ML19317H345
| ML19317H345 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/08/1980 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8005290151 | |
| Download: ML19317H345 (74) | |
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UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION
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4 PUBLIC MEETING 5
BRIEFING ON ACTION PLAN 6
7 Nuclear Regulatory Commission 8
Room 1130 1717 H Street, N.W.
9 Washington, D.C.
10 Thursday, May 8,1980 11 The Commission met, pursuant to notice, at 2:00 p.m.
12 BEFORE:
13 JOHN F. AHEARNE, Chairman of the Commission
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14 VICTOR GILINSKY, Commissioner 15 JOSEPH HENDRIE, Commissioner l
l 16 PETER A. BRADFORD, Commissioner i
17 NRC STAFF PRESENT:
18 E. HANRAHAN 19 R. MATTSON SIHIS DOCUMENT CONTAINS 20 W. DIRCKS f% POOR QUAUTY PAGES 21 K. CORNELL 22 23 24 30
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CHAIRMAN AHEARNE:
This af ternoon the committee meets 3
to continue a long series of meetings on the TMI Action Plan.
We have before what the EDO has identified as the final version which indicates either a level of frustration, resignation or f0 some other sentiments.
We also have an action plan description n
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decisionmaker which goes through a number of sets of recommen-dations including globe power requirements, implementation sched-d c
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ule for other tasks, a series of points on reprogramming and then h
10 a policy for future requirements.
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4 II Now in substance this covers a very large amount of U
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material and at least I myself am not ready to reach a decision 9
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on all of these issues today but I certainly think we can all E
14 benefit from a description and discussion and beginning to chew w
2 15 our way through and at least at some stage in today's presen-wx tation addressing from the standpoint of NLR and EDO on the oper-t 6
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i ating license question.
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18 Bu: there certainly is a lot of material and I guess
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I should also mention a series of responses from EDO to a 20 series of letterr from ACRS concerning the action plan and previous 21 i
drafts and modifications of drafts, et cetera.
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l Before turning it over to you I would like to comment 23 i on a couple of points that are made in your introduction in l
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the action plan.
You point out that the action plan provides a 25 comprehensive and integrated plan for all actions based upon I
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primary concern about perceived immediacy for the need for e
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1 In one of the ACRS responses you print out that some 2
of these issues will be taken up by and are part of the reason 3
for some of the NRR reorganization, the new types of offices 4
that are set up.
5 "So I guess I would say that although the Action Plan 6
has got a large list of items in it, all reflecting the 7
decisions proposed and actions taken as a result of these 8
reviews, they are not, therefore, the complete defined list of i
9 the responses of the agency.
10 So with that sort of long opening remark, Bill.
11 NR. DIRCKS:
Just let me mention, now, on this point 12 of it not representing the complete fulfillment of everything, 13 it certainly represents a substantial contribution to it.
On i
14 the whole business of attitude and integration, we will see 15 that as we implement the thing as we go down the road.
16 The building blocks are here.
It is the vigor and 17 enthusiasm with which we put it all together that counts.
18 That is how you judge attitude.
I don't want to be like the 19 corporal at the army squad talking about the attitude of the 20 squad.
I want to see som'ething happening about attitude.
We i
21 can get into that.
22 The Commission, I guess, met the last time on this 23 Action Plan on February 22nd.
Since then we have gone through 24 two more revisions, culminating in the version you have before 25 you today.
ALDERSON REPORTING COMPANY, INC,
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I do want to say a few words about the gratitude that 2
I have for the steering group that put this thing together.
3 They have been at it for months.
They have reviewed and 4
digested about a thousand specific recommendations and have 5
put this thing together in the volume you have before you.
6 I think it is an exceedingly difficult job they had 7
to face and they did an excellent job of putting it together.
8 The version that you have considers the previous 9
Commission commants that we have had in the meetings with the 10 Commission. It considers the ACRS comments to the extent we 11 have been able to address them.
We have given the letter that 12 I think we sent to the ACRS on May 2nd where we address many 13 of the. comments.
14 The directors of each of the major program offices 15 have concurred in the plan that you have before you.
When we 16 get to it, they have concurred in the reprogramming section of 17 the decision program that you have before you.
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18 As you pointed out, the purpose of this series of 19 meetings, I am sure, will be a series to concentrate on four 20 decision areas that we have outlined in the decision 21 memorandum. The first is the use of the requirement as a means 22 of full power licensing.
23 The second one is the implementation schedule for the 24 rest of the Action Plan.
Third is the reprogramming 25 activities that we would like to go through to get ;o where we ALDERSON REPORTING COMPANY, INC,
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can finance this operation.
'the fourth is the implementation 2
policy for future requirements.
3 As I mentioned,'the program directors are here to 4
answer any specific questions.
I will ask Roger to go into l
5 the OL requirements portion of the paper.
I will ask Kevin to 6
address specifically the reprogramming items.
7 Let me just mention a few things about'the OL 8
requirements.
You saw the first list of Action Plan 9
requirements on near-term operating licenses on January 5th.
10 On the basis of that discussion, we moved ahead.
11 The meeting broke up with the indication that the 12 requirements represented a necessary step forward, and there 13 was a discussion of the sufficiency of the list.
1-4 You asked the ACRS to review the NTOL requirements 15 and provide the Commission its views.
The ACRS has advised us 16 that, subject to certain comments on specific items, the list 17 of NTOL requirements provided a satisfactory basis for 18 resumption of licensing.
l 19 We sent you the staff response to the ACRS comments, 20 as I mentioned, on May 2nd.
21 What I will do at this point is ask Roger to get into 22 the changes, if any, that have been made to the NTR list, the 23 basis for any changes, and any contingent items you have on 24 that list as a result of these various reviews.
25 Then if we have time, I would like to get into a
ALDERSON REPORTING CCMPANY,INC,
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1 reprogramming.
But there is one item I want to mention on 2
reprogramming at the start.
What we have done here represents 3
a significant stretching of staff resources and program 4
resources.
It represents an exceedingly tight program.
5 The reprogramming that we have suggested to the 6
Commission l' eaves very little leeway for contingencies.
It is 7
based on certain assumptions. It is based on the assumption 8
that we get a supplemental to our 1980 budget.
9 CHAIRMAN AHEARNE:
In particular, the supplemental 10 that is in front of the Congress.
11 MR.
DIRCKS:
Yes.
It also is based on the 12 assumption that we do not get a measurable reduction in the 13 1981 budget.
14 CHAIRMAN AHEARNE:
In other words, it assumes that 15 any cuts such as proposed by the Senate committee do not 16 occur.
17 MR. DIRCKS:
That is right. It also assumes that we 18 are able to meet a $9 million shortfall in the NRR budget in 19 1981.
If we get the 1980 supplemental and we get the 1980 20 budget, we will be able to do some reprogramming to get to the 21
$9 million shortfall.
We did not cover that in this.
22 CHAIRMAN AHEARNE: In other words, this reprogramming 23 does not treat the reprogramming that would be necessary in 24 order to handle that additional.
25 MR. DIRCKS:
That is right. So we will have to come ALCERSON REPORTING CCMPANY,INC, sutsriwruesau:n%5vn
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back to you for later reprogramming. But the point is that 2
this action item, this list represents a very tight budget for 3
the agency.
We have not built in contingencies.
4 CHAIRMAN AHEARNE:
I don't expect we will today 5
at this stage, but what confidence would you have that if we 6
were to approve the reprogramming you have here -- and you 7
have moved ccme money from A to B -- that in order to do the 8
reprogramming that might be necessary to cover the $9 million, 9
that you wouldn't then have to take that money which you moved to from A to B and move it to C?
11 Would you have much confidence?
Little confidence?
12 MR. DIRCKS:
I would'have not much confidence that we 13 would be able to swing it. Now, I am saying that as a general 14 term.
Of course, when we look at individual items we will 15 have to cost it out again.
But it was very difficult putting 16 this thing together in the first place. It is like pulling a 17 string on a sweater; you may unravel the whole thing.
l 18 So we are putting it up to you.
But if there are a 19 lot of changes or major changes or something happens in the l
20 next year or so in the future of the program and we have to 1
21 shift resources around, we will have to take this whole thing n
back to the drawing board.
l 23 CHAIRMAN AHEARNE:
I see.
l 24 Now, I have one other question on the reprogramming, 25 if I may.
The reprogramming that you are proposing is one 4
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1 that you have now reached agreement on with the office 2
directors, or are there significant things to be heard from 3
the office directors?
4 MR. DIRCKS:
There is agreement.
5 MR. CORNELL:
There is one other item that is assumed 6
in ais reprogramming, and that is that the current hiring 7
freeze doesn't significantly affect the availability of staff.
8 CHAIRMAN AHEARNE:
Another way of saying it is if the 9
current hiring feeze doesn't last very long.
10 MR. CORNELL:
That is right.
l 11 MR. DIRCKS:
Roger, can you go into this NTOL list as 12 a licensing list now?
13 MR. MATTSON:
I would like you to turn to Enclosure 1
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14 of the Commission paper.
It would be easier to follow along.
15 CHAIRMAN AHEARNE:
Why don't you assume that we 16 either have read it or will read it.
I have no problem with 17 turning to Enclosure 1, but I hope you can describe for us any 18 majcr changes.
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19 MR. MATTSON:
That is what I am going to do.
20 CHAIRMAN AHEARNE:
Fine.
21 MR. MATTSON: I want to first describe how this list 22 in five parts compares to the NTOL list that you approved on 23 February 7th as being necessary but not necessarily 24 sufficient.
You start with a summary statement, which is 25 essentially the same.
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There have been slight changes as to implementation 2
details, and there has been some enlargement of the specifics 3
insofar as the Bulletins and Orders Task Force final 4
recommendations we"e concerned.
5 You will recall on February 7 the NTOI, list had one 6
item.
It said the appropriate final recommendations of the 7
Bulletins and Orders Task Force. We said subsequently we would 8
break those items out. They have been broken out and are 9
included in this list now.
10 There is another general characterization of this 11 list.
It comes in five parts for ease of understanding when 12 the five parts apply and to whom they apply. So Part I is that 13 set of. fuel load requirements, which we have, in fact, used on i
14 three license applications to date: Sequoyah, North Anna 2 and 15 Salem 2.
16 Part II are the full power requirements, that is, 17 those things from the NTOL list that you approved on 18 February 7th that were condiditions for full power.
19 Part III is the list of things that we said we wanted 20 to complete internally before we were in a position of 21 granting licenses.
Some of those things we said we wanted to 22 do before fuel load, like telephones, some before full power, 23 like notice of intent to conduct rulemaking.
24 Part IV is a list that has caused some 25 misunderstanding and interpretation of the NTOL list.
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probably the real reason for breaking all these things out.
2 That is the list of things that we call data requirements.
3 They have a date certain beyond which any plant in' operation 4
must be in conformance with the requirements, but they were 5
not preconditions of licensing.
6 In other words, Salem 2, North Anna 2 and Sequoyah 7
were merely required to commit to meet those requirements by 8
the specified date. Saying it another way, they were treated 9
as if they were operating, on that list of requirements.
