ML19331B415
| ML19331B415 | |
| Person / Time | |
|---|---|
| Issue date: | 08/01/1980 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8008120091 | |
| Download: ML19331B415 (71) | |
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NUCLEAR REGULATORY COM.ISSION n
r COMMISSION MEETING In the Matter of:
BRIEFING ON NEAR TEPJi REQUIREMENTS FOR CONSTRUCTION PERMITS FOR POWER REACTORS
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DATE:
August 1, 1980 pAGES:
1 - 44 AT:
Washington, D. C.
IHIS DOCUMENT CONTAINS S P00R QUALITY PAGES ALDERSON REP 1MIT1XG S* Y V
400 virginia Ave., S.W. Washing en, D.
C.
20024 Telephene : (202) 554-2345 800812069/
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1 UNITED SIATES OF AMERICA 2
NUCLEAR REGULATCRY COMMISSION 3
4 RRIEFING ON NEAR TERM RECUIREMENTS 5
FOR CONSTRUCTION PERMITS FOR POWER REACTORS 6
7 8
Nuclear Regula tory Commission 9
Room 1130 10 1717 H Street, N.
W.
11
'4a s hin g to n,
D.
C.
12 13 l,
Friday, August 1, 1980 14 The Commission met, pursuant to no tice, at 2:03 15 p.
m.
16 3EFORE:
17 JCHN F. AHEARNE, Chairman of the Commission l
18 VICTOR GILINSKY, Commissioner 19 l
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l 21 22 23 24 25 ALCERSCN RE?ORTING COMPANY, INC.
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9 1 N?.C STAFF PRESENT:
2 L.
BICKWIT, General Counsel 3
3.
p"EptF 4
H. DENTON 5
J. SCINTO 6
A.
KENNEXE 7
E. CASE 8
J. GALLO 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ALCE.RSON REPCRT NG COMP ANY, INC.
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The saecing sas open :o public a::andanca and obse:va:1cn.
This ::a= scrip has =c: been reviaved, ec: ac:ad, or edi:ad, and i: =ay c:w " i=accuracias.
The ::a= scrip is is:anded solely for ga=eral ':fc =a:1cual purposes.
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CHAIRMAN AHEARNE:
The Commission meets this 3 afternoon to hear a proposal from the Director of haclear' 4 Reactor Regula tion rega rding the policy and proceedings 5 pending construction permit and manufacturing license 6 applications.
7 This is another step in the long development of a 8 number of action items following Three Zile Island, the 9 accident at Three Mile Island, and ve have given the staff 10 direction on what to do with respect to resuming review of 11 operating license applications.
12 We then asked for the staff to provide a 13 recommendation on what to do with proceeding with 14 construction permits.
Earold?
15 MR. DENTON:
Rob Purple will be our spokesman.
He 16 has a 15-minute presentation to summarize the process we 17 vent through and the options we identified.
Let me turn it 18 directly over to Sob.
19 MR. PURPLI:
If I might have the first vu-graph.
20 (slide.)
21 MR. FURPLE:
Just by way of review, and in a sense l
22 to repeat what you just said, Mr. Chairman, the Commission 23 has gone throuch the establishment of the needed 24 requirements for operating reactors.
Those took place 25 pr im arily in the summer of 1979, and are listed on the i
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1 board, the major elements.
And as you say, we have nov 2 determined what the necessary and sufficient set of 3 requirements are for operating licenses, which includes the 4 NUREG-0694 and also includes the Commission's endorsement on 5 what was called Proposed Dated Requirements, those that 6 would have an implementation date beyond the first of this 7 calendar year.
8 The question now was what to do and wha t is the 9 proper set of requirements and timing td resume the 10 licensing review of construction permit applications which 11 have been suspended since March of 1979, since the T3! 2 12 accident.
13 We considered a range of options -- May I see th e -
l 1-4 next Vu -gra p h, please?
15 (slide.)
16 MR. PURPLE:
Just to put a bound, a total envelos 1~ on the range of options, th e first op tion is really an 18 unacceptable one, but it puts the lower bound, and that is 19 the idea tha t one might proceed with reviewing CP's using 20 the pre-T!I licensing envelope, taking no account of-the TMI 21 incident.
'Je certainly would not recommend that.
ZZ At the far end, Option 3 would be one that would 23 say, let's indefinitely or postpone consideration of C?
24 applications un til such time as the major rulemaking that is 25 evolved from the !!! evaluation is complete and the new ALCERSoN REPORTING COMPANY, INC.
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1 requirements, whataver they may be, are in place.
2 Nov, between those two extremes, Options 3 --
3 CHAIRMAN AHEARNE:
'Jould you say a fev vords about 4 why you think -- I can understand the first one as being 5
MR. PURPLZ I have not discarded the last one as 6 being unacceptable, anu I will come back to it with a few 7 words about the pros and cons.
8 In between those two extremes would be Options 3 9 an d C, which says, surely 1.mpose the pre-TMI licensing 10 envelop modified to include those licensing items now 11 racuired for NTOL's.
Basically what is in 0594, and 12 depending on what year you are in when you are reviewing it.
13 The third option, Option C, is similar to the 14 second, that is, pick up on the NTOL type requirements, use 15 th e pre-III licensing envelop, but then select a few special 16 topics f or special consideration, and those namely are the 17 topics that are the sub jects of rulemaking that may go on 18 for sev+ral years before they are finalized.
19 Now, the rela tive adva ntages and disadvantages of 20 at least the last three options, Option 3, which makes 21 th e pending CP's pretty much the same as the NTCL's that we 22 are licensing.
This would minisire th e review and 23 construction impact.
24 It is probably tha quickest route to having 25 additional nuclear capacity on line for these plants.
The ALrEASON REPCRTING CrMPANY, !NC,
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9 1 disadvantage is that it fails to capitalire on the 2 o p po rtunity you have to achieve signifirant safety 3 improvements in a plant that has not yet been built, 4 although it has been in each of the six cases largely 5 designed.
6 The third option, Cption C, which pulls out some 7 additional special f eatures for special consideration, the 8 big advantage of that is that it vould retain the 3* flexibility to be able to incorporate into the design of 10 these plants certain significant safety improvement features 11 that may result from the rulemaking during the pendency of 12 the construction period by leaving open -- by not 13 foreclosing during the construction period the ability to 14 put in some of these features.
15 A disadvantage of Option C is that it still 16 retains in the eyes certainly of the applicants and the l'7 builders of the plants some degree of uncertainty because it 18 is not easy to predict the cutcome of rulemaking with any 19 perfect certainty.
20 Option 3, of course, would provide the maximus 21 potential safety inprovements.
It allows the rulemaking to 22 run its course, the various rulacakings to run their 23 courses, better assurine 24 CHAIRMAN AHEARNE:
It eliminates the uncertainty.
25
- 53. FUEPLI:
- t certainly eliminates the ALDERSCN REPORT'.NG COMP ANY. ;NC.
7 1 uncertainty, but it does probably mean a minimum of two, 2 maybe three years of delay, depending on the number of 3 rulemakings.
4 The next vu-graph, please.
5 (Slide.)
6 MR. PURPLES Our proposed approach is one that 7 selects Option C, and which we f eel is the most suitable.
8 First of all, we have to and that was composed of thei 9 pre-TMI design envelop or review envelop, and then secondly, 10 I said it would be the pulling out of the action plan items 11 th a t are appropriate, so the first two bullets up thera are 12 referring to that portion of the definition of what is
- 3 neeied, and that is to go into the action plan item by item
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14 and determine, first of all, which items are actually 15 applicable to C?'s, and secondly the second bullet, then, s
16 look at each one and decide what kind of informa tion should 17 ve require to be available for our review and consideration 18 prior to issuing the CF.
19 Taking both of those bullets, then, and turning it 20 into a NUSEG document, a new NUEEG document which we 21 presently have in the typewriter -- I am
.? o rry to say we i
but it is 22 don't have in front of you right today 23 basically a review of the ac tio n pl a n, defining how much 24 informa ion we need for each of the actions in the action 25 plan that are appropriate for 0?'s.
ALOERSON RE.coRTING COMP ANY, INC.
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CHAISMAN AREARNE:
Is it introducing any new items?
2
- 33. PURPLE:
No new items. No new items.
The only 3 thing it may introduce in the sense of being new, you may 4 recall that there were in the action plan things like 5 Decision Group C items, things f or which in the sense of 6 talking about operating license applications or operating 7 reactors, we said we would not impose those until we had 8 brought them forward to the Commission for separate 9 consideration.
10 We do take some of those Cecision Group C items 11 and we look at them in the sense of a CP and ask -- our 12 definition of what we want from an applicant is that he 13 address the subject of that based on the sta te of the art or 14 the state of the requirement as it may exist in that year.
15 CHAIRMAN AHEARNE:
Can you give me an exam ple ?
16 3R. PURPLE:
Control room design, where we have a l'7 rather long range requirement.
We have not established new 18 requirements, but we like applicancs to at least address the 19 degree to which they are going to advance the state of 20 control room design in their control rooms.
21 So, they would be asked to speak to things that we 22 aren't today necessarily asking OL's and CR's to sp?ak to, Z3 so there would be the NUEEG document which is the subject of 24 a Federal Register no tice that was -- that was a draft 25 attached to the Commission peper.
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We then identified four areas requiring 2 significant -- significant a reas. requiring policy 3 decisions.
Sin.ce we identified these four, the Com:ission 4 has acted on two of them, so they have become no longer 5 items of debate.
6 You have approved a transition siting policy in 7 connection with the new siting rulemaking proceeding.
We 8 defined quite clearly what should be done with respect to 9 new CP's of the type v# are speaking of here today.
10 Let me pass, before I talk about those four items, 11 and go on through this chart.
The next chart will talk 12 about the actual special requirements.
13 We propose that -- leave that one on, please.
We 1-4 propose that the NUREG document and the Federal Register 15 no tice which is in the staff paper describing the special 16 requirements and what we think needs to be done be issued I'7 for public comment.
18 We are interacting with the ACRS, and after we 19 have received th e public comments and after we have 20 completed our review with the ACRS, we vould propose to 21 return to the Commission with a final package of appropriate 22 recommend ations on what are the necessary and sufficient set 23 of requirements for CP's.
24 CHAIRMAN A F.E A R N E :
As : read -- You say th e ACRS 25 comments from their letter -- auch of it is a description, ALCERSCN AE?CRENG COMP ANY. INC.
10 1 and the rest is a support of a recommendation to put staff 2 resources on six items.
3 MR. PURPLE:
Eut we anticipate, f o r example, this 4 coming veek we are meeting a gain with the Subcommittee of 5 the ACES, and anticipate, as they say at the end of the 6 letter, that they will consi' der the matter f urther and work 7 with us, jou know, and come out with another letter where
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8 they have looked at it more substantively than they have yet.
