ML19331E438
| ML19331E438 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 08/20/1980 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8009100181 | |
| Download: ML19331E438 (57) | |
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NUCLEAR REGULATORY IOMMISSION f-r\\
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e In the Matter ef:
DISCUSSION OF NORTH ANNA FULL PCWER LICENSE 4
I DATE:
Aucust 20, 1980 PAGES:
1 thru 50 l
AT: ' Washington, D. C.
e ALDERSON REP 1MYT1.YG r-Q 400 Virginia Ave., S.W.
Wasnington, D. C.
20024 Telechene : (202) 554-2345 l
8009100 9 l
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION.
3 PUBLIC MEETING DISCUSSION ~ OF NORTH ANNA FULL POWER LICENSE s
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8 Nuclear Regulatory Commission aj 1717 H Street, N.W.
9 Room 1130-
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10 Washington, D.C.
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3 The Commission met, pursuant to notice, at 2:05 p.m.
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BEFORE:
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gl JOHN AHEARNE, Chairman
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!15 J SEPH'HENDRIE, Commissioner B
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VICTOR GILINSKY, Commissioner g
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STAFF PRESENT:
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EISENHUT H. SHAPAR 21 i
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DROMURICK E. WEBSTER ll 23,
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ROSS 25 F.
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B. GRIMES 3
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This is an unofficial ::anse:1p: of a saattag f cha Uni:ad States Nuciaar Regulatory Comission held on kflo f'D in the Commission's officas a: 1717 E Screa:, N.' W.', Washington, D. C.
The maating was open :o public attendance a=d obserratics.
This ::anscrip has so: baan reviewed, cc::ac:sd, or edi:ad, and it may contain inaccuracias.
The ::a= script is 1 :andad solely for ganaral infor_ational purposes.
As provided by 10 CTR 9.103, 1: is not par of :he for=al or infor=al record of decision of :he =at:ars discussed.
Expressions of opd d en in this ::anscript do not nacassarily reflec: final datarminations or baliafs.
No pleadd g or other paper =ay be filed vi-d :he Co= mission in any proceed 1=g as tha result of or addressed to any sta: aman: or argn=an: conta1=ad harais, axcept as the Co= mission =ay autherf:a.
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CHAIRMAN AHEARNE:
The meeting on an operating license 3
for North Anna, as mentioned several weeks ago in a meeting 4
at which the Director of Nuclear Reactor Regulation first brought e
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to us his recommendations regarding the North Anna Unit 2.
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North Anna is the first full power license to come to this Commis-En 7
sion since the Three Mile accident, and at the previous meeting N
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it was pointed out that there was still an emergency drill to be d
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g conducted, and I mentioned that 'at least for me it was essential eH 10 for that drill to be conducted before at least I was prepared
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to address the license.
And this was because it was one of the d
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new requirements that came out of the Three Mile Island accident, E
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The drill has been held.
- Today, I' expect we.will 0
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discuss several items; that drill and the Federal Emergency 16 l Management Agency's preliminary conclusions regarding that drill,
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17lI some ques tions that Mr. Gilinsky has regarding documentation on 18 l Cz
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environmental qualification of equipment, a review done by the I
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g-General Counsel's office as to whether the NRC's approach to 20,
j issuing licenses is legal -.
To jump ahead, they found that it 21 was legal.
22 (Laughter. )
23 !
But they have recommended several improvements and the 24 I
Diractor of NRR will speak to how they are moving ahead on these !
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improvements.
There are some points that Commissioner Gilinsky j
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wishes to make regarding the license, some points that commissione:
2 Bradford wishes to have made regarding the license, perhaps some 3
points Commissioner Hendrie wishes to make regarding the license, 4
and then we will get to address the actual license and whether or 5
not issue it.
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Harold ?
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MR. DENTON:
I would propose 'to cover first the events n
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which have occurred since we last met with you on this application a
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and I'll turn the briefing over to Daryl Eisenhut.
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MR. EISENHUT:
Thank you.
This slide is an outline of
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on today.
The emergency preparedness, as you mentioned, a new
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3 14 selected other issues which we will jus t mention again.
To x
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summarize, dated requirements, fire protection and environmental d
Ib qualification.
And finally, we'll be discussing the improved M
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5 18 If I could, I'll turn it over to Bryan Grimes, who will
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be making the presentation on emergency preparedness.
I 20 l MR. GRIMES:
I'd like to go through a few slides which 21 i
go over the response exercise, and also the material we've i
22 received from the Federal Emergency Management Agency in regard 23 '
to the adequacy of the plans of the State of Virginia and local 24,
and county plans.
25 The exercise was a joint exercise involving both the 1
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I licensee onsite activities and county activities and state activi-2 ties. It was observed both onsite and offsite by NRC, FEMA and 3
several other federal agencies who participate with FEMA in 4
offsite plan reviews.
There was a pre-briefing before the 5
g exercise on Friday, August 15th, followed by the exercise on 6l Saturday that lasted from about 6: 30 in the morning until mid-R
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afternoon.
There was then an internal licensee critique with A
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NRC present at the Emergency Operations Facility af ter the drill.
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There was a more formal critique the next day, and by both NRC o
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5 II to provide immediate feedback from the federal observers to the E
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I2 participants in the exercise.
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13 l The scenario itself was a simulated steam generator I4 tube leak with some st3bsequent events which are listed on the 15 slide.
I will not go through each one in detail.
I would,
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however, point out that several -- all four stages of emergency A
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were passed through, all the way from notification of an unusual c
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event through the Alert class; the more serious site emergency to ch g
I9 l the highest class, General Emergency.
n 20l The scenario was managed by giving parameter information I
on the licensee side to the control room operators, and the data 21 22 flow was then from those people who would normally get the i
23 parameter information to the decisionmakers in the Technical 24 Support Center and Emergency Operations Facility for the licensee!
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l 25 and off site to the s tate.
There was also an offsite scenario J
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control which a-little later John McConnell from FEMA may wish 2
to describe.
3 I will, a little later, go over some of the general 4
lessons that we learned out of this exercise and how detailed a
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scenarios should be and what kind of review they should receive 3
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beforehand.
I would just say briefly that in this case, the 8
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initial intent of the exercise on VEPCO's part was not to partici-8 8
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pate a full player; we changed that when we reviewed their d
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scenario materials Tuesday before the exercise, so there's a 10 f airly short period of time in which they changed from providing i
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E we think they did do a good job of turning that around and being g
13 a very thorough and enthusiastic player, both on the decision-5 I4 5
making end and on the technical analysis end.
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The timeframe here was compressed, which is another
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j criticism we'd have.
In the future we would like to see real i
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l time escalation through these events rather than compressed time 18 i 5
because it requires too much additional information that wouldn't 3
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ordinarily be given by the controllers.
20 i CHAIRMAN AHEARNE:
Bryan, are you saying, then, that 21 you would -- for example, this case, prefer something that would 22 !
l take about three days to run?
23 I MR. GRIMES:
No, I think we'd prefer -- although in 24 l
-some cases you might occasionally want a very long scenario to 25 f
test-the stamina and the shif t changeability of the forces, we I
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prefer scenarios which do go through real time events in this 2
kind of a timeframe.
3 The overall finding was that the performance of both the 4
onsite and offsite players was satisfactory.
There are a number -
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CHAIRMAN AHEARNE:
Whose finding was that?
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MR. GRIMES:
That is our finding, and that's my overall E
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input and our Nuclear Reactor Regulation also provided some d
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g observors who I got direct feedback from, and my reading of the og 10 Federal Emergency Management Agency's critique of the offsite.
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When we get into the FEMA area, I'll turn to John McConnell and d
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ask him to fill in a little of the detail in that regard.
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With respect to the licensee areas for improvement, we S
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identified several.
Communications,. there were minor things; E
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wrong numbers, the notification to the counties for the general
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emergency went from the licensee to the state instead of as 6
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state.
However, in this case, the state was sitting beside the
,8 19 l. licensee in the Emergency Operations Facility, so it was not a --
20 the licensee knew that the communication had been made.
21 The location of the EOF in particular is a question 22 mark in view of our new guidance in NUREG-0696.
We'll have to r
have either a habitable area provided close to the plant or a 24 !
permanent facility provided further out, which would be allowed 25 by the 696 guidance.
At this point, we have not required VEPCO l
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operation.
They're being treated like all the other power reactons 3
with the dated requirement to upgrade these facilities.
4 CHAIRMAN AHEARNE: What is their dated requirement for that?
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MR. GRIMES :
The Safety Evaluation Report indicates that En 7
the previous date of January 1,1981 to upgrade the facilities n
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was being relaxed somewhat, as we told the Commission, I believe, do 9
g in our presenta' tion on NUREG-0696.
It's being relaxed to April 9
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E 1982 to provide a sure integration of all the data information E
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network and computerization required by our new requirements.
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We want the safety parameter, special safety parameter information 13 5
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Operations Facility to be upgraded in concert, and our requirements y
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will require the purchase of substantial computer equipment, I T
16 l believe, which will not make it possible for a January 1 date to i
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be met.
w 5w 18 i CHAIRMAN AHEARNE:
You say, though, that one of the
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possibilities would be to have a dif ferent f acility. Has VEPCO 20 l
thought much about that?
21 MR. GRIMES:
We have not.
We just last month put out --
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in fact, it was in the Federal Register just las t week -- the 23 '
availability of NUREG-0696, and we're having regional workshops I
this week, so we have not had a good dialogue with any utility 25 yet.
