -- in the point that, at least in the i
19 foreview espoused in other letters that there comes a point j;
20 where the Commission acts as a collegial head of an agency and lit there it is the majority and this is the Commission majority 21 f{
22 speaking.
It is the staff direction, it is telling the staff
{si
>!j 23 here is the way the agency is to be run.
15!
.5" 24 COMMISSIONER GILINSKY:
I think I am inclined il 53 25 t
n
._g Pass.m 69 I
to agree with that, each Commissioner is free to send a 2
letter to the executive director expressing his views on i
3 this document.
4 CHAIRMAN AHEARNE:
But this is that single entity I
5 l
you spoke about, the Commission.
6 COMMISSIONER BRADFORD:
I must say, that in the 7
particular context he has here he will get too strong an 8
argument from --
9 MR. BECKERLEY:
I think that proves a little I
10 too much.
I mean there are so many situations to which 11 I
that principle applies.
12 COMMISSIONER HENDRIE:
Being in the minority i
13 here, hence, presumably one of the agrieved parties in i
l that view has adopted, I am willing to accept it here if 14 i
15 it is acceptable in other areas as well, okay?
l 14 CHAIRMAN AHEARNE:
No, let's see, what does that 17 l
mean?
18 COMMISSIONER HENDRIE:
That means that when the I
l majority speaks it may, for instance, on assorted pieces 19 20 of advice and expression of opinion simply the majority 21 l
may decide that they,.in fact, represent what is the thing i
22 i
called in the law of the Commission and that's it.
There 23 isn't any other voice.
I.
24 COMMISSIONER BRADFORD:
That, I think, is the 25 principle that was making me --
twrummarunnaa. Veseaftw MEPCfrf94& lNC.
me smarw curm. remurr. s. ar. survu ser e_ Z. _ a & C. EME
70 1
CHAIRMAN AHEARNE:
And, I guess, in general I'm 2
willing to agree with that.
(~
3 COMMISSIONER BRADFORD:
I would say that if we 4
would have a principle like that the furthest I would take 5
it would be the purpose of internal documents.
6 CHAIRMAN AHEARNE:
Well, but this is an internal 7
documents.
8 That's what I am trying -- that was the point I 9
was raising, that this is internal documents.
10 CHAIRMAN AHEARNE:
You raised it in broader terms.
11 MR. BICKWIT:
I understand that but I am not sure 12 that's what Joe has in mind.
.13 COMMISSIONER HENDRIE:
Not all, and furthermore, you 14 must recognize that even though it is internal in the sense that 15 it's programmed planning document of the agency it's certainly 16 not going to be internal in the sense that it is not going 17 to be possessed by, viewed by, read by, given weight and 18 quoted by numerous people of all persuasions outside the 19 agency, that is, as a Commission Policy Document it will have l
}I 20 a considerable dignity in the scheme of things even though i ".
21 j
it is normally " internal documents".
So, I think it has l.g 22 some importance.
Now as a matter of fact I think people, 1-!
23 generally, are aware of where I stand for myself.
I would l5W 24 be disinclined to add an asterisk or whatever Commissioner "I
25 Hendrie thinks this is a bummer in this document.
2
71 n
a raas so.
l l
l t
1 The present language was an aid in that direction.
I i
2 CHAIRMAN AHEARNE:
I mean, my vote would either i
l be to only say the Commission has endorsed or in fact the 3
i l
NRC has endorsed or else to strike the paragraph.
I just 4
3 don't -- I think it's inappropriate to the basic concept 6
l of a policy and planning guidance to the staff to start 7
having
- dissenting ' views that --
3 COMMISSIONER BRADFORD:
No, I agree with that.
9 That was the -- and if, in fact, Joe is comfortable, as I
10 l
astute, with language, at least accepting it.
Here then I
i 11 I shouldn't move to press the point any further.
12 COMMISSIONER HENDRIE:
I would be amiable with 13 the present paragraph with Commission majority and would l
l 14 not add my own remarks.
I would also be amiable with removal 13 of the paragraph, I leave that up to those of you on that I
16 side of the vote.
I guess I'd be less amiable with the commission the Commission has endorsed.
17 I
13 l
COMMISSIONER BRADFORD:
Oh, I see.
I thought 19 you were --
i l
20 l
COMMISSIONER HENDRIE:
But I still don't know 21 i
whether my degree of unhappiness would lead me to want 22 my separate opinions appear simply enough, i
23 CHAIRMAN AHEARNE:
I think it's an important 24 point, Victor.
It really addresses the concept that you i
i 23 guys have of the collegial head of the agency.
And when i r -- v no re i,.e.
I me eastw cammm. rrwest s, n. sufra tot w:Z
_.m EL C. Jimms
l pass No.
72 o
e
\\
1 you're giving the guidance to the staff it has to be the 2
Commission.
It is not a majority of the Commission, or l
Commissioners X, Y, and Z think this and Commissioners 3
4 l
A and B think that.
It is the Commission.
Is the staff I
5 i
really supposed to be told here is what the Commission I
{
has said the policy is.