10 Part V is a similar list, dated requirements that 11 have not yet been approved but are contained in the Action 12 Plan with the expectation that they will be approved 13 relatively shortly, and which are required to be met by the 14 end of this year, January 1, 1981.
15 With that brief overview, what I would like to do is 16 just skip through the five categories.
That is the reason I 17 would like you to turn there, because I am going to hit just a 18 few of these and try to show you the kinds of changes that 19 have occurred since you saw the list on February 6th.
1 20 CHAIRMAN AHEARNE:
And you will call out any 21 significant change.
M R". MATTSON:
Yes, I will call out all significant 22 23 changes.
CHAIRMAN AHEARNE: Fine.
24 25 MR. MATTSON:
First, in the list of fuel load
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requirements, which is the first part, on page 1 of those 2
requirements, item I.A.1 3 from the Action Plan, shift
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3 manning.
4 When we stated it for you on the 6th anc 7th of 5
February, we said one RO and one SRO in the control room at 6
all times. Since that time, in implementing that requirement 7
we have gotten into more detail about what do.you do for a 8
single unit site and a multi-unit site.
9 The staff has implemented it in a way that is 10 completely satisfactory to the steering group that put 11 together the requiroment in the first place. It is consistent 12 with the objectiv; that was intended to met.
And the 13 additignal words that are written here provide guidance for 14 future implementation of this requirement on multi-unit or 15 single-unit sites.
16 It just clears up some uncertainty that the simple 17 statement of one SRO and one RO was not sufficient to cover.
18 For example, if you said one RO and one SRO, the utility might 19 say, fine, I will stop letting or requiring the SRO to tour 20 the plant.
Well, that is counter to safety.
21 That was not the intent of the requirement.
The 22 intent of the requirement was to have enough SR0s to have one 23 in the control room and one touring the plant, which really is 24 a two-SRO requirement.
This makes it perfectly clear that 25 that is the case.
ALDERSON REPORTING COMPANY, INC, 6
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Turn the page to item I.B.1.2 at the bottom of the 2
next page, evaluation of organization and management 3
improvements of near-term OL applicants.
This is the business 4
of the on-site safety engineering group, the goodness of 5
criteria for operations management and so forth that were 6
described in the previous list.
7 What has happened since then is that there have 8
been some draft criteria issued by the staff.
They have been 9
provided to the Advisory Committee and to you, and we are 10 using those draft criteria, not as hard and fast rules in 11 these on-site team visits but as guidance to the staff and to.
12 the licensee as to what we are looking for.
13 Turn over to page 5.
There is an item II.B.4 near i
1-4 the bottom called training for mitigating core damage.
This 15 is a good example of how in this new OL requirements list we 16 have broken things down into much more understandable 17 portions.
18 In the old NTOL list, on this item it said do 19 something~by fuel load and then do something more by full 20 power.
In this case, have a training program by fuel load, 21 conduct a training before full power. Here it occurs twice, 22 once as an entry in the fuel load list, and then again as an l
23 entry in the full power list.
l 24 The reason I called this one out as an example is we 25 found it very useful in the last couple weeks to take this 7
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list from the steering group perspective and go back with the 2
four project managers and their branch chiefs and assistant
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3 directors and the technical staff that is assigned to the 4
review of these near-term OLs to find wnere there had been 5
miscommunications or differences of interpretation of the j
6 discrete or short descriptions contained in the February 6 7
list.
8 This is one where we found slight differences in 9
interpretation. The implementing staff had followed up with 10 training for operators, where the steering group had intended 11 training for the operational staff generally.
This is 12 something that will now be picked up on the three near-term 13 OLs before they are issued full-power licenses, and picked up 14 on future OL applicants before they reach the fuel load stage.
15 I don't think that is a disabling difference.
It is 16 just that with as many requirements as we are talking abcut 17 here, with the discrete phasing of them, there is bound to be 18 some difference of interpretation.
We think we have ironed 19 cut a number of those in the past couple of weeks in reviewing 20 this list.
21 Turn to pages, to page 8 and 9.
Notice on page 8 at 22 the top, II.K.1, and on page 9 about the middle, II.K.3 23 Before, in the near-term 7L list, these were simple one-line 24 entries that said implement the Bulletins and Orders stuff.
25 Now they have been broken out.
You will see from the ALDERSON REPORTING COMPANY, INC, f647d tnJ5LgjyyAdypp@ gsfam 6
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bulletins, II.K.1, there are a number of specific requirements 2
that stand alone. That is, they are not covered by anything 3
else in the Action Plan.
4 CHAIRMAN AHEARNE:
The'ACRS should be happy.
5 MR.MATTSON: Oh, yes. the ACRS was very happy with 6
this. This happened, actually, back at draft 3 that we made 7
the breakout.
All of this, broken out and reviewed piece by 8
piece now, has been accomplished with the Advisory Committee.
9 The significant point of difference is gone at this juncture 10 and has been gone for a couple months now.
11
, Those are the only differences I would call out as 12 significant in the fuel load requirements section of this 13 list..As you can see, they are relatively minor changes.
1-4 If you go to Part II, the full power requirements 15 list, you will notice at the bottom of page 2 of that section, 16 II.B.4, it says to complete the training of all operating 17 personnel for mitigating core damage. That is the example I 18 called out to you a minute ago that will be picked up on all 19 plants now that we have completed that.
20 CHAIRMAN AHEARNE:
Before you pass page 1,
could I 21 ask you a question?
22 MR. MATTSON:
Yes.
23 CHAIRMAN AHEARNE: You have a requirement to be met 24 before the issuance of a full-power license, the low-power 25 test program being completed before the issuance of a ALDERSON REPORTING COMPANY, INC,
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full-power license.
Does this embed in it the concept of 2
double license, a low-power license and a full-power license?
3 MR. MATTSON: The assumption here is that there will 4
be two licenses: a fuel-load and lower-power license, and a 5
full-power license. A full-power license is the authorization 6
to do anything above 5 percent power, other than the testing 7
that was done below 5 percent power.
8 CHAIRMAN AHEARNE:
Bill, that is where you came out, 9
that you believe the double license is appropriate?
10 MR. DIRCKS:
In this case, yes 11 COMMISSIONER HENDRIE:
But someplace down the line we 12 get to a place where the full array can be considered in one 13 review.and we don't have to go through two stages with the 14 staff and two stages here.
l 15 MR. MATTSON:
McGuire and all subsequent plants, as it s.ays in the Commission paper.
NRR is reviewing for just l
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17 one license.
18 CHAIRMAN AHEARNE:
I understand that.
That is why I 19 asked the question.
That is not what this says.
20 MR. DIRCKS:
This is the three-load power.
21 MR. MATTSON:
Let me try to explain. For McGuire, you n
take the fuel-load requirements and the full-power requirements and complete the review on all of those before 23 24 any license, plus commitments to meet the data requirement.
COMMISSIONER HENDRIE:
Then they get one document and 25 l
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can go.
2 MR. MATTSON:
Yes.
3 CHAIRMAN AHEARNE:
But see, that is what --
4 MR. MATTSON:
Your problem is completing the review 5
of the results of the lower-power testing.
6-CHAIRMAN AHEARNE:
That is right.
7 MR. MATTSON:
That has to be handled as some kind of 8
special condition in the license. If you want to put a hold on 9
them, to review the results of those tests before going 10 forward.
11 CHAIRMAN AHEARNE: It is one thing to say that before 12 that final step could be taken, this test program would be 13 reviewed. But it says it differently here.
14 MR. MATTSON:
You would have two choices.
You would 15 say I don't need to look at it, or you would say I do need to 16 look at it, and in order to make sure that happens, I will put 17 a condition in the license that says before they go beyond, 18 they must submit the results.
19 COMMISSIONER BRADFORD:
Where is McGuire now?
When 20 do you contemplate issuing that?
21 CHAIRMAN AHEARNE:
I am sorry. Can NRR answer that n
question?
23 MR. DENTON:
As far as McGuire, we would intend to 24 file a supplement with the Board covering the Commission's 25 approved list of full-power requirements within the next 30 to l
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60 days.
2 CHAIRMAN AHEARNE: Or within 30 to 60 days after --
3 MR. DENTON:
After approval of a satisfactory list.
4 CHAIRMAN AHEARNE:
But it is contested?
There is a 5
board.
6 MR. DENTON:
Yes, it is.
7 MR. MATTSON:
Did that answer your question?
8 CHAIRMAN AHEARNE: That is fine.
9 MR. MATTSON: Turn over to page 4 of this list. I will 10 call to your attention one we left out, one under II.K.2 on 11 page 4. If one reads closely Table C.2 of Appendix C of the 12 Action Plan, you will find that there is an additional item, 13 C.2.2,.that was omitted from this list.
It has to do with 14 procedures and training to initiate and control aux feedwater 15 independent of the integrated control system.
16 That is something that still has to be done for all 17 B&W plants. Any B&W plant that would be licensed according to 18 this list would have to do that.
That was an inadvertent 19 omission.
20 On page 5, upgrade emergency preparedness, I just 21 want to call to your attention that the final implementatien Z2 of the joint FEMA /NRC responsibilities for full-power license 23 have not been exercised yet.
There still is some remaining 24 uncertainty in the completion of those responsibilities.
25 This list, although we tried to draw down the ALDERSON REPORTING COMPANY, INC, smu.mpam
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uncertairty in each of the requirements areas, did not 2
significantly advance the ball on this particular issue.
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'3 think you are going to have to draw that uncertainty down with l
4 a plant-specific example like Sequoyah.
5 What I am saying is there will be uncertainty until
-6 you reach a final point.
7 CHAIRMAN.AHEARNE: Until they actually.do one.
8 MR. MATTSON:
Yes.
9 That is all I would call out in that section.
10 If you turn over a couple pages to NRC actions, there 11 are two pages of them.
Only three are of interest, I think, 12 for today's discussion.
The rest have all been completed or 13 are within the domain of the staff to complete and are not k.
14 part..cularly troublesome.
15 The three of interest are II.B.7 and II.B.8 on page 16 1.
Those are the ones having to do with degraded core l
17 cooling.
There is one on hydrogen control, the paper that 18 has been sent to you, the meeting you have held, subsequent i
l 19 filings that you have asked for, leading ultimately to some 20 Commission position on interim hydrogen control measures for 21 small containments.
22 That is one we have to come back to you on outside of 23 the context of the Action Plan, but it is contained in the l
24 Action Plan, and one that we expect we will want to decide 25 before licensing new plants for full power.
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The second item, of course, is associated with it.
2 That is the degraded core rulemaking, the advance notice of 3
intent to conduct rulemaking, and the associated item of an 4
interim rule to incorporate not only the other degraded core 5
cooling things that we have done in the short term, like the 6
short-term lessons learned, but also the decision in II.B.7 on 7
interim hydrogen control measures, if any.
8 We would expect that to be in the interim rulemaking.
9 So both of those we have to come back to you on.
10 And again on page 2, item III.B.2 is that 11 implementation of NRC and FEMA responsibilities that ties back 12 to the other list. We have got it stated twice in this list.