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1 MR. DENTON:
Once our views are firm on the Tech Support 2
Center and supporting equipment,. both in the plant and offsite, 3
we probably will implement that by order on all plants, and 4
treat VEPCO,and North Anna 2 exactly the same as any other opera-e 5
ting plant with the same deadline.
An 3
6 MR.' GRIMES:
We also had some criticism on guidance for R
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projection of the duration of release.
We think more attention 8
needs to be given, and I think will be given in the future, to d
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Where ioy 10 operating procedures assume release will continue for an hour, E
5 11 we really need to project beyond that time in terms 'of thinking
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12 about whether public protection measurer, should be recommended to E=
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And I think VE?CO agrees with us on that and l
14 l has revised their procedures in that regard.
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air samples had to be brought back into the facility.
This is a
p 17 l something we had not focused on in our guidance before, but we w=
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believe it would be an improvement not to have to bring those air,
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samples back into the facility for analysis if there's an accident n
20 going on in the facility.
21 Monitoring equipment -- there was some problem in the 22 offsite support people having to come into the facility to pick i
23 y the monitoring instruments and go back out.
We believe it's i
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- desi~rable to have the monitoring kits at some offsite location so l i
25 that people don' t have to come into the f acility and go back cut. j I
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And again, it's a concern in a radiological release and time 2
saved also, in obtaining equipment.
3 Visual aids could stand improvement.
Again, this is 4
something that you observe in an exercise; 'whether adequate 5
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decisionmaking tools are available, and we believe there could 8
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be better status boards and maps and things available in the Ea 7
Emergency Operations Facility.
All of these things VEPCO has N
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Item number 4 indicated 9/15/80 for the purenase order, oF 10 E
and we understand about another month would be required to obtain
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solved.
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In all, I would say on the licensee findings, there's E
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requirements and criteria and we would make a favcrable finding
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on their existing state of preparedness.
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A successfully demonstrated the capability to respond to radiologi-20 cal emergency.
I think I'll ask John McConnell to perhaps say 21 a few words on the extent -- what his perception is of the exercise at this point.
23
CHAIRMAN AHEARNE: Fine.
John, for the purpose of the t
24 '
i transcript, would you identify yourself, please?
25 MR. McCONNELL:
Th ank you, Mr. Chairman.
I'd like to I
ALDERSON REPORTING COMPANY, INC.
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11 put the exercise in perspective to the chain of events that FEMA 2
was faced with in attempting to accommodate an urgent request by 3
NRC, VEPCO.and the state to make some kind of an evaluation.
4 In 1979, the state really got the jump on the new e
5 criteria by attempting to incorporate 0396 with the 10-mile ar.d g
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3 6I 30-mile planning zones into-their plans that existed at that time.
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As a result, they did get concurrence on the old concurrence N
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procedure from NRC late in the calendar year.
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only on its state level plan and didn't do anything with the E
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local plans.
When the new criteria were made available to them, d
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and our regional office in Philadelphia gave them ah evaluation d
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of their existing plans, it was on the-basis of the new criteria, E
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0654.
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The state eventually submitted their state level plan
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to the region for review in June, and that was being reviewed by 6
17 our regional of fice which normally tak'es about 30 days with the az 5
18 six federal agencies that are involved in our Regional Assistance E"
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Committee.
That was in process at the time this rather urgent 20 request for an assessment was made.
21 We had a meeting in my office between Bryan Grimes and 22 his staff, VEPCO officials and the State Emergency Preparedness 23 l officials.
We agreed at that time to speed up the sequence ti l
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actions, but with the understanding that this would not replace 25 l the formal review procedure that FEMA would eventually undertake
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when the plans were formally submitted.
2 In three days, we reviewed the state plan with an 3
intensive effort of highly qualified people from headquarters as 4
well as the regions and gave the state a complete analysis of our e
5 assessment of the deficiencies in the state plan. The state agree 3 3
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also to put an intensive effort down at the local level in the 8
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five counties to upgrade their plans to meet the local -- the new 8
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It was understood that the plans would not be com-d d
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pletely rewritten, but supplements would be provided so that if an Cb 10 l l
exercise was conducted it would be on the basis of the new criteriz E
11 We were satisfied by having a man in the state office J
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state plan and to the local plans. He happens to be here today E
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case you have any questions of him.
And he provided an analysis g
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of the condition of the plans on Friday, the 15th, the day before j
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the exercise.
That was attached to the letter that we sent to W
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l We organized an observor team of 21 people, consisting E
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l of mostly FEMA repr esentatives but also included six federal 20!
l agencies that are involved in the Regional Assistance Committee, 21 I and put them in various locations so as to best observe the 22 exercise.
We also had involved a contractor who was assisting 8
us. to upgrade our advice ard guidance to the states on conducting 24 :]
exercises, and how to control and observe the exercises.
I think 25 this is going to be very beneficial and the next state that comes, AL.DERSON REPORTING COMPANY. INC.
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along with their exercise will have much more help and a'ssistance 2
than did Virginia.
3 They devised the scenario in a time protracted situation 4
so that they were continual *1y jumping ahead. in time and did not 5
g have time actually to complete actions that were started _ with a
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e one. phase of the incident until the next phase occurred.
So 'that R
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We do feel that they exercised most of the things that d
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we wanted to see in verifying that people understood that 10 resources were available, communications worked and there was
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There were a number of things that we observed in the m
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exercise that either had to be questioned because they didn't E
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standpoint.
The state has agreed, and I talked to Mr. Jones W
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18 I cll of those deficiencies will be rectified, the plans will be H"
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rewritten to incorporate the supplements that were devised in 20 the past three weeks and will be submitted to FEMA for final 2I review and considered approval by the middle of September.
I'm 22 convinced that all the material is there; it's a matter of putting i
23 f it together and correcting some of the deficiencies we observed in the exercise.
f 24 25 i CHAIRMAN AHEARNE:
It sounds, John, that there was a lot r
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of cooperation.
Is that correct?
2 MR. McCONNELL:
Very much cooperation.
Personal interes t -
3 by the Governor, the state department heads and the local govern-4 ment officials in particular.
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CHAIRMAN AHEARNE:
There's some concern about the 3
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Could you comment n
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on that?
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MR. McCONNELL:
Yes.
There are drills and exercises of c
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If one is attempting to test rather than demons trate g
10 the capability, you can certainly find more flaws by giving un-j 11
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announced and completely unrehearsed conditions.
I think a state
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with an expensive, time'-constrained situation where they have to g
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tion and get a lot of people involved; quite unlike a utility
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I which is fulltime on the job and it's their only concern.
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That's one reason the state chose to have this on Saturday.
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19 :l chose to have it in a period of time that would be sufficient to x
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end in the middle of the af ternoon and still have some time for 20!
putting notes together before a public meeting mid-morning on 21 !
l Sunday.
So actually, the exercise only ran about 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and 22 j j
i they tried to work in events that would probably more normally transpire in about 24 hourr.
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n So it was somewhat unrealistic, there was quite a bit ofl 25
.i simulation; mos t of the simulations were realistic and, again, e
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could have been 7ccomplished.
The few that were not we pointed 2
out in the observor reports and it's well understood by the state, 3
CHAIRMAS AHEARNE:
I gath er, though, that you don't view 4
that as a f atal. flaw, this scripting?
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g MR. McCONNELL:
No, sir.
We feel that we saw a good 3
6 demonstration of a capability.
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CHAIRMAN AHEARNE:
Thank you, John.
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8 MR. GRIMES:
I might just wrap up by the next slide, i
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g which is the overall NRC finding and point out that FEMA did E
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flag to us two particular points in the state plan which were E
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deficient in that the training programs for the state individuals d
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were not identified yet in the state plans, and the exercise d
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frequency has not been committed to and worked out.
And those E
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I will have to be worked out with FEMA.
We are putting a condition 2
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in the license, whenever it may be issued, to specify that VEPCO T
16 reports back to us on all these matters within about 90 days, d
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so we'll have a status on each item that FEMA is concerned with Cw 18 g
and that we are concerned with by that time.
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l I'd like to take just a minute for backup slide number 20 l two, which is lessons for the future.
I've not discussed these 21l with John McConnell and FEMA yet, but we',ll be getting together 22 l l
with FEMA and comparing observations on how we should improve 23 our own process.
I think we need the scenario to be used well in 24 l l
advance and it would be desirable if we could develop scenarios i
25 ourselves, and we have some consultant work going on in that i
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regard so that we would have an agreed-on scenario.
And we need 2
to allow adequate time for the licensee and state to revise the 3
scenario.
In this case, there were major changes only four days 4
before the exercise, 5
g Third, the scenario needed to emphasize the decision-9 6
making process. This scenario was a little weak in that regard R
7 partly because we changed, on the licensee's part at least, from Ml 8
a strictly input to the state exercise to a joint licensee as a d
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player exercise at a fairly late date.
And a lot of people on 10 the management level probably knew the scenario although the
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11 analyzers and control room operators did not apparently know 5
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We believe.it's important to simultaneously exercise m
14 the licensee and the state and local agencies.
You ' find a
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15 lot of problems when you try to work everybody at once that-you m
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And a mix of announced and w
17 unannounced exercises is highly desirable, as John McConnell 5
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Some federal or state influence is tolerable during the 5
20 play of the exercise.
We think we introduced some uncertainty 21 in the scenario by declaring one of the key licansee players to 22 have died in a car crash on his way to the EOF, so somebody else 23 had to pick up that.
The licensee knew that some one of his key 24 ;
-people would be taken out but did not know who.
Although thin has 25 to be used with some caution.
You can destroy an exercise by l
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pulling too many uncoordinated surprises.