9 So, it is not that letter I am speaking about.
It 10 would be others.
11 I see the vu-graph said from th e May 6th letter.
12 Sorry about that.
13 (General laughter.)
14 MR. PURPLE:
That misled you.
It is the later 15 review, not just that letter.
16 CHAIEMAN AREARNE:
Okay.
17 X3. DENTON:
They had identified six issues.
"e 18 have only identified four.
The other two are ones that we 19 do not think have quite th e veicht th a t the four do, and 20 those two that are on the ACRS list are not shown.
They are 21 picked up in our NUEEG document.
ZZ MR, ?"3PLE:
Yes, they are.
23
- R. DENTON
The scrion plan, control and design 24 of management.
25 MR. PURPLE:
In addition, we sention in the SECY ALCERSON REPCRT;NG COMP ANY, !NC.
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1 paper that there is an owner's croup of the six pending CP's 2 that have been interacting with us since they made that 3 presentation of those six topics.
The ACES letter says the 4 industry group says these are the six important ones.
They 5 at least on an informal level have ag reed that it is not 6 such a long list, and it is more or less the,ones we have 7 iden tified here.
8 ME. DENTON:
It is important to reccqnire -- at 9 least I envision this -- this only applies to pending 10 applications before us.
They are not quite a clean slate.
11 Th e review is far advanced.
The designs are -- this is not 12 intended to apply to an y a pplica tion tha t is not before us.
13 CHAIRMAN AH EA RN E :
Would you intend to --
14 MR. DENTON:
If someone were to come in with a 15 brand-new one, I think we would have a cleaner slate to 16 write on, and perha ps risk assessmen t would be a far more 17 sweeping part of the original review.
Here we have 18 iden tified certain systems for risk assessnent purposes.
19 One of the bullets, for example.
I see this as something 20 less than a clean sla te, but --
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21 CHAIEMAN AHEARNE:
When do you expect the next i
Z! application?
23 ME. DENTCN:
Xy feeling is that I cannot state 24 that.
25 CHAIEMAN AHEAENE:
In other vords, you don't feel ALOERSON REPCRTING COMPANY. INC.
12 1 an overwhelming problem there because you 'vould not apply 2 this to new applica tions tha t have not yet been received?.
3 MR. DENTONs That is correct.
I was trying to 4 characterize it properly, based on the utility executives I 5 have talked to, the present universe of plants, which 6 includes those before us, seems to them to represent all the 7 plants that the NRC will have to deal with in the time f rame 8 up to about 1990.
9 CHAIRMAN AMEARNE:
Another way of saying that is, 10 in other words, they don't expect another application until 11 1990.
12 MR. DENTON:
Until we get very close to 1990, and 13 that is a very hazy picture.
14
(*4hereupon, at 2:15 p.m.,
Commissioner Bradford 15 entered the hearing room.)
16 MR. DENTON:
I certainly have no indication that l'7 in the next few years we vill have one.
18 CHAIRMAN AHEAENE:
Very interesting.
19 MR. PURPLE:
Put en the nex t vu-graph, please.
20 (slide.)
21 MR. PURPLE:
I said I would talk in a little more 22 d e tail o n th e four special topics for which we thinx special 23 requirements need to be imposed.
I already mentioned in the 24 siting issue that for SECT 153 the Commission has already 25 given instructions as to vqat is the transition p olicy for e
ALCERSCN REPCRTING COMPANY, INC.
13 1 just this class of plants, and of course we would require 2 that to be done.
3 The most di f f icult, I think, of all of the four is 4 the degraded core rulemaking.
We would propose that first, 5 since -- by the time review probably begins on these CP's, 6 the interim rule very likely will be in place.
We would ask 7 obviously -- then the CP applicant vould have to describe --
8 CHAI2 MAN AHEARNE:
If I could track that 9
ME. PURPLE Yes.
10 CHAIEMAN AHEARNE:
-- Harold a coment ago said 11 these are a number of plants for which th e review has 12 already begun.
13 XR. PURPLE:
It in most cases -- it is essentially 14 complete, and in many cases the hearing is closed and so 15 forth.
16 CHAIRMAN AREARNE:
And I would say again th e n --
17 MR. PURPLE:
We have not yet defined what is a 18 necessary set of conditions to now seriously evalua te and
_.19_ s a y yes, now we can issue CP's.
I am saying there is a 20 period of time before that.
It is these requirements before 21 that gets in place.
22 CHAIEMAN AHEAENE:
I am trying to get the timing b ther.
When do you expect the interim rule to be in place?
24 MR. PURPLE:
I expect the interim rule to be 25 issued in August with a 30-day comment period, where ALOEPSON REPORTING COMP ANY. INC.
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.r-1 accelerating that as mu ch as can be, I guess another month 2 after that.
We are probably talking October.
3 COMMISSIONER GILINSKY:
Where do ve stand with 4 th a t ?
5 MR. PURPLE:
I say the interim rule should go out 6 for public comment in August.
7 MR. KENNEKE:
The paper is about to come to you.
8 MR. PURPLE:
I don 't think the paper is before you 9 yet.
10 MR. SCINTO:
It should come to the Commission soon.
11 CHAIRMAN AHEARNE:
All right, so --
12 MR. KENNEKE:
We have seen the pre-version.
13 CHAIRMAN AHEARNE:
The paper should be here soon.
14 COMMISSIONER GILINSKY:
Pre-version?
15 MR. KENNEKE:
The final stage.
16 CHAIRMAN AHEARNE:
You would expect that to be an l'7 interim rule proposal.
18 MR. PURPLE:
Yes, and a rather short comment 19 period, a 30-day comment period.
20 CHAIRMAN AHEARNEs I see.
Okay.
21 MR. PURPLE:
So that it is likely it could be in ZZ place -- if is not in the place by the time -- for one
_. 23 reason or another --
24 CHAIRMAN AH EA RNI I understand that.
25 MR. PURPLE:
All right.
ALCERSCN REPORTING COMPANY. INC.
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CHAIRMAN AHEARNE:
I had a longer time f rame in 2 sing, 3
MR. PURPLE:
That is one item we would ask for.
e 4 Th e second is to the extent practicable, that applicants 5 provide assurance that the options for meeting the final 6 requirements from the rulemaking are not foreclosed.
1 7
CHAIRMAN AHEA RNE:
The final requirements.
You 8 mean, the rquirements would come in th e final rule, not ones 9 directed toward any actions in the interia rule.
10 MR. PURPLE:
That is correct.
The final rule.
11 CHAIRMAN AHEARNEs What do you sean by the phrase, 12 "to the extent prac tica ble ?
13 MR. PURPLE:
We are speaking, as Harold said, 14 about a fixed class of plant which has basically their 15 design drawings totally complete and reviewed.
We believe 16 it is not unreasonable to give the option to applicants to l'7 look at the various requirement that might flow from a 18 deg raded core rulemaking, and really the main focus of 19 concern is the core retention feature, and to be able to 20 make an argument to the staff that that feature, for 21 example, would be an impracticable thing to try to put in 22 now for that plant.
This would be a case by case basis.
23 At the same time, th e y may be able to demonstrate 24 - t h a t they can leave open the option for all the other 25 features.
We expect th e y can.
I think their major
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10 1 difficulty is in their core retention feature, which is a 2 possible outcome of the rule, but we don't know that for a 3 certainty yet at this point.
4 MR. DENTON:
We discussed the foreciesure question 5 before.
Certainly if you don 't know the outcome of a 6 rulemaking, you cannot guarantee you will not foreclose 7 something by going ahead, but our own judgment about where 8 things vill come out leads me to think there are actions you 9 can take not to f oreclose the first two items, namely, 10 filter containment venting for operating plants, and 11 hydrogen control is another one that is in the same sort of 12 category.
13 The hardest one is the core retention.
If we 14 really knew what core retention devices were, or really knew 15 what one looked like, we could deal with the question, but 16 that is -- has always been a goal.
So, we have tried to 17 I viewed -- in each of these six plants, they are 18 different.
Some are BWR's, some are PWR 's.
It is a real 1S_mixtur.e_ofa lants.__So_,_we_would require each applicant to 20 address all the things tha t he might do to avoid foreclosure l
21 of what the ultimate rulemaking might end up with, and we 22 would be looking case by case, then.
23 C H A IE MA N hM555NE: ~~
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Are any of those six plants ice i
24 co nden se r ?
25 MR. PURPLE:
Yes, one of them is.
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CHAIRMAN AHEARNE:
I see.
2 5R. DENTON:
Rut among the things, for example --
3 one of the issues in core retention is gas generation after 4 the core melts through.
Applicants could commit to using 5 different sort odconcreteandlimestone which would 6 minimize the generation of CO so we think in each case 2
7 th ere vould. be diff eren t things th a t migh t be done, that can 8 be done for each design, that go a long way toward not 9 foreclosing options.
10 COMMISSIONER GILINSKY:
'4hich is the CP which is 11 an ice condenser plant?
12 MR. PURPLE:
I cannot find and that is.
13 COMMISSIONER GILINSKY:
I thought there 14 MB. PURPLE:
I believe the only one is --
15 XR. DENTON:
The manufacturing license.
16 MR. PURPLE:
The manufacturing license.
l'7 CHAIRMAN AHEARNE:
All ri gh t.
18 COMMISSIONER GILINSKY:
Now, would this wait until 19 the interis tule went out?
20 MR. DENTON:
No, because we have identified the 21 same issues as the action plan, so I propose not to wait.
22 Th e se a re th e three features that th e action plan identified
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Z3 and the interim ru1e worked toward.
24
- 33. PURPLE:
It is a long term rule.
25 C0?MISSIONER GILINSKY:
Someone who is respondinc 1
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13 1 to this rule going out, vould you not have problems in 2 complying with the request, even if we don't have a final 3 interim rule?
/
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- 53. DENTON:
' dell, let me take a more specific 5 example.
Take filtered containment venting.
"e could 6 hequire all these six to design and propose a filtered 7 containment venting on the assumption th a t that is where th e 8 final rule is going to end up, but you ask yourself, shculd 9 that -- is that really necessary?
'de cannot reject the --
10 COMMISSIONER GILINSKY:
I as talking about the 11 in te rim rule.
12 CHAIRMAN AHEARNE:
I think his question really is, 13 you are proposing, since we have read the pa per and you know I
14 you will end up proposing a Federal Register going out to 15 comment, and one of the comments is the handling of the 16 degraded core rulemaking and its conformance to the interim 1'7 rule.
Fis question, I believe, is, don't you or do you 18 think that people vould ha ve dif ficulty responding to that 19 request f or comments in the absence of seeing the interim 20 rule going out?
21 COMMISSIONE3 GILINSKY:
I don't know what I would a do without my interpreter, but he has it exactly ri g h t.