13 Once is as something that the licensee has to clear up, and 14 one is as something that the staff has to clear up.
15 Turning the page, we come to the dated requirements 16 that I have summarized our definition of before.
If you will 17 turn to page 3 of that list, I will call to ycur attention ul item I.C.1. This is the third phase of the three-phase l
up accident analysis and procedure revision program, the i
short-term lessons learned and the Bulletins and Orders Task 20 21 Force working.in concert.
22 The first two phases are required to be implemented 23 as fuel-load conditions.
The third phase was required to be 24 implemented summer.
What we have found is that there are difficulties in deciding how much resources to spend before l
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you make what improvements in analytical capability.
2 There has been significantly better understanding of 3
how to model some transients and small break local accidents 4
more realistically in the past year.
So what is happening in 5
I.C.1 is a slip in the ability to produce the final revised 6
procedures that were involved in that third phase.
7 You will recall that was all of the Chapter 15 8
transients and accidents for a standard safety analysis 9
report, a significant analytical undertaking.
10 What we are proposing here is to redefine the program 11 to be more manageable chunks or pieces of that big third 12 ' phase, and then to couple it to item I.C.9 in the Action Plan, 13 which was the long-term upgrading of procedures.
1-4 Now, to us reakes very clear technical sense to do 15 that. What it means is the revision of procedures in operating 16 plants will proceed at a more deliberate pace than if we were 17 to insist upon this work being complete this summer. One of 18 the reasons for doing that is clearly a need not to change to 19 procedures on the basis of analyses that were done too rapidly 20 and potentially incorrectly.
21 It is a deliberate slowdown of this third phase to 22 avoid drawing improper conclusions of some of these transients 23 and accidents.
24 CHAIRMAN AHEARNE: What kind of a completion date will 25 they shift it to?
ALDERSCN REPORTING COMPANY,INC, FA7G RTRMT. M. asp @RTERS BUILOING, WASHINGTCN, D.C. 20024 (202) 554-2345
2Z 1
MR. MATTSON: The statement here is that they will by 2
July define that.
I have said in the course of the last year 3
that I think what we ought to do is recognize that the 4
reanalysis and the retraining and the steady improvement of 5
procedures is essentially a lifelong endeavor in the nuclear 6
power business from now on, like it is in the nuclear navy.
7 I understand that that is probably not very 8
satisfying to you.
9 CHAIRMAN AHEARNE: It sounds like you just said we to will never finish.
11 MR. MATTSON:
That is exactly what I said. And I hope 12 we adopt an attitude where we never will finish, where we 13 will always try to understand better.
I 14 CHAIRMAN AHEARNE: But let us assume that you had here 15 a narrowly-defined task.
16 MR. MATTSON:
I think we should shoot to couple it 17 with I.C.9, a complete revision on philosophical and technical 18 underpinnings for emergency procedure revision, casualty 19 procedures.
If we do that and that is the outcome of the 20 considerations between now and July, it would mean several 21 years.
But it would come in pieces between now and the end of 22 those several years.
23 If we decide that no, we ought to take the codes we 24 have now and that there is a need to revise certain kinds of 25 procedures promptly, then you will see a different kind of
(
l ALDERSON REPORTING COMPANY, INC, l
911GLf1TRT6. RW, R3 PORTERS BUILCING, WASHINGTON, D.C. 20024 (202) 554 2345
23 1
answer.
The things that will go into that decision are the 2
pilot project audits of emergency procedures that are going on 3
now for the near-term OL's that are in this list of 4
requirements.
5 COMMISSIONER GILINSKY:
Could I just take you back 6
for a moment *to II.B.77 It is the analysis of hydrogen 7
control.
That is to be completed before issuance of a 8
full-power license.
What I would like to ask you is whether 9
you are confident that moving forward on a limited license 10 would not foreclose any options for fixes that might be 11 employed as a result of our review of this problem.
12 MR. MATTSON:
Yes.
I think you have, in fact, made 13 that decision in the case of Sequoyah.
14 COMMISSIONER GILINSKY:
Well, it is nct clear that we 15 thought that one through clearly.
16 MR. MATTSON:
In any event, the answer to your 17 question is yes.
I think you can --
18 COMMISSIONER GILINSKY:
I mean we did approve 19 Sequoyah, and you might say implicitly.
I understand what you 20 are saying. But I have come to learn a good deal more about 21 the subject since then, and I guess I would like to have your Zt opinion.
23 MR. MATTSON:
Well, operations that produce 24 insignificant fission product inventories, I don't see how 25 they could affect the ability to make design changes relative ALDERSON REPORTING COMPANY, INC, I
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1 to a clean plant at all.
Why 10 there any difference?
2 MR. DENTON:
Roger, we see this as an important 3
consideration when we come to discussing cps because there it 4
is possible to take actions to moot the issue.
But I don't 5
see that at the fuel-load license, it forecloses options.
6 COMMISSIONER GILINSKY:
So that is not going to buy 7
us the options one way or the other.
8 MR. DENTON:
No, I don't see that it materially 9
changes our ability.
10 MR. MATTSON: What was an implicit decision to you was 11 fairly explicit to us down at the staff. We did cross that 12 bridge purposely and think it through.
13 Back to the list we were on, page 4, item II.D.1, k
14 relief and safety valve test requirements.
This is one where 15 the Office of Research has told the Office of Nuclear Reactor 16 Regulation that in their judgment there are some potential 17 schedule slippages in this item, a major test program 18 undertaken by the Electric Power Research Institute, which 19 most licensees have endorsed as a way of meeting this 20 requirement.
l 21 l
22 23 24 25 l
ALDERSON REPORTING COMPANY, INC, M
25 1
That is a question that underlies several of these 2
dated requirements, not insofar as the full power licenses are 3
concerned, but the operating plants, I believe, are more of 4
interest as to what will be your policy when the plants come 5
around later this year and are having difficulty meeting the 6
second, or Phase B short-term lessons learned deadlines.
7 CHAIRMAN AHEARNE-We will obviously ask the leader 8
of the Lessons Learned Task Force why he came up with such 9
impractical deadline.
10 MR. MATTSON:
He will respond that he didn't think 11 they were or does he now think it is impractical.
12 CHAIRMAN AHEARNE: But on this particular one, Roger, 13 you are saying that they are planning to meet this by an EPRI 14 program.
15 MR. MATTSON:
Yes.
i 16 CHAIRMAN AHEARNE: And the EPRI program is going to l'7 take longer?
Is that the point?
18 MR. MATTSON: It is not as if the program were 19 slipping by years.
But because they put it together in one 20 big and, frankly, good research program that involves major 21 expenditures of dollars, there seems to be some hedging about 22 a year in advance of the completion date.
23 Buying and procuring and installing equipment and 24 then doing the analysis and the engineering so that you are 25 able to represent that a specific number of tests are, in l
I i
ALDERSON REPORTING COMPANY. INC.
~
$6 1
fact, characteristic of a large number of valves and valve 2
arrangements is a very difficult undertaking and I think 3
people are trying to offer fair notice that this date may 4
- slip, 5
I am just adding to that there probably are some 6
others that'will slip and we need to think,that through.
7 CHAIRMAN AHEARNE: But are you talking months, years?
8 MR. MATTSON: I am not talking years. I am talking 9
months, weeks.
10 MR. BUDNITZ:
Mr. Chairman, on that one, and there 11 may be others like it, if we think that the thing has been put 12 together in a good way and that it is comprehensive, and it is 13
(
a little longer than what was written down several months ago 14 as a schedule, we are just going to follow it and do it right.
15 CHAIRMAN AHEARNE:
Of course.
16 MR. MATTSON:
The final group is proposed dated 17 requirements.
There are about 15 of them in there. Only two 18 of them are n'ot Bulletins and Orders requirements.
Thirteen 19 of them are specific things taken out of the Bulletins and 20 Orders final recommendations, broken out here and recommended 21 for implementation prior to January 1, 1981.
There are a Z2 couple dates that are shorter than that.
23 None of these have been issued save one, the last 24 one, which has a July 1, 1980 deadline.
Although it is in 25 this proposed and not approved list, in fact it has been 9
ALDERSON REPORTING COMP ANY, INC,
27 1
informally issued by the staff, a response has been received 2
and is under review right now.
3 CHAIRMAN AHEARNE: In general, Roger, on the dates, 4
getting to a similar point that you and Bob were just making, 5
there are a large number of requirements, and dates lent 6
to these requirements.
That obviously has been something that 7
you and the ACRS, industry groups, et cetera have been trying 8
to wrestle with.
9 Putting aside the question of what substantively 10 ought to be done, the questions of how can this be done best 11 and what kind of timeframe can it be done on, are the dates 12 that you have reflected here significant modifications from 13 those that you started with, or are we pretty much at this 14 point still sticking with our early dates with the expectation 15 that as it begins to get more solid substance in each program 16 as reflected by these, that they may have to shift?
17 MR. MATTSON:
These are the dates we started with, 18 with the following exceptions.
In Part V, in the proposed 19 dated requirements, you can go to the Bulletins and Orders 20 final recommendations.
You will find that they recommended 21 implementing some of their recommendations within about a Z1 six-month period, which would have put, if you added the six 23 months to the date of the reports, a number of these January 24 1,
1981 dates earlier than January 1,
1981.
25 The steering group, hardened by multiple revisions of ALDERSON REPORTING CCMPANY. INC,
28 1
the Action Plan, said it is hard to expect we will reach 2
decisions on which to approve or disapprove in time to meet 3
those dates, and stretched them pretty much across the board 4
to January 1,
1981.
We did so on the basis of what we thought 5
was good for safety, and you will see that some of them didn't 6
go as far as' January 1, 1981.
7 But all of them that you have seen before and 8
approved before are still on the same dates as originally 9
recommended.
H)
CHAIRMAN AHEARNE: All right.
11 MR. MATTSON:
That is all I would do to summarize the 12 OL requirements list. Again, I would say they are fairly 13
(
inisignificant changes. We have not added appreciably, nor 14 have we subtracted appreciably, and we have tested them in a 15 variety of ways since last we spoke to you on them in 16 February.
17 CHAIRMAN AHEARNE: I wonder if I could get Harold to 18 at least provide his comments on how he would view these lists 19 from the standpoint of how NRR would look at them as a set of 20 requirements.
i 21 MR. DENTON:
We in the Division Directors have looked 22 very carefully at it and concur with Roger's charaterization.
23 Do you mean in terms of the adequacy of the requirements and 24 their dates, or from some other standpoint.
25 CHAIRMAN AHEARNE:
From the standpoint that one of ALDERSoN REPORTING COMP ANY, INC,
29 1
the issues we obviously had oefore and we will have to get to 2
is the Commission is going to have to give direction to NRR, 3
to say that now we believe that there are a set of 4
requirements that are both necessary and sufficient for going 5
ahead and that we are also going to have to give some 6
direction towards.
7 So I am asking, really, from your point of view, what 8
recommendation are you in NRR making to the Commission?
9 MR. DENTON: Let's assume that you concur that these 10 are the ones that you would like to direct us to focus our 11 resources on and that we start reviewing against these 12 criteria.
It does leave the remaining question,of how do you 13 specify for the adjucicatory process?