2 Number eight, there were notifications to the NRC 3
Operations Center, chey were made and acknowledged, but the 4
workload that would be caused by the NRC questions was not simu-e 5
g lated and it.-s important occasionally to include that in the a
3 6l exercise also, because it is a significant impact on the decision-E";
makers nd on the' peopl'e who are coordinating the information.
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I think that completes the emergency preparedness dd 9
g presentation.
oP 10 COMMISSIONER GILINSKY:
What was the extent of the NRC
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Operations Center involvement?
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MR. GRIMES:
They were notified, they acknowledged the E
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notification;each time an emergency class was reached the t
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communication was made to the Operations Center.
It was acknow-k 9
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ledged as having been received and that was the extent of the
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6 17 l MR. EISENHUT:
On that issue, Bryan, one point.
In the w
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license, the actual condition that Bryan mentioned was not in the H"
19 8
license that was sent downtown.
It's a license condition to be n
20 added to 20.D which we will petition for.
It's a 90-day commit-21l ment that VEPCO will report to NRC the status of any items 22 relating to emergency preparedness from either FEMA or the NRC.
23 I'd like to turn to the next item in our overall outline.
24 i That item is a new item, since our July 31st presentation. It 25 relates to Table S-3 in the uranium fuel cycle, and I'd like to ALDERSON REPORTING COMPANY, INC.
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have Frank Miraglia summarize this issue.
2 MR. MIRAGLIA:
As the Con 1 mission probably recalls, they 3
promulgated the final rule in the S-3 rulemaking in Nugust of 4
1979, and as part of that promulgation of the rule, in the state-5 ment of consideration which issued the rule in final form, it
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6 directed the staff to do two things.
The staff is directed to R
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prepare an explanatory narrative which would explain the numerical g
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was to prepare this narrative; the narrative was to be used in o
h 10 a fursher rulemaking in which it would be adopted as part of the
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12 The second thing that the Commission d.rected the staff 5
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5 13 l to do is pending the adoption of this narrative and the completion mj 14 of the notice and comment on the narrative, the stuf was to
$j 15 discuss certain important generic fuel cycle issues in cases
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FES on North Anna Unit 2.
The original FES, the addendum to the P"
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FES and the errata to.the FES, did discuss the proposed interim n
20 rule which was issued in October of 1976.
The errata updated 2I that to the final rule which was adopted in March of 1977.
And 22 the second addendum completes compliance with the Commission 23 !
directive by utilizing the narrative, the narrative that has been 24 prepared by the Division of Nuclear Materials Safeguards and 25 Safety, which has been before the Commission and which the l
l ALDERSON REPORTING COMPANY, INC.
19 1
-Commission has commented on, and it's the latest draf t which 2
incorporates the responses to the Commission comments and concerns 3
And that narrative has been cdopted and utilized in the preparatic 4
of the second addendum 'to the FES, which is included in the
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3 6
I MR. EI'SENHUT :
Thank you.. The next issue we'd like to a
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just summarize is other issues that will be completed af ter the j
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These are the major issues that we're proposing.
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Commission and we're just basically following the Commission 's E
11 guidance in each of these areas.
I'll just mention them.
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S final by November 1st with the alternate shutdown. system by E
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That is consistent with the May 23rd Commis-2 15 y
sion order.
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to submit the results of their review of all aspects by November 18 5
1, 1980, with the staff SER issuance being February 1st, 1981.
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Again, with upgraded equipment or else all equipment verified by 20 June 1982.
Those conditions are in conformance with the May 23rd 21 l
order from the Commission.
22 I f
One other issue, or one other aspect of this that we 're 23 !
adding to the license that, again, you do not have in the draft 24 {
license in front of you, is that we will be adding the license 3
25 condition which was sent down to the Commission as a proposed i
i ALDERSON REPORTING COMPANY. INC.
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condition in SECY-80-370, dated August 6th. That condition had 2
to do with a central location for keeping all the information 3
relating to environmental qualification, describing the methods 4
used to show that all safety-related equipment complies with
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We're proposing that Mn 6
we put tha t in as a license condition. That matter is, again, R
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pending before the Commission in SECY-80-370.
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mentioned and discussed with the Commission on a number of 10 occasions.
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$j 15 the equipment, procure it and get it installed were as we set z
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I believe the three of them were i
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in about April of 1981; two of them, the reactor system events s
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19 CHAIRMAN AHEARNE:
That's to' coincide with the M
20 fueling outage.
i 21 1 MR. EISENHUT:
That would be coinciding with the refuelihg 22 outage.
On those issues you will recall that the earliest the i
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utility is estimating they could probably get everything ready i
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to put in anyway would be the Fall of 1981, so this would entail i
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a couple of months for convenience.
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There are, of course, m number of other issues that we 2
briefed you in various other briefings.
3 COMMISSIONER GILINSKY:
Is that a realistic date, that 4
December 1981?
Because I gather that there was some change in
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29 3
6 MR. EISENHUT:
Yes, we did a review on those and we R
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and have those installed, we concurred with the 12/81 date.
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2o 10 MR. DENTON:
This is an ' area in khich each utility has 3
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14 CHAIRMAN AHEARNE:
I don' t think Commissioner Gilinsky 's ae 2
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Let's ask Denny Ross who's reviewing that w
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area of the comment.
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I think as f ar as the ef forts of the utility E
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staff for its review, allow for a reasonable amount of question 21 and giving and taking, and for the staff to prepare its Safety 22 Evaluation, it's reasonable to believe that we could be rer.dy in 23 '
the Fall of 1981.and that the system and the hardware would be 24 i ready to install.
If that's the thrust of your question.
25 j CHAIRMAN AHEARNE:
Are they really going to-be ready to A
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have a design and come up with th proposal in time to then 2
have you do your review for the equipment to be procured to be 3
ready for that installation?
4 MR. ROSS:
Yes.
I think it's reasonable, and based on 5
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information looks like the Fall of 1981 is a good date.
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CHAIRMAN AHEARNE:
Has anyone completed a design?
2Cg 10 MR. ROSS:
Not to the extent that we reviewed it, z
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or upgrading a ~ requirement that we would have had put in place i
n 20 by 1/1/81.
An example would be the emergency offsite f acility 2I that Mr. Grimes mentioned.
And, of course, if we 're changing the 22 requirement, that is, upgrading the requirement to something 23 ;
substantially more, we're going to be coming down to you and 24 proposing that the dates change.
25 We have right now under preparation what we call a fa i
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clarification letter that' we're going out to all utilities with, 2
which we anticipate sending down to you within the next week.
3 And that letter will go through all of the 1/1/81 items. that we 4
anticipate there will be any kind of a change in.
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In essence, the approach I think will be 2
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established a standard of best efforts to earliest date.
And 20 that's what, in essence, we'll be proposing here for these 21 items that can' t be met by those original action plcn dates.
22 MR. EISENHUT:
It will be the same approach we 23 discussed with the Commission on the short-term Lessons Learned.
One other I'll just mention in passing, and again it's 25 just indicative of some very minor changes that will have to be i
i ALDERSON REPORTING COMPANY. INC.
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done to the proposed order that's down here.
Things like, we 2
refer to Reg Guide 1.97, Rev. 2.
Well, there is no Rev. 2.
The 3
action plan was referring to a Rev. 2 that we had hoped would 4
be issued by this time --
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5 CHAIRMAN AHEARNE:
Which has run into some problems.
29 6
MR. EISENHUT:
Which has also run into its own problems, Rg 7
yes, so we will be referring to the proper edition of the 8
requirements and the utility will be committing to whatever our d
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I thought that's the way it was E_
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Or an alternate equivalent acceptable to E
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Yes.
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What would you end up saying?
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When Rev. 2 is finally adopted, we'll have i
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19 MR. EISENHUT:
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There will be some minor fine tuning.
But again, 21 certainly not changing any of the substance.
22 That's completed all we were going to highlight on this i
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item.
The last item.
24 !
COMMISSIONER GILINSKY:
I wanted to ask about the environc 25 mental qualification.
I've gone over this several times and I'm 4
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not sure I understand it yet.
What precisely happens November 17 2
What is supposed to happen by that date?
Is it that the licensee 3
or the applicant is to have from his vendorsa documentation to 4
cover the qualifications of all these items?
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Let me back up just a step.
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your May 23rd order had the February date in it, and stated that R
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all operating plants, and we are interpreting --
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COMMISSIONER GILINSKY:
The ev'aluation will cover the
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25 ; _ there by November 1st.
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l ALDERSON REPORTING COMPANY. INC.
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believe are qualified, and here's how we're going to continue to 2
go down the road of qualifying equipment; per test or analysis, 3
et cetera.
4 One thing that he must have in addition to that is that 5
he is controlled by Tech Specs which say that if the utility 3
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That covers the 92 categories m
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that can be exposed to this accident environment.
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Does that go beyond the 92 1
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And Vince Noonan may want to elaborate on that.
24 l MR. NOONAN:
Vince Noonan, Division of Engineering.
The Il 25 92 types of items that we now have are all the safety-related i
i ALDERSON REPORTING COMPANY. INC.
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equipment that are required that are exposed to a harsh environ-2 ment and required for safe shutdown of the plant.
3 COMMISSIONER GILINSKY:
Okay,- so it is all of them in 4
this case.
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It is that class of equipment.
8 6l COMMISSIONER GILINSKY:
Now, you're saying that if by R
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qualification of that equipment, you draw an X through that item d
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So some of them may not be qualified j
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Okay. But some reasonable 5
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MR. DENTON:
That's right.