C (General laughter.)
24
!?. PU3PlI:
I think they would have to respond to 25
- if that were the case on the timing, they vould then have i
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1 to respond to the version of the interim rule as it appears 2 on the action plan, which spells out in pretty good detail 3 what is going to be in the interim rule, or at least what
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4 the staff proposes be in the interim rule.
5 MR. DENTON:
I think our proposal is based on th e 6 assumption that the rule would track along with the action 7 plan.
Therefore, we will know what is likely to --
8 CHAIRMAN AHEARNE:
I gather the paper, which we 9 have not yet seen, will essentially be tracking the action 10 plan.
11 MR. PURPLES Yes.
12 MR. DENTON:
Yes.
It is some -- it is somewhat 13 disjointed.
That is for sure.
And that is a question we 14 face since we started looking at this.
The way to a final 15 action.
Ihat is -- That is a bit uncertain.
I guess what I 16 a m g ra p pling for is to give some definitiveness to these 17 pending applications so th e y can make whatever decisions 18 th ey need to about whether they defer or continue their 19 applications.
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20 COMMISSIONER GIIINSKY:
What you are saying is, 21 even thcuch there is some uncertainty, they need enough ZZ guid ance so they can get on and comply wi th these requests 23 in a reasonable way that is going to be helpful for them and 24 fo r us.
5
- 52. OENTON :
They definitely need some guidance.
l I
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l We have not giv'en them any so far.
2 COMMISSIONER GILINSKY:
Yes.
3 MR. DENTON:
And I think this vill give them 4 enough so maybe they can make their individual choices about 5 vhat they would like to do with the application.
6 MR. PURPLE:
The third topic is reliability
- 7. analysis, and Harold has really already mentioned that, 8 where we are asking we vould ask CP applicants to perform 9 reliability analyses of selected subsystems, more than we 10 have asked of existing CL's, less than we would ask of a 11 brand new CP that walked through the door, and this 12 particular system we propose is spelled out in the staff 13 paper.
(
144 MR. DENTON:
We have identified the ten systems or 15 so which we think we have a good developmental methodology 16 and data base for and know how to really apply and get an l'7 answer back.
We are not asking for a complete risk 18 assessment from the ground up.
We don't know quite what to 19 ask for.
20 MR. PURPLE:
In emergency preparedness, that one i
21 again is pretty well settled because there is now a rule on ZZ th e stree t, as we first drafted this, we did not know when 23 that rule would ever appear, and we had a ce'rtain set of 24 requirements we vould ask them to do, but r. o v, of course, a 25 CP applicant would simply comply with the applicable I
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21 1 portions of the new amended rule.
2 CHAIRMAN AHEARNE:
Would tha t be primarily site r
3 location?
4 MR. PURPLE:
Well, no, I think primarily the site 5 location itself would be that which is handled 6
CHAIRMAN AHEARNE:
What -- what do you see as the 7 applicable parts of the emergency preparedness rule --
8 applicable to the CP applications?
9 MR. DENTON:
I think it would be some sort of 10 demonstration that there is a reasonable assurance the rule 11 could be met at the OL stage.
12 COMMISSIONER GIIINSKY:
We certainly want to knov 13 if there is anything that would keep'you from complying with
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14 the rule.
15 MR. DENTON:
I don't see you,have to comply with 16 the OL rule at the CP stage, but 1'7 CHAIRMAN AHEARNE:
I was wondering, other than the 18 site location 19 MR. PURPLE:
I have not read from front to rear 20 the emergency planning rule myself, but I did look at tne 21 front end of it, and there was a specific reference to 22 CP 's.
It is my understanding th e re is a section in the new 23 amended rule that spells out what the information 24 requirements are, but I have not read that.
25 CHAIRMAN AHEAENE:
Yes, it is just that most of ALCERSON REPCRTING COMP ANY, INC.
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1 the rule applies to developments, procedures, requirements 2 on both licensee and sta te and local governments that are 3 much more germane to the operating licenses.
It would be 4 kind of hard do get those kind of commitments --
5 MR. PURPLE.
Apparently it did call for expanded 6 information base over what it used to be yesterday, for 7 example.
8 CHAIEMAN AHEARNE Yes.
9 MR. DENTON:
Embedded in out concept is an 10 important factor.
If we were just concerned about accident 11 prevention, we would not deal with Item 2.
We would only 12 deal with Item 3, improving systems te prevent accidents by 13 requiring in Item 3 not f o reclosing this.
It indicates our 14 dete rmina tion to improve the mitiga tion f ea tures of these 15 plants, and not foreclose the implementation of that.
16 So, while some people have tried to drive us down l'7 the track of a saf e ty goal, we are going down for prevention 18 and mitigation.
l 19 CHAIEMAN AREARNE:
Yes.
A l l r-i g h-t =
l 20 MR.' PURPLE:
That completes what I have to say or 21 am prepared to say.
22 CHAIEMAN AH EA RNE :
And you would propose, then, to 23 put out, as I understand it from your paper, a Federal l
l l
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1 the action plan.
2 XR. PURPLE:
That is correct.
3 MR. DENTON:
The action plan itself fo r 01's is g
4 now out for Comment with -- it vould be appropriate to have' 5 this one in the same time frame since it interprets that 6 action plan or C?'s.
7 CHAIRMAN AHEARNE:
Joe?
8 COEEISSIONER HEND2II:
Comment period?
Let's see.
9 MR. PURPLE:
Forty-five days.
10 COMMISSIONER HENDRII:
When can we be ready to 11 move --
12 MR. PURPLE:
You mean with the issuance of the 13 Fede ral Register notice?
14 COMMISSIGNER HENDRII:
Well, presumably --
15
- 33. PURPLE:
You mean afterward, to be able to 16 move with resuming th e review?
1:7 COMMISSIONER HENDRIE:
It would take a while to 18 co mpile commen ts.
19 MR. PURPLE:
Yes, it vill.
Yes, it will, because 20 they will have to be sort of coordinated with those from the 21 -- coming in on the action plan itself, and the action plan Z2 commen t period is 90 days.
I would guess we are talking 90 23 days before ve are -- on the order of three months before ve 24 are ready to be back here with a proposal for Commission 25 approval to proceed with the licensing reviews.
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1 COMMISSIONER GIIINSKY:
I don't have anything to 2 add he e.
3 COMMISSIONER RRADFORD:
Harold, what are the 4 resource implications of beginning to shift this potential 5 amount of attention back towards CP's?
Can you reach back 6 in to the budget discussions we have had over the ast week 7 or ten days, and say -- indicate what sorts of -- what sorts 8 of impacts are involved ?
9 MR. DENTON:
I think the resources involved in 10 putting together a formal proposal at the end of the comment 11 period are small.
We certainly would come back with a 12 proposal.
13 COMMISSIONER BBADFORD:
Right.
(
14 MR. D EN TO N.-
If the final policy of the Commission 15 is along the lines we have suqqested here, the re sources are 16 absorbable within our present budget, because there are only 17 a few applica tions in volved, and review of those 18 applications against pre-THI standa rds is essentially 19 complete, and in many cases was, so we only would have to be 20 looking at those commitments at the C? stage to do things at 21 the OL stage where the action plan requires, and then we Z1 have to look in detail case by case for foreclosure and 23 reli ability assessments.
24 So, it would probably require a man year er two 25 per application, depending upon how this works out in the ALDEASON REPORTING COMP ANY, INC.
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1 end.
2 COMMISSIONER 3RADFORD:
How does that 3
MR. DENTON4 I don't expect all of these pending g
4 applications to remain viable.
I am not able to project hov 5 many might actually go through.
6 COMMISSIONER BRADFORD:
What is the rough rule of 7 thumb that you use in terms of man-years per C? application?
8 MR. DENTON:
I think it is on the order of 12 man 9 years, but that 12 is already in on th e s e.
10 COMMISSIONEE BRADFORD:
I understand.
I 11 underntand.
12 COMMISSIONER GIIINSKY:
I do have one-point to 13 raise.
It seems to me that we ought to be taking a greater
(
14 interest in how the vendor and the AE fit together in the 15 construction of plan ts.
We now recognize th a t parts of the 16 plan we thought were less important turn out to be more l'7 important f rom the point of view of safety and so on, and we 18 have asked that vendors and AE's in te rest themselves in 19 procedures of the plant.
20 It seems to me that tha t is a poin t worth raising 1
21 with applicants, what plans they have for closer integration 22 of the efforts of the conflicting factors.
23 MR. DENTON:
That is not listed in our -- that 24 will be listed in our proposed document under the heading, I 25 think, Management Atten tion Curing Construction, te make th e ALDER 1 son RF.a f'NG COMPANY, INC.
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26 1 utilities play a much more direct role in integrating both 2 the vendor and the steam supplier, and actually overseeing 3 their product.
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COMMISSIONER GILINSKY:
You do have that on your 5 list?
6 MR. DENTON:
We have the management issue.
I am 7 not sure we can address in particular what you have asked, 8 but we can do that.
9 COMMISSIONER GILINSKY:
I think it migh t be ' worth 10 setting that out.
11 MR. PURPLE:
We can take care of that.
12 CHAIRMAN AHEARNE:
Anything else?
13 COMMISSICNER 3RADFORD:
Now, are these -- are
(
14 these plants ones that have been th ro ugh the full standard 15 review plan nervork?
16 MR. D ENTO N :
I am pretty certain they are, but l'7 th at is another area we can also clean up if we have not.
18 These reviews of these are so tecent, they probably have 19 been.
The standard review plan came into being in 1975.
20 COMMISSICNER BRACFORD:
Right, and I guess I just 21 don't know how it was appli.ed to CP applications then Z1 pending.
23 MR. SCINTO:
A cross the board.
24 COMM!SSIONER 3RADFORD:
Any C? application that 25 was pending as of whatever that date was would have been ALCERSON REPCRTING CCMPANY, INC.
-23L9
27 1 reviewed.
2 MR. CASE Yes.
3 COMMISSIONER READECRD:
With or without 4 grandfathering?
5 MR. CASES Without.
6 MR. DENTON:
It would be my intention to --
7 COMMISSIONER RRADFORD:
Joe?
8 MR. SCINTO:
I know they would apply to any of the 9 CP 's that came in af ter that date, and I think all C?
10 applications after that date, but that was some time in 1975.
11 Looking at this list, I cannot think of any of 12 these C7's tha't have been around since 1975.
13 MR. DENTON:
It would be my intention to make sure 14 we have the applicant 's iden tifica tion in the application of 15 where he purports to comply wi th each applicable regulation 16 and each general design criteria, and we vill ake a special l'7 effort on these to get tha t area well documented.
So, our 18 review is focused on a one to one.
I am trying to do that 19 now for the OL applications, where we have not yet completed 20 our SER.