14 CHAIRMAN AHEARNE:
No, I understand that that is 15 a separate issue. The issue is that from your role as the 16 director of NRR, are there some areas that you feel 17 uncomfortable with that are not included in here?
Or are 18 there come areas that are included in here that you don't 19 think need be?
That is really the question.
20 MR. DENTON: I concur in these areas. We looked and we 21 did find a couple of areas, and we looked to see what was 22 being done in those areas.
There are not any areas that I 23 think need to be in here that aren't in here, and I am 4
24 comfortable with this list.
25 There are a few things where I know actions are l
ALDERSON RE?CRTING COMPANY,INC,
30 1
occuring in that area and I don't have resources programmed.
2 My concern is less with the substance of it than it is my 3
programmatic reshuffling to meet these dates. In going through 4
the list, we did identify a few areas which we hope to come to 5
fruition, perhaps by encouraging NPO to work harder in certain 6
areas so tha't they do some things and we don't have to do 7
them.
8 I am comfortable in the sense of reprogramming that I 9
will get all these done and this is an adequate set.
So we 10 have looked at it from the standpoint of what would we add and 11 what would we delete.
12 CHAIRMAN AHEARNE:
Now, several of them, as Roger has 13 pointed out, like the hydrogen one, have requirements which I
(
14 guess, as we shift down through the spectrum, either fall 15 on you or Bob to produce material for us.
And do you think 16 that you can do that?
17 MR. DENTON: Yes, I do.
That comes back to the l
l 18 issues, though, that Bill raised originally. We are strained 19 to meet these dates and all our other obligations.
It has no l
20 contingency in it. It assumes supplements and that sort of 21 thing.
22 So it wouldn't take a lot to disrupt our ability to 1
23 meet some of these dates.
As I am sure it is in Bob's case, 0;
lack of money would affect his ability to meet certain dates.
l l
25 MR. BUDNITZ:
What is in there from the Office of l
ALDERSON REPORTING COMPANY, INC,
31 1
Research I think we can meet, even with cuts that we might 2
sustain, because they are high proiority and we will do that.
3 But there are a couple of places where I have a little 4
nervousness, and they are in the supporting of the upcoming 5
rulemakings.
6 There is going to be a rulemaking upcoming on siting, 7
according to the plans, and another one on what is called the 8
degraded core issue, which is really all tied in with 9
reevaluating design basis accidents and Class 9 and so on.
10 It is not completely clear to me that we are going to 11 be able to do all that is necessary in time for those if they 12 come along as fast as they may, and considering how long it 13 takes to resolve some of these technical issues. We are 14 working very hard on that.
15 Our 1982 budget plan, and then with that, backing 16 into 1981 to support those things, is vigorously under study 17 right now. In the next few weeks we will have that straight. I 18 can't promise that we will be able to do all that is needed in 19 time.
I know Bob Minogue and I have talked, for example, 20 about the siting question.
But otherwise we should be okay.
21 CHAIRMAN AHEARNE:
I am not sure what you have ended ZZ up saying there, Bob.
23 MR. BUDNITZ:
It may be that some questions that you 24 would like to have resolved for some of those rulemakings are 25 going to take longer to accomplish than the schedule has.
ALDERScN REPCRTING COMPANY,INC, eem
32 o
1 CHAIRMAN AHEARNE:
But I don't think there is a 2
conclusion date for the rulemaking.
3 MR. BUDNITZ:
That is right. It just depends on how 4
quickly that rulemaking comes along.
5 CHAIRMAN AHEARNE:
It depends on what you have in 6
mind.
7 MR. BUDNITZ:
Yes, that is right.
8 MR. HANRAHAN:
I think we would agree, Mr. Chairman, 9
that the list is sufficient.
10 CHAIRMAN AHEARNE: I was going to ask you whether you 11 have reviewed this or are planning to.
I thought, since this 12 has only arrived and is large, you are reviewing it, are you 13 not?
\\..
14 MR. HANRAHAN:
As far as we have gone. We have looked 15 specifically at the question of sufficiency and we really feel 16 that it is sufficient.
There would be nothing that we could 17 think of that ought to be added to this list.
18 COMMISSIONER BRADFORD:
Let's see what else you could 19 be reviewing once you had reached that conclusion. That is the 20 conclusion I think I would reach at the end.
21 CHAIRMAN AHEARNE: What I meant by reviewing is the 22 whole thing.
There is a whole bunch of reprogramming actions, Zi a whole bunch of reschedules.
But that is as far as this 24 particular item.
l 25 Joe?
/
ALDERSON REPCRTING COMPANY, INC,
33 1
COMMISSIONER HENDRIE:
Roger, why do you want an 2
advance notice of rulemaking on the degraded core thing, 3
II.B.8 under list 3, before full-power license issues?
4 MR. MATTSON:
Well, it isn't really the advance 5
notice that buys you anything.
This is the discussion we had 6
before in February on draft 2.
I read'that in the cold light of this morning perhaps the same way you are " reading it.
7 8
It is what the advance notice says that is important, 9
and meeting what the advance notice says that is important.
10 The advance notice says we are going to conduct rulemaking on 11 degraded core cooling.
The way we are going to do that is 12 issue first an interim rule, and then undertake some further 13 studies and some research and finally issue a final rule.
14 It is the interim rule, in fact, that is of interest 15 to us to have issued about the time we resume full-power 16 licensing.
17 CHAIRMAN AHEARNE:
Let me see if I understand. Are 18 you saying that what this requirement is is that an interim 19 rule be issued?
20 MR. MATTSON: If I had to write it all over again, 21 this morning I said to myself I would have written that 22 differently, yes. I would have written it that the interim 23 rule should be issued before resumption of licensing.
24 I believe that the use of words has been a little bit 25 loose between the advance notice for rulemaking and the ALDERSON REPORTING CCMPANY, INC,
34 1
interim rule.
They are, in fact, moving parallel within the 2
staff on their way down to you for approval.
3 CHAIRMAN AHEARNE:
They are different things.
4 MR. MATTSON: Practically, it doesn't make a lot of 5
difference.
That is what I am saying.
6 CHA'IRMAN AHEARNE:
Is that sort of what your steering 7
group would agree with?
8 MR. MATTSON:
I am sure they would. If there are 9
people from the steering group who think that is not what we 10 were planning all along, they ought to speak.
11 CHAIRMAN AHEARNE:
Okay. So we should then revise 12
" advance notice" to really be " interim rule."
('
13 MR. MATTSON:
Joe points out that II.B.8, the thing 14 we have characterized as an advance notice for rulemaking, is, 15 in fact, both the advance notice and the interim rule and the 16 final rule, all within one section of the Action Plan.
That 17 is probably what has led to the characterization.
18 CHAIRMAN AHEARNE: Now, Joe you are saying that in the 19 actual bulk of the Action Plan, all those items are included 20 under that.
21 MR. SCINTO:
Under the heading of Advance Notice.
22 The title is too long.
23 CHAIRMAN AREARNE:
Yes, except what I am really 24 trying to focus on is this section that is called NRC Actions.
25 As I come down here, I see the only thing that is spelled out ALCERSON REPORTING COMPANY, lNC,
35 1
is issuing advance notice of rulemaking.
2 MR. MATTSON:
If you want to be completely precise, 3
you say " issue the interim rule."
That is what we are after.
4 What I have said is that practically speaking we are'close 5
enough together, trusting the system can get them both out on 6
about the time schedule, that it doesn't make any difference.
7 But to be completely precise and pin'it down 8
completely, I think you would say " issue the interim rule, 9
first."
10 COMMISSIONER HENDRIE:
Roger, as I renamber the 11 proposed interim rule, it simply deals with the present 12 regulation on hydrogen design basis.
13 MR. MATTSON:
I am sorry. I was trying to listen to 14 two people at once.
15 COMMISSIONER HENDRIE:
The interim rule, so-called, 16 simply deals with, I believe, 5044, the present hydrogen 17 design basis?
18 MR. MATTSON: No, the interim rule is intended to 19 cover more than that.
We would intend to put into the rule 20 the other things that we have done, through letters, fo r 21 example, as short-term lessons learned that have to do with 22 degraded core cooling.
For example, there is the improved 23 leakage control, the improved shielding, the training for 24 degraded core cooling.
25 Those kinds of things would also be included. So it ALDERSON REPcRTING COMPANY,INC.
m m
36 ;
I would be an amendment to 5044 plus these other things that 2
would be contained in the interim rule.
3 Now, the way that we would decide to amend 5044 would 4
depend upon the outcome of II.B.7. That is, what is our 5
interim position on hydrogen control pending long-term 6
rulemaking?'
7 COMMISSIONER HENDRIE:
Do I remember it was our 8
intention to make the interim rule immediately effective?
9 MR. MATTSON:
Words like that have been used. I am to more of a mind to consider that we do it some other way.
11 MR. MINOGUE:
If I can recall, originally we came up 12 here with words like "immediately effective" and discussed it 13 before the Commission, ar,d the basis for "immediately 14 effective" did not seem to be there.
We are not now thinking 15 of an immediately effective.
13 MR. MATTSON:
We are also not thinking of a year long 1'
rulemaking.
18 COMMISSIONER HENDRIE:
There are no other kind.
19 But watch out that you better not 20 write this r quirement to be completed before a full-power OL.
21 At least a couple of full-power OLs should be looked at.
Z!
MR. MINOGUE:
The scope of the interim rulemaking has 23 been broadened from the first cut.
I think that is what the 24 problem comes from.
The original concept was very narrow, and 25 it was the kind of thing you could talk about being i
ALOERScN REPcRTING COMPANY,INC,
37 1
immediately effective. Since then, the system has managed to 2
fold into it some of these other short-term' actions that have 3
been taken. As the scope has gotten broader, it is no longer 4
the kind of thing you can make immediately effective.
5 CHAIRMAN AHEARNE: It is fairly broad scoped as listed 6
in this.
7 MR. MINOGUE:
That is correct.
But the original 8
scope was very narrow.
9 CHAIRMAN AHEARNE:
And you aren't going to do it in to less than a year.
11 MR. MINOGUE:
The more the scope broadens, the longer 12 it will take because it raises more issues.
13 CHAIRMAN AHEARNE:
But yet your conclusion is that 14 that should be completed.
15 MR. MATTSON:
Not completed.
It ought to be issued.
16 MR. MINOGUE:
Proposed.
17 CHAIRMAN AHEARNE:
Issue the proposed rule.
18 MR. MATTSON:
Issue the proposed rule, yes. That is 19 why I say it comports with the timing of the advance notice of 20 rulemaking, which says we are going to do it in two steps.
21 MR. DENTON:
The reason that this one is an important 22 one, or it has been my thought, at least, is that issuing a l
23 proposed one would provide sufficient guidance to the scope of 24 activities that would fall within this to allow the staff to 25 define it and work on that basis. We didn't require that it be ALOERSON REPORTING COMPANY, INC, 1
38 1
brought to fruition.
2 CHAIRMAN AHEARNE:
Well, Joe, this is still your 3
series of questions.
Continue.
If you are leaving this 4
topic, I want to follow some more.
But if you are still on 5
this one, continue.
6 COMNISSIONER HENDRIE:
Well, let me recap and see if 7
I understand.
