ML19337A468
| ML19337A468 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/16/1980 |
| From: | Ahearne J, Ahearne J, Bradford P, Gilinsky V NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML19337A469 | List: |
| References | |
| REF-10CFR9.7 SECY-80-414, NUDOCS 8009290021 | |
| Download: ML19337A468 (65) | |
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COMMISSION MEETING In the Matter of:
PUBLIC MEETING DISCUSSION OF COMMISSION PROGRAM TO REVIEW OPERATING LICENSE APPLICATIONS DISCUSSION AND VOTE ON 5EQUOYAH
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DATE: September 16, 1980 PAGES: 1 - 62 AT:
Washington, D. C.
ALDetSOX REPORTING f.
400 Virginia Ave., 5.W. Washing =n, D.
C.
20024 K
Talachena: (202) 554-2245 8 009290 ogg
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1 1
UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
PUBLIC MEETING 4
5 DISCUSSION OF COMMISSION PROGRAM TO REVIEW OPERATING LICENSE APPLICATIONS 6
7 DISCUSSION AND VOTE ON SEQUOYAH 8
9 10 Nuclear Regulatory Commission 11 Boom 1130 1717 H Street, N.W.
12 Washington, D.C.
13
, Tuesday, September 16, 1980 14 The Commission met, pursuant to notice, at 10:08 a.m.
15 BEFORE:
16 JOHN A. AHEARNE, Chairman of the Commission VICTOR GILINSKY, Commissioner l'7 PETER A. BRADFORD, Commissioner JOSEPH M.
HENDRIE, Commissioner 18 NRC STAFF PRESENT:
19 SAMUEL J. CHILK, Secretary 20 LEONARD BICKWIT, General Counsel R. DENTON 21 E. CASE H. SHAPAR 22 K. CORNELL E. HANRAHAN 23 L.
RUBENSTEIN 24 25 ALDERSON REPORTING COMPANY, INC.
400 VIRGINIA AVE. S.W.. WASi INGTON. 0.C. 20024 i202) 554-2345
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CHAIRHAN AHEARNEt The Commission will come to 3 order.
4 This morning we have a number of items which we 5 return again to address.
I am not really sure how far along 6 we will get on all of them, or any of them, for that matter, 7 but let me just briafly review.
8 We have an issue on ice condenser plants, in 9 particular with respect to the Sequoyah plan t.
We had 10 addressed that on the recommendation from the Director of 11 NRR to issue an operating license on Sequoyah, and 12 Commissioner Gilinsky had concern with respect to the i
13 hydrogen control in the ice condenser plants and hydrogen 14 control in 7eneral, and there is an outstanding issue, 15 therefore, with regard to th a t element.
16 We also have an outstanding request from 1'7 Commissioner Bradford that prior to issuiag any more 18 operating licenses -- and therefore, tha t would include 19 Sequoyah -- that the Commission address a program to have 20 plants reviewed a. gainst a variety of Commission regulations, 21 requirements, et cetera.
22 Related to that is a requirement that the 23 Commission provide a status report to the Congress on its 24 program to implement what is known as the Bingham amendment, 25 which is Section 110 of the NRC's FY 81 Authorization Act.
t ALDERSON REPORTINO CCMPANY, INC.
l l
400 VIRGINIA AVE. S.W., WASHINGTON. D.C. 20024 (202)554 2345
3 1 That also, then, is an additional element that we hate to l
2 end up resolving on how we are going to go about doing that.
3 In order, I believe, for us to eventually move to 4 readdress the Sequoyah operating license issue, we have to 5 havo that issue resolved also.
6 So those are the items we have before us, and I 7 guess I would -- only because the issue came up first --
8 suggest that perhaps Commissioner Gilinsky describe for us 9 his position with respect to the Sequoyah modification of 10 its license.
11 COMMISSIONER GIIINSKY:
I would be happy to dC 12 that.
I thought on the program the items were listed in 13 reverse order.
1-4 CHAIRMAN AHEARNE:
They may well have been, but 15 would you mind addressing that?
16 COMMISSIONER GILINSKY:
I would be happy to do 17 that.
18 A week ago I circulated a memorandum suggesting a 19 way of dealing with the hydrogen control issue as an 20 alternative to what I had proposed before, which was that 21 the presenca of an effective and operational system ce,a 22 requirement for the full power license.
Wha t I propose in 23 this memorandum is a modification of let's see -- I guess 24 it is Section 2.C 22D of the license, which is titled 25 " Hydrogen Control Measures."
~
w ALDERSON RFPORTING COMPANY. INC.
400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554-2345
4 1
What I would do, in effect, is restore language 2 that was there in the first place, which would require that 3 -- let me just read it.
"By January 31, 1931, TVA shall by 4 testing and analysis show to the satisfaction of the NHC 5 staff that an interim hydrogen control system will provide 6 with reasonable assurance protection of breach of 7 containment in the event tha t a substantial quantity of 8 hydrogen is generated."
4 9
This, it seems to me, would allow tim 2 for the 10 reviews that are now under way in the staff experimental 11 programs which were described as requiring until the end of 12 November or December to ce comple ted, and wo uld, in eff ect, 13 defer the requirement on an interim hydrogen control 14 system.
It the meantir the reactor could operate at full 15 power.
16 In addition,1 would for the longer term add a 17 paragraph,. and let me read that.
"For speration of the 18 f acility beyond January 31, 1982 -- thit is a year later --
19 the Commission must confirm that an adeq1 ate hydrogen 20 control system for the plant is installed and will perform 21 its intended function in a manner which mai tains 22 containment pressure below design limits.
23 I feel that for the longer term, the system ought 24 to be re. quired to perform in such a way that there is a 25 substantial safety mar;in greater than one would accept for ALDERSON REPORTING COMPANY, INC.
400 VIRGINIA AVE. S.W.. WASHINGTCN, D.C. 20024 (202) 554-2345
5 I an interim system.
I use the term " design limits."
That 2 happens in this case
- .o be approximately 12 psi.
I am not 3 sure that that is, in fact, the right number to use, but by 4 that I mean, in ef fect, a number that does provide for the 5 substantial safety margin, and particularly in view of the 6 fact that the material that the containment is made out of 7 turns out to be stronger than was thought previously.
That 8 might be a reason for upping the design number.
9 And finally, during the interim period of 10 operation, TV A shall continue a research program on hydrogen 11 control measures and the effect of hydrogen burns on safety Il functions.
It shall submit to the NRC quarterly reports on 13 that research.
~
14 It seems to me the time scale of the longer-term 15 requirements is consistent with the times that were 16 suggested by the ACRS when we talked of several reactor l'7 years, three reactors.
The estimate is between one and two 18 years.
They all said yes, that was roughly what they 19 mean t.
At any rate, this is approximately a year and a half 20 if the optimism that has been expressed by TVA, N3R and the 21 ACBS is warranted.
22 I don't think these conditions will constrain 23 plant operation.
I don't want to hide the fact that if it 24 turns out that the op timism is not warranted, it would 25 2cnstrain operation, or at least the matter would come down ALDERSCN REPORTING CCMPANY, INC.
400 VIRGINIA AVE. S.W. WASHINGTON, D.C. 20024 (202)554-2345
6 1 for Commission consideration.