21 CHAIRMAN AHEARNE:
Any other questions?
22 (No response.)
23 CHAIRhAS AHEARNE:
Are we willing to vote out --
24 putting this out for comment?
25 COMMISSICNER GIIINSKYs I think so.
ALDERSON AEPORTING COMP ANY, INC.
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28 1
COMMISSIONER BRADFORD:
Yes.
2
' CHAIRMAN AHEABNE:
Jce?
3 COMMISSIONER HEND3IE:
I don't object to it.
It 4 seems to me that 90 days is a long time.
5 CHAIRMAN AHEARNE:
I think you have 45.
6 COMMISSIONER HENDRII:
Well --
7 MR. PURPLE:
We have a 45 -d a y notice in here.
I 8 was saying, you have to figure how to handle the fact that 9 th e action plan is being commented on in a 90-day period, 10 and this refers -- this draws directly f rom the action plan, 11 and it would probably be at least a week from now before we 12 have the NUREG ready to go into th e Federal Register.
It is 13 going to come close to 90 days, even moving as rapidly as we i
14 Can.
15 CHAIRMAN AHEARNE:
It is hard to see how u 5 da ys 16 -- how we could have anything shorter than that.
17 COMMISSIONER HENDRIE:
Well, it means that what we 18 say is that you know, it is going to be two weeks to get 19 it into the Federal Register, and you want 45 days, and 20 another u5 days plus a little bit to round up the comments 21 and come back, and that means in four months, while we can 22 sit down again and think about whether we are ever going to 23 do anything about these pending construction permit 24 applications, and that seems to me a long time.
3 I wonder if there is not some way to make some ALCERSON 9EPORTING COMPANY. INC.
400 VIRGINIA AVE. 3.W., WASHINGTCN. o C. 20024 12021554-2345
29 1 modest progress, at least with those CF's, where the people 2 who are applying for them are still still would like a 3 decision to make more motion at a more rapid pace.
(
4 As far as I know on these cases there probably is 5 not a great deal to be done, and what is recommended in this 6 paper is a way of treating things.
Again, it does not 7 require a great deal of work, it does not seem to me.
The 8 guy who wants the CP if he wants it is going to have to make 9 some commitments about how he de als with areas that ma y --
10 in which there may be requirements flowing from the 11 rulemakings and so on, and he makes those commitments, and 12 so on.
13 Why, it does not look to me like that in itself is 14 going to be a great long process.
If he decides not to, 15 why, okay, he goes away and pulls the application.
If he 16 decides to do it, why, it ought to be matter, I would think, 17 of relatively short time, a few weeks to gather it up.
He 18 is not going to be able to detail things, I don't th ink.
19 CO3MISSIONER GIIINSKY:
Why do you say it is going 20 to be another a5 days until the end of the comments?
21 COMMISSIGNER HEN DEII:
Well, you --
22 COMMISSIONER 3RADFORD:
The sense of the na*.ure of Z3 the thing --
24 COMMISSIONE3 HENDEIE:
Th e 35 -d a y comment won't 25 reart until it is published, two weeks to ;et it published, ALCERSCN REPCAUNG CCMPANY, INC.
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30 1
a 45-day comment period.
The comment period ends.
Now, you 2 sit down to look at the comments.
My guess is, it would be 3 another 45-plus days before the staff can be back in here 4 saying, well, now we have the comments, and here is our 5 adjusted construction permit proposition, and the Commission 6 will think about scheduling it, and a few weeks down the 7 line or a month, we will eventually gather on it.
8 COMMISSIONER GIIINSKY:
The comments, I assume, 9 vill be presumably from those who are applying.
10 COMMISSIONER HENDEII:
I doubt it very much.
11 COMMISSIONER GIIINSKY :
They are going to be from 12 others?
13 COMMISSIONEE HEN DRIE:
Yes.
14 COMMISSIONER GIIINSKY:
After all, even the 15 proposed rule, he can get some reasonable guidance about 16 what he is doing.
I'7 COMMISSIONER HENDRIE It is not quite a rule we 18 are looking at here.
19 COMMISSIONER GIIINSKY Policy statement, sorry.
20 COMMISSIONER HENDRII:
The proposition here in 21 going out for comment is that people complained that we did 22 not do that on the basic action plan, and the OL list.
The l
23 proposition here is, let's ;c out for comment in this case.
24 '4h a t I am saying is, I think that is a good idea, and that l
25 is all well and good, but I wonder if we
--if there is not l
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some way to do something other than to have absolutely no 2 motion on these f ew cases for what seems to me to be four 3 months following which the staff can prepare some things.
c 4
The applicant can file a few things.
Ihe staff 5 can prpeare its case and go back to the hearings in each 6
case.
7 CHAIRMAN AHEARNE:
Are any of these six in 8 hearings already?
9 MR. DENTON:
I think all six are.
10 CHAIRMAN AHEARNE:
All six are.
11 MR. DENTON:
Is that correct?
12 MR. SCINTO:
Yes.
13 MR. DENTON:
So that means the staff SER's and i
14 environmental statenents a re all issued.
15 COMMISSIONER.HENDEII:
Most of them are well along 16 in the hearing stage.
17 CHAIRMAN AHEAENE:
What you are really talking 18 about is the final -- cort of the TMI related issues before 19 th e hearing boards.
20 MR. DENTON:
Yes.
If the Commission vanted to 21 separate out some segment of these issues and decide today 22 that they were -- would be carried out, the staff could 23 begin to work on those and get back to the boards on-that.
what would you 24 COMMISSIONEE GILINSKY:
What 25 propose, Joe?
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M3. DENTON:
I as trying to respond to the i
2 Commissioner --
3 COMMISSIONER GIIINSKY:
I understand.
4 MR. DENTON:
I have no t figured out how to parce 5 out such an approach.
6 MR. BICKWIT:
Have you gone as far as you can go 7 with the issues not covered by the action plan?
8 COMMISSIONER GIIINSKY:
I wonder whether in f act 9 there is all that much time lost and that once this goes out 10 an applicant has some notion of what it is he ought to be 11 putting together.
That takes some time.
12 CHAIRMAN AHEARNE:
Tha t seems to be realistic.
13 Commissioner Gilinsky is pointing out that clearly when you 14 put that out, just given the past history, the applicant who 15 is interested ought to reasonably conclude this now is 16 essentially the list of the things he is going to have to l'7 do.
I think you can p,robably expect that there is not going 18 to be much of a weakening of th o se.
There may be a 19 strengthening, but as far as backing off very much, he would 20 not have tha t much confidence in that happening.
The work 21 he would have to do in trying to meet those is going to take Z1 some time.
It is not clear that that vill necessarily be 23 th er ef o re vasted time.
24 MR. CENTON:
It is certainly conceivable that an 25 applicant could at his own risk begin to comply wi th th e se ALDERSON PEPCRTING CCMPANY, tNC.
689 VIR$1NIA AVE. S.W., WASHINGTON._ O.C._200 4_ t 202) 554-2345
33 1 by going to the appropriate co.mcitments and detail, and the 2 staff could review that along internally vithout coning to 3 an y j udgments on it.
In that sense, stay moving.
So that 4 when a final position was adopted, we would know where the 5 plant stood in tha t regard.
6 CHAIRMAN AHEARNE:
Did you have another specific 7 question, Joe?
8 CCM3ISSIONER HENDRIE:
No.
9 CHAIRMAN AREARNE:
Joe, you have raised a point 10 that these are now in front of the boards.
Given the recent 11 difficulties on the instructions to operating license 12 boards, it would appear that we ought to at least have 13 identified the issue of what instructions to give to 1<4 Construction pernit boards With respect to -- how ought the 15 construction permit boards treat these new issues.
16 I had asked Len to look at possible language that l'7 ve micht use.
18 MR. BICKWIT:
Would you pass that around?
What I 19 would suggest is language, just a sentence, which would be 20 th e second to the last sentence of the note as it would 21 simply say, comments are also requested regarding the extent 22 to which the judgments reached by the Commission on these Z3 matters should fo rm the basis fcr instructions to licensing 24 and appeal boards and construction permit and manufacturing 25 license proceedings.
l i
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34 1
COMMISSIONER 3R ADICED:
I guess if there is 2 interest in the Commission in following the operating 3 license policy statement -
precludins or limiting f
4 litigation of these issues befoce licensing boards I think 5 tha t that sentence ought to be preceded by one that says 6 that.
That is, the Commission is considering the following, 7 and then just go on and say, comments are requested on this 8 or other possible methods.
9 The reason I say that is, this does not quite put 10 a potential commenter on notice that this may be his or her 11 last chance to comment on these issues.
12 (General laughter.)
13 COMMISSIGNER 3RADFORD:
And if the Commission is 1-4 in fact to take that step, it seems to me to be important to 15 be explicit about it in the no tice when it goes out for 16 comment.
17 CHAIRMAN AHIARNE:
Don't be cynical, Peter.
1 18 CCMMISSIGNER 3RADFORD:
I was being absolutely 19 serious.
20 (General laughter.)
21 COMMISSIONER HENDEII:
I did not think you vere 22 being cynical.
23 COMMISSIONER BRACFCEC:
P e s simisti c, perhaps, but 24 not cynical.
23 (General laughter.)
ALDERSCN REPCRTING COMPANY, INC.
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CHAIRMAN AHEARNE:
I had asked Len to address --
2 it would appear to me we ought to ask for comment on how
(
3 ough t we treat these issues, and that is what that sentence 4 does, and it was not with any pre-fixed judgment, as far as 5 any possible -- now, I would guess that there are at least a 6 few people who have seen that other applicant issue and will 7 probably address that kind of comment, but I did rot have in 8 mind going down tha t route.
9 As a matter of fact, since we in the other case, 10 we had really, ! felt, devoted so much more time in working 11 through very -- in great detail,what to do about operating 12 reactors or near operating reactors.
It is a different 13 background.
So I did not come at this one with the same 14 view, 15 MR. BICK'JIT :
You could attach some press 16 clip pin g s.
17 (General laughter.)
18 CHAIRMAN AHEARNE:
Seriously, I felt when I read 19 th e Federal Register notice -- I f elt that any ccamenter, 20 having been familiar with the operating license issue, that 21 would be an open question, so I thought we ought to at least 22 address it, and rather than four months f rom now having 23 three months, whenever that comes up, having them come back 24 and say, well, gee, we really ought to address what to do 25 about instructions to the beards, and too bad we did not ask ALCERSoN REPCRTING COMPANY, lNC.
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36 1 for comments on it.
2 CCMMISSIONER 3RADFORD:
I agree with that, and 3 certainly USC or anybody who has been directly through the 4 comment on the operating license policy statement reading 5 this --
6 CHAIRMAN AHEARNE.
I really went at it more from 7 the stand;oint -- in fact, completely from the standpoin t 8 that we ought to at least point out that there would be some 9
there is the possibility of giving some instructions to 10 the boards on it when we ask for the comments.