What you propose under this item is that as a 8
condition for the issuance of the first full-power license, 9
that we have published a notice of a proposed ir.terim rule on 10 degraded core matters.
11 MR. MATTSON:
Yes. That is what we have said to.you 12 before.
The difficulty is the lawyers and the Office of 13 Standards Development have said to us that they must split 14 those into two documents.
One is an advance notict with 15 intent to conduct rulemaking, if I have got the words 16 straight, and the other is a proposed interim rule.
17 COMMISSIONER HENDRIE:
Let me go back again and 18 retread. What I now understand you saying is that before the 19 first full-power operating license issues, you will want the 20 advanced notice of a rulemaking on an interim rule for 21 degraded cores to have been published.
22 MR. MATTSON:
No, I don't think so.
I will tell you 23 what I want. I want the advance notice of intent to conduct 24 rulemaking to be issued, to have it say we are going to do it 25 in two steps, and I want the first step -- that is, the 9
ALDERSCN AEPORTING COMPANY, INC,
39 1
proposed interim rule -- to be issued for public comment.
2 CHAIRMAN AHEARNE:
Before you issue the full-power 3
license.
4 MR. MATTSON:
The full-power license.
I believe that 5
has been the intent of the steering group, at least, since we 6
first started talking to you about this back in December.
7 COMMISSIONER GILINSKY:
What you are saying is that 8
you want to have an interim position.
9 MR. MATTSON:
We want you to have an interim 10 position.
11 COMMISSIONER GILINSKY:
You want us to have an 12 interim position.
We all have it together.
13 MR. MATTSON:
Yes.
We want us all to have an interim 14 position.
15 COMMISSIONER HENDRIE:
And we are going to have the 16 text in hand to consider, of both a proposed interim rule and 17 the text of a notice of advanced rulemaking for the broader 18 scope and longer-term rulemaking.
And you will expect to have 19 that in the Commission's hands for consideration in 90 days.
20 MR. MATT DN: Oh, I would say within the next month.
21 They are moving well along.
The Action Plan calls for these 22 decisions to be made in July.
23 Ed points out to me that the Action ?lan still says 24 "immediately effective" rule.
The discussions we are 25 describing are rather late-breaking discussions, and the ALOERSON REPORTING COMPANY, INC,
40 1
Action Plan on this issue has not kept pace.
So the words 2
won't quite comport.
3 CHAIRMAN AHEARNE: Roger, the fact that you have a 4
date in the Action Plan doesn't necessarily mean that the 5
paper will get here at that time.
But I think Bob has just 6
said he expe' cts about a month.
7 MR. MINOGUE:
No, I didn't say that. I know it is 8
very, very far along.
There has been a bit of an element of a 9
moving target.
If we can lock in on the target, I think they 10 are there.
There is a substantive agreement within the staff 11 on all the big issues, and the package is in a good, 12 well-written shape if we can gel it.
13 COMMISSIONER GILINSKY:
The important item here, I 14 assume, is the interim position, because it doesn't take much 15 to give advance notice of conducting a rulemaking, unless one 16 gets specific.
17 MR. MINOGUE:
This advance notice lays out the scope 18 of a very sweeping rulemaking action.
It involves the study 19 of a very wide-ranging spectrum of accidents, it involves a lot of very complex issues in terms of how that rulemaking 20 l
21 interfaces with the siting rulemaking and so on and so forth.
22 Actually, the drafting in this advance notice has
[
23 been quite a difficult task.
24 COMMISSIONER GILINSKY:
I didn't want to suggest that 25 it wasn't a sizable task, but it seemed to me that the more ALOERSON REPcRTING COMPANY, INC.
I 41 1
difficult think to agree on would probably be the interim 2
position.
3 MR. MATTSON:
You are saying that the interim 4
position on hydrogen, a part of the interim rule, is something 5
that has already been up here, has been wrestled with, that 6
there are differences of opinion among reasonable people on 7
what is the right thing to do in the interim "for hydrogen.
8 That is a decision yet to be taken, and until that decision is 9
made, he can't write with certainty the proposed interim rule.
10 I think that is exactly right.
11 MR. MINOGUE:
But it is basically a judgmental 12 matter.
If we had all the insurance, it would be different.
13 There will be a significant element of engineering judgment; 14 some belief as to where things should go.
15 COMMISSIONER GILINSKY:
Sure.
I au just trying to 16 say that I thought that was the item that we are going to end 17 up struggling over.
18 CHAIRMAN AHEARNE:
There are also, I guess, some 19 resource questions when you go into that large a rule.
When 20 you are saying that we are going to do all these things, that 21 is a commitment, if we agree to it.
22 MR. MATTSON:
That is Bob Budnitz's earlier comment, 23 especially about research.
MR. SUDNITZ:
That is exactly right.
24 25 MR. MATTSON:
We are talking millions of dollars of ALDERSON REPORTING COMPANY, INC,
42 I
research over a several-year period.
2 CHAIRMAN AHEARNE: Vic?
3 COMMISSIONER GILINSKY: Not on this particular phase.
4 CHAIRMAN AHEARNE:
Peter?
5 COMMISSIONER BRADFORD: Not on this.
6 CHA'IRMAN AHEARNE:
Why don't you move on, Bill.
7 COMMISSIONER HENDRIE:
Before we go on, I do have a 8
sort of general question.
Since the dates herein on dated 9
requirements and indicated action dates on other things and so 10 on, are either the ones from the previous drafts of the Action 11 Plan or, in the case of some of the Bulletins and Orders 12 stuff, a sort of evening out at the first of 1981 from various 13 four-month implementation or six-month implementation or 14 whatever?
15 I have the impression that the overall package of 16 things to be done by applicants and licensees is not greatly 17 different than has been before us with previous Action Plan 18 versions, and the time scales proposed are the same.
I am 19 compelled, the r e fo r e, to ask what of the considerable 20 complaint from the industry groups who have been studying the 21 matter, that while these are all good items taken one by one, 22 that if you try to swallow them all at once, the pill won't go Il down: that there aren't the people out there to do it, the 24 resources in money to do it, in subcontractors and vendors and 25 suppliers of equipment and people who do things?
4 ALOERSCN REPORTING COMPANY, lNC,
43 1
Now, do I misunderstand the scope and timing of the 2
things that have to be done by various dates here, or do you 3
conclude that the industry complaint was unjustified and we 4
simply ought to go ahead on the old basis?
5 MR. MATTSON:
I think you misunderstood the industry 6
complaint.
What we are discussing here is essentially the 7
near-term OL list.
It is essentially the sam'e as revision 2 8
of the NTOL list which you saw on February 7th. The 6th is 9
when it was mailed to you.
10 In January, upon seeing the first NTOL list, you said 11 we ought to check it with an operator's perspective.
We went 12 out on a site visit, you remember, that Jim O'Reilly put 13 together.
We came back to you in February and said you were 14 right, there was too much.
Although each of them individually 15 were okay, there were some where it was too much.
16 17 18 19 20 21 22 23 24 25 1
ALDERSCN REPORTING COMPANY, INC,
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So we gave you a basis of priorities and duplication 2
and insufficient specification to remove a number of items 3
from the first NTOL list in arriviag at the second.
That was 4
done between drafts 1 and 2.
5 Now, the Atomic Industrial Forum made a presentation 6
to the ACRS on March 6th, based on its review of some 51 7
requirements from draf t 2 of the Action Plan, which included 8
the near-term OL list.
They said that although their pr iority 9
one list was somewhat different, and I will quote here: "If 10 the NRC staff and the ACRS agreement on our list is not 11 forthcoming, the staff's NTOL list is not an unreasonable 12 substitute, contingent upon the revisions necessary to achieve 13 adequately bounded scopes and realistic schedules.
14 Now, we believe that we have reviewed their comments 15 sincerely. We have given back to them and to you a detailed 16 accounting of every twit that changed as a result of reviewing 17 those comments.
We have informally asked them if they wanted 18 to reconsider, given our responses to their comments, as to 19 whether the NTOL list had adequate, reasonable schedules on 20 it 21 They chose not to take the opportunity.
- Now, i
22 informally doesn't buy much for you, but I think we have taken 23 a considerable effort to guard against moving more quickly 24 than the resources and talent of the nation would permit in
)
25 applying back to these plants: that is, going to fast that we 1
ALDERSON REPORTING COMPANY. INC,
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reduce safety rather than increase it.
2 I believe that this testimony at the ACRS by Warren 3
Owen from Duke and the other responses of the industry confirm 4
our belief that we are moving as quickly as we can do it 5
correctly.
6 CHA'IRMAN AHEARNE:
The only problem with relying on 7
that testimony, Roger, is that, as you have just quoted, he 8
said they agreed subject to changes of more realistic 9
schedule.
I don't think Commissioner's Hendrie --
10 MR. MATTSON: There is one point I should bring up, 11 and perhaps this will ring a bell.
There has been some 12 difficulty, both with the industry and.the ACRS, on a couple 13 of the* Bulletins and Orders requirements, one having to do 144 with pumps on, pumps off, and the other having to do with 15 automatic closure of the PORV, and the other having to do with 16 keeping the high pressure coolant injection turned on.
17 On those three, the steering group, on the urging of 18 both the industry and the ACRS, took a hard look at what 19 further studies needed to be done and what phasing there 20 needed to be of those further studies with, for example, 21 installing automatic reactor coolant pump drip.
And some 22 of the further out requirements not on this list have, in 23 fact, been changed as a result of that input.
24 You may be confusing some of their very adamant 25 counter-to-safety arguments, which were made and were ALDERSON REPORTING COMPANY, INC,
46 1
responded to, I think correctly, with their other comments on 2
the NTOL list.
So those kinds of changes we e made.
l 3
Insofar as changing the implemen' ation deadlines in 4
the short-term lessons learned, which is essentially the heart 5
of the NTOL list, there hasn't been any change.
I don't think 1
6 the industry ever said that they couldn't do those.
They said 7
that if you keep adding at that rate, 30 or 40' things at a 8
clip, with very tight implementation deadlines, you will 9
saturate the system. I don't think they ever said they are 10 already saturated.
11 COMMISSIONER BRADFORD:
Encompassed within that may 12 have been the answer to a slightly different question.
13 Schedules and resources aside, Roger, has there been as part 14 of all this a process of working out the related concern of 15 how well these changes play off against each other, which I 16 Euess really is the pumps on, pumps off problem.
17 COMMISSIONER HENDRIE:
We have now got great 18 improvements in 107 individual places.
Do they in aggregate 19 make the overall system safer? Is it clear that they do, or is 20 it clear that they maybe don't?
21 MR. MATTSON:
There have been people who said, based 2?.
on my experience and my general knowledge of what these things 23 will do to nuclear power plants and my general knowledge of 24 how they have operated in the past, they are a net safety 25 improvement.
dQ ALDERSON REPORTING CCMP ANY, INC.
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In the sense of doing a more definitive analysis such 2
as was done for the B&W task force that Mr. Tedesco recently 3
headed, if you read chapter 7 of that task force analysis, you 4
will find what I think is one of the finest pieces of 5
analytical work to come to that question directly.