Of course, the Commission 2 could do whatever it wanted, but I think if it turns out 3 that we were too optimistic, it ought to come back hore to 4 the table.
5 Anyway, that is a proposal which I recommend to 6 rou. I feel it is reasonable and accommodating, and I feel --
7 CHAIRMAN AHEARNE:
Your second item, the adequate 8 hydrogen con trol system, you have something different or 9 extended, or could it be just more analysis of the system?
10 COMMISSIONER GIIINSKY:
It migh t be.
I will tell 11 you what I have in the back of my mind.
Basically, the way 12 we approach the HARK I plans, we accepted a certain reduced 13 margin of safety for an interim period, but for the longer l# term, we required a more substantial margin of safety, and 15 it strikes se as a regional approach.
16 CHAIRMAN AHEARNE:
So that --
17 COMMISSIONER GIIINSKY:
It might be confirming 18 that what was an Iterim system is in fact an adequate 19 syst em.
It might mean that an interim system has to be 20 beef ed up or modified in some way, or it conceivably might 21 mean an altered system.
21 CHAIRMAN AHEARNE:
The finding you are asking for j
23 in the first one, in A,
is the' igniter system provides 24 reasonable assurance of protection against breech of 25 containm=nt in the event a substantial quantity of hydrogen ALDERSON REPORTING COMPANY. INC.
400 VIRGINIA AVE S.W., WASHINGTON. D.C. 20024 (202)554 2345
7 1 is generated.
I am not sure what beyond that you had in 2 mind beyond the reasonable assurance tha t protection be 3 provided.
4 C3HMISSIONER GILINSKY:
Well, I think de ought to 1
5.be' aiming for a hi;har standard for the longer term for a 6 system that will operate for many, many years than ve would 7 aim for necessarily in the short run.
Now, if one can j
8 achieve that standard in the short run, then fine.
That may 9 in the end turn out to be what we accept for the long run.
10 But what I am saying is I, for one, would accept a lesser 11 standard of performance for the short-run interim operation.
12 CHAIRMAN AHEARNE:
But at least in your view, you 13 would require that the igniter system be shown to be an 14 improvement, or else by January 31 you would like to review 15 the license.
16 COMMISSIONER GILINSKY By reasonable assurance, I l'7 try to use words -- and if you can find better words, I 18 would be happy to consider them, but my point is simply that 19 clearly the system is not going to deal with every 20 contingency. There are going to be situations that one can 2T dream up that this system cannot deal with.
What I am 22 saying is that after analyzing the system, I do f eel that it 23 deals with a large part of the problem.
24 CHAIRHAN AHEARNE:
I guess the thrust of my 25 question, though, was the ACRS recommendation had not, as l
ALDERSON REPCRTING COMPANY. INC.
400 VIRGINIA AVE. S.W.. WASHINGTON. D.C. 20024 (202)554-2345
a 1
1 you correctly pointed out -- they had tied several reactor 1
2 years to addressing a solution to this.
I did no t get the 3 flavor from them that they felt the igniter system had to 4
prove out in the next couple of months'.
5 COM$ISSIONTR GILINSKY:
Ihe near-term aspect of 6 this goes beyond unat the ACRS is talking about.
Ihe longer
)
7 term, I think, is consistent with what the ACRS was talking 8 about.
9 CHAIRMAN AHEARNE:
Anyone else have any quertions 10 about Victor's proposal?
11 COMMISSIONER HENDRIE:
I don't have any question.
12 I have a comment.
13 CH AIRMAN AHEARNE:
All righ t.
14 COMMISSIONER GILINSKY
'I had better steady myself 15 here.
16 (Laughter.)
l'7 COMMISSIONER HENDRIE:
Vic, if you contend that 18 the thrust of Part A of your proposal be that the igniter 19 system be shown to be,a worthwhile addition to the 20 protective array of the plant rather than in itself a cure 21 for hydrogen in toto, I am not sure that the langrace quite 22 gets you there.
After all, we talk about reasonable 23 assurance and then go through Appendix K and all the modeJ s 24 in an extremely conservative way for ECCS performance just 25 to ' achieve that, and I do not think we are at the same sort 4
ALDERSON REPORTING COMPANY, INC.
400 VIRGINIA AVE S.W., WASHINGTON. O.C. 20024 (202)554-2345
9 1 of level here.
2 So that the words " reasonable assurance" put you 3 into the standard, highly conservative practice of the 4 safety review because it is a term of -- rather than 5 allowing tha flexibility which your remarks seem to imply 6 you had in mind.
7 The staff language, which was slightly different, 8 was not that great either, but au least it did seem to me to 9 be a little bit more fle xible.
Their language was "will 10 function in a manner that will mitiga te the risk that could 11 stem from the generation of hydrogen."
l 12 I suppose that one could then argue whether ther 13 me t all of the risk or most of the risk or some of the risk.
14 COMMISSIONER OILINSKY:
What bothered me about was 15 ' mitigate" in effect means make better.
Of course,, the 16 question is is that 1 percent or 75 percent.
I thought by I'7 using the words " interim system," that in effect keys it to 18 past practice in dealing with interm approaches and 19 introduces the flexibility that I think the near-term 20 finding ought to allow for.
21 COMMISSIONER HENDRIE:
Part of the comment on your 22 proposal here is tha t we are in the process of dealing with 23 the hydrogen question and the broader core damage question 24 for all plants.
I must see I don't see any particular 2S reason to tie this license up so that it has to be brought ALDERSON REPORTING CCMP"NY, INC.
400 VIRGINIA AVE. S.W.. WASHINGTON. D.C. 20024 (202)554-2345
10 1 back to the table on the 31st of January, 1982 in the event 2 all of that is not in place.
3 All I can see that leading to -- if the general 4 solution is in place before that date, that is fine.
In 1
5 that case there was no need to have put this provision in 6 the license.
If the general solution is not in place by j
7 January
'32, why, this license and several others in which 8 the provision might appear will have to come back to the 9 table.
10 We will by that ti m e, I trust, be making 11 reasonable progress on the general solut:, in and we will have 12 to go through the exercise of pulling this provision out of 13 the license. So I would just start out by not putting it in.
14 COMMISSIONER GILINSKY:
Ihese plants do have --
15 COMMISSIONER HENDRIE.
And I would say that John's 16 counter-language to yours is much more reasonable and to th e l'7 point.
18 COMMISSIONER GILINSKY:
Well, the general solution 19 deals -- I gather you are talking about how we are going to 20 deal with the possibility of substantial core danage in all 21 plants.
That is something that is a pretty knotty issue and 22 it is going to take us many years to deal with.
These 23 plants happen to have a very special problem which I feel 24 needs to be dealt with before we get on to this general 25 solution, as you say.
ALDERSON REPORTING COMPANY. INC.
400 VIRGINIA AVE. S.W., WASHINGTON. D.C. 20024 (202!554-2345
1 11 1
COMMISSIONER HENDRIE:
I think we will know a good 2 deal more about this particular class of plant in the next 3 year, and if we feel a need for some further interim 4 measures, we can always take them with the plants as a 5 class.