11 COMMISSIONER BRADFORD:
Okay. Let me then ask the 12 same question sort of backwards.
Len, if at the end of the 13 comment period the Commission decided on the basis of having 14 solicited comments to preclude litigation of these issues, 15 would you feel that legally this comment process with just 16 this notification in it was an adequate basis for doing 17 that?
By preclude, I mean, completely preclude.
No 18 possibility of raising it to the Commission at th e end - in 19 effect treatinc this as a rule.
20 MR. B ICK'4IT :
I do not think if you are going to 21 treat this as a rule, then obviously you have to -- you have 22 to provide some notice, but that is not what the previous 23 policy statement did, and adhering to the notion that the 24 previous policy statement was a legal action of the 25 Commission, I do not believe this comment period is even ALOERSoN REPORTING COMPANY, INC.
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.so 1 required.
2 So, as a legal matter, it follows that the extent 3 of the notice is irrelevant, as a matter of comity and 4
CHAIBMAN AHEAENE:
That is 1-t-y, c-o-m-1-t-y 5
(General laughter. )
6
'CHAIBMAN AHEA RNE:
A common phrase in Congress.
7 MR. BICKWIT:
If your question is, could the 8 notice be defined more sharply, I think the answer is, yes.
9 COMMISSIONER 3RADFORD:
I am rea'lly not trying to 10 he cute about it, or drag up the cid operating license 11 policy s ta te m e n t.
I do want to be clear, though, tha t -- my 12 own assumption would be that this could not be the basis for 13 going, what I would say is a step further than the 14 Commission position in the o pe ra tin g license cases, as I 15 understand it, and being used as a complete bar to raising 16 these issues in subsequent li tig a tio n.
That is, no l'7 possibility of raising them even to the Commission.
18 MR. BICKWIT: If it is meant to bind all potential 19 litigants so that they have no opportunity to raise the 20 policy of the Commission bef ore the Commission or boards in 21 an adjudication, then this notice I do not think would be 22 su f f icien t.
23 COMMISSIONER 3RADF0ED:
Ihat is all I was after.
24 MR. BICKWIT:
But that was -- that was never the 25 intention of the Commission, as I understcod it, in putting ALOERSON REPCRENG COMPANY. INC.
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38 1 out the policy statement.
2 ME. SCINECs I wanted to comment that the notice
(
3 that was in the paper, that was given to the Commission, was 4 not intended to address that issue.
It was intended to 5 provide a notice of the substantive issues that the staff 6 has in mind.
It is not addressing the procedural matter 7 which the Comnission had considered at some length in 8 connection with OL's.
9 CHAIRMAN AHEARNE:
Hight, but I thought it was 10 necessary.
11 COE3ISSIONER HENDRIE:
When is the 90-day period 12 up on the other one?
13 MR. PURPLE:
It is my understanding it vent to the 14 Federal Register, and I don 't know if that means it was 15 published.
I think it went to the Federal Register about 16 two days ago on the a ction pla n, so I guess it is a week or l'7 two from now that it is actually published.
I really don't 18 know for sure.
It is roughly 90 days from now.
19 COMMIESIONER HENDEII:
8/1 -- 11/1.
20 CHAIRMAN AHEARNE:
It took a long time to get out.
21 CotMISSIONER HENDRII:
It took a long time to get U out.
D COMMISSI0 lier HENDEII:
12/1 -- I think it is a 24 grand process, but I would hate to th in k tha t we would hava 25 to sit here on the 1st of ;ugust and contemplate that !
ALCERSON REPORTING COMPANY. INC, e
39 1 think.there are probably three of those C? cases that are 2 still possible, viable projects, and say tha t it vill be r
3 Christmas ti=e before ve kncv what to do or can begin to
\\
4 gather up our resources and move back into hearings.
5 The staff review, whatever.
6 CHAIRhAN AHEARNE:
Do you have an alternative?
7 The difficulty I have in recogniring the problems you have, 8 I still think that Vic is right, that these applicants are 9 going to have a reasonable amount of work te dc -- to o
10 through to provide the information review that is gcing to 11 be required on a number of these items.
I mean, look at 12 Enclosure 2.
It may just be a generation of paper effort 13 they are going to have to go through.
Certainly you can 14 saj, vell, there is no reason for them to get started on 15 th a t pa th until this whole process is completed.
16 I think they could get started, and it vould 17 appear to se that would be the only sensible thing, but I do 18 not really see a good alternative.
19 3R. GALLO:
Mr. Chairman, is it possible to be 20 recognired?
21 CHAI2 MAN AHEAENE:
In general, we do not reccanire 22 people f rom the audience.
! as sorry.
23
- 13. GALLO:
Zoes that =ean I shculd sit devn?
24 CHAIRfAN AHEAENE:
Ycu say remain standin;.
3 (General laughter.)
AL ERSCN CEscRTING COMP ANY. ;NC.
40 1
MB. GALLos Thank you.
2 COMMISSIONER HENDRIE:
Is it -- we are going to 3 wait f or comcents on the action plan.
Those are November
(
4 1st.
A month and a half to gather it up and 5
CHAIRMAN AHEARNE:
I guess to some extent that was 6 really those were focused specifically on the operating 7 license hearings, and operating license requirements.
These 8 are focused on the construction permits.
It is not obvious 9 to me that they are not separable tb some extent.
! do not 10 see why if we put in a 45-day comment they cannot begin 11 reviewing those, but realistically these are either 12 substandard issues or they are not.
If they are not 13 substandard issues, then the comment should not be that 14 hard.
Raising it should not be very difficult.
15 Remaining actions by the staff and the board 16 should not be very difficult.
If they are substantive l'7 issues, the licensee is going to have to do some work to 18 respond to them, in which case that time period is not that 19 settled.
20 COMMISSIONER GIIINSKY:
Harold, what is your sense 21 of how much work is involved here?
Suppose this was the 22 final statement that the applicant was to comply with.
How 23 much work is involved and how long would it ta k e ?
24 ME. DENTON:
A 1.o t of them are just commitments, 25 some of the action plan items, because theydo not have to --
ALOERSON AE?ORTING COMPANY, INC,
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COMMISSIONER GILINSKY Presumably they have to 2 think of these as commitments.
(
3 MR. DENTON:
They have to make some commitment in 4 a form that would show --
5 COMMISSICNER GILINSKYs They may want to modify it 6 in one form or another.
7
- 33. DENTON:
Others are more substantive, such as 8 the probabilistic assessment of csrtain systems will require 9 fault trees and event trees and data gathering and 10 calculations.
11 COMMISSIONEB GILINSKY:
Presumably not all of them 12 would have the people right at hand to do tha t.
13 MR. DENTON:
We have been talking ahout this issue 14 for some time in various forms. It has been a part of our 15 thinking for some time.
I guess it would be comparable to 16 the short term lessons learned effort.
17 "R.
PURPLE:
Perhaps a little biccer, because 18 there is some added i tem s that were not in the short-term
- 1essons._ Learned.-_..
20 COMMISSIONER GILINSKY:
Roughly, you would expect 21 to get back a completed package from them in how long a time 22 f ram e ?
Let me ask it a different way.
Suppose these were 23 the final spec [f[Na$1ons for what it was they had to do?
24 How long do you think it vould take them to do it?
25 ME. DENTON:
I would quess three months or so. We ALOERSON RE?CRTING COMP ANY, lNC.
42 1 have been talking about these various -- the most difficult 2 issue is the degraded rulemaking, trying to analyze the
(
3 existing design so as not to foreclose, but I would quess a 4 three-month effort.
5 MR. PURPLE:
At least.
I would say three to six.
6 COMMISSIONER GILINSKY It does not sound to me 7 like there is a lot of lost time here.
I mean, there would 8 be if there were some major modification along the way of 9 what it was we were asking them to do, but if one assumes 10 that there will not be a major departure from this list, a 11 major revision of it, then it does not sound as if there 12 would be.
13 MR. DENTON:
You could assure that.
You could
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14 make it effective immediately and have it required from the 15 start.
16 CHAIRMAN AHEARNE:
I think this would lead them to l'7 start.
I don 't know.
The health and safety aspects --
18 COMMISSIONER HENDRIE:
I will vote with some 19 reluctance because ! vould --
20 COMMISSIONER GIIINSKY:
I as not saying that to 21 pressure you.
I was just trying to understand what your 22 ob_jections are.
l Z3 COM[ISSIONERHENO2II:
It is what seems to be a 24 very long time before things can move forward.
God knows l
3 th e exten t to which applican ts will be ready to move i
4 i
ALDERSON REPCRTING COMP ANY, INC.
43 1 forward, but at least to the extent that anyone listens and 2 pays any attention to what is said here today at this table 3 in the course of approving this proposition for comment, let
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4 me note that Commissioners up and down the table have said 5 knowledgeable applicants will get sovinc on these things.
6 That is, anybody that wants a construction permit, the 7 various Commissioners have said can reasonably get working 8 with the engineers to prepare the sort of ma terials that 9 would be necessary on the assumption that the items in this 10 for comment document will be at least included among those 11 th at will be in the final directions, if not in fact the 12 inclusive list.
13 CHAIRMAN AHEARNE:
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14 MR. EICXWIT:
Bob and I have had a discussion 15 about a minor point, but I just vanted to put it on the 16 record.
'Je have agreement on it.
As we read Option C as it l'7 related to degraded core rulemaking, it was consistent with 18 th e regulation which requires that the proposed design must 19 be such that the Commission can find with reasonable 20 assurance that the plant, if built according to that design, 21 can be constructed and operated without undue risk to public 22 health and safety.
He assured me tha t that was the way it 23 was.
24 MR. SCINTO:
Or, -I assume,, the oth er portions of 25 5035.
~.' h e y would conform to the other portions of 5025.
ALDEASCN REPoRENG COMPANY. INC.
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CHAIEMAN AHEAENE:
We are not violating our other 2 regulations.
Can I have a vote to issue this as sodified?
r 3 Aye.
4 COMMISSIONER BEADF0EDs Aye.
5 C0%3ISSIONER GIIINSKY:
Aye.
6 COMMISSIONER HENDEIE:
Aye.
7 CHAIRMAN AHEARNE:
Very good.
Thank you.
8 (Wheceupon, at 3:03 p.s.,
the meeting was 9 ad j o u rned. )
10 11 12 13
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14 15 16 17 18 19 20 21 22 24 25 ALOERSON RE?CRTING COMP ANY, INC.