6 7
COMMISSIONER GILINSKY:
That'll teach your 8
Grandmother to suck eggs.
9 CHAIRMAN AHEARNE:
Aren't you going to tell them 10 if you have dog dunbar.
l 11 COMMISSIONER BRADFORD:
Well, I'm parfectly happy 12 with the language of the Commission and I am content with 13 the principle, at least, in this document that there should 14 be no asterisks and dissenting views, presumably if 15 over time the majority of view shif ts, the appending sentences 16 I
will shift accordingly, i
17 COMMISSIONER GILINSKY:
It seems to me every 18 Commissioner is free to take this and mark it up and send 19 it to the executive director.
t l
20 CHAIRMAN AHEARNE:
Of course.
21 l
COMMISSIONER GILINSKY:
Say these are my views 1
22 l
and I want you to know that --
23 CHAIRMAN AHEARNE:
Sure.
24 j
COMMISSIONER GILINSKY:
And I want you to know 25 that I support XYZ and I'11 support the following.
in no 6 v n= nea===. la.c.
i me marew cammen stueur, t e. sung ter a
w--
_w o. c. amas
o O
cazz.m 73 i
CHAIRMAN AHEARNE:
Yeah.
2 COMMISSIONER BRADFORD:
You implement this at 3
your card upon memory of charge.
4 CHAIRMAN AHEARNE:
My time runs until --
I would say that we ought to say the Commission
~
3 had been and then hope that the good judgement of the dissen-6 7
ting colleagues will prevail.
3 MR. BECKERLEY:
You have the votes for that.
CHAIRMAN AHEARNE:
What?
9 10 MR. BECKERLEY:
I think you have the votes for i
11 l
that.
Do you want,us to add in front of it, at the present 12 time.
13 CHAIRMAN AHEARNE:
Thirteen was moved.
14 MR. BECKERLEY:
Well, may I suggest what the 13 Commission might say.
Instead it must be consistent, I l
14 l
would suggest must not be inconsistent with the Congressional.
l 17 CHAIRMAN AHEARNE:
I would prefer it must be 18 consistent.
COMMISSIONER BRADFORD:
And what do you see the 19 1
l 20 big indifference?
l 21 MR. BECKERLEY:
I don't think you need Congres-22 sional guidance.
23 MR. HANRAHAN:
Because of the Comptroller General?
24 l
CHAIRMAN AHEARNE:
Wait, you are drawing a real 23 distinction between action is what you must be consistent I
Iwrusesariosena.Veneague Rapestress, tam, j
me souTw carvTun, smarr. s, n. surfs ser e:. -. lu Q. C. m
^
a e
74 ruxx n with.
What if there is no action?
I MR. BECKERLEY:
There is no action going by the 2
I Congress, it seems to me the Commission can do what it 3
wants.
l CHAIRMAN AHEARNE:
Right, that would be consistent.
5 i
i MR. BECKERLEY:
Well, I think that's right but 4
it is not clear.
You'say not inconsistent then that's 7
not clear.
8 CHAIRMAN AHEARNE:
Unfortunately, that because 9
I of the way that the Comptroller General has come back I 10 would much rather say consistent with.
i 11 i
i 12 l
MR. BECKERLEY:
You're saying that if the Congress 13 says nothing then you'll go ahead and adopt the program 14 then you're being consistent.
I 13 i
CHAIRMAN AHEARNE:
Yes, yes.
I id i
MR. BECKERLEY:
With that interpretation I have 17 no problem.
Then it seems to me that you have no 18 Congressional guidance on that basis.
I 19 CHAIRMAN AHEARNE:
And it would be consistent i
l 20 then too.
21 l
MR. BECKERLEY:
I don't see how you can be consis-22 tent if you have none.
i 23 COMMISSIONER BRADFORD:
That isn't quite right,
/
i 24 j
Leonard, it's not that we have no guidance.
What the Comp-25 troller General has told us is that the guidance is binding.
m ne,.u.va.uvuneanomt<
ase smam curm. rvuarr. t w. surre to, w -... _.
ik C. mint
0 o
ruas no. 75 1
COMMISSIONER HENDRIE:
Isn't binding.
2 COMMISSIONER BRADFORD:
Isn't binding, that's 3
right.
4 MR. BICKWIT:
That's not the point I'm referring i
5 to here.
You're saying if you have no guidance, does the 1
6 Commission feel free to move with an intervenor funding 7
program, I think the answer is yes and if you feel that 8
way I think the better way to express this is that you 9
l will take no action -- to the immediate system.
I
{
CHAIRMAN AHEARNE:
What I am worried about is 10 11 I
the phrase inconsistent with -- not inconsistent with being i
12 j
picked up as saying a ha, Comptroller General has said 13 something and you're just' tracked immediately with what I
14 l
he said.
15 MR. BICKWIT:
I think you should comply with i
14 I
what he says.
i 17 CHAIRMAN AHEARNE:
He said two things.
18 I
MR. BICKWIT:
You would be inconsistent with 19 l
Congressional guidance if you proceeded to implement a program I
20 in this year.