~
6 I must say I have some reluctance to pick hydrogen 7 out and run ahead -
you know, getting too far ahead of an 8 understanding of the overall safety approach that one wants 9 to take for this more severe range of accident, by just i
10 picking out a particular f acet of that accident array and 11 saying we will cure that facet.
12 Now, that may or may not turn out to lead to 13 measures which are ef fective and coordinated and, indeed, 14 compatiLI < with measures that one might want for mitigation 15 of severe core damage.
I would like to know where -- you 16 know, one would like to see the overall pattern of safety l'7 attacked before one gets too far out on this limb.
18 COMMISSIONER GILINSKY:
The way I look at it, this 19 would bring these plants up to where the others are, and 20 then we can rtudy the grant question of degraded core.
21 CHAIRMAN AHEARNE:
When you say these plan ts, 22 would you put this as a condition into both of them?
23 COMMISSIONER GIIINSKY:
I would, yes.
24 CHAIRMAN AHEARNEt Any other comments?
Peter?
3 COMMISIONER BRADFORD:
No.
I think I would ask ALDERSON REPORTING COMPANY. INC.
400 VIRGINIA AVE. S.W., WASMNGTCN. 0.C. 20024 (202) 554-2345
12 1 the question you just did.
I think I do see a pattern of 2 sorts here. That is, we try to adjust for things that have 3 already happened.
There are aspects, obviously, the 4 degraded core rulezaking, that have not occurred yet, but we 5 have now decided to take them into account.
6 To me, hydrogen is more like a number of other 7 changes we have made in plant licensing as a result of the 8 Three Mile Island accident.
Improved operator training.
We 9 have new requirements as to instrumentation.
We are on the 10 vay to other changes and have sort of partial changes and 1T interim changes.
12 I would not license a plant that I did not f eel --
13 we had some reasonable assurance that it could cope with it.
14 CHAIRMAN AHEARNE:
I am not sure I understand, 15 though, where that ends up leaving you.
16 COMMISSIONER 3RADFORD:
It leaves me supporting 17 Victor's proposal.
18 CHAIRMAN AHEARNE:
All ri gh t.
Well, let us see, 19 then.
We could spend, I think, some parliamentary time 20 jockying around on what is in front of us and who votes on 21 what so that makes the record and so forth.
But that arcane 22 artistry is not one I pref er to practice, so let's just see 23 whether or not I think I understand what the vote is on 24 it, but Victor has a proposal. I gather Peter and Victor are 25 in favor of his.
I am in favor of mine.
ALLERSON REPOfiT;NG COMPANY. !NC.
400 VIRJINTA AVE, S.W., WASHINGTON. D.C. 20024 (202)554-2345
13 1
Joe?
2 COMMISSIONER HENDRIE:
I would go with yours.
I 3 would just as soon have -- I don't see a need for such 4 proficiency in this license, but I will go with yours.
5 CHAIRMAN AHEARNE:
That would leave us 2 to 2 6 split on being able to put in either.
There was an 7 alternative, which was Harold's original.
Are there any 8 votes for Harold 's original?
9 COMMISSIONER BRADFORD:
What is Harold's original?
10 CHAIR 3AN AHEARNE:
You don't happen to have a copy 11 with you?
Il COEMISSIONER GIIINSKY:
As I said, there was a 13 specific reason why I did not simply want to use the word i
14 " mitigate" because it was no t clear whether that mean help 15 by 1 percent or help by 10 percent or help by 50 percent.
I 16 think the sense of it was that it would do some substantial 17 good, but that is not what the words as drafted make clear, 18 and that is the reason why I changed them to the ones I have 19 in Paragraph A.
20 I also believe the other parts are important, that 21 we do need to revisit the issue, we do need to have a better 22 system or at least confirm that a good systao is in place 23 for the younger run. So I would stick with what I have here.
24 COMMISSIONER BRADFORD:
Do we know whether the 25 appif ; ant objects to the condition as Victor proposed it?
ALCERSON REPORTING COMPANY. INC.
400 VIRGINtA AVE. S.W., WASHINGTCN. D.C. 20024 (202)554-2345
in 1
CHAIRMAN AHEARNE4 I, at least for myself -- that 2 really was not rel3vant.
3 COMMISSIONER BBADFORD:
Nonetheless --
4 CHAIBMAN AHEARNE:
What I was trying to do was i
5 decide what I thought was the logical step to be taken.
I 6 was trying to understand where we were as far as our 7 technical understanding and knowledge of the issues, and 8 that is where I came out on that basis.
Whether or not ther 9 enthusiastically endorse the other approach or disagree with 10 it, that just was not relevant.
11 What Harold had proposed is, pending further 12 action which may be required as a re uit of rulemaking, no 13 later than January 31, 1981, TVA shall by testing and 14 analysis show to the NRC's satisfaction the interim 15 distributed ignition system will function in a manner that 16 will mitigate the risk which could stem from generation of 17 hydrogen.
18 I would suqqest that since that is what neither 19 Victor has proposed nor I proposed, it could be used for a 20 compromise.
21 C05MISSIONER GIIINSKYs This is a compromise from 22 where we were beforehand.
It is like if you go halfway, 23 three quarters of the way well, I would stick with this.
24 COMMISSIONER BRADFORD:
I would still ask whether 25 there have been discussions with TV A about Commissioner ALCERSON REPORTING COMPANY. INC.
400 VIRGINIA AVE. S.W.. WASHINGTCN. D.C. 20024 (202) 554-2245
15 1 Gilinsky's proposal, and do they find it something that they 2 cannot comply with?
3 MR. DENTON:
I am not sure we have TVA's formal 4 opinion on these.
Let se ask if any members of the staff 5 here know the answer to that question.
6 MR. RUBENSTEIN I have had informal --
7 CHAIRMAN AHEARNE:
Could you use a microphone and 8 identify yourself for the transcript?
9 MR. HUBENSTEIN Lester Rubenstein.
I have had 10 informal conversation with TVA regarding the A,
D and C 11 conditions, and, of course, TVA is here and can speak for 12 themselves. They are most concerned about our condition B, 13 and an interpretation of the design pressure as language 14 which was f airly restrictive in terms of getting the 15 appropriate safety ma rgins.
16 I believe the staff has looked at it and that Jim 1:7 Knight is prepared to talk to that point.
18 COMMISSIONER GILINSKY:
As I said earlier, I would 19 be happy to changa that to a pressure which still allows for 20 a substantial safety margin, words like that.
21 MR. RUBENSTEIN:
Along those terms, then I think 22 the languaga is reasonable and acceptable to TVA, as they 23 informally indicated to me.
24 CHAIRMAN AHEARNE:
Peter, did you want to ask a 25 further question on that?
ALDERSON REPORTING COMPANY. INC.
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16 1
COHHISSIONER BRADFORD No.
No.
The language as 2 modified makes sense to me, and I guess I am reinforced in 3 that by my sense that the applicant itself does not feel 4 that they cannot compir with it.
So I would be inclined to 5 adhere to it.
6 NR. DENTON:
I would inject a note of caution on 7 what the applicant's views are.
I am not sure we have 8 form ally asked them, as les said.
9 COMMISSIONER BRADFORD:
I was not asking for their 10 endorsement or non-endorsement.
I would have been 11 interested if their position was that they could not 12 possibly comply with it, and I gather that is not the case.