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NUCLEAR REGULATORY CO.WISSICN This is 50 Oertify thac the attached proceecings before :he s
Commission
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in the matter of: Briefing on Near Term Requirements for Construction Premits for Power Reactors Date of ?roceeding:
August 1, L980 Uccket tiumber:
Place of ?roceeding:
Washington, D. C.
were held as herein appears, anc that this is the Original transcript thereo f for,the file of :he Coc=ission.
David S.
Parker Official Reporter (Typec)
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NRC REC'JIREMENTS FOR LICENSING 0
OPERATING REACTORS SHORT IERM LESSONS LEARNED, INCL. B&O SELECTED ITEMS FROM ACTION PLAN OPERATOR QUALIFICATION EMERGENCY PREPAREDNESS 0
OPERATING LICENSES APPLICATIONS NUREG-0694 (INCLUDES OR ITEMS)
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s PROPOSED DATED REQUIREMENTS 0
CONSTRUCTION PERMIT APPLICATIONS NOT YET ADDRESSED BY COMMISSION REVIEWS SUSPENDED SINCE MARCH 1979
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1 OPTIONS FOR CP REQUIREMENTS A.
CONTINUE WITH PRE-TMI LICENSING ENVELOPE B.
PRE-TMI LICENSING ENVELOPE, MODIFIED TO INCLUDE ITEMS N0w REQUIRED FOR NT0LS.
C.
PRE-IMI LICENSING ENVELOPE, MODIFIED TO INCLUDE ITEMS N0w REQUIRED FOR NT0Ls aLus SELECTED s.
SPECIAL CONSIDERATIONS.
D.
INDEFINITELY POST-PONE CONSIDERATION OF CONSTRUCTION PERMIT APPLICATIONS.
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DEFINE REQUIREMENTS REVIEW ACTION PLAN - DEFINE ITEMS APPLICABLE TO CPS DEFINE REQUIRED INFORMATION/COMMITTMENTS FOR CP-ISSUE NUREG ESTABLISH SPECIAL REQUIREMENTS:
1
- - SITING
- - DEGRADED CORE RULEMAKING
- - RELIABILITY ANALYSES
- - EMERGENCY PREPAREDNESS 0
OBTAIN PuBLIC COMMENTS ON PROPOSED REQUIREMENTS 0
CONSIDERING PuBLIC COMMENTS AND ACRS COMMENTS (FROM MAY 6, 1980 LETTER), DEVELOP PROPOSqD APPROACH / REQUIREMENTS O
COMMISSION ISSUE POLICY STATEMENT
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J "SPECIAL" REQUIREMENTS SITING PER SECY 80-153, COMPARE CP SITES WITH NUREG-0625 0
DEGRADED CORE RULEMAKING DEFINE CONFORMANCE TO INTERIM RULE TO EXTENT PRACTICABLE, PROVIDE ASSURANCE THAT OPTIONS FOR MEETING FINAL REQUIREMENTS FROM RuLEMAKING ARE NOT FORECLOSED (E.G., FVCS, CORE RETAINER, H )
2 SUBMIT EVALUATION OF ADDITIONAL PREVENTIVE /
IIITIGATIVE FEATURES THAT HAVE POTENTIAL F,0R SIGNIFICANT RISK REDUCTION O
RELIABILITY ANALYSIS PERFORM RELIABILITY ANALYSES FOR SELECTED SYSTEMS USE EVENT / FAULT IREE TECHNIQUES TO IDENTIFY NEAKNESSES PROPOSE DESIGN MODIFICATIONS SPECIAL CONSIDERATION OF:
HUMAN ERRORSJ COMMON CAUSES). SINGLE POINT VULNERABILITIESJ AWD T&M o
EMERGENCY PREPAREDNESS PROGRAM TO COMPLY WITH NEW EMERGENCY PREPAREDNESS RULE
July 28, 1980 SECY-30-348 COMMISSIONgApTION For:
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Wilfiam J. Dircks, Acting Executive Director for Operations Frem:
Harold R. Denten, Direc:cr-Office of' Nuclear Reactor Regulation Subjen:
POLICY ON PROCEEDING WITH PENDING CCNSTRUCTION PERMIT AND MANUFACTURING LICENSE APPLICATIONS
Purpose:
To obtain Ccmmissicn approval of a policy fer proceeding with pending ccnstruction permit (CP) and manufacturing license (ML) applications.
The T'it-2 Action Plan, NUREG-0660, dces not specifically address '
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requirements for CP and ML applications.
There are currently pending six CP acplicatiens for eleven plants and one ML accli-cation for eight floating nuclear plants.
Staff review of these acplications has been suspended since the TMI-2 accident pending the femulation of a policy to a::propriately reflect the lessens learned from the accident.
The applicants for the six pending CP aaplications have formed a group to interact with the staff in the develecment of the requi rements.
A meeting was held witn an ACRS succcmmittee and with the full cemittee to discuss the pregram and the preliminary findings.
An ACRS letter dated May 5,1980, frem Chaiman Plesset to Chairman Ahearne is enclosed (Encicsure 1).
Discussien:
Octions Considered We censidered three coticns:
1.
Resume licensing using the pre-TMI CP recuirements augmented by the acclicable requirements identified in :he Ccmmissicn's J'une 15, 1980 Statement of o licy regarcing ccerating licenses.
c In effect, this treats One :ending C? and
L 3CnI'03 i ns as
- ncugn :ney were the last of :he resen: gener; 1:n :
nucisar cwer piants.
Centact:
R. A. Purcle, NRR:0L SECY.10TE:
This :a::er :s senecuisc f:r x27572 discussicn :n 'ugus i, 1950.
N
. 2.
Take no further action on the pending applications until the rulemaking actions described in the Action Plan have been completed.
This would, in effect, treat the pending appli-cations as the first of a new generation of nuclear power plants.
3.
Resume licensing using the pre-TMI CP requirements augmented by the applicable requirements identified in the Comission's June 16, 1980 Statement of Policy regarding operating licenses and require certain additional measures or comitments in selected areas (e.g.,
those that will be the subject of rulemaking).
Option 1 would minimize the review and construction impact, thereby minimizing delays in reaching regulatory decisions for the planned facilities.
The principal disadvantage of Option 1 is that it fails to take advantage of the fact that, since construction has not started, it would be relatively easy to provide design flexibility, to implement potential significant safety improvements.
Option 2 would maximize the safety improvements but would result in extensive delays and possible cancellations.
We believe that the cost of such delays are not justified provided that design flexibility can be demonstrated.
Option 3 is believed to be a suitable compromise between the extremes of Options 1-and 2..
This option will ensure that approved action items in the Action Plan are applied to the new cps and will provide for-early consideration of added safety measures that can be incorporated into the design without the need for inordinately costly backfit.
By establishing a clear statement of policy with respect to the issues to be determined by rulemaking, a degree of stability is introduced into the CP review process thereby allowing prospective applicants to make better-informed decisions.
The proposed Acoroach We have carefully examined the Action Plan to determine the extent to which it should be applied to the pending CP and ML applications.
We have identified four areas that we believe merit special attention and the development of a clear statement of requirements.
These areas, which correspond to items 1, 2, 3 and 6 of the ACRS letter (Enclosure 1),
are:
1.
Siting The Comission has already established a transition policy for CP applicants.
This policy was established by Ccmmission consideraticn of SECY 80-153 and recorded in a memorandum dated June 30, 1980, from S. J. Chilk to W. J. Dircks. CP applicants, accordingly, will be asked to ccmcare their sites with the reccmmendations of NUREG-0625, as modified by OPE and ACRS ccmments. At such time as the proposed rule is issued for cenrent (scheduled for October 1980),
CP applicants will be required to assess their sites against the criteria contained in the proposed rule.
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2.
Degraded Core Rulemaking CP and ML applicant's should describe the degree to which their designs conform to the proposed interim rule. Applicants should also provide reasonable assurance, to the extent practicable and taking into account the present state-of-the-art of this technology, that issuance of cps or MLs will not foreclose or preclude the modification of the facilities to accommodate potential requirements that may result from the rulemaking proceedings.
These potential requirements include such features as filtered vented containment, molten core retention, and hydrogen control systems.
Special attention should be given to those facility designs with small containment volumes, i.e., ice condenser and Mark III containment designs.
Prior to issuance of a CP or ML, applicants will also be required to submit their evaluation of the additional features, both preventive and mitigative, they propose to include.at their facilities that have the potential for significant risk reduction.
3.
Reliability Engineering CP and ML applicants should perfonn simplified system reliability analysis for the following systems:
subcriticality systems, emergency feedwater systems (PWRs), reactor core isolation cooling system, (BWRs), ECCS injection and recirculation systems, shutdown cooling system, containment cooling and spray systems, safety features actuation systems, and auxiliary systems upon which these depend (alternating and direct current, compressed air, essential service water or cooling systems, and heating, ventilating and air conditioning systems).
These analyses should use event-tree and fault-tree logic techniques to identify design weaknesses and possible system modifications that would be made to imp.'ve the capability and reliability of the above systems under various transient and LOCA events. Particular emphasis will be given to determining potential failures that could result from human errors, common causes, single point vulnerabilities, and test and mainten-ance outages.
CP and ML applicants should provide sufficient information to describe the nature of the studies, how they are to be conducted, the completion dates, and the program.to assure that the results of such studies are factored into the final designs.
J.
Emercency Precaredness CP applicants shall submit, prior to the issuance of construction pennits, a discussicn of their preliminary plan for coping with emergencias addressing the amended rule (Appendix E to 10 CFR Part 50) as it applies to construction permit apolications.
Sufficient detail shall be presented to provide reascnable assurance that the require-ments will be implemented prcperly.
. The remaining Action Plan items that are determined to be applicable to the pending CP and ML applications, including Items 4 and 5 identified in the ACRS letter (Enclosure 1),
have been identified (Enclosures 2 and 3). We plan to issue a NUREG document that identifies the remaining Action Plan items and defines the required cemitment or design information necessary to permit completion of the safety reviews.
As Decision Group C items become approved by the Comission, they would be added as requirements for CP and ML applicants.
Imolementation We recomend that the approach described in this paper be noticed in the Federal Register for public comment. The proposed Federal Register notice is included as Enclosure 4.
Upon receipt of public comments and further review by the ACRS, we would plan to return to the Commission for approval to resume review of CP and ML applications.
Recommendation:
That the Comission approve the rtaff proposal to obtain public coment on the set of requirements described in this paper.
Coordinatics:
The Executive Legal Director has no legal objection to the recommendations in this paper.
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Haro'd P. Denton, Director Offue of Nuclear Reactor Regulation DISTRIBUTION
Enclosures:
Comissioners 1.
Memorandum, Chairman Plesset to Comission Staff Offices Chairman Ahearne, dated May 6, 1980 2.
Action Plan Items Applicable to Pending Exec Dir for Operations ACRS Construction Permit Applications Secretariat 3.