He must have completed his 5
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first look by that date and given us his list and reasons and 21 rationale as to why it does or doesn't so we can begin.
22 CHAIRMAN AHEARNE:
Does that mean if he -- let's take 23 '
one item on your lis* --
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MR. DENTON:
Certainly, if he concludes it's unquali-i i
25 fied, so would we.
l ALDERSON REPORTING COMPANY,INC.
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CHAIRMAN AHEARNE:
If he comes in on November 1st with 2
one of these items and he says that he was counting on being able 3
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I gather, from at least this report 9
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documentation from his suppliers.
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Yes, sir.
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So he has some confidence at the
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21 MR. NOONAN:
That's right.
In his hands right now he i
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November 1st he will have that documentation in.
24 COMMISSIONER GILINSKY:
Let me understand what happens 25 and maybe you've given the answer.
But to be absolutely sure, t
l ALDERSON REPORTING COMPANY, INC.
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what happens if by November 1st, simply documentation is lacking 2
as opposed to getting information that, in effect, the item is 3
unqualified?
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In fact, there will be plants that the e
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What would have been the case l9 S
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21 MR. EISENHUT:
At North Anna I think if we don't have 22 the information --
23 '
COMMISSIONER GILINSKY:
The newer plant.
24 lI MR. EISENHUT:
Certainly.
If we don' t have the informa-25.
tion, we'll have to look at what items they are and make a decisior i
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based on that.
2 CHAIRMAN AHEARNE:
But I think what you're saying is 3
that November 1st is a date in which the effort then, rather than 4
an automatic action on North Anna, more becomes the responsibility 5
y of the NRC staff to then recommend something.
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That is right.
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And it may well result in plants being 5y 18 shut down.
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COMMISSIONER GILINSKY:
If on November 1st rather than n
20 having specific information that a component is unqualified, 21 if you just have information lacking on a number of components,
22 I you mar well not get around to reviewing that for weeks maybe.
23 MR. CENTON:
Well, there's nothing magic about the first 24 date, it was just a target to enable us to prepare the safety 25 evalaation for the next --
3 l
ALDERSON REPORTING COMPANY. INC.
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CHAIRMAN AHEARNE:
By February ist.
2 MR. DENTON:
By February 1st.
We generally wanted it 3
all in from each applicant by November 1st.
Now, we expect to 4
get it in by around November 1st from all applicants so that we e
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because that will be 70 big stacks of paper.
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Normally, our priorities for reviewing 21 the generic answer start out with the high density sites and 22 other critical plants, so I would expect that North Anna 23 !
wouldn't necessarily be the first response that we would pick up 24 I
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When we start through the response from all 70 25 plants and as determinations are reached, if they are unable to i
ALDERSON REPORTING COMPANY, INC.
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establish that tha equipment is there, the Tech Spec becomes 2
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But presumably, you will have f~
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this one by that date with a written safety evaluation.
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requirements, both the Technical Specifications of Sequoyah and l
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20 taken the same approach and put that requirement in place on II North Anna.
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ALDERSON REPORTING COMPANY, INC.
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1 Spec.
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itself all of the commix ments, requirements, that are a one-time requirement; that is, it either must be done at some point
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you can tell in the license by just the size and the number and 20 the types of items that are there and, in fact, by a change of 21 1 I
about a third or slightly larger number of the Tech Specs, with 22 j
an eye towards making them clearer and making them more enforce-I 23 able.
Those were the key ingredients.
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We still have a ways to go but I think I
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2 MR. EISENHUT:
That basically completes the items 3
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4 CHAIRMAN AHEARNE:
There is one item that came in with
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MR. BICKWIT:
Problems have been raised with our approach 3
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tions of the Commission will be complied with, if there's any i
6 17 doubt that that is a statutory requirement.
wm 18
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The problem that is raised is that under the normal C
19 1 8
l staff review practice, the st aff does not review specifically 20 for compliance with each and every regulation by the applicant.
21 There are really two component parts to this problem.
First of 22 all, the utaff conducts an audit review.
They are looking at 23 '
comoliance with various regulations and drawing inferences from 24l!
the results of those reviews. They draw broad inferences that 25 all the regulations are, in faci, complied with.
I I
ALDERSON REPORTING COMPANY. INC.
33 1
The second problem is that they do not, in fact, when 2
reviewing against requirements review directly against the regu-3
- ations themselves, but rather, against the provisions of the 4
standard review plan which references the regulations in many
'e 5
instances but does not follow tb s regulations specifically h
6 provision by provision.
R 7
Our conclusion is that there'is a basis for finding X
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that the inferences that are drawn across these two hurdles are d(
9 consistent with the statute.
10 CHAIRMAN AHEARNE:
They are consistent?
II MIi. BICIG1IT:
Are consistent with the statute.
B y
12 CHAIRMAN AHEA N For those of lay people, what 3g 13 you're saylng is that you've concluded it's legal.
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14 MR. BICKWIT:
We have concluded it's legal.
15 CHAIRMAN AHEARNE:
I hesitated to ask that question g
16 l in memory of a previous situation.
d i
f I7 I MR. BICIG1IT :
I remember it well.
x l
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18 We've outlined-in a memo exactly how we come to that E"
19 conclusion.
Let me simply say that in coming to that conclusion g
20 we recognize that while we are ccafortable with the legality of 21 the continued issuance of licenses, we could be more comfortable.
22 And we are, to some degree, skating fairly close to the line, I
23 to the bare minimum contemplated by the statute.
And therefore, 24 we have recommended a program which would provide greater assur-25 ance that the regulations are, in face, complied with and it's i
il ALDERSON REPORTING COMPANY,INC.
34 I
a three-part program included in this memorandum.
First, we 've 2
recommended that the staff compare the SRP and the regulations 3
generically, and ensure that all of the regulations are, in fact, 4
included in the requirement's of the standard review plan.
5 Secondly, we recommend that applicants with pending e
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6 applications be requested to state with supporting references that Rf7 each and every applicable NRC regulation is complied with.
COMMISSIONER GILINSKY:
One single statement would d*
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suffice?
oH 10 j
MR. BICKWIT:
One single statement would suffice.
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CHAIRMAN AHEARNE:
You said with supporting references.
NI MR. BICKWIT:
Yes.
5 fI MR. BICKWIT:
Third, we recommend that the review l
14 process have a very strong emphasis on the qualifications of g
15 applicants and applicants ' contractors.
This is because since z
d I0 in an audit process it is necessary to rely in great degree on M
the representations of the applicant, it is extremely important x
18 for the Commission to be satisfied that those representations
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20 And we are not sufficiently familiar with the current i
21 I practice to know whether an increase in emphasis is in fact 22 needed in order to ensure that.
But we are arguing for a very 23 I strong emphasis on those particular factors.
24 CHAIRMAN AHEARNE:
The point you' re making, I believe, 25 is sor t of to go along with an audit process, that's a requiremente lI b
3 ALDERSON REPOPTING COMPANY, INC.
35 1
I since you end up relying on the applicant's statement, then f
2 you have to have a good amount of confidence that the applicant 3
is someone that you can trust.
4 MR. BICKWIT:
That's right.
And finally, I think it 5.
5 ought to be stated that with respect to existing plants, the
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Bingham amendment by law would require a review process which t
R R
7 would actually go b'eyond this particular process that we've Xl 8
recommended, and would require specific review by the Commission, d
c 9
by the staff, against the regula' ions that are regarded as most
,z h
10 significant by the Commission.
And under that amendm'ent, a plan 3
l 11 for the conduct of that review must be submitted to Congress is
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-and I unders tand that that plan is underway.
13 l
14 CHAIRMAN AHEARNE:
Harold, my unders tanding is that, nj 15 at least from reading some material you have, that you are z
16 ambarked upon those steps.
Can you speak to that?
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17 MR. DENTON:
We've made forays in this direction before, 18 l k
andIagreewithandinfactintendtodocompletelytherecommen-l -
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R 19 dations of Items 1 and 2.
They're similar to the ones we proposed 20 before; namely, to go through the standard review plan which is 21 the present guidance to the staff and be sure that all the signi-22
' ficant regulations are covered and instructions to the reviewer 23 with regard to acceptance criteria and evaluation findings, so tha-24 -l the standard review plan has.an established, ccmplete congruence 25[
with the set of regulations.
l 1
ALDERSON REPORTING COMPANY. INC.
30 I
Sec mdly, we are obtaining from all licensees --
2 CHAIRMAN AHEARNE:
In this memo you've provided us you 3
say that where that comparison isn't explicitly referencins.
4
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the regulation, you then identify that and make the modifications.
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And modify the standard review plan where necessary.
8 6
MR. DENTON:
Yes, that's right.
And we would propose N
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We would modify n
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It might take us dd 9
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a while to codify it in the standard form of the standard review oh0 plan since there are so many standard review plans and the
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rewrite may take a while, but we're already attempting to move d
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in dnat direction when we find an area that seems to need
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Secondly, we asked North Anna and asked all licensee:
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15 g
to provide a report documenting how they comply with the Commis-T 16 sion's regulations, the Regulatory Guides and 'the standard review i
17 I w
plan.
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CHAIRMAN AHEARNE:
And that's what the August lith 9
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response from North Anna 1s.
20 MR. DENTON:
And I think that response is only with 21 regard to how they comply with regulations.
Now, we.have also 22 obtained from the company how they comply with Reg Guides, and.
I 23 in the. course of review every application always has a listing of 24l how an application complies with the Reg Guides but we didn't, 25 as Len said, we focused on Reg Guides and standard review plans p
I
. ALDERSON REPORTING COMPANY. INC.