13 HR. DENTON:
I think, you know, they have been 1<4 exhibiting a desire to comply with most of any of our 15 requirements in general, but they perhaps have not focused 16 on the specifics.
17 CHAIREAN AHEARNE:
let me ask each of you a 18 different question.
Victor, if we accept your version with 19 that modification to the last, do you have any other 20 outstanding objections to the Sequoyah license?
21 COMMISSIONER GILINSKY We have agreed to deal 22 with Peter's concerns.
I think we ought to turn it over to 23 him.-
I am not asking you to vote on the license.
I am just 24 trying to clarify.
With the Sequoyah license per se, do you 3 have any other objections?
ALDERSON REPCRTING COMPANY, INC.
400 VIRGINIA AVE. S.W.. WASHINGTCN. 3.C. 20024 f 202) 554-2345
17 1
COMMISSIONER GILINSKYs Do you nean safety issues 2 or questions of that sort?
3 CHAIRMAN AHEARNE:
That is right.
If we accept 4 your modified version, and assuming we resolve Peter's 5 issue, would you be favorably inclined?
6 COMMISSIONER GILINSKYa I would vote for the 7 license on those terms.
8 CHAIRMAN AHEARNE:
And Peter?
9 COMMISSIONER BRADFORDs Same answer.
10 CHAIRMAN AHEARNE:
I think we have a situation, at 11 least what I find myself in is that the scientific knowledge 12 we have in front of us, at least recommended both by our 13 staff and by the Advisory Committee we have, does not lead 14 us to imposing these license conditions.
Th'at was the 15 primary rationale, I think, that the Commission ought to use 16 in imposing license conditions.
17 Unfortunately, I think we are ending up finding 18 that a large group of people in a service area of TVA will 19 thereby be denied the use of this facility, and I don't 20 think it is really relevant whether TVA objects to the 21 conditions or not.
The Co m m ission, I assume, tries to apply 22 conditions based upon what it thinks is right.
23 I feel at least an obligation to meet some other 24 responsibilities, one of which is to try to have the 25 Commission address issues when they come before us. So I ALDERSON REPORTING CCMPANY. INC.
400 VIRGINIA AVE. S.W., WASHINGTON. D.C. 20024 (202) 554-2345
18 1 vill reluctantly accept the modified amendment with the
,2 modification of design pressure that Victor proposed.
3 COMEISSIONER HENDRIE:
I recommend against B.
I 4 think all the analyses which you have show that if you try 5 to keep that below design pressure and so on, you simply are 6 not going to make it.
You can take it up through design 7 pressure. What you are going to do is to say,in January of 8 1982, good, tear out the igniter system and inert the 9 containment.
10 There does not seem to be a responsible way to 11 deal with the license. We are at var with the issues.
12 COMMISSIONER GILINSKY:
I did not suggest a 13 change, and I would be happy to ask you, to obtain the
~
14 alternate lanquage from ycu.
I just scribbled this hastily:
15 "In a manner which maintains containment pressures at levels 16 that allow for substantial safety margins."
What I have in l'7 mind is the kind of margin we normally expect in a 18 containment, something on the order of a factor of 2.
19 COMMISSIONER HENDRIE:
For how much hydrogen?
20 COMMISSIONER GILINSKI:
For amounts roughly 21 comparable to what was generated at TMI.
22 COMMISSIONER HENDRIE:
I don't think you are going 23 to g e t it.
If you are going to shut the plant down in 24 January of
'82, you may as well not license it.
25 COMMISSIONER GILINSKY That does not seem to be ALDERSCN REPORTING COMPANY, INC.
400 VIRGIN!A AVE, S.W., WASHINGTON, D.C. 20024 (202)554-2345
19 1,-- at least as I understand it the view of the people who 2 have been doing the analyses, at least the tentative 3 analyses.
4
- 58. DENTON:
I think it depends on the wording.
5 COMHISSIONER HENDRIE:
If you talk about 6 substantial safety margins, the staff is going to come back 7 with a safety factor of 3 on th e yield pressure.
Now you 8 are back down from a 45 pound gauge to 15.
9 COMMISSIONER GILINSKY:
Shall we write in a factor 10 of 2 ?
11 COMMISSIONER HENDRIEa I recommend if you have to 12 have this language, I would recommend you say "as installed 13 will perform its intended function in a manner that provides 14 appropriate or reasonable safety margins" or something like 15 that.
I can't tell what all the conditions are going to be 16 u p the line, and I think it is already pretty clear that for 17 ice condenser plants that are already constructed, unless 18 the Commission contemplates rebuilding th em in toto or not 19 allowing them to operate, that there is going to have to be 20 an element of grandf athering.
21 COMMISSIONER GILINSKY:
There is an element of 22 grandf athering in all of this.
- 4e would not be doing all of 23 this or approving this arrangement if we were starting all 24 over again. So there is a substantial amount of 25 grandfathering here already.
ALDERSON REPORTING COMPANY, INC.
400 VIRGINIA AVE. S.W., WASHINGTON, D.C. 20024 (202)554-2345
20 1
Now, if what you interpret a reasonable safety 2 margin to be is roughly a factor of 2, then that sounds 3 perfectly fine to me. I mean that is basically what we 4 require elsewhere.
5 CHAIRMAN AHEARNE:
I think the best --
6 COMMISSIONER HENDRIES It is what turns out to be 7 the case.
8 CHAIRMAN AHEARNE:
I think the best we will get is 9 to say a reasonable safety margin.
There is going to have 10 to be a lot of analysis done between now and a year from 11 now.
That is about all I think we can get.
There has been 12 a lo t of understanding.in the last three or six months with 13 regard to this type of containment.
A lot more will come in 1<4 the future.
15 COMMISSIONER GILINSKY:
We can put down 16 " reasonable safety margin."
17 COMMISSIONER BRADFORD: Let's put down " adequate 18 safety margins."
19 COMMISSIONER GILINSKY:
That is even better.
20 COMMISSIONER BRADFORD:
We have gotten out of 21 whatever it was before that.
22 CHAIRMAN AHEABNE:
Adequate safety margin.
23 C3MMISSIONER HENDRIE:
That allows you to look at 24 something besides system pressure, the amount of hydrogen 25 you are requiring to be calculated.
If you are going to sa y ALDERSON REDORTING COMP ANY, INC.
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21 1 75 percent 2
COMMISSIONER GILINSKY:
I put down design limits 3 because it was the one pressure that had a name to it.
4 Let's put down adequate c'fety margins.
5 CHAIRMAN AHEARNE:
All right.
6 COMMISSIONER HENDRIE:
And from your discussion 7 previously, we understand the way you interpret "will 8 provide with reasonable assurance protection against breech 9 of containment," you do not expect us to cover every 75 10 percent hydrogen in all circumstances.
That is not what 11 your intent is.
12 COMMISSIONER GILINSKY:
No.
13 COMhISSIONER HENDRIE:
All right.
I advise 14 against it. But 15 CHAIRMAN AHEARNE:
Well, it passes.
16 COMMISSIONER HENDRIE The Secreta ry wild note 17 : hat I vote for the license but against A, B and C of this 18 proposal.
i9 CHAIRMAN AHEARNE:
Okay.
All right.