Action Plan Items Applicable to Pending Manufacturing License Application 1
Proposed Federal Register Notice Comissioners' comments should be provided directly to the Office of the Secretary by c.o.b.
I
' day, August 12. 1980.
Comission Staff Office comments, if any, should be submitted to the Commissioners NLT August 5, 1980 with an information copy to the Office of the Secretary.
If the paper is of such a nature 0
that it requires additional time for analytical review and comment, the Commissioners and the Secretariat should be apprised of when ccmments may be expected.
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ENCLOSURE 1 1
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ENCLOSURE 1
- g *4,. f/ h NUCLEAR REGULATORY CO.*."dISSION e
ADVISORY COTJ*4ITTEE Cts RE ACTOR sMECUARos
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May 6, 1950 Menorable John F. Ahearne
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Chairman U.S. Nuclear Regulatory Commission
'!ashington, DC 20555 SU3 JECT:
NEAR-TERM CONSTRUCTION PEPJil7 APPLICATIONS Cear Or, Ahearne:
Curing its 241st meeting, May 1-3, 1980, the ACRS reviewed the s stus of applications for near-term construction ' permits (NTCPs).
In its review the Committee had the benefit.of discussions with the NP.C Staff and with repre-sentatives of the applicants for the NTCPs.
A subcommittae meeting on this subject was held on April 9, 1980.
The six NTCP applicants and the reactor types involved are as follows:
Black Fox Station, Units 1 and 2, ?ublic Service Company of Oklahoma, General Electric EHR/6, Mark III pressure suppres-sion containment Skagit Nuclear Pcwer Project, Units 1 and 2, Puget Sound Pcwer
& Light Company, General Electric BWR/5, Mark III pressure suppression containment Pilgrim Station, Unit 2, Boston Edison Company, Combustion Engineering custom NSSS, large dry containment Perkins Nuclear Station, Units 1, 2 and 3, Duke Power Company, Combustion Engineering CESSAR System 80 NSSS, large dry con-tainment Allens Creek Nuclear Generating Station, Houston Lighting &
Pcwer Ccapany, General Electric SWR /6, Mark III pressure sup '
pression containment Pebble Springs Nuclear Plant, Units 1 and 2, Portland General Electric Company, Sabccck and Wile'ex custom NSSS, large dry containment The NRC Staff has approached this matter primarily by examining the Action
?lan and judging the applicability and scheduling of each it2. to an NTCP.
This procedure has resulted in placing, many important items in a category wherein the NRC has yet to develop criteria applicable to construction par-mit applicants.
Action Plan item II. A on siting intreduces questions whose resolution must be achieved pricr to issuance of a construction permit.
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9,:nceable John F. Ahearne May 6, 1930 L/.
Item II.3 on degraded or melted cores bears directly on containment design, as well as other safety features.
Item II.C on reliacility engineering and risk assessment could bear significantly on the design requirements for many im;ortant plant systems.
There are many other items in the Action Plan and in the ACRS report of April 17, 1980 which also might impact directly on im-pcetant design aspects of these plants.
Mr. Harold Denton advised the Committee that he envisaged permitting con-struction to proceed if there are no obvious site-related questions in tar =s of the Report of the Siting Policy Task Force (NUREG-0625) and if the contain-ment design pressure were such as to withstand hydrogen combustion, on the assumption that other design aspects could be changed later if so required.
The utility representatives advised the ACRS that, in their opinion, there was a need for the resolution of several policy questions which relate to how and whether construction permit applications will be processed in the near term.
The utilities identified the following six policy issues as being in mest urgent need of resolution:
1.
Siting 2.
Emergency planning 3.
Degraded core conditions 4.
Control room design 5.
Management for design and construction 6.
Reliability and risk assessment The utility representatives recommended that a concerted effort be under-taken to develop an acceptable interim approach to resolution by the Commis-sion of such issues in the next few months.
The ACRS supports this recom-candation and urges that appropriate Staff resources be made available for this purpose.
An ACRS Subcommittee plans to work actively with the Staff on the topic with the anticipation that the full Committee would review the NTCP matter within a few months.
Sincerely, W
/. /, -
Milton S. Plesset Chairman
References:
1.
.umerandum from D. F. Ross, NRC, to R. F. Fral ey, ACRS,
Subject:
Trans-mittal of NTC? Requirements List, dated April 22, 1980.
2.
"amorandum from William F. Kane, NRC, to Addressees,
Subject:
Request for Review of Preposed BI-2-Related Requirements for NTC? Applicants, dated April 4,1950.
3.
U. S. Nuclear Regulatory Commission, "NRC Actica ?lans Develoced as a Rasult of the TMI-2 Accident," USNRC Report NUREG-0660 Craft 3, dated
" arch 5, 1980.
4.
U. S. "uclear Regulatory Commission, " Report of the Siting Policy Task Force," USNRC Repor: NUREG-0625, dated August,1979.
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ENCLOSURE 2 1
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ENCLOSURE 2 ACTION PLAN ITEMS APPLICABLE TO PENDING CONSTRUCTION PERMIT APPLICATIONS f.A.1.1 Shift Technical Advisor I.A.1.2 Shift Supervisor Administrative Duties I.A.1.3 Shift Manning 1.A.2.5 Plant Drills 1.A.3.1 Revise Scope and Criteria for Licensing Exams I.A.4.2 Long-Term Training Simulator Upgrade I.B.1.1 Organization and Management Long-Term Improvements I.C.1 Short-Term Training Simulator Upgrade I.C.2 Shift and Relief Turnover Procedures I.C.3 Shift Supervisor Responsibilities I.C.4 Control Room Access I.C.5 Procedures for Feedback of Operating Experience I.C.6 Procedures for Verification of Correct Performance of Operating Activities I.C.7 NSSS Vendor Review of Procedures I.C.9 Long-Term Program Plan for Upgrading Procedures I.D.1 Control Room Design Reviews I.D.2 Plant Safety Parameter Display Console I.D.3 Safety System Status Monitoring I.D.4 Control Room Design Standard I.E.4 Coordination of Licensee, Industry, and Regulatory programs I.F.1 Expand QA List I.F.2 Develop More Detailed Criteria II.A.2 Site Evaluation of Existing Facilities II.B.1 Reactor Coolant System Vents II.B.2 Plant Shielding to Provide Access to Vital Areas and Protect Safety Equipment From Post-Accident Operation II.8.3 Post Accident Sampling II.8. 4 Training for Mitigating Core Damage II.8.8 Rulemaking Proceeding II.C.4 Reliability Engineering II.D.1 Testing Requirements II.D.2 Research on Relief and Safety Valve Test Requirements II.D.3 Post Accident Sampling II.E.1.1 Auxiliary Feedwater System Evaluation II.E.1.2 Aux 111ary Feedwater System Autcmatic Initiation and Flow Indication
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.. Reliance on ECCS II.E.2.1 Uncertainties in Performance Predictions II.E.2.3 Reliability of Power Supplies for Natural II.E.3.1 Circulation Dedicated Penetrations II.E. 4.1 Isolation Dependability II.E.4.2 Integrity Check II.E.4.3 II.E.4.4 Purging II.E.5.1 Design Evaluation B&W Reactor Transient Response Task Force II.E.5.2 Additional Accident Monitoring Instrumentation II.F.1 Identification and Recovery from Conditions II.F.2 Leading to Inadequate Core Cooling Instrumentation for Monitoring Accident Conditions II.F.3 (Reg. Guide 1.97)
Power Supplies for Pressurizer Relief Valves, II.G.1 Block Valves, and Level Indicators Organization and Staffing to Oversee Design II.J.3.1 and Construction Provide Procedures and Training to Operators II.K.l.20 for Prompt Manual Reactor Trip for LOFW, TT, MSIV Closure, LOOP, LOSG Level, and Low Pressurizer Level Provide Automatic Safety-Grade Anticipatory II.K.1.21 Reactor Trip for LOFW, TT, or Significant Decrease in SG Level Describe Automatic and Manual Actions for Proper II.K.1. 22 Functioning of Auxiliary Heat Removal Systems when FW System is not Operable Describe Uses and Types of RV Level Indication II.K.1.23 for Automatic and Manaul Initiation of Safety Systems. Also Describe Alternative Instrumen-tation.
Procedures and Training to Initd ite and Control II.K.2.2 AFW System Independent of Ir es ated Control System Analysis and Upgrading of Integrated Control II.K.2.9 System Hard-Wired Safety-Grade Anticipatory Reactor II.K. 2.10 Trips II.K. 2.13 Thermal-Mechanical Report.
Effect of HPI on Vessel Integrity for Small-Break LOCA with no AFW II.K.2.14 Demonstrate that Predicted Lift Frequency of PORVs and SVs is Acceptable Analysis of Effects of Slug Flow on Once-Through II.K.2.15 Steam Generator Tubes After Primary System Voiding
.. II.K.2.16 Impact of RCP Seal Damage Following Small-Break LOCA with Loss of Offsite Power II.K.3.2 Report on Overall Safety Effect of PORY Isolation System II.K.3.3 Report Safety and Relief Valve Failures Promptly and Challenges Annually II.K.3.5 Continue to Study Need for Trip of RCPs.
Modify Procedures or Designs as Appropriate II.K.3.11 Control Use of PORV Supplied by Control Components, Inc. Until Further Review is Completed II.K.3.13 Separation of HPCI and RCIC System Initiation Levels. Analysis and Implementation II.K.3.15 Modify Break Detection Logic to Prevent Spurious Isolation of HPIC and RCIC Systems II.K.3.16 Reduction of Challenges and Failures of Relief Valves.
Feasibility Study and System Modification.
II.K.3.18 Modification of ADS Logic.
Feasibility study and Modifiaction for Increased Diversity for Scme Event Sequences II.K.3.21 Restart of Core Spray and LPCI Systems on Low Level.
Design and Modification.