21 CHAIRMAN AHEARNE:
All right, all right.
Okay.
22 MR. BICKWIT:
I'm saying you're committing your-t 23 self not to be inconsistent.
l 24 CHAIRMAN AHEARNE:
Well --
t 25 And I don't care which way it goes.
i.,r Tia v
- m.===T==.
t c me sen,T90 CMET4llE. Sf9'ET. L 8-33875 !WF
- 3. C. BEEE
76 1
MR. BICKWIT:
I think the non-inconsistent better 2
expresses the view that you stated.
3 CHAIRMAN AHEARNE:
All right.
4 COMMISSIONER BRADFORD:
As a practical matter, John, 5
what are you saying that in FY '80 are you saying that since 6
there is Congressional guidance we should not have an 7
intervener funding program even though the Comptroller General 8
said we can if we wanted to?
9 CHAIRMAN AHEARNE:
That's right, that's what I 10 am saying.
11 MR. BICKWIT:
And I think either way of expressing 12 is consistent with that view.
13 COMMISSIONER BRADFORD:
I think you may have a lA different majority for the second sentence in that paragraph i
15 than you do for the third but I think you probably have a 16 majority for both.
17 CHAIRMAN AHEARNE:
Well, page 13.
18 MR. HANRAHAN:
Thirteen.
The number four there 19 suggested that that represents a policy statement that ought jg 20 to be moved to --
i!I 21 CHAIRMM AHEARNE:
What does number five mean?
Iil e%
gjg 22 MR. HANRAHAN:
Number five we're just deleting all I3!
5l!
23 together.
{al 24 CHAIRMAN AHEARNE:
Okay.
II
.! I 25 MR. HANRAHAN:
It's --
77 4
e Paez no.
1 COMMISSIONER GUILINSKY:
It's a just a way to 2
slip in policy statements, you go to the planning section 3
and then --
4 l
COMMISSIONER HENDRIE:
Draw a dashing line through 5
them.
I 6
COMMISSIONER GILINSKY:
I wonder if that means 7
when we get to program guidance, why there'd be a lot of a
things with dashes through them that will be following up 9
in the planning area.
10 COMMISSIONER BRADFORD:
And then you use the I
11 Wolf Creek Standard on reopening the policy section.
12 COMMISSIONER HENDRIE:
Clearly, we will do all 13 these things, i
14 l
CHAIRMAN AHEARNE:
Yeah.
l i
13 COMMISSIONER HENDRIE:
Whether when you are to l
receiving save them here or elsewhere?
l 17 CHAIRMAN AHEARNE:
Well, I just, I just --
1 13 l
MR. BICTWIT:
Didn't we just say that.
19 CHAIRMAN AHEARNE:
If you think that we have l
20 not in the past --
i 21 COMMISSIONER GILINSKY:
Well then you have to I
1 22 i
say we will improve, or we will remedy deficiencies or i
23 l
something like that.
Simply to say we will work with other 24 agencies where we have shared responsibilities or something.
y
,s 25 i
It seems to me is complying with th'e law, i,,r.- - v w is i
me sawm mit sresent, s.
surre te7 m
I 4
0 l
PAGE No. 7R I
CHAIRMAN AHEARNE:
Well, I suppose it's a little 2
f bit more than that.
It's just calling attention to people on i
3
' the staff that may not reali::e that one of our -- that really h
is our policy to cooperate and work with these other agencies.
4 i
l 3
COMMMISSIONER GILINSKY:
Well, we ought to spell 6
out some important relationships.
7 CHAIRMAN AHEARNE:
That would have been the appro-3 priate section of planning section developed from that 9
policy.
l 10 CHAIRMAN AHEARNE:
All right, let's do that.
i 11 i
MR. HANRAHAN:
All right.
You want a planning 12 statement against this one.
13 CHAIRMAN AHEARNE: All right.
Do you have any i
14 other points that you had?
13 l
MR. HANRAHAN:
Ncpe.
f 14 CHAIRMAN AHEARNE:
Peter?
i 17 COMMISSIONER BRADFORD:
Did you all deal with 18 the NNPA Policy Statement part of a covering memo before l
19 l
I got here?
l 20 CHAIRMAN AHEARNE:
No.
Ed said he's going to l
be ccming around to the offices on the policy section.
21 22 MR. HANRAHAN:
I would leave it -- this -- today's i
23 meeting was in the planning.
24 CHAIRMAN AHEARNE:
I propose now to make the 2
corrections, as I understand them, to the planning section.
l leermuseam VW'ennu REPCs'fWE IML me sunnu c.aerros. stessur. t e. suere ter e -_1 i e &C. Em8
I o
e i
79 auxx.m
- ~,
I I have to take them around to the offices.
When they've 2
done that I will get you a clean copy and then your agree-2 ment to that, then move it to the staff for their review 4
and comment.
3 CHAIRMAN AHEARNE:
Very good.
[
4 (Whereupon the meeting was adjourned at 3 :27 7
p.m.)
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