Assuming we 20 can now satisf actorily address Peter's concerns -- neither 21 of you have any remaining issues with regard to the approval 22 of the Sequoyah license, is that correct?
23 COMMISSIONER GILINSKY:
That is right, but I do 24 vant to add that I have a remaining concern, which I will 25 not tie to the license itself, about TVA testimony before ALDERSON REPORTING COMPANY. INC.
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I 22 1 the ACRS concerning the tests that they are going to 2 concern.
But I will not raise that in connection with this 3 license.
4 CHAIRMAN AHEARNE:
Peter, is that correct?
5 COMMISSIONER BRADFORD.
Same answer.
Yes.
6 CHAIRMAN AHEARNE:
Let us move on to a variety of 7 issues which relate to the Bingham amendment and so forth. I 8 was having great difficulty following through all these 9 grea t varieties of plans, et cetera.
Commissioner Gilinsky 10 was, also.
He has attempted to have a summary made, but I 11 think I heard Peter say that that was an incorrect summary.
12 COMMISSIONER BRADFORD.
I am not sure that the 13 summary as a whole is wrong. I have not had a chance, 14 re ally,. t o go through it.
There was a particular sentence 15 in it that I do not think is accurate, although the staff 16 would know better, and that is the first sentence of the 17 second paragraph. I don't know if the staff even has the --
18 CHAIRMAN AHEARNE:
Perhaps, Harold, could you walk 19 us through -- I suppose you might as well use this if you 20 find this convenient - walk us through your proposed plan, 21 and I guess the way you entitled it, Program to Revise --
21 Commissioner Gilinsky's -- NRR Plan to Require Licensees and 23 Applicants Document Deviaticas from Current Sa f eg ua rd s 24 Requirements.
25 HR. DENTON:
I took a look at this.
It very much ALDERSON REPOrtTING CCMPAN'. INC.
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I 23 1 represents what I originally proposed, and I am concerned --
2 C05HISSIONER.GILINSKY This is not any sort of 3 proposal on my part. It is my effort to 4
MR. DENTON4 I understand that, yes.
5 COEMISSIONEH GILINSKYs If you are doing it and it 6 is wrong, it is something that can be corrected.
7 HR. DENTONs Let me back off from this a little 8 bit.
CRAIRHAN AHEARNE:
I just received a request for 10 clarification.
The question is have we voted on the 11 Sequoyah license?
The answer is no, we have not.
We 12 clarified one set of concerns and we are now moving to the 13 second set of concerns that relate to a requirement of 14 Commissioner Bradford's prior to his willingness to address 15 the Sequoyah license.
So we have not yet addressed the 16 Sequoyah license.
I'7 Excuse me.
18 MR. DENTONS Let me give a little background.
We 19 have committed to revising the Standard Review Plan to 20 assure a much better congruence with the regulations, and we 21 have set that in motion inside the staff, and we are having 22 each branch identify in tabular form whether or not all 23 areas within their responsibility are covered.
We are going 24 to make sure that every regulation is covered appropriately 25 by some Standard Review Plan.
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24 1
So we have some 240 Standard Review Plans. I 2 expect this exercise to result in the modifications to the 3 existing Standard Review Plans and the acceptance criteria 4 and the evaluation of findings, and possibly the addition of 5 new Standard Review Plans if it turns out necessary to cover 6 gaps or areas that were not covered before. So that is in 7 progress.
8 Secondly, we were looking at Of fice letter Number 99, which said we will document deviations from the Standard 10 Review Plan. But that office letter put the burden on the 11 staf f to document the devia tions.
That is a burden I think 12 is sisplaced.
I think it should be, in the first instance, 13 required tha t the licensees document deviations from a 14 standard review plan.
15 So we asked ourselves when could we have the 16 standard review pisns revised so that someone would have a 17 document to look at to know how to document deviations.
And 18 we have estimated that it would take us about six months to i
19 prepare these documents.
So around April 1st, w'asn't it, 20 Ed, before we could have revised standard review plans that 21 had the --
22 C35HISSIONER GILINSKY When you say plans, is 23 t h at one for each reactor?
24 MR. DENTONs The plans are what we -- procedures 25 that we provide to the technical reviewers of the staff, and ALDERSON REPORTING COMPANY, INC.
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i 1 they use these in reviewing any application.
2 CHAIRMAN AHEARNE:
Each little section is called a 3 standard review plan.
4 NR. DENTON:
Hydrologists use their procedures, 5 and it is called a plan, but it is a review plan for each 6 technical specialty.
7 MR. CASES There are some 240 individual plans 8 that make this up.
9 COMMISSIONER GILINSKY:
You couldn't call them 10 subplans.
11 MR. DENTONs It is the basis for the review and 12 tells the individual reviewers how to approtch the subject, 13 what codes to use and what standards to apply, and what 14 findings to make.
So we could have that by April 1st.
15 CHAIRMAN AHEARNE:
Harold, is it correct that that 16 does not overly stretch your current resources?
1'7 ER. DENTON:
That is right.
18 CHAIRMAN AHEARNE:
That aspect you see yourself 19 being able to do with the current resources that you exp1ct.
20 MR. DENTON:
That is correct.
This could b9 done 21 within the branch by the branch chief. It is part of their 22 normal ef fort and would not require in the sense of a lot of 23 review by the staff, so I would ask for no additional 24 resources.
25 CHAIRMAN AHEARNE:
To do that, we don't at the ALDERSoN REPORTING COMPANY, INC.
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26 I same time, then, have to go to 03B or the Congress and say 2 we need 3
MR. DENTON:
Not at all.
We would absorb that in 4 revising our plans.
Then the manpower-intensive part is 5 reviewing applications using that plan and documenting and 6 writing justifications for deviations from that plan. At the 7 acaent we do not provide in our safety evaluation reports 8 bases for deviations from those plans.
We describe the 9 licensee's design, find it acceptable, but we do not have a 10 listing for each one of these 240 plans, whether they are 11 met, and of course the present set does not have the exact 12 congruence with the regulations.
13 So then I asked when could we begin to review 14 applications using -- when could we begin to produce safety 15 evaluation reports using this new stack of procedures for 16 review.
Well, you would have to allow a little time in the 17 system for reviewers to start doing it this way, questions 18 to applicants, answers back and reviews.
So I don't think 19 we could produce until the en'd of the year new safety 20 evaluation reports that had a chapter that described 21 deviations f rom the revised stadard review plan.
22 So we thought it would be the end of next year 23 bef ore we could begin to produce safety evaluation reports 24 that would have a specific description of how these 25 applications comply with the revised standard review plans t
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27 1 and document all tne deviations and ressons for it if there 2 are any suct. deviations.
3 So that was really my bounding case, that by the 4 end of next year, in any new applications we were reviewing 5 we could begin to document.
Likewise we could send that 6 plan out to all plants that had operating licenses, and we 7 could get them to describe f or us how well they complied 8 with the plan.
And the plan when it is revised will be the 9 current interpretation of the Commission's regulations.
10 So we would send that out to all operating plants 11 and they would eventually in some staggered manner, I hope, 12 reply, and we would review their answers for all operating 13 plants to see if there are any hot coals, areas where we are 14 really concerned about the deviation.
We would act on those 15 right away.