37 I
rather than the regulations.
2 CHAIRMAN AHEARNE:
The Geraral Counsel's recommendation, 3
though, was, at least request the applicant tc state with the 4
references that every re gulation is complied with, and that seems e
5 to be what this -.
5 l
6 MR. DENTO:7:
Yes, it's done here, and I would envision R
7 we do at least that and possibly more in terms of getting the Kl 8
burden shifted to the licensee to identify the differences d
o; 9
between his design and our requirements in Reg Guides and 5
10 standard rev'iew plans in order to facilitate the staff 's identifi-E j
11 cation and attention to those differences.
y 12 COMMISSIONER GILINSKY:
In past applications, is there 5
13 i no statement on the part of the licensee saying that all applicabl e
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15 MR. DENTON:
There are s tatements that he complies with z
y,16 Reg Guides, which our standard format has required a comparison d
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18 Sinca the mid-seventies --
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19 COMMISSIONER GIL?.NSKY:
There's no one broad statement --
20 COMMISSIONER HENDRIE:
The standard format also specifies 21 the section in which the applicant speaks to his conformance to 22 the general design criteria; that is Appendix A, Part 50, which 23 l is probably the core of the safety requirements set out in generat i
24 terms for the design of a plant.
And I suspect that when people 25 file applications, they make summary conclusions saying we think i i
i ALDERSON REPORTING COMPANY. INC.
38 I
we comply with everything.
I think that's the guess but I don't 2
have anything at hand.
3 MR. DENTON:
I couldn't find very many instances where 4
they'd made a flatout statement in the' application.
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5 CHAIRMAN AHEARNE:
I guess the question would be, have g
3 6
you ever required a boilerp1Tte language provision?
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7 MR. DENTON:
No, because I' guess I never in the past n
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tion Ebat's important.
And the reality of the situation I think og 10 z
has been that for those regulations where the Commission had E
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explicit guidance is Appendix I and Appendix K, and there has d
12 Z
always been an explicit review by the staff and a finding by the E
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staff where there is detailed criteria to be met.
But where the E
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Commission's criteria wer'e more general, we turned to a Reg Guide 5
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which laid out really the basis for a finding without always x
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establishing that that Reg Guide was completely responsive to the 6
17 a
j regulation or that it may be applied to more systems.
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So the more detailed the regulations, the more explicit 9"
19 the statement by the licensee.
But we will satisfy Item 2 of 20 Len's recommendation in all future applications.
21 With regard to Item 3, that's one that's done in a 22 variety of ways, and I don't think it's as easily done by the 23 i
stroke of a pen as the first two are.
We do it through computer 24 code audits; for example, we just gave you the results of an 25 j
audit of computer codes at a steam supply outfit such as i
iI i
ALDERSON REPORTING COMPANY, INC.
I l
39 I
Westinghouse architect engineers; we're improving our requirements 2
on the technical qualifications of operators.
I don ' t know of 3
any single action I can take to supplement number 3, but we 'll 4
certainly consider ways to make that more apparent.
CHAIRMAN AHEARNE:
I'm sure Len may have aHditional ef0 points, but at least as I read what he was saying, it's to high-M R
7 light to all of the reviewers that since it is an audit approach, N
k that it is critical that they keep in mind that the overall d
quality of the. applicant, the overall quality of the applicant's o
h contractors, is a major factor in having confidence in an audit
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Speaking as a reviewer, it's always been o
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E 14 COMMISSIONER GILINSKY:
I think our enforcement policy
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is not unrelated to this.
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MR. BICKWIT:
This specifically references enforcement 6
17 policy questions, and I guess I would agree with your statement az 5
18 that you want to highlight that but you also want to conduct
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your review such that you back up the words with deeds.
Again, I'm not saying that that isn't done at this 21 point.
And our memo may have led people to conclude that in 2
that we did say --
CHAIRMAN AHEARNE:
You said you included increased 24 !
l emphasis.
25 MR. BICKNIT:
Increased emphasis, I'd like to change it.
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ALDERSON REPORTING COMPANY, INC.
40 1I I don't think it's appropriate for us to use the words increased 2
emphasis when we haven't a satisfactory to ours&lves understanding 3
of what emphasis is now placed.
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4 COMMISSIONER GILINSKY:
Does the law require that we 5
j review for compliance each and every regulation, or would certain 9!
O summary statements on the part of licensees suffice?
In other R
b 7 f words, saying that they comply aith regulations A through L?
Kl 8
MR. BICKWIT:
It requires that we make a" finding that d
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the regulations are complied with.
z 10 CHAIRMAN AHEARNE:
But your opinion is that the audit 11 approach satisfies that.
3 N
I2 COMMISSIONER GILINSKY:
But there 's an audit within 1
3 5
13 a regulation and there's a higher level audit which would simply--
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I4 which wouldn't audit every regulation.
$j 15 CHAIRMAN AHEARNE:
And that's what Mr. Bickwit says
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What l'n saying is you do not have to x
M 18 review against each specific regulation; you can conclude from C6 I9 g
your review that some regulations are met; that all regulations e
20 are met i
2I CHAIRMAN AHEARNE:
And that's also, though, based upon, 22 as I read your paper, the conclusion that many of those that on any given license may not be reviewed are not being reviewed 23 24 h because the principles of how they are met have been well 25 established by previous reviews -.
ALDERSON REPORTING COMPANY,INC.
41 1
MR. BICKWIT:
That is certainly one element of the 2
rationale.
3 COMMISSIONER GILINSKY:
It also occurs to me that one 4
of the reasons you may not be reviewing some of these items is e
5 that you don't think they're important and you nay be right and 3n h
6 maybe we ought to be changing the regulations.
Rg 7
CHAIRMAN AHEARNE:
Well, that's a separate issue which M
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also Len mentions in his paper..
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It seems it's good. policy in terms of d
9 MR.
T iog 10 maximizing the effectiveness of our review to focus it on the E
5 i
areas which we know are most troublesome nd that we're most 3
y 12 likely to find inadequacies in the review rather than on design 5
y 13 areas which have been settled for perhaps a decade, rather than 1
l 14 just duplicating another review in that area.
So the review E
2 15 typically has focused only on those areas that the Board, the 16 ACRS, the staff and yourselves have highlighted as having the g
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17 maximum payoffs.
wz 18 COMMISSIONER HENDRIE:
I'd like to note, before we go P
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19 away from this question of the audit nature of the review, it's M
20 always been apparent that the government staff is not about to i
21 reproduce on a one-to-one basis the hundreds of thousands of 22 person years of professional effort that go into the design and q'ality assurance work on a large facility.
So we've always 23,
u i
24 ;
understood that there was an audit nature to this, since 15-odd 25 ;
person years of staff _ professional time are used to review an I
I ALDERSON REPORTING COMPANY, INC.
42 0
4 1
application which has required many orders of magnitude more 2
professional. effort to prepare.
3 But I also wouldn't want people to go away with the 4
thought that the audit review is ineffectual.
There are substan-e 5
h tial areas, the design and construction of these plants, as 3
6 e
g Harold has pointed out, where satisfactory solutions have.long 8
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since been arrived at.
For instance, I dare say that on the 8
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the pressure vessel in the primary system was adequately designed g
10 and constructed with regard to stress analysis and a'll the rest j
11 of the great t' c.gs you do in primary system design, I suspect j
12 5
the reviewer checked the commitment of VEPCO that these matters g
13 l i
were carried out in accordance with Section 3 of the Pressure l
14 Vessel Code of the American Society of Mechanical Engineers,
2 15 5
which is cited in the regulations as a requirement.
And that all j
16 the vessels have an "N" stamp from ASME, and the piping similar A
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18 l accreditation.
5 5
Now, the f act that the reviewer simply verifies this 19 i commitment by VEPCO in. this case is an audit step. But behind it 20,
I lies literally thousands of professional manyears of hard-fought 21 analysis, disagreement, compromise, agreement in. She setting of 22 very rigorous standards on these components, and I regard the 23 l reviewer's verification of that commitment, you see, which you 24 ;
can regard as audit if you like, as being an absolutely first 25 l
class review of th'e pressure vessel and primary system components,.
ALDERSON REPORTING COMPANY,INC.
43 I
1 So, " audit" has a number of meanings here, and I would not like 2
there to be the suggestion that there is something cheap and 3
dirty about audit review.
4 CHAIRMAN AHEARNE:
Any other general questions?
5 COMMISSIONER GILINSKY:
I don't think so.
0
' COMMISSIONER HENDRIE:
We might talk a minute about R
7 some things on the emergency exercise which are not in the O
nature of particular questions about the North Anna exercise but d"
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perhaps relate a little more to the generic aspects.
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f I2 the first major test of the combined licensee / local government /
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13 state government /NRC/ FEMA involvement in the whole schmear, there m
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I48 is, of course, a strong desire on everybody's part ot exercise 15 all of the various parts.
You want to go through all the four z
d I0 stages of notification, the Alert, the Site Emergency and the us l
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General Emergency, and you want to go through various sorts of 5
IO exercises and contingencies within each of those levels.
g" 19 You get led, then, for that first general exercising of 20 the integrated plan almost inevitably I think to some sort of I
version that is similar to the North Anna exercise.
That is, I 22 think there are bound to be places in the drill where you will 23l either want to run it on an accelerated timescale, or you'll want 24 to run in real time but. then keep cutting and advancing to a next 25 step and renormalization of initial conditions, as it were, in ALDERSON REPORTING COMPANY, INC.
l i
44 1
order to get all of these exercising done in an overall time 2
which is compatible with the ability of -- as John McConnell 3
pointed out, folks have to come in on weekends and all the county 4
organizations and state people, to say nothing of John and his e
5 troops and our staff.