6 or course, they are working with fewer changes. They 7
are not working ulth thousands of recommendati*ons and dozens 8
of specific changes; they are working with a more discrete 9
set. It does provide a good analytical answer.
10 Now, for the short-term lessons learned changes, the 11 ones already implemented, the best overall system answer we 12 have is Crystal River.
I note Mr. Hanrahan's recent review of i
13 that concluded that the things we have done so far seem to be
\\
14 in the direction of safety, given that piece of operating 15 experience.
16 I can't point you to an overall system answer to the l'7 net effect of these NTOL changes.
It hasn't been done and it 18 probably isn't easy to do in any short period of time. We 19 understand your questions are coming more and more in that 20 regard. We understand the criticism of the way we make changes 21 have been concentrated in that area.
22 We are learning and we are trying.
The best example 23 of our ability to do it is the recent, I think, B&W task force 24 report that the PAS staff did for Mr. Tedesco.
25 COMMISSIONER GILINSKY:
Well, it is obviously a very l
l l
ALDERSON REPORTING COMPANY, INC, 1
48 1
hard thing to do when you are dealing with a vast number of 2
changes.
You would expect that the net result would be 3
positive if you'are talking about improving manning of the 4
control room, on the one hand, or improving instrumentation, 5
on the other. Yoo wouldn't expect that they would interfere.
6 But, of course, there may be things that do 7
interfere. Have you taken a look at, rather th'an trying to 8
integrate it all into one calculation, which is impossi' le, at 9
those things which do interact to see whether there are any 10 sort of odd interactions which might defeat the purpose of the 11 individual improvements?
12 MR. MATTSON:
The hardware changes, you mean?
13 COMMISSIONER GILINSKY:
Yes.
(
14 MR. MATTSON:
Yes.
In making the recommendations to 15 institute such hardware changes, whether the recommendations 16 came from the Bulletins and Orders Task Force or the 17 short-term lessons learned, such considerations were made in 18 quite a bit of detail, by competent engineers, and 19 double-checked in the sense of your operating experience 20 feedback that you asked for in January, by going to operating 21 staffs of eight plants and asking them that question.
22 Again, it was in the sense of asking the engineering 23 talent of the nuclear industry to comment on that kind of l
24 problem, the sort of thing that Warren Owen addressed the ACRS 25 with some months ago.
l l
l 50 ALDERSON REPORTING COMPANY,INC,
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MR. DENTON:
I think that the areas where we had the 2
most potential for that kind of close call was in the 3
Bulletins and Orders prescriptive requirements issued right 4
after the accident. Most of the remaining Bulletins and Orders 5
are more in the area of study the effects of this and that.
6 So it doesnt take a prescriptive one.
7 It is more a perf'emance standard or provide a means 8
to accomplish this. So there is less chance of our going out 9
with a direct prescriptive requirement than there was a while 10 back.
11 So I think the ones which have raised questions were 12 those ea'rly prescriptive ones which were at the margin, with 13 arguments on both sides, and then it is a question whether we T4 call the right side or not.
15 Roger, my reading of the remaining Bulletins and 16 Orders is there are only one or two left in the prescriptive 17 line, and they have not caused the type of questions that 18 those early ones about pumps on, pumps off caused.
19 MR. MATTSON:
That is right.
20 CHAIRMAN AHEARNE:
I think that as far as some of the 21 criticisms that have been raised, though, I agree with Harold 22 that -- certainly when I talk to the ACRS -- much of the 23 concerns that they were raising were on either specific 24 procedures or very detailed prescription that we had written 25 in.
Some of those questions were more related to having gone f
ALDERSON REPORTING COMPANY,INC,
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through it enough, had we done enough analysis on it.
2 The second set was are we overloading.
Where the 3
safety questions seemed to arise, we were putting on so many 4
requirements that in order to try to get them all done 5
rapidly, we would either overload the people who had to do the act'al installation work, for example, and end up having stuff 6
u 7
put in that was not checked out as well as it 'should be, not 8
done as well, or whether we were overloading on sets of 9
procedures for operators.
Were we making so many changes in 10 both' instrumentation and approaches that you were getting into 11 safety.
That was a separate set.
12 I think a lot of the changes you have made in your 13 approach have really addressed. hose.
t' 14 And then the third question was really more are we 15 doing more of the same in a continuing approach to review, 16 that is, an additional approach, albeit an improvement, on top 17 of the old approach and shouldn't there be a different way to 18 do it.
19 The only problem with that kind of criticism is that 20 we still haven't yet got a different way of doing it.
21 MR. DIRCKS:
The ACRS did have several reviews and 22 they did comment c. hat it was a well-balanced plan and 23 sufficient to proceed.
24 COMMISSIONER GILINSKY:
Joe, in raising questions 25 about this, are you concerned about the overloading aspects of
'3 ALDERSON REPORTING COMPANY, INC, 1
51 1
it or one of these provisions defeating another one, or both?
2 COMMISSIONER HENDRIE:
I think both.
They are rather 3
different.
You could have a very well-integrated set of 4
changes which in fact complimented one another and formed a 5
much-improved safety situation on a system basis, but still 6
could.concei'vably be in a situation where if you said do all 7
this tomorrow afternoon, everybody is running &round and there 8
aren't the resources to do it well in.that time, and that 9
could be a problem.
10 So it is really both, and I think we have all been 11 aware of the difficulties on both sides.
It always takes some 12 careful weighing.
We, for instance, in this set of 13 requirements are going to have'a new set of openings in the
\\
14 primary pressure boundary.
It is not large. They will be, 15 presumably, modest-sized pipes, an inch or two-inch pipes, 16 with multiple valving on them, and then probably tail pipes l'7 off down to a quench tank or something like that.
18 The aim will be that if you ever get noncondensables 19 in the system or maybe too much steam someplace, you can open 20 these valves and vents and you won't have a trapped hydrogen 21 bubble a la Three Mile Island.
22 But one also has to stop and think of what are the 23 valve failure statistics and what are the chances that down 1
24 the line I am going to have a small break loss coolant 25 accident because I had one of these lines break off or the l
l l
ALDERScN REPCRTING COMPANY, INC, t
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valves open unexpectedly on me and so on.
2 I think there are ways to make that assessment as to 3
whether you are gaining or losing.
It is the risk assessment 4
sort of business, and I assume that as we make those things, 5
we conclude we are gaining.
6 CHAIRMAN AHEARNE:
And you have skepticism?
7 COMMISSIONER HENDRIE:
Well, we are doing a lot of 8
things, in spite of the way the months drag on, in a 9
relatively short time.
Many of these things are not simple 10 analyses and not simple to form judgments on.
And because of 11 the large volume, I think it legitimately remains a concern 12 for us that we may be hopping a little too fast.
13 MR. DIRCKS:
Of course, that was a decision made by
(
14 the Commission back in September.
15 COMMISSIONER HENDRIE:
Yes, we have had that one on 16 the books a long time. I cite it just because it is fairly 17 obvious. It lends itself,well as an example to the discussion 18 of on the one hand and on the other hand.
19 CHAIRMAN AHEARN:
There are many of our decisions at 20 various stages that we may feel a little uncomfortable about.
21 MR. DENTON:
I would like to add one perspective on l
l l
22 that issue.
Fundamentally the issues haven't changed over the 23 past several months, and the industry and the staf f had had a 24 chance for more dialogue on the same point, to rethink about 25 it.
I think the issue, Roger, has calmed down a lot and we 1
ALDERSON REPORTING COMP ANY, INC, l
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have learned a lot over the time you have been developing the 2
various drafts of the Action Plan on these same items.
3 I am now being told by many utilities that things 4
like shift technical advisers are working out very well, they 5
are glad they have got them and it has been a significant 6
addition.
S'o I would have been far less certain of an answer 7
to this question back in Janary than I am here'today.
8 I think the passage of time has allowed the staff and
~
9 industry to work through some of these questions and we are on 10 much sounder ground than we were when we first thought up the 11 idea in some of these areas just because of the chance to 12 discuss it.'
13 MR. MINOGUE:
This is probably a good area.
The kind 14 o'r analysis that Dr. Hendrie talks about as needed to balance 15 the design of these things so that it improves safety instead 16 of detracting from safety is now built in to the requirement.
17 COMMISSIONER GILINSKY:
Up to now we have made these 18 decisions on the basis of engineering judgment, or what?
What 19 lies behind the conclusions that you are gaining when you 20 adopt one or another of these measures?
21 MR. MATTSON:
I think engineering judgment is the 22 wrong word. I think engineering analysis underlies the 23 decision to require all of these things if you accept that 24 engineering analysis supports human factors.
You might want 25 to call it something besides engineering. They have all been ALDERSON REPORTING COMP ANY, INC.
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54 1
analyzed. They have all been thought through.
2 COMMISSIONER GILINSKY:
Joe, what is this that you 3
find lacking here?
And Bob was shaking his head.
I wondered 4
what he had.in mind.
5 COMMISSIONER HENDRIE:
I think we still have to shake 6
down a sort of integrated assessment of all of these things.
7 That is, people have thought about them and argued about them 8
and said you would require this or not require it or require 9
it with a 90 degree turn to the left, and some analysis had 10 been done.
I think a lot of it continues to be the judgment 11 of staff people, knowledgeable. people, and to be a judgment
' 12 which is just not one person's snap judgment but considered 13.coalesoing of the judgments of a number of people over a
\\
14 considerable period of time.
15 I think there is reason to have reasonable confidence 16 in it, but I think also it is true that we have not really sat 17 down -- because it would be a very difficult and 18 time-consuming job to do it -- and really sort out for 19 ourselves to say, look, on plant model 3A, of the assorted 20 things we are requiring, this group over here will improve 21 safety that much, and this one is dead neutral, and these four 22 over here don't seem to make any difference within the ability 23 of risk assessment technology to implement, and you are left 24 with your intuition as to whether it is good or not, and so 25 on.
t i ALDERSON REPORTING COMPANY, INC, wvier.Wrc6m J51R SNn FRER Fth5aM
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Now, I don't propose that comment or this general i
2 line of comment as a reason not to move forward. If you try to 3
be sure that everything is perfect in the world before you put l
l 4
one foot in front of another, you are never going to get off 5
the place you are standing. So I think we have to move 6
forward.
7 We have been wrestling with this part'icular animal t
8 long enough so that I think I am willing to boot it out on the 9
street and send it down the road.
10 One of the reasons I make the comments I do here, 11 both about what it all may eventually turn out to mean in a 12
- carefully done and integrated assessment, and the comments I 13 make with regard to are we really sure we can get all this
'14 stuff done this fast, is that I would hate to have us move 15 forward on the proposed Action Plan with the thought in mind 16 that, by God, we have now done it, this thing is graven in 17 stone, we are so smart, and we have written it down here, and 18 these are the dates, and anybody that doesn't meet them can 19 knock his plant down and cart it out to the dump, and anybody 20 that can't meet them can't start a plant, no matter 21 what.
22 It just isn't that way. We have to recognize that in 23 spite of enormous effort over an extended period of time and a 24 very substantial achievement here, that it nevertheless is, I 25 think, not a perfect product. We are going to have to adjust ALDERSON REPORTING CCMPANY, INC,
56 1
it as we go down the line, both with redard to implementation 2
schedules and with regard to specific provisions.