Otharvise, we would have to plan a resource 16 effort to go through all of these operating plants and see 17 if the differences are reasonably justified.
18 That left in the middle the plants which are 19 coming through right now.
So we have plants that are about 20 to go to hearing or come to you which are SERs or the review 21 is complete. So if you wanted to review those against the 22 revised SER, our standard review plans, we won't have those 23 until af ter April.
And I really could not get it in that 24 mold until the end of next year.
25 Sc in trying to get as far into this system as I ALDERSON REPORTING COMPANY, INC.
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28 1 could, I proposed tha t all SEBs that we issued after April 2 1, that we start documenting deviations and differences from 3 the existing standard review plans. Tha t picks up some 4 plants between April and the end of the year.
5 Actually, it would oe much cleaner if we do not 6 put in that interia step of documenting deviations from 7 existing standard review plans and just wait so that all 8 safety evalulatians produced after the end of next year have 9 it in there.
10 I think when we threw in this April 1 deadline, 11 that caused some concern about where the plants were.
But 12~ the concern is plants in the middle.
All the plants are in 13 operation that we are going to document deviations from the 14 standard review plans.- All future plants af ter some date 15 will document deviations from the revised standard reviev
'16 plan.
17 Then it depends on how fine we want to cut it.
If 18 you cut it too fine, we will not be able to produce them on 19 the previo'us schedules.
20 CHAIRMAN AHEARNE:
All righ t.
21 Now, I gather from your comment that you are not 22 sure of the utility of requiring th a t interim comparison 23 against the existing 24 MR. DENTON:
That is correct, because it will have 25 to be redone even on t h o's e plants, even when we apply the ALDERSON REPORTING COMPANY. INC.
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29 1 existing standard review plans for plants between, say, 2 April and the end of next year.
We will still have to go 3 back to them with the revised standard review plan to see 4 what additional areas -- tha t is recycling twice, this 5 area.
And I do not think that for these plants which are 6 currently under review, we will pick up that much in saf ety 7 for the cost.
8 COMMISSIGNER GILINSKY:
You are talking about 9 Group 3s.
10 CHAIRMAN AHEARNE:
That is right.
11 MR. DENTON:
Yes. Yes.
So I would tend t go ahead 12 and treat Group 3 like Group 2, so that, in essence, Groups 13 1, 2 and 3 become operating plants and they would all 14 eventually, in a staggered review, demonstrate their 15 deviations from the revised standard revi_ew plan.
Group 3, 16 if you wanted to begin it a little bit earlier, we could on l'7 those safety evaluations use today's standard review plan.
18 But when you look at our process and the review is 19 in action, some of these reviews have been done in the 20 laboratories.
They do not document deviations.
21 COMMISSIONER HENDRIS:
I know where at least one 22 of those reviews is, and it seems to me it is pretty far 23 alon g.
24 MR. DENION:
That is right.
So I as really not 25 advocating doing that.
I was trying to respond to the need ALCERSON F.EPORTING CCMPANY. INC.
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e 30 1 to sove a= quickly as possible, and that is an, alternative.
2 CHAIRMAN AHEARNE4 At least from my understanding, 3 would you work through this set in addressing plants that 4 already have operatinag licenses?
The Bingham amendment 5 explicitly applies to that.
Are you proposing to go to them 6 twice with a requirement based on the Bingham amendment and 7 then an additional requirement, or are you proposing to go 8 to them once and the Bingham amendment will then be subsumed 9 in that?
10 MR. DENTON:
The latter, only once.
11 CHAIR 5AN AHEARNEs The request will be once the 12 revised SRP is developed, to then go to them with that 12 request.
14 HR. DENTON:
Yes.
15 CHAIRMAN AHEARNEs And as I recall from th e l
16 Bingham amendment, if we agree with that approach we will be l'7 required -- we first have to notify the Congress of the 18 status of our implementation, but we also have to go out for 19 public comment on that approach, is that correct?
20 MR. DENTON:
Yes.
Now, one reason I have subsumed 21 Bingham into that approach is that Bingham only requires 22 that we do this for regulations of particular safety 23 significance. But that is very hard to cut those out v: the 24 knowing about the plant in detail.
So I would have the 25 utility do the first cut to document all the differences, ALDERSON REPORTING COMPANY, INC.
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31 1
and then in our review of that, we would pay attention to 2 those of particular safety significance.
3 CHAIRMAN AHEARNEs Where it says Group 1 operating 4 plants 1 and 2, it would be one step, is that correct?
5 MR. DENTONs That is just one step, and it would 6 consist of sending them the revised standard review plan and 7 asking them to document deviations from that.
And probably 8
9 CHAIRMAN AHEARNEs And you say j t's tif y 10 HR. DENTON:
Justify the differences, if any, 11 between their design and operation p ractices.
12 CHAIRMAN AHEARNE:
And we would review that, the 13 significanca of the deviation, and our justification.
14 3R. DENTON:
I would propose a two-step review 15 processs a quick revi,ew upon the arrival to find out if 16 there are areas that really concern us that we should act l'7 upon immediately, and then a longer-term review with the 18 proper amount of resources over some longer time frame.
19 Now, I would like to stagger these reviews coming 20 in.
I envision that our plan to get answers back is that we 21 would not require all licensees to respond by the same 22 date.
I think we create problems for ourselves and 23 industry. We are unable to review everything, and we get 70 24 or 80 documents in on the same day and we would base it on 25 the older plants or the high population plants.
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CHAIRMAN AHEARNE4 We give everybody this deadline 2 and then our review process stretches out longer.
3 MR. DENTON:
I would try to make a more rational 4 staggering to mesh our resources as we could use them.
5 CHAIRMAN AHEARNE:
Now, your recommendation is 6 Group 2 and 3 plants are differentiated from Group u how?
7 MR. CASES By the date of the SER.
8 COMMISSIONER HENDRIE:
By time.
9 MR. DENTON :
Time.
Group 2 are ones which I would 10 propose to issue without documenting deviations because the 11 reviews of these have been ongoing for years and it is 12 essentially complete.
We may have issued at least one or 13 mora supplements of SERs in that.
14 CHAIRMAN AHEARNEs Your recommendation would be to 15 treat those as current operating plants.
16 MR. DENTON:
Current operating plants.
17 CHAIRMAN AHEARNE:
There a comparison with the 18 respect to the revised SRP would be on the same basis as the 19 operating license.
20 ER. DENTON:
That's right.
21 MR. CASE:
Even though not required by the Bingham 22 amendment.
23 MB. DENTONs We have incorporated them, in 24 essence, into Group 1.
They would all compare to the 25 revised.
l t
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COMMISSIONER BRADFORD:
Let's see, Harold.
That 2 is your proposal as of today.
It modifies somewhat the 3 proposal advanced --
4 MR. DENTON:
It is the same for Group 2.
Group 2 i
5 were ones where the review is so f ar along it has alreeiy 6 been issued.
You recall tha t we have cases f or SERS in l
7 adjudication way in advance of the operation of the plant.
j 8
COMMISSIONER BRADFORD:
Group 2 and 3 are 9 essentially a split of your old category of intermediate 10 operating license.
11 MR. DENTON:
Yes.