So it makes it very inconvenient to run Aa 6
one that goes on for many days.
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7 As one moves on from that first plan which attempts to nl 8
test many elements' of the integrated operation and looks to d
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further drills down the line, then I think one looks more to E
10 real time exercises that will exercise more particularly some E
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That is, we've talked about annual drills and 3
y 12 that is a requirement under the new rule of the Commission, and
=l 13 I. think then you come to your first annual drill, the one af ter
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g 15 rather than try to cover again everything in that drill, you may
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19 g
exercising of that particular phase.
M 20 But I think we ought to keep in mind that since the 21 purpose of that first significant integrated test of the combined 22 emergency plans does need to test various aspects, that we 're 23 !
always going to have certain of these accelerated time or cut and l
24l move to the next step elements.
And I don' t think that's neces-25 sarily a bad thing.
My impression from the reports that have come '
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1 ALDERSON REPORTING COMPANY,INC
45 I
back is that everybody has learned a great deal out of this one.
2 I found that to be
- 6. rue in emergency drill exercises we've gone 3
through here at the Commission.
Both real and drill, I must say.
4 (Laughter.)
e 5
So I think the exercise that was conducted has had E
6 great value and. is very usef ul in its results.
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7 CHAIRMAN AHEARNE:
Let me ask a question of Harold and l
8 perhaps Howard and Len also might want to answer.
Peter Bradford d
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lef t a note saying that -- and I think this relates very much to 2
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10 the discussion we just recently had with respect to compliance
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He points out that on the first page 3
f I2 of this license, the finding that we end up making is that the O
5 13' Commission's regalations are met.
And he believes that it might m
14 be more appropriate to say that the NRC has reasonable assurance k
9 15 that'they are met.
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I've described the nature of our review; W
h I7 I guess it's a legal question.
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18 MR. SHAPAR:
Yes.
The Act and the regulations do, P"
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in particular-the regulations, do use the words " reasonable n
20 assurance" in some places and don' t use that term " reasonable 21 assurance" in others.
The findings that you have here comply 22 with the statutory terminology and the terminology in your own 23 !
regulations.
24{
As an example, if you take a look at one of the regula-t 25 :
tions that's directly in point, 56.57, and you look at 50.57 (2),
I ALDERSON REPORTING COMPANY, INC.
46 o.
I the finding that you need to make is that the facility will 2
operate in conformity with the application as amended, and the 3
provisions in the Act and the rules. and regulations of the 4
Commission.
" Reasonable assurance" is not used.
By the way,
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0 the statute.
" Reasonable assurance" is not used there.
Just R
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a flat out, absolute finding.
Al 8
On the other hand, it's slightly different terminology, d
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and I hope nobody asks me why these differences in terminology zog 10 cropped over the years because I'd be hard pressed to answer, E
h 11 but if you look at the very next 3
y 12 COMMISSIONER HENDRIE:
I thought you drafted the
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13 chapter 10 -.
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14 MR. SHAPAR:
You're not only wrong but you're much g
15 too kind.
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16 (Laugh ter. )
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So to give you an example of reasonable assurance, --
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18 CHAIRMAN AHEARNE:
We can correct both of them.
P "g
19 (Laughter.)
n 20 MR. SHAPAR:
To give you an example of where an almost 2I similar area in which " reasonable assurance" is used, look at 22 the very next finding in 50.57, and it says, "There is reason-23 {
able assurance that the activities authorized by the operating 24 license will be conducted in compliance with the regulations of 25 this chapter."
i ALDERSON REPORTING COMPANY, INC.
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47
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so what you see in front of you in the license is 2
almost a verbatim repeat of what's in your own regulations and 3
what's in the statute.
4 MR. BICKWIC:
So I think your conclusion is that you 5
g ought to leave it the way --
9!
0 MR. SHAPAR:
I was leaving the conclusion for the R
b 7
Commission to draw.
N 8
8 MR. BICKWIT:
I see.
That's a dangerous proposition.
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9 (Laughter.)
Eg 10 MR. SHAPAR:
I have complete confidence in the Commissiorm II MR. BICKWIT:
I'd like to make a recommendation to the E
f I2 l Cormission; whether or not I have confidence in the Comaission, 3
5 13
(
it is the Commission's decision, and my recommendation would be
=
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5 14 to leave the finding as it is.
I think it's clear from the 5j 15 discussion we've had that nobody has absolute assurance that x
16 l g
l the regulations are complied with.
And it's also clear that the A
I7 statute didn't contemplate absolute and total assurance.
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point.
I think it is not necessary in order to make that point n
20 l to revise the finding, and I'd rather have the finding directly 2I parrot the language of the regulations.
22 MR. SHAPAR:
I'd like to add in connection with the 23 relationship between this discussion you pointed out and the 24ll earlier discussion, I agree with Len's conclusion about the 25 legal basis for supporting our present requirement.
I don't j
l l
ALDERSON REPORTING COMPANY, INC.
l i
48 1
however, view it as close to the line as he indicated.
I think 2
it's comfortably above the line.
In my opinion, it's not a 3
question of whether or not the regulations have been complied
(
4 with.
I think the technical staff will tell you they have a e
5 good deal of confidence, as I do myself.' It's really a question h
6 of documentation rather than actual compliance with the regula-R 7
tions.
So I'd like to make that point.
Nl 8
CHAIRMAN AHEARNE:
Yes.
I don't think Len was trying c;
9 to imply a belief that th'e regulations may not have been complied 10 with.
It was, I thought, a. concern that the method by which we j
11 can document support is weak.
3 y
12 MR. BICKWIT:
That is the case, and could be improved, 5
13 and I think we ',re in agreement 'on how it could be improved.
l 14 CHAIRMAN AHEARNE:
Yes.
Ej 15 MR. DENTON:
I'd just like to add support to what Howard z
j 16 said.
We do substantial technical review of these applications, l
d d
17 j but our documentation in the past has been rather scanty, d
18 carried around mainly in people's memories rather than system-E h
19,
atically written down, and it's just a situation we can't n
1 20 rectify along the lines proposed.
21,
CHAIRMM AHEARNE:
Yes.
And I think that's what Len's i
22 was.
23,
COMMISSIONER GILINSKY:
On this question of wording of 24 the license, I interpret these findings based on reasonable assur-25 ance on the part of the people who make the findings.
I don't 1
f ALDERSON REPORTING COMPANY. INC.
l
49
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1 think it could be otherwise.
2 CHAIRMAN AHEARNE:
Yes.
I would then stay with it.
3 COMMISSIONER HENDRIE:
So would I.
(
CHAIRMAN AHEARNE:
I have no problem with -- based upon
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the information we've received and the exercise and the comments j
6 on the exercise -- I have no difficulty with saying that Harold S
7 should go ahead and issue the license.
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8 COMMISSIONER GILINSKY:
I would approve issuance.
dd 9
g COMMISSIONER HENDRIE:
So would I.
h 10 COMMISSIONER GILINSKY:
With the comments that I would z=
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in the discussion.
S 13 '
CHAIRMAN AHEARNE:
Yes.
I think Harold's would be E
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the decision.
He will issue a license and I would suggest that 9
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if you wish to add any additional ' comments that Harold can --
T 16 COMMISSIONER GILINSKY:
There must be something
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18 -
CHAIRMAN AHEARNE:
I don't think so.
I think it's just 19 j
Harold has the ~ delegated authority to issue licenses and he's 20 provided us with the information.and I think we 're in agreement.
21 l
COMMISSIONER HENDRIE:
Vic, a perf ectly reasonable thing 22 to do that I guess I've done not quite in this context but in
'3
^
l connection with ~ other things that come up in a particular case 24 i l
is a copy certainly ought to be filed in the docket file for the 25 !
l North' Anna 2 application so it is there on the formal public recor@
l i
ALDERSON REPORTING COMPANY. INC.
50
,..o 1
of the application.
And maybe it wouldn' t be inappropriate if 2
Harold mailed a package to VEPCO in due time saying,
Dear VEPCO,
3 your license is enclosed.
You might also enclose a copy of 4
comments by the Commissioner.
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5 COMMISSIONER GILINSKY:
I guess I thought the Commission E
6 would ' issue an order and it sounds like you're disinclined to do R
R 7
that.
But isn'.t there a memorandum from the Secretary?
Aj 8
MR. BICKWIT:
In the past there has been.
dd 9
COMMISSIONER HENDRIE:
I think it would be perfectly E
10 appropriate for an immediate jolt memorandum on behalf of the 11 Commission reflecting the decision here ac the table.
I 12 CHAIRMAN AHEARNE:
I'm sure that Sam will be delighted 5
y 13 to attach your comments to the memorandum.
But I think the real a
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5 14 issue is that the Commission has approved Harold's request.
9 15 MR. DENTON:
We will proceed with your concurrence and a
j 16 issue a license, and I'll get-together wi th Commissioner Gilinsky l
17 !
to decide how best to incorporate his comments in that action.
Ew 18 We have most of the paperwork together.
As we indicated, there E
19 e
are a few changes. in the license itself, so we'll move expedi-n 20 tiously to be sure that satisfies all the requirements we've 23 talked about.
22 CHAIRMAN AHEARNE:
Very good.
Thank you.
23 (Thereupon, at 3:30 p.m.,
the meeting in the above-24 entitled matter was adjourned.)
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ALDERSON REPORTING COMPANY, INC.