3 And if we can understand that and also understand our 4
need to move something, then okay, let's go with it. And as 5
the difficulties ecme up and become more clearly defined down 6
the line, let's recognize that we are just going to have to 7
sit down and deal with them as they come up.
8 But I sure don't want us to sit here and start 9
telling ourselves that, boy, we better not hear from anybody 10 who can't complete this or we better not hear from anybody 11 that he thinks this one is not going on my plant.
12 MR. MATTSON:
I must say that your remarks are 13 completely in accord with the philosophy that went into the
(~
14 development of this.
15 CHAIRMAN AHEARNE:
Sure.
And I don't think any of us 16 who have sat through many of these sessions and worked through 17 all of these action plans are going to conclude this now is 18 ready for the tablet.
19 COMMISSIONER HENDRIE:
Well, I wanted to make this 20 explicit because the Commission on other matters has had an 21 inclination to build into its planning statements prejudgments 22 as to how likely it was to be willing to listen to 23 difficulties down the line.
I don't want us to be under any 24 illusion that this is so well-perfected a set of things that 25 no consideration of the difficulties would be given.
ALDEP. SON REPORTING COMPANY,INC, sm2 arg@6RL ED.R. K6#4 t9aal @2S2345
57 1
CHAIRMAN AHEARNE: What I would like to do is close 2
around 4 o' clock.
This is the first of several meetings, I 3
think, on this Action Plan. So Bill, perhaps you could take a 4
couple more minutes to talk about a few of the other pieces.
5 COMMISSIONER GILINSKY:
Let me just slip 1 word in 6
here edgewis'e.
I think what Joe says is reasonable. At the 7
same time, we don't want to be inviting everyone to be 8
slipping the schedules either. So it is a matter of finding a 9
judicious level of reasonableness.
10 COMMI'SSIONER HENDRIE:
If we now say, well, gee, some 11 of them may be difficult to meet, let's move everything off a 12 year, thed all over the land people will say "how about that" 13 and slip all their schedules a year. And a year from now we
(
14 will be saying they can't meet it because so on and so on.
So 15 yes, you are right.
16 CHAIRMAN AHEARNE:
We always will be reasonable.
17 MR. DIRCKS:
Enclosures 2 and 3 are related.
18 is a recognition that we couldn't achieve nearly 19 the number of tasks that were imposed in the Action Plan.
20 represents a balancing of the priority of various 21 Action Plan items, compared to the overall operating programs 22 of the agency.
23 What we intend to do here is outline that we can 24 achieve the highest priority tasks, priority group one.
Many 25 of the priority group two tasks can be initiated in fiscal l
l ALDERSON REPORTING COMPANY, INC.
L-
58 1
1980 and 1981.
2 We are identifying certain tasks that will be 3
deferred to fiscal 1982 and beyond.
The feeling is that those 4
tasks that have been deferred represent relatively less safety 5
significance or that we have other actions that we have taken 8
in short-term measure to make the deferral of actions 7
acceptable.
8 CHAIRMAN AHEARNE:
And the deferral being necessary 9
because of resources.
10 MR. DIRCKS:
That is right. It is based on resource 11 requirements.
12 What'we do, then, depending on whether you approve 13 this, is figure those into the 1980-81 budget, again based on
(
14 the assumptions that I outlined earlier, and then cover the 15 remaining Action Plan items, those deferred to 1982 and 16 beyond, and address them in the context of our 1982 budget 17 pres.entation.
18 Roger, did you want to go through any of that 19 7 20 MR. MATTSON: You have summarized it beautifully, 21 except on page 3 there are two mistakes.
I would like to make 22 sure the records are consistent.
You will see a little "c" on 23 page 3 with a list under it.
The first one in that list, 24 I.A.2.2, and then down in the middle of that list, II,F.5, 25 both belong up under "b."
Circle them and draw an arrow and ALDERSON REPORTING COMPANY,INC, SIO 7th 2TRsET. @,W AEPCRTERS BUILDING. WASHINGTON, D.C. 20024 CO2) 554 2345
59 1
put them up.
2 These were items that on first consideration looked 3
like they should be deferred; on reconsideration, the steering 4
group and NRR agreed they ought to be started in 1980 and 1981 5
and they put them in.
6 MR." DIRCKS:
I should mention, Roger, in this 7 there are 29 Decision Group B item's. These are 8
tasks which have not as yet been approved by the Commission.
9 Our plan here is, if you review them, we would like to start 10 15 of those Group B items in the 1980-81 program, and we have 11 cssumed them into our reprogramming action.
12 There are 14 we would like to defer into the 1982 13 year and beyond.
Given that sort of breakout, the whole 14 reprogramming subject, then, is based on this outline of tasks 15 and the task action plans.
16 Kevin has prepared the reprogramming.
17 CHAIRMAN AHEARNE:
Why don't you just give them an l
18 overview on it.
l 19 MR. CORNELL:
As Bill mentioned before, the 20 reprogramming exercise was done on the basis of a number of 21 underlying assumptions.
The first was that our FY 80 22 supplemental request of about $50 million would be granted.
23 Second was that our full FY 81 budget of about $470 million 24 would also be granted.
25 We did not assume the proposed 5 percent cut, for i
i ALDERSON REPORTING COMPANY, INC,
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instance, which has been talked about in the Senate 2
authorization bill.
Second, it did not take into account any 3
possible impact of the hiring freeze on the availability of 4
NRC staff.
5
.MR. DIRCKS:
The hiring freeze is significant not 6
only in terms of numbers but of skills and disciplines that 7
are built into this Action Plan, the whole range of human 8
factor skills. I think Harold would emphasize it is an 9
important part of this plan, and we certainly need some relief 10 from that hiring freeze to get those people.
11 CHAIRMAN AHEARN:
As you know, we are entreating OMB, 12 and I think tha general counsel or someone, or was it you, 13 Bill, who us
. examining for us the issue as to what extent we 14 are obligated co build?
15 MR. DIRCKS:
I have been talking to OMB and I think 16 we will get some decision out of them in the early part of 17 next week.
18 MR. CORNELL:
In FY 80 we did not look and did not 19 come up with any interoffice reprogramming.
In FY 81 we did 20 not either, but I fully suspect, depending on the outcome of l
21 the other outstanding problems, the supplemental and the FY ZZ 81, that there may have to be some interoffice reprogramming 23 for example, taking some funds from research and transferring 24 them to NRR.
25 We have not looked at that yet, but I fully suspect i
s'
l l
ALOERSON REPORTING COMPANY,INC, l
i 300 7th STREET, S.W. RE?ORTERS SUILDING. WASHINGTON. D.C. 20024 1202) 554-2345
1 we wil have to.
2 MR. DIRCKS:
But we do have that $9 million shortfall 3
hanging over our heads.
4 MR. CORNELL:
In FY 80 we have programmed a total of 5
108 professional staff years.
The most significant impact is 6
in NRR, which accounts for about 40 percent of that.
The 7
remaining professional staff are in NRR.
We h' ave also 8
reprogrammed a total of $2.4 million in FY 80.
9 MR. DIRCKS:
Let me question a verb you are using.
10 MR. CORNELL:
We have not reprogrammed.
We are 11 recommending these as reprogrmaming ections.
12 Mr. DIRCKS:
Thank you. That was the question.
13 CHAIRMAN AHEARNE:
Some of these will require s
14 approval.
15 MR. CORNELL:
That $2.4 million figure does not 16 include $49 million in the Office of Research, which you were 17 characterizing as a redirection and reprogramming.
On the l
18 basi's of the realization of research, we began a redirection l
19 of the program a number of months ago.
20 In FY 81, we are proposing a reprogramming of 151 21 professional staff years.
We have not proposed any 22 reprogramming for program support in FY 81 because there are l
23 so many uncertainties.
What we have been able to do is to use i
24
-- the FY 81 budget request contained what is being termed as 25 a planning wedge.
That is $3 7 million.
That was used to i
l l
ALDERSON REPORTING COMPANY, INC,
62 1
address a substantial portion of the funds needed in FY 81.
2 But what we are left with is roughly a $9.4 million shortfall 3
in FY 81, $7 million to fund a continuation of the lab loaner 4
program, $2.4 million to accomplish TMI-related activities:
5
$1.4 million in NRR an $1 million in I&E.
6 Because of the size of this shortfall, and also 7
because of the uncertainties of the supplement *l, which we a
8 will ration into 1981, and the uncertainties of the FY 81 9
budget itself, we haven't attempted to go through the details 10 op. reprogramming.
11 We fully expect that a culmination of interoffice 12 reprogramming, perhaps an FY 81 supplemental, as well as 13 intraoffice reprogramming will have to be used to account for 14 that shortfall.
15 CHAIRMAN AHEARNE:
In your reprogramming, do they 16 include additional reprogrammings within FY 80 that would 17 require going back to the Congress?
i 18 MR. CORNELL:
Yes. Our next item was in FY 80 there 19 are three items which would require congressional approval. I 20 would like to emphasize that because of the logistics of 21 sending that out, a 30-day layover, if there is much delay in 22 those decisions, some options may be foreclosed.
23 A fourth item relates to a requirement in the 24 authorization for semi-annual reports.
We are proposing some 25 cutbacks in funds which may require either release of that l *Lja W -
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ALDERSON REPcRTING COMPANY,INC, I
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63 1
commitment or release of understanding of the amount of work 2
that will go into those reports will be scaled down.
3 CHAIRMAN AHEARNE:
The programs are finished.
4 MR. CORNELL:
But we still have a semi-annual report 5
to Congress required indefinitely.
6 COMMISSIONER HENDRIE:
I wonder if the report can 7
just consist, starting pretty soon, of a sing 1,e line on the 8
status of the program, and then every six months --
g MR. CORNELL:
That was what was my understanding of 10 what the report would contain.
The report which has either 11 come to the Commission or is about to is a fairly modest one 12 this year.
13 There is one other thing I would like to call to your 14 attention. This reprogramming does not take into account a 15. number of items which I think are called Category C, that are 16 items that are to be studied. Some decision ha to be made for implementation at a future date.
Several of those are 17 signficant 18 19 One is nuclear data link. If the decision is to go 20 ahead with the nuclear data link, that could cost up to $20 million.
Other than $3 million which is already in the FY 81 21 22 budget, we have not addressed any additional funds.
CHAIRMAN AHEARNE:
And we will be hearing about that, g
24 I guess, next week.
MR. DIRCKS:
Come on.
25 h
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MR. CORNELL:
You will be hearing about it.
2 Another item in that category is possible expansion 3
of the IREP program, where it is conceivable about a $1.5 4
million expansion of that program in FY 81 could be 5'
contemplated.
We have not included funds to accomplish that.
6 That is a rough overview of the whole thing.
7 CHAIRMAN AHEARNE:
Let me say what I would suggest we-8 do is to take this all under advisement, and I will come 9
around and talk to each of you on how you would propose to 10 proceed. We have got really a series of decision issues that 11 we have got to face, and some of them, like the direction of 12 the staff and reprogramming, if we are going to go that route, 13 because they are congressional, would have to be done, I would
(
1-4 guess, in the next couple of weeks.