And then I had diccussed the 12 possibility of this Group 3 being ones that are later in 13 time, where we would have an opportunity to perhaps document 14 deviations from existing sta,ndard review plans.
But I will 15 not have the revised standard review plan in hand until 16 Aprill, so I could not produce the safety evaluations on j
l'7 scaadule using the revised standard review plan.
18 CHAIRMAN AHEARNE:
Your recommendation would be to l
19 collapse 3 into 2.
l 20 MR. DENTON:
Avoid tat intermediate step of 21 documenting deviations from existing standard review plans 22 because that is only a partial step.
It taxes my resources i
23 to do that and still meet the schedules that are required 24 f o r this.
3 MR. CASE: That is different.
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MR. DENTONs I would say all SERs issued after the 2 end of next year would have this documentation of deviations 3 from the revised standard review plan.
I do not get the 4 standard --
5 CHAIRMAN AHEARNE:
That is Group 4?
6 MR. CASES No, he is still --
7 MR. DENTON:
Yes, that is Group 4 8
CHAIRMAN AHEARNEs And that SER issuance date is --
9 MR. CASES 1/1/82.
10 MR. DENTON:
I could put in the hands of my 11 reviewer, then, on April 1 the new revised standard review 12 plan, and they could begin then to apply tha t to plants such 13 as in Group 4 because their production dates would be at 14 last eight months away.
COMMISSIONER BRADFORD:
Some of the plants in 15 16 Group 2 are, in fact, plants which were to have been 17 reviewed against the existing standard review plan.
18 MR. CASES By the staff.
19 MR. DENTON:
By the staff, yes. And I think it was 20 th a t "by the staff" that really prevented us from knowing 21 quite how to proceed, and then we had to find the deviations.
22 COMMISSIONER BRADFORD:
That is the problem we 23 talked about last time.
24 MR. DENTONs So what I would do come April is send 25 all these Group 4 plants the revised standard review plan O
e ALDERSON REPORTING COMPANY, INC.
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35 1 and ask them to document promptly the differences, and that 2 would become a part of our normal review for all of those.
3 And they would -- our SERs for all the Group a plants.
THey 4 are all not due in December of 1982.
They a re due at 5 staggered intervals.
6 I would also send that same standard review plan 7 to all the plants then in operation, which would include 8 Groups 1,
2 and 3, and treat them all as operating plants 9 and have some staggered response from them.
10 I really think the Groups 2 and 3 and the use of 11 the interim move is not manpower-efficient using the 12 existing standard review plan.
It will leave open the 13 question -- I can see we would issue a document in June 14 using the existing standard review plan, but we would 15 already have per; Jed the revised standard review plan, and 18 you are just opening yourself up.
~4hy don't you redo it l'7 using the ravised standard review plan, and yo - have to 18 recycle ir all the way through the review process.
19 CHAIRMAN AHEARNE:
If I could first focus the 20 a ttention, then, on this section before moving to cps, so 21 you would then see this would now treat all plants at the CP 22 stag e.
23 MR. DENTON:
Yes.
24 CHAIRMAN AHEARNEs You have swept up all the 25 plants in this block, those under construction and currently ALCERSON REPORTING COMPANY, INC.
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36 1 operating. The Bingham amendment requires -- there is no 2 date by which this has to be completed, so that it would 3 you are starting the revised SRP independent of any time.
4.So we would have an opportunity to go out for public comment 5 and get revision, if necessary, completed before you~would 6 have the revised SRP.
7 MR. DENTONs That is right.
8 MR. CASES Yes.
9 CHAIRMAN AHEABNE:
Vic, do you have any questions 10 on operating plants regarding Harold's suggestion?
Joe?
11 COMNISSIONER HENDRIE:
If you are going to go in 12 this direction, I certainly recommend that those plants in 13 Group 3 be moved up into Group 2.
Otherwise, what you will 14 do is end up throwing in six months to a year delay on those 15 operating licenses in order to do this exercise, and I 16 really do not think that is warranted.
I'7 I dare say the Commission would find some 18 difficult at that time in justifying the holdup.
19 I have some other questions, but on this point it 20 seems a reasonable way to cut it.
21 C3MMISSIONER GILINSKYs When one is getting public 22 comment on this --
23 COMM!SSIONER BRADFORD:
I have no difficulty with 24 merging the two groups.
It does, though, I think carry with I
25 it an underlining of the importance of getting the re vised i
4 1
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37 I standard review plan completed in six months.
Otherwise, 2 the categories start breaking apart again.
3 MR. DENTON:
That is right.
4 CHAIRMAN AHEARNE:
Also, since they are tying the
$ Bingham amendment to that --
6 COMMISSIONER BRADFORD:
Yes.
7 CHAIRMAN AHEARNE:
And, as Vic suggests, we could 8 ask that the public comment on the approach.
9 COMMISSIONER BRADFORDs That is right, although I 10 think that Harold's point about the efficiency of the 11 approach makes enough sense to me that I would not insist on 12 including the other way of proceeding.
13 CHAIRMAN AHEARNE:
It does make more sense to me.
14 po.you have any estimate or better estimate of the staff 15 resources that will be required to do this examination af ter 16 they come back?
17 MR. DENTON:
Let me ask Ed to comment.
But there 18 at two distinct classes.
There are the resources required 19 to review the new applications for OLs, and then there are 20 the resources required to review those plants which we 21 licensed many years ago.
22 I think the impact on the new OLs will be small 23 and will be absorbable in our current budgeting, and the 24 uncertainty that has existed over this proposal is what will 25 it require f or a plant, say, like Yankee which was licensed o
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1 38 1 20 years or so ago.
2 MR. CASE:
I don't know' that I have much to sdd to 3 that except to say that the fitting in with normal review 4 process manpower is predicated on staff review and 5 ju'stification of the significant deviatiou_, not all 6 deviations.
And should the Commission or the' licensing 7 process -- and by that I mean licensing boards -- asking 8 questions or individual commissioners asking questions about 9 a particular deviation, or the ACRS asking questions about 10 all deviations -- could raise that estimation of manpower up 11 to perhaps two additional man-years per application 1Z You see, we are a prisoner of question askers by a 13 lot of group and we have no control over that.
The part we 14 have control over we do not think it would add to the 15 present aanpower requirements for an OL review.
16 Now, for the Bingham plants applying the same 17 approach, we estimate between one and two man-years for each 18 plant for reviewing and justifying the significant 19 deviations.
20 CHAIRMAN AHEARNE Not all. Not all.
21 MR. CASES Not all.
Now, our plans for the safety 22 evaluation of these operating plants go beyond just 23 reviewing the deviations.
They involve selected use of 24 saf ety topics, saf ety issues, as in the present SEP plus 25 what we learned out of the IREP program.
So we would expect ALDERSON REPORTING COMPANY, INC.
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O 39 1 that the total review per plant for operating plants would 2 be perhaps three to f our man-years per plant.
3 3R. DENTONs And the older the plant, the larger 4 its share of these resources.
5 CHAIRMAN AHEARNE:
That three to four estimate is 6 for current operating plants.
7 MR. CASES Yes.
)
8 CHAIRMAN AHEARNE:
Do you nsve an estimate of what 9 kind of licensee effort will be required?
10 MR. CASE:
Not that I have any confidence in.