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'nu NUCLEAR REGULATORY COM4ISSION This is to certify tha: the a:: ached pecceedings bef:re -he
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in tne =a :er ef:
SUNSHINE MEETING - PUBLIC MEETI$G - DISCUSSION OF NORTH ANNA FULL POWER LICENSE
- Date of ?receecing:
August 20, 1980 Decket !!u=b er :
Place of ?receeding:
Washington, D. c.
were held as herein appeers, and tha this is :he crisinal transcrip:
therec f for -he file of the Cc==1ssd ~
Fuzanne Babineau Official Repcr er (Typed)
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Cfficial Reper:er (signa ure) l k
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In the Mattar of:
DISCUSSION OF NORTH ANNA FULL POWER LICENSE I
DATE:.
Aucust 20, 1980 PAGES: 1 thru 50 AT: ' Washington, D.'C.
(
4LDER$1Y REPORTING
- r. y 400. Virginia Ave., S.W. Washington, D. C. 20024 b'-
Telephone : (202) 554-2345
- 3.
t NORTH ANNA 2 Rlll POER BRIEFING AusuST20,1980 GENCY b N URANIUM FUEL CYCLE (IAB E S-3) 0mER ISSUES
- DATED REQUIREMENTS
- FIRE PROTECTION
- ENVIR0tNENTAL QJALIFICATIONS
.IwROVED GPERATING LICENSE / TECHNICAL SPECIFICATIONS 1
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NORTH ANNA POWER STATION JOINT EMERGENCY RESPONSE EXERCISE SCHEDULE OF EVENTS FRIDAY, AUGUST 15 PRE EXERCISE BRIEFING BY STATE IN RICHMOND SATURDAY, AUGUST 16 6:30 AM - 2:30 PM JOINT EXERCISE 4:00 PM VEPC0 CRITIQUE WITH NRC AT EMERGENCY OPERATIONS FACILITY SUNDAY, AUGUST 17 10:00 AM NRC/ FEMA CRITIQUE AT LOUSIA COUNTY JUNIOR HIGH SCHOOL s.
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SCENARIO 0630 NOTIFICATION OF UNUSUAL EVENT STEAM GENERATOR TUBE LEAK 0700 ALERT SAFETY INJECTION 0745 STEAM GENERATOR ISOLATED ONE OF TWO AVAILABLE HIGH PRESSURE SAFETY INJECTION (HPSI) PUMPS FAILS 0830 SITE EMERGENCY STEAM GENERATOR SAFETY VALVE LIFTS 0915 FIRE - LAST HPSI PUMP FAILS CONTAMINATED INJURY OCCURS 1000 GENERAL EMERGENCY LOSS OF SUBC00 LING MARGIN 1200 ONE HPSI PUMP RESTORED TO SERVICE 1230 ONE MORE HPSI PUMP RESTORED TO SERVICE 1330 STEAM GENERATOR SAFETY VALVES RESET.
l 1400 CORE 500F SUBC00 LED 1430 EXERCISE ENDS'
- TIME WAS COMPRESSED:
ONE EXERCISE HOUR EQUALS EIGHT ACTUAL HOURS
RESULTS OF EMERGENCY EXERCISE OVERALL FINDING - SATISFACTORY AREAS FOR IMPROVEMENT FOR VEPC0 1.
COMMUNICATIONS LOCATION - CONTROL ROOM, TSC, E0F WRONG NUMBER FOR HANOVER COUNTY (CORRECTED DURING EXERCISE)
NOTIFICATION TO COUNTIES BY STATE ONLY 2.
EMERGENCY PLAN IMPLEMENTING PROCEDURES GUIDANCE FOR PROJECTION OF THE DURATION OF RELEASE 3.
FIELD ANALYSIS OF 0FFSITE AIR SAMPLE EQUIPMENT TO MONITOR I0 DINE 4.
MONITORING EQUIPMENT DEDICATED EQUIPMENT LOCATED OFFSITE 5.
VISUAL AIDS ISOPLETHS, MAPS, STATUS BOARDS SCHEDULE FOR COMPLETION 1.
09/15/80 VEPC0, 10/01/80 C&P TELEPHONE 2.
09/15/80 3.
09/15/80 4.
09/15/80 (PURCHASE ORDER) 5.
09/15/80
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FEMA FINDING LETTER DATED AUGUST 19 - OVERALL EVALUATION THAT THE COMMONt!EALT OF VIRGINIA STATE AND LOCAL GOVERNMENTS HAVE SUCCESSFULLY DEMONSTRATED THE CAPABILITY TO RESPOND TO A RADIOLOGICAL EMERGENCY.
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l NRC FINDING THE EMERGENCY PREPAREDNESS PROGRAM IS SATISFACTORY.
THE LICENSEE'S PLANS ARE ACCEPTABLE AND CAPABLE OF BEING IMPLEMENTED.
THE STATE AND LOCAL PLANS ARE ACCEPTABLE AND CAPABLE OF BEING IMPLEMENTED.
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IPANIlN PE_ CYOI IWACTS (TABLE S-3) t.
- C0tNISSION PR0ftLGATED FINAL FUEL CYCE Rua AUGUST 12$ 1979 Gill FR L15362)
- DIRECTED STAFF TO PREPARE EXPLANATORY NARRATIVE TO BE ADOPTED BY RULEMAKING
- DIRECTED STAFF TO DISCUSS IWORTANT FUEL CYCLE ISSUES IN INDIVIDilAL CASES PENDING RULEMAKING ON NARRATIVE
= ADDENDlM AND ERRATA TO NORTH AtNA FES DISCUSSED URANIUM FUEL CYCLE IMPACTS
' SECOND A mENDlM TO FES PREPARED TO COW LY WITH C0tNISSION DIRECTIVE
- UTILIZES LATEST NARRATIVE PREPARED BY h% WHICH INCORPORATES C0tNIS'SI(X1 C0ffENTS r g meee w,
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- IMPLEMENTATION BY NOVElSER 1, M
- ALTERNATE SHUTDOWN SYSTEM 3Y APRIL 1,1981 i
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ENVIR0lHENTALQUALIFICATION
-SUBMITRESULTSOFREVIEWBYNOVBSER1,1980 i.
- STAFF SER ISSUED BY FEBRUARY 1, 1981
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- UPGRADED / VERIFIED EQUIPMENT BY-JUNE, 1982 t
NUREG-0694TMIISSUES a
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NUCLEAR REGULATORY COMMISSION
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SSINS 9199 MDORANEGi K)R:
N. C. Itseley, Director, Division of Peactor Operations Insp::ction FROM:
J. Philip Stohr, Onef, FEMI Branch
SUBJECT:
GGI ANNA I. NIT 2 - EMEPGE2Cl EXEBCISE VEP(D participation in the joint Emergency planning exercise, conducted August 16, 1980, was evaluated by Pegion II perramel, assisted by NRR j
observers. The NRC perscnnel also attended the VEPCD critiqw and presented detailed commts on items of concern and irprowstents needed.
Areas high-lighted as having greatest significance were diemm1 with VEPCD Iranage-ment en August 16 and again with Station managenent cn August 18, and correctim acticn -4*=mts were received. 'Ihese itens and ccx:mitments are enclosed.
Our overall.assessmmt of VEPCO's performan in the exercise is that it demmted an adequate capability to implemmt the licensee's radiological arcrgency res;xnse plan. 'Ite identified weaknesses, wit te requiring attenticn, are not sufficiently serious to preclude, a recarnendatien that l
a full power license be issued for North Anna 2.
'Ibe Director, legica II, is crnfirtang the ocxtmit:nmt dates identified in the enclosure with VEPCD senior management.
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him: As Stated cc:
F. Pagano, NRR J. Sniezek, OIE CXX7DCr: George Jenkins 242-5541
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ENCEOSURE CCM4I' DENTS CN 8/16/80 N. ANNA EME3CENCY EXENW r_ IDS
'Ihe following corrective action itens were reviewed with VEPCN nanage-nent cn 8/16/80 and 8/18/80; VEPCD comi.tmants for correctiw acticn are indicated.
1.
Item: 'Ihere is no spe"4 #4M c=Phility for perforning field analyses of air sanples collected by offsite ex:nitoring teams.
Q2xnitment: 'Ibe necessary equipaent and procedures wil'. be avail-able and crxaplete to provide the cgn.nhility for field analyses of air ei as.
l ECD: 9/15/80 2.
Item: There is no dedicated equipuent located outside ths Station for use by Staticn offsita nonitoring teams.
C%mnitnent: Mic*M equipaent kits will be located outside the protected area for this purposej purchase orders will be issued for additional equipmnt (radios; air sanplers, etc.) needed for these kits; nonthly inventory and operaticnal testing of the r1Mic*ad equignent will be inc1 W in Periodic Test procedures.
ECD: 9/15/80 3.
Itan: Existing nmrgency Plan Inplementing Procedure (EPIP) does not provide for long duratica releases whei projecting offsi'a integrated doses.
.1 Ctmuitment: Bevise EPIP to provide for longer duraticn releases, and to provide for an early mnfezence betwaan the Ecergency Director, Health Physics, and Operaticns to assess p*hle duraticn of releases.
ECD: 9/15/80 4.
Itan: Initial notificaticn to munties too slow, Canmitnent:
(1) Ensure correct telephcne numbers en emergency call list. C%ropleted:
8/18/80 (2) Evaluate and inglenent plms for inprowd 1meim for Cbntrol R:an comunicator to minimite noise and other distractions.
ECD: 9/15/80 l
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Item.
'Ib.lephcne locatims and iAanH F4 cation of instrunent with inccrti.l1g call inp.ded ocutunications at both 'Itxtnical Support Center (TSC) and Emergency Operatims Facility (IDF).