II.K.3.23 Central Water Level Recording II.K.3.24 Confirm Adequacy of Space Cooling for HPCI and RCIC Systems II.K.3.25 Effect of Loss of AC Power on Pump Seals II.K.3.27 Provide Common Reference. Level for Vessel Level Instrumer.tation II.K.3.28 Study and Verify Qualification of Accumulators on ADS Valves II.K.3.30 Revised Small-Break LOCA Methods to Show Compliance with 10 CFR 50.46 II.K.3.31 Plant Specific Calculations to Show Ccmpliance with 10 CFR 50.46 II.K.3.44 Evaluation of Anticipated Transients with Single Failure to Verify no Significant Fuel Failure II.K.3.45 Evaluate Depressurization with Other Than Full ADS II.K.3.46 Response to List of Concerns From ACRS Consultant III.A.1.1 Upgrade Emergency Preparedness III.A.1.2 Ungrade License Emergency Support Facilities III.A.1.3 Maintain Sucplies of Thyroid Blocking Agent (Potassium Iodide)
III.A.2.1 Amend 10 CFR Part 50 and 10 CFR Part 50, Appendix E III.A.2.2 Develocment of Guidance and Criteria III.A.3.3 Ccmmunications III.A.3.S Training, Drills, and Tests
.o
. Primary Coolant Sources Outside the Containment III.0.1.1 Structure III.0.1.2 Radioactive Gas Management Ventilation System and Radiof odine Adsorber Criteria III.D.l.3 III.D.2.3 Liquid Pathway Radiological Control III.D.2.4 Offsite Dose Measurements III.0.2.5 Offsite Dose Calculation Manual Radiation Protection Plans III.D.3.1 III.D.3.3 In-Plant Radiation Monitoring III.D.3.4 Control Room Habitability s
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9 ENCLOSURE 3
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ENCLOSURE 3 ACTION PLAN ITEMS APPLICABLE TO PENDING MANUFACTURING LICENSE APPLICATION Organization and Management Long-Term Improvements I.8.1.1 Short-Term Accident Analysis and Procedure Revision I.C.1 Procedures for Feedback of Operating Experience I.C.S Control Room Design Reviews I.O.1 Plant Safety Parameter Display Console I.O.2 Safety System Status Monitoring I.D.3 Control Room Design Standard I.O.4 Coordination of. Licensee, Industry and Regulatory I.E.4 Programs Expand QA List I.F.1 Develop More Detailed Criteria I.F.2 Reactor Coolant System Vents II.B.1 Plant Shielding to Provide Access to Vital Areas and II.B.2 Protect Safety Equipment From Post-Accident Operation Post Accident Sampling II.B.3 Rulemaking Proceeding on Degraded Core Accidents II.B.8 Reliability Engineering II.C.4 Testing Requirements II.0.1 Research on Relief and Safety Valave Test Requirements II.D.2 Relief and Safety Valve Position Indication II.D.3 II.E.1.1 Auxiliary Feedwater System Evaluation Auxiliary Feedwater System Automatic Initiation and II.E.1.2 Flow Indication Reliance on ECCS II.E.2.1 II.E.2.3 Uncertainties in Performance Predictions Reliability of Power Supplies for Natural Circulation II.E.3.1 Dedicated Penetrations II.E.4.1 Isolation Dependability L_ _ _ _
II.E.4.2 Purging II.E.4.4 Additional Accident Monitoring Instrumentation II.F.1 Identification and Recovery frcm Conditions Leading II.P.2 to Inadequate Core Cooling Instrumentation for Monitoring Accident Conditions l
II.F.3 (Reg. Guide 1.97)
_.. _ _.II.G.1_
Power Supplies for Pressurizer Relief Valves, Black Valves, and Level Indicators II.J.3.1 Organization anc Staffing to Oversee Design and Contruction II.K.3.2 Report on Overall Safety Effect of PORY Isolation System
c
. Report Safety and Relief Valves Failures Promptly II.K.3.3 and Challenges Annually Continue to Study Need for Trip of RCPs. Modify II.K.3.5 Procedures or Designs as Appropriate Proportional Integral Derivative Controller II.K.3.9 Modification Anticipatory Trip Modification Proposed by some II.K.3.10 Licensees to Confine Range of Use to High Power Levels Control Use of PORY Supplied by Control Components, II.K.3.11 Inc. Until Further Review is Completed Confirm Existence of Anticipatory Trip Upon Turbine II.K.3.12 Trip Revised Small-Break LOCA Methods to Show Compliance II.K.3.30 with 10 CFR 50, Appendix K II.K.3.31 Plant Specific Calculation to Show Ccmpliance with 10 CFR 50.46 Upgrade Licensee Emergency Support Facilities II I. A. l.2 Development of Guidance and Criteria III.A.2.2 Primary Coolant Sources Outsite the Containment Structure III.0.1.1 III.0.1.2 Radioactive Gas Management Ventilation System and Radiciodine Adsorber Criteria III.0.1.3 Liquid Pathway Radiological Control III.D.2.3 III.D.3.1 Radiation' Protection Plans In-Plant Radiation Monitoring III.D.3.3 Cont-ol Room Habitability III.D.3.4 J
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G ENCLOSURE 4 t
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o ENCLOSURE 4 PROPOSED FEDERAL REGISTER NOTICE NUCLEAR REGULATORY COMMISSION 10 CFR PART 50 PENDING CONSTRUCTION PERMIT AND MANUFACTURING LICENSE APPLICATIONS AGENCY:
U. S. Nuclear Regulatory Commission ACTION:
Proposed Licensing Requirements for Construction Permits and Manufacturing License
SUMMARY
The Nuclear Regulatory Commission is considering requirements to take into account in the design of pending construction permit (CP) and manufacturing license (ML) applications lessons learned in connection with the Commission's consideration of the TMI-2 accident.
There are currently pending six CP applications for eleven plants and one ML application for eight floating nuclear plants.
Staff review of these applications has been suspended since the TMI-2 accident on March 28, 1979 pending formulation of a licensing policy to appropriately reflect the lessons learned from the accident.
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DATES:
Comment period expires 45 days from the date of publication of this notice.
ADDRESSES:
Written _ comments _ shculd be submitted to the Director of Nuclear Reacter Regulation, U. S. Nuclear Regulatory Ccamission, Washington, D. C.
20555.
FOR FURTHER INFORMATION CONTACT:
Robert A. Purple, Deputy Directcr, Division of Licensing, Office of Nuclear Reactor Regulation, U. S. Nuclear Regulatory Commi ssion, Washington, D. C.
20555, Phone (301) 492-7672.
.. SUPPLEMENTARY INFORMATION:
Based upon its extensive review and consideration of the issues arising as a result of the Three Mile Island accident, the Comission recently approved the TMI Action Plan, NUREG 0660.
The Comission noted that the Action Plan presents a sequence of actions.
That will result in a gradually increasing improvement in safety as individual actions are conpleted and the initial imediate actions that were taken soon after the accident are replaced or supplemented by longer term improvements.
By Policy Statement dated June 16, 1980, the Comission identified (in NUREG 0694) the set of TMI-related requirements for new operating licenses that are necessary and sufficient for responding to the TMI-2 accident.
The Comission further decided that current operating license applications should be measured against the regulations, as augmented by these requirements.
The staff is now developing a position with respect to the set of necessary and sufficient TMI-related requirements that should be applied in the review of applications for construction permits and manufactoring licenses for nuclear power plants.
In developing this position, the staff considered three options:
1.
Resume licensing using the pre-TMI CP requirements augmented by the applicable requirements identified in NUREG 0660.
2.
Take no further action of the pending applications until the ralemaking actions described in the Action Plan have been completed.
3.
Resume licensing using the pre-TMI C? requirements augmented by the the applicablNequirements identified in NUREG 0660 and require certain additional measures or commitments in selected areas (e.g., those that will be the subject of rulemaking).
,. Option 1 would minimize the review and construction impact, thereby minimizing delays in reaching regulatory decisions for the planned facilities.
The principal disadvantage of Option 1 is that it fails to take advantage of the fact that, since construction has not started, it would be relatively easy to provide design flexibility to implement potential significant safety imp rovements.
Option 2 would maximize the safety improvements but would result in extensive delays.
The staff believes that the costs of such delays are not justified provided that design flexibility can be demonstrated.
The staff believes that Option 3 is a suitable compromise between the extremes of Option 1 and 2. This option will ensure that approved action items in the Action Plan are applied to the new cps and will provide for early consideration of added safety, measures that can be incorporated into the design without the need for inordinately costly backfit.
By establishing a clear statement of requirements with respect to the issues to be determined by rulemaking, a degree of stability is introducted into the CP review process thereby allcwing prospective applicants to make better-informed decisions.
In its review of the Action Plan the staff has identified four areas that they believe merit special attention.
The following idantifies these areas and describes the staff's present position with respect to the require-ments that should be met by CP and ML applicants.
1.
Siting The Commission has already established a transition policy for CP applicants.
CP applicants would be asked to compare their sites with the recommendations of NUREG 0625, as modified by the NRC's Office of Policy Evaluation and Adviscry Committee on Reactor Safeguards.
At such time as the proposed rule en siting is issued for ccament
_4 (scheduled for October 1980), CP applications would be assessed against the criteria contained in the proposed rule and any needed additional requirements will be proposed by the staff.
2.
Degraded Core Ruiemaking s.
CP and ML applicants would describe the degree to which their designs conform to the proposed interim rule.
Applicants would also provide reasonable assurance, to the extent practicable and taking into account the present state-of-the-art in this technology that issuance of cps and MLs will not foreclose or preclude the modification of the facilities to accomodate potential requirements that may result from the rulemaking proceedings.
These potential requirements include such features as filtered vented containment, molten core retention, and hydrogen control systems.
Special attention would be given to those facility designs with small containment volumes, i.e., ice condenser and Mark III containment design.
Prior to issuance of the CP or ML, applicants would be required to submit their evaluation of the additional features, both preventive and mitigative, they propose to include at their facilities that have the potential for significant risk reduction.
3.
Reliability-Engineering CP and ML applicants would perform simplified system reliablity analyses for the f:llowing systems:
subcriticality systems, emergency feedwater systems (PWRs), reactor core isolation cooling system, (%Rs), ECCS injection and recirculation systems, shutdcwn cooling system, containment cooling and spray systems, safety features actuating systems, and auxiliary systems upon which these depend (alternating and direct current, ccepressed air, essential service water er cooling systems, and heating, ventilating and air conditioning systems).
These analyses would use event-tree and fault-tree logic techniques to identify design weaknesses and possible system
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Particular emphasis would be given to determining
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potential failures that could result from human errors, common causes, single point vulnerabilities, and test and maintenance outages.
CP and ML applicants should provide sufficient information to describe the nature of the studies, how they are to be conducted, the conpletion dates, and the program to assure that the results -of such studies are factored into the final designs.
4.
Emergency Preoaredness NTCP applicants would submit, prior to the issuance of construction permits, a discussion of their preliminarf plan for coping with emergencies addressing the amended rule (Appendix E to 10 CFR Part
- 50) as it applies to construction permit applications.
Sufficient detail would be presented to provide reasonable assurance that the requirements will be implemented properly.
The remaining Action Plan items that the staff has determined to be applicable to the pending CP and ML applications are set forth in NUEEG which also sets forth the required comitment or design information necessarf to permit completion of the safety revi ews. As Action Plan Decision Group C items become approved by the Comission, they would be added as requirements for CP and ML applicants.
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Public coments are requested with respect to: (1) the fcur areas identified above for special consideration; and (2) the requirements identified in NUREG Folicwing receipt of public comments, the staff dill finalize its pcsition and present appropriate recommendations for Comissien consideraticn.
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