15 At least for myself, I am not prepared to take any 16 decision this afternoon on it.
17 COMMISSIONER BRADFORD:
There is a whole Category B 18 here of items where we are expected to attache the schedule of*
19 priority and all that; like develop an NRC policy statement on 20 safety. I suppose if we were to say that that should begin in 21 FY 80, that might have an impact on somebody's budget plans as 22 well.
23 COMMISSIONER HENDRIE:
If it goes as well as a recent 24 draft licensing policy statement.
25 COMMISSIONER BRADFORD:
That is not to say that it i
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won't consume resources in the process.
2 CHAIRMAN AHEARNE:
What I would like to do in the 3
remaining minutes this afternoon is see if any of the office 4
directors had additional comments they wanted to add. As we 5
think through this', it might have a lot of impact.
6 Harold?
7 MR. DENTON:
I have a more procedu'ral. issue I would 8
like to raise with the Commission. I have not filed for any 9
adjudicatory proceeding any response in connection with to post-TMI matters.
11 CHAIRMAN AHEARNE:
One of,the action items that I 12 have got to address with my colleagues is the direction to NRR 13 on what,to do.
(
1-4 MR. DENTON:
It is important because some of the 15 schedules that we have given the people maybe were too 16 optimistic as to doing some of these things. I guess I would 17 propose today to continue developing information that could be 18 submitted but not to move forward until we hear from you what 19 the scope should be and how we should proceed.
20 CHAIRMAN AHEARNE: One of the first items that I want 21 us to be able to reach a decision on is what direction to give 22 to you, and also what direction to give the boards.
I recall 23 in a hearing to Mr. Bevel that was one of the issues that we 24 essentially have committed to.
25 MR. DENTON:
So we will continue as a staff working ALDERSON REPCRTING COMPANY, INC,
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away using thi
- s interim guidance, but we won't be producing 2
anything out of the staff.
3 CHAIRMAN AHEARNE: I think that is correct.
4 CCMMISSIONER BRADFORD:
Is one of the issues inherent 5
in that, John, the extent to which these issues rewain 6
litigable? That is, if somebody wants to say in this 7
particular area we haven't gone far enough.
8 CHAIRMAN AHEARN: I think so, yes.
9 Bob.
10 MR. BUDNITZ:
I had a couple of comments in detail, 11 one of which is to note that when Kevin talks about 12 interoffice reprogramming --
13 (General laughter.)
14 MR. BUDNITZ:
You guys have the check valve, and I 15 have got the accumulator.
16 (General laughter.)
17 MR. BUDNITZ:
I assume'that it only goes one way.
18 (General laughter.)
19 MR. BUDNITZ:
But I was hoping otherwise because we-20 are short.
21 I wanted to comment about IREP. Commissioner 22 Hendrie's comments about how the risk assessment techniques 23 can come along later and tell us whether some of these 24 detailed actions are actually not quite right is exactly on l
J the mark.
But I don't want to nold out the hope that IREP can i
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do that.
2 IREP is a wonderful thing and it is going to lead us 3
dowr. to an awful lot of interesting detailed information and 4
some general stuff, too.
But IREP is not a Wash 1400-type 5
risk assessment in all those plants.
6 COMMISSIONER HENDRIE:
IREP won't go deep enough into 7
the plant system detail.
8 MR. BUDNITZ:
It cannot, not only because of the time 9
scale but because for almost everybody that will be doing it, 10 it will be a learning experience. We are hoping to get
~11 industry involvement.
And also because for many of the
. 12. methodologies that we are introducing now that are better than 13 what was done in Wash 1400, it will be in the nature of 14 research.
We will be trying them out for the first time and 15 finding out what doesn't work and where uncertainties are.
16 I think it is going to be some time before we really 17 are going to get to the nitty-gritty of some of these, 18 especially the inter-system dependencies.
You had your break 19 in the primary system with a couple of valves, and presumably 20 there was instrument error going to a solenoid and some 21 electricity; and the dependence of loss of various electric l
22 and service functions, like water for lubrication and so on on l
23 each other in various accident sequences is very complex.
It 24 is different in every plant from its neighbor.
l 25 I am sure that as a matter of definition that not l
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everything we did is exactly perfect and it is just going to 2
be a long time before we straigten that out.
3 Now, one other general comment.
The research program 4
has been trying, and Sol began this right sfter the accident, 5
to move in the direction of supporting not just wnat is in the 6
plan but the general things that are new directions.
I want 7
t'o try to make the point that in 1982 we are moving even 8
stronger in that direction, and you will see that when you see 9
the budget.
10 But I am still really nervous about our being able to 11 support those rulemakings. I just can't say it any other way.
12 If they are as broad in scope as they could be, the siting 13 rulemaking, the degraded core rulemaking, and if they are 14 going to be coming along at a schedule which is as rapid as 15 they could be, we are not going to have the technical basis 16 for it in hand, 17 CHAIRMAN AHEARNE:
I assume that as these papers come 18 forward to us, though, you will incorporate your views.
19 MR. BUDNITZ:
Of course.
But unfortunately, it could 20 be that the needs to get on with some of these things will be 21 perceived to be so great, and probably are so great that the 22 technical basis won't be so strong as we would like.
And not 23 to appreciate that won't be fair.
24 The sooner that warning is understood, the better.
25 CHAIRMAN AHEARNE:
Fine. But as those papers come ALDERSON REPORTING COMPANY, INC, KGTaLMIME EtVA Rf@ORTf@@ OM@lNR WA@HINGT@N, D.C. 20024 C2) 554-2345
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forward, I will rely on you to make sure that view is in 2
there.
3 MR. BUDNITZ:
That is our obligation.
4 MR. DIRCKS:
I think Bob's point is the point we all 5
tried to make.
The whole thing is very tight.
6 CHAIRMAN AHEARNE: Of course. I understand.
7 MR. MINOGUE:
I would like to add to what Dr. Budnit:
8 said, particularly about the siting rulemaking.
I think this 9
is a concern now.
The actions of Congress in the 10 authorization bill may ease this problem somewhat.
The 11
' wording that I saw recently that came out of the conference 12 committee gives much more latitude to an orderly thinking 13 through of the scheduling.
14 I think, further, a lot of the work that NRR is doing 15 looking at some of the more difficult sites like Indian 16 Point and Zion is developing insights and information that 17 will impact the rulemaking.
I am just advising the Commission 18 we are right now sort of reexamining the scheduling on that 19 rulemaking, taking into account some of these problems of 20 resources, and also looking at what might be a more orderly 21 sequencing of addressing come of these questions on the siting 22 rulemaking.
23 It is quite likely we will propose some rescheduling 24 of that that may ease some of this problem.
25 MR. DENTON:
One other point I would like to make is j
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that we will be sending down to the Commission another paper 2
dealing with construction permits only, and the discussion 3
today is not intended to apply to pending construction 4
permits.
5 CHAIRMAN AHEARNE: Is there someone from I&E?
6 MR. DEYOUNG:
I might add a few points.
One is that 7
we always hear about this living document, and it truly is. It 8
keeps changing day by day.
Not all the things are in the 9
wrong direction.
Sometimes the staff gets things done before 10 we expect them to be done, and then we have to begin to 11 implement the plan.
Some of these are happening, and we have 12 to change things back and forth.
13 One of the other points is I have talked to about I
14 three vice presidents of utilities recently. They think it is 15 time to move forward.
They have to get something defined to 16 move on. At the same time, they feel as stretched as the staff I'7 is and the resources are limited, they are going to do their 18 best. But they say they are at the limit right now, that we 19 are stretching them to the extreme and there is not much play l
20 left in what they can do.
21 So we might expect some requests for extensions of 22 schedules and so on.
But we really believe in trying to move 23 forward and trying to get it out.
24 CHAIRMAN AHEARNE:
Thank you.
25 Is anybody from NMSS here?
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MR. MATTSON:
I want to raise a small point.
A 2
number of these things, as we acknowledged way back in the 3
beginning six or seven months ago, are actually moving 4
forward.
5 CHAIRMAN AHEARNE: Of course.
6 MR. MATTSON:
And we have been trying to keep drafts 7
of this thing publicly available to anybody interested to keep 8
track of what we are doing.
We have held this last one 9
because we wanted to get it as clean as we could get it before 10 it was publicly distributed. We have a number of changes that 11 will go into the typewriter in the next few days.
12 My plan is to print 1000 copies of this May 1980 13 version of this Plan and begin to distribute it broadly about 14 May'27th.
I think if we call it the May 1980 version, 15 realizing, as Dick just said, it is a living document, that 16 shouldn't cause any difficulty relative to the fact that there l'7 are still decisions yet to be made.
18 CHAIRMAN AHEARNE: I have no problem with that.
19 COMMISSIONER HENDRIE:
I think it is a good idea 20 because there are a number of copies of the previous verions 21 around, and you would kind of like to get the current thinking 22 available for people to look at.
23 MR. MATTSON:
The last title we went under was Draft 24 3, and it is out of date.
25 CHAIRMAN AHEARNE: Kevin.
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MR. CORNELL:
One additional piece of information I 2
forgot to mention. We have gotten an indication of what the 3
full committee mark is in the House of Appropriations.
They 4
have given us roughly 60 percent of the funds we asked for 5
and 50 percent of the people.
6 CHAIRMAN AHEARNE: This is the supplemental, you mean?
7
'MR. CORNELL:
Yes.
8 COMMISSIONER HENDRIE:
What fractions?
9 MR. CORNELL:
Sixty percent of the funds and fifty to percent of the people we asked for.
11 CHAIRMAN AHEARNE:
That is pretty drastic.
12 Roger, I would like to thank you very much, you and 13 all the people who worked with you.
There are many times, I
(
14 am sure, over the months when you weren't sure whether it 15 could be digested. It is very impressive work. I think we all 16 owe you a big, hearty thanks for that.
17 MR. MATTSON:
These people have worked their tail off 18 in the last six months.
19 CHAIRMAN AHEARNE:
Yes.
It is really excellent.
A 20 very fine presentation.
21 I think that the whole agency and the people we are 22 responsible to and that we regulate will over the many years 23 really benefit from it. Very good.
Thank you very much.
24 Thank you, gentlemen.
25 (Whereapon, at 4 o ' clock p.m, the meeting was l
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concluded.)
2 3
4 5
6 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ALDERSON REPORTING COMPANY, INC, 300 7th STREET. S.W. REPORTERS BUILDING, WASHINGTCN, D.C. 20024 (202) 554-23:5
a.-.s o.
A This is to certify that the attached proceedings before the NUCLEAR REGULATOR'? COMMISSION in the clatter of: PUBLIC MEETING - BRIEFING ON ACTION PLM
- Date of ?receeding:
May 8, 1980 Docket Nu::1ber:
Place of ?roceeding: ifashington, D.
C.
wore held as herein appears, and that this is the original transcript thereof for the file of the Ceci::lission.
Doris Golstein Official Reporter (Typed)
Cfficial Repor er (Signature) i 1
1 t
l l
l l
l I
,,,