Omnitment:
aalocate telephones at 'ISC and ECP. to prod 5 nore effective distributicn, and add lights to telephcne instrments to identify ir-ing calls.
ECD: 9/15/80 for VEPCO action 10/1/80 for C&P Telephcne C3. acticn 6.
Item:
Notification of a sinulated General DnergEncy was luade to the Gaunties by the State. on 8/16/80.
Omnitnent:
Procedums will be reviewed and revised, if needcd, to ensu m that the initial notification of a General Buergency will be made by VEPCD to the Cbtnties.
ECD: 9/15/80 7.
Itan:
Visual decisional aids (iscpleths, -4s, status boards, etc.)
for offsite rM4n1@l conditions were either not available or not adequate.
Qx:mitmnt: Visual aids to m ht with assessnent of offsite radio-logical conditiens will be emanded and inproved.
ECD: 9/15/80 e
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I fiUREG-0053 Sunplement flo. 12 August, 1980 SAFETY EVALUATION REPORT RELATED TO THE OPERATION OF NORTH ANf!A POWER STATI0!i, UNIT 2 Docket flo. 50-339 VIRGIflIA ELECTRIC Atl0 POWER COMPANY SUPPLEMENT NO. 12 0FFICE OF flVCLEAR REACTOR REGULATI0fl U.S. NUCLEAR REGULATORY COMMISSION
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TABLE OF CONTENTS Page.
1.0 INTP^0VCTION AND GENERAL DISCUSSION.................
1-1 1.1.
' Introduction 1-1
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22.0 TMI-2 REQUIREMENTS........................
22-1 22.2 Full Power Requi rements...................
22-1 III.
Emergency Preparation and Radiation Prenaredness.. 1 III.A.1.1 Uograde Emergency Preparedness..........
22-1 23.0 CO N CL U S I0.';S............................
2 3 - 1 Appendix A Continuation of Chronology of Radiological Review......
A-1 i
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1.0 INTRODUCTION
AND GENERAL DISCUSSION 1.1 i,'troducti on On June 4,1976, the Nuclear Regulatory Commission (Commission) issued its Safety Evaluation Report regarding the application by the Virginia Electric and Power Campany (VEPC0, licensee) for licenses _ to operate the North Anna Power Station, Units 1 and 2.
The Safety Evaluation Report was supplemunted by Supplement flo.1 through 11 which documented the resolution of several outstanding issues in
.further support of the licensing activities.
On November 26, 1977, the Facility Operating License NPF-4 was issued for North Anna Power Station, Unit 1.
The license permitted fuel to be loaded into Unit 1 and was subsequently amended [ Amendment No. 3] on April 1, 1978 to permit Unit 1 to operate at 100 percent power.
On April 10, 1980, the Commission issued Supplement No. 10 to the Safety Evaluation ~ Report related to the issuance of an operating license for North Anna Power. Station, Unit 2. -This action permitted VEPC0 to load fuel and to achieve criticality, and to operate Unit 2 at power levels not to' exceed five percent of full power, i.e., low power operation in accortince with require-ments developed from the lessons learned from the TMI-2 accident.
Subsequently on July 3,1980, authorization was granted by the NRC to VEPC0 to conduct its special low power test program. The program consisted of conducting seven special tests involving ccnditions for natural circulation heat removal.
Training _ was provided for the operators during the conduct of the tests.
Further 1-1 l
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- details of.the program ar.d the results are given in Section 22.2 Item I.G.1 of Supplement No. 11 to the Safety Evaluation Report.
In August,1980 we issued Supplement No.11 to the Safety Evaluation Report.
In Supplement No.11 we concluded that subject to resolving matters related to emergency
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preparedness, the operating ' license can be issued to allow power operation at full rated power (2775 megawatts thermal).
The purpose of this supplement is to update the safety evaluation presented in Section 22.2 (Item III.A.1.1.) of Supplement No.11 to the Safety Evaluation Report related to emergency preparedness.
In this report we stated that prior to authorizing full power a successful emergency exercise had to be parformed. This was accomplished on August 16, 1980.
Section 22.2 (Item III.A.1.1) is supplementary to and not in lieu of the discussion 2.tn the Safety Evaluation Report and the supplements thereto, except where specifically noted. Appendix A is a continuation of the chronology of any principal actions related to the processing of the application.
On the basis of staff review including a letter from FEMA dated August 19, 1980, we conclude that the North Anna, Unit 2 facility may be operatea safely at full power in accordance with the facility Technical Specifications without undue risk to the health and. safety of the general public.
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22.0 TMI-2 REQUIREMENTS 22.2-FULL POWER REQUIREMENTS III.
Emergency' Preparations and Radiation Protection III.A.l.1 Upgrade Emergency Preparedness POSITION a.
Provide an emergency response plan in substantial compliance with NUREG-0654, " Criteria for Preparation and Evaluation of Radiological Response Plans and Preparedness in Support of Nuclear Power Plants" (which may be modified af ter May 13, 1980, based on public comments) except that only a description of a completion schedule for the means for providing prompt notification to the population (App. 3), the staffing for emergencies in addition to that already required (Table B.1), and an upgraded meteorological program (App. 2) need be provided.
NRC will give substantial weight to FEMA findings on effsite plans in judging the adequacy against NUREG-0654.
b.
Perform an emergency reponse exercise to test the integrated capability and a major portion of the basic elements existing within emergency preparedne?s plans and organizations.
DISCUSSION AND CONCLUSIONS In Section 22.2 (Item III.A.l.1) of Supplement No.11 to the
-Safety Evaluation Report, we stated that we reviewed the applicant's revised emergency plan and found that it is in substantial comoliance i
with NUREG-0654 and meets the requirements of 10 CFR 50, Appendix E.
ke also stated that, the Federal Emergency Management Agency was reviewing the State and local emergency plans and that we had not received their findings and determinations. We also stated that
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c.
prior to authorizing full power operation, we would reouire a successful emergency response exercise to test the-integrated capability and a major portion of the basic elements existing within emergency preparedness plans and organizations.
The Federal Emergency Management Agency'(FEMA) has reviewed the State and local radiological emergency response plans and found them to be i
in substantial comoliance with NUREG-0654.
Based on that review and the successful Joint Emergency Response Exercise conducted on August 16, 1980, FEMA stated in a letter dated August 19, 1980, that the State and local governments have successfully demonstrated the capability to respond to a radiological emergency.
Based on our review of the FEMA's findings on State and local radio-logical emergency preparedness and our evaluation of the successful Joint Emergency Response Exercise, we conclude that the emergency preparedness program for North Anna and the related emergency planning zones is acceptable, capable of being implemented and meets the. regulatory requirements of 10 CFR 50, Aopendix E.
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23.0 -CONCLUSIONS I
' Based on-our evaluation of the application as set forthlin our Safety Evaluation Report issued on June 4,1976 and Supplement Nos.- 1 through 11.and our evaluation
._.as set forth in this supplement, we conclude that the operating license can be issued to allow power operations at full. rated ' power (2775 megawatts thermal)
~
subject to licens9 conditions which will require further. Commission approval-and license amendments before.the stated condition _can-be removed.
4 We conclude that the construction of the facility has been completed in accordance f
with the requirements of Section 50.57(a)(1) of 10 CFR Part 50, and that construction of the facility has been monitored in accordance with the inspection program of the. Commission's staff.
[
Subsequent to the.. issuance of the operating license for full rated power for the North Anna Power Station, Unit 2, the facility may then be operated only in accor-dance with the Commission's regulations and the conditions of the operating license under the continuing surveil. lance of the Commission's staff.
We conclude that the activities authorized by the license can be conducted without endangering the health and safety of the public, and we reaffirm our conclusions as stated in our Safety Evaluation Report and its supplements.
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APPENDIX.A Continuation of Chronology of Radiological Review July 16, 1980 Letter from applicant concerning auxiliary feedwater system requirements.
July 18, 1980 Letter from applicant supporting their request for a full power license. -Letter discusses emergency-plan implementing procedures.
July 22, 1980 Letter to applicant cnncerning emergency preparedness program for a full power license.
July 22, 1980 Letter from applicant concerning multiple structure ARS concern.
July ~23, 1030 Representatives from PSE&G, VEPCO, TVA & NRC meet in Bethesda, Maryland to discuss matters related to TMI-2 dated requirements.
(Summary issued August 8,1980.)
July 25, 1980 Letter from applicant concerning multiple structure ARS concern.
July 28, 1980 Letter from applicant concerning Nb.7EG-0588and concerning safety in start-up and operation of North Anna Unit 2.
July 28, 1980 Letter from applicant concerning Auxiliary Feedwater System Requirement.
July 30. 1930 Letter from Applicant concerning multiple structure ARS concern.
July 30, 1980 LLetter from applicant concerning containment pressure boundary fracture toughness requirements.
July 31, 1930 Letter to applicant (generic) concerning interim criteria for shift staffing.
August 4, 1980 Letter to applicant concerning emergency action levels of Section 4.
August 12, 1980 Representatives from VEPC0, the State of Virginia and NRC Staff meet in Bethesda, Maryland to be briefed on the planned joint emergency exercise.
August 12, 1980 Letter to applicant transmitting 20 copies of Supplement No.11 of the North Anna, Unit No. 2 Safety Evaluation Report.
August-18, 1380 Letter to app!; cant transmitting Amendment No. 2 to License NPF-7 granting an exception to Technical Specification 8.1 of Appendix A to perform a water hammer demonstration test.
.