11 CHAIBMAN AHEARNEs I guess we could expect to get 12 some comments in the public comment.
13 MR. CASE:
Yes.
I think at least the pending 14 license applicants, that is, or OLs and cps, are more 15 concerned over the added time to the licensing process that 16 will result from this step rather than from the manpower 17 they might use to justify deviations.
They see a ready-made 18 list of contentions, a source of questions by the boards, by 19 the Commission, by everybody.
20 And it is the extending of the entire process tha t 21 is of most concern to them.
22 COMMISSIONER BRADFORD:
My problem there is that 23 somehow the darker this picture gets in terms of possible 24 contentions and questions f rom the boards, questions from 25 the ACRS and what have you, the more urgent the task seems, ALCERSoN REPORTING COMPANY, INC.
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40 1 as well.
2 3R. CASES Or more worthwhile, at least.
3 CHAIRMAN AHEARNEs Except we have a statement from 4 Harold embedded in this that these kinds of reviews may not 5 be necessary or useful la evaluating the overall safety of 6 the plant.
7 COMMISSIONER BRADFORD:
If th a t turns out to be 8 the case, that is, that everything winds up checking out and 9 being in order, then it does not provide endless ammunition 10 for contentions.
11 CHAIRMAN AHEARNEa At least I thought the point 12 that was embedded in here is not that the de tails -- the 13 deviations may not be significant.
That was Ed's point, 14 also.
The fact that the deviation is not significant can 15 still make it a point of contention to take time to 16 resolve.
That, I thought, was more their point that ther 17 vere trying to make.
18 COMMISSIONER BRADFORD:
Le t 's see, though. As to 19 the plants where there is the greatest potential for that 20 kind of answer, the most you are going to see is a 2.206 21 petition in any case.
22 MR. CASES They are not in the licensing process 23 there. They have gone beyond.
Then you would expect 2.206.
24 MR. DENTON:
I think Ed's comment was in the 25 context of pending applications before the Commission.
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CHAIRMAN AHEABNE:
The newer ones 2
C3MMISSIONER BRADFORD Yes.
3 MR. DENTON:
We have required information of a 4 sort in several specific instances, so we do have some i
5 i~nformation back from licensees.
And I queried those, and 6 the best answer I can get is that someone would expect that 7 given that task, they would turn to their nuclear steam 8 supplier and AE to supply this report listing whether ther 9 compir with the standard review plan and justifying 10 deviation within three or four or five months.
11 Foc today's pending plants, their concern, as Ed 12 mentioned, anyplace where they have a deviation or maybe 13 where they don 't have deviations, they would expect 14 questions and answers from the staff, and this is a several 15 zonth process of turnaround.
They it would open up the i
16 administrative delays in putting that issue to bed.
I'7 So I think it is time for those people. They don't 18 expect it to be particularly difficult to justify, but just 19 by having it, doing it this way will open it up.
20 MR. BICKZITs In a previous memo you estimated 21 that the licensee man-year requirement for plants under 22 review would be tuo man-years.
Have you lost confidence in 23 that?
24 MR. CASE: I think for them that is a fair estimate.
25 MR. BICKWIT:
But with respect to the others?
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42 1
MR. CASES I think there is a wide error band 2 possible in that.
3 MR. DENTON:
Ihat is the actual ef f ort to prepare 4 this first package.
What is required f rom there on?
You 1
5 know, I have not tried to account for, but just to get a 6 response from them that we could start with.
Now, for the 7 older plants, the Bingham plants, the ones in operation, it 8 is much harder to estimate what will be required. These 9 guides and approaches just were not current.
10 MR. CASES I did not expect that concern of the 11 licensees to be particularly satisfying to you, but I 12 thought I should mention it.
13 COSMISSIONER BRADFORDs Obviously, the criteria 14 for mentioning things at this table should not be simply 15 whether or not it is what a commissioner wants to hear.
~ 16 CHAIRMAN AHEARNEs Hopefully not.
17 COMMISSIONER BRADFORD:
Certainly it has not been 18 in the past.
19 (Laughter.)
20 CHAIRMAN AHEARNEs I think each of us --
21 uonstruction permits.
Now, you had proposed, Harold, to 22 separate cps into two groupss again, one set on existing 23 SRPs a nd tha other on --
24 MR. DENTON:
Here T thought the bifurcation using 25 existing standard review plans at the CP stage and the ALDERSON REPORTING COMPANY, INC.
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1 43 1
revised standard review plans at the OL stage had more 2 appeal to me and made more sense. These plants are already 3 going to be pacing in the reviev, iepending on their 4 response to these other issues that we have asked them to 5 address or that we are about to ask them to address.
'6 In the course of their addressing these issues 7 that we know we are going to raise with them, they could 8 address the existing standard review plan.
9 CHAIRMAN AHEARNEs What is 07187 10 MR. CASES That is the TMI requirements translated i
IT to cps that you all approved our working on.
)
12 MR. DENTON:
Citing degraded core aspects.
13 CH AIRMAN AHEARNE How would you see this working 14 with respect to these plants that are in these hearings for 15 construction permits?
To stop the construction permit 16 hearing and have this review?
17 MR. CASE 4 It is already stopped because they are 18 waiting f or our IMI additions.
19 CHAIRMAN AHEARNE:
Would ther --
20 MR. DENTONs They would be taking the next several 21 months to address these near-term CP requirements that flow 22 f rom TMI.
So if we were to take the existine standard
" review plan and have them concurrently along a parallel path j
24 documenting deviations from existing standard review plans, 25 indications are for plants as current as these are, they ALDERSON REPORDNG COMPANY. INC.
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I 44 1 could complate that chore within the same time frame that 2 they documsnt all the other near-term CP requirements.
I 3 So then our review could proceed down on that basin.
4 CHAIRMAN AHEARNE:
And what would you propose?
5 You would review their submission, and after the completion 6 of that review you would then be prepared to go back to the 7 licensing board? Is that --
8 MR. DENTONt Yes.
Not only these items, but the 9 near-term CP items.
And then we would have a table, a table
~
10 showing deviations, if any.
By the time they come in at th e 11 OL stage, we would require that they address whatever 12 modifications, so they would have to --
13 CHAIRMAN AHEARNE:
I would guess if we had to be 14 consistent and put that requirement out for public comment, 15 then that would also be an additional time before it would 16 he possible f or it to go back to the board.
Is that correct?
17 MR. CASE:
We have to yet put out the TMI 18 requirements for those cps.
19 CHAIRMAN AHEARNE:
Eight.
20 MR. CASE:
For public comment.
They would go out 21 concurrently.
22 MR. DENTON:
We would put it out at the same time.
23 CHAIRMAN AHEARNE:
I guess th a t answers my 24 question.
25 COMMISSIONER GILINSKY:
Let me ask you.
Are there ALCERSON REPORTING CCMPANY, INC.
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45 1 CP applicants whose applications are inactive?
2 MR. CASE No.
3 COMMISSIONER GILINSKYs There are not?
4 MR. CASE:
There are some where they had an 5 application in and they decided to hold on it for a while 6 and not prosecute the application.
7 COMMISSIONER GILINSKYs You would regard those as 8 applicants who come af ter these six applicants listed?
9 CHAIRMAN AHEARNEs They are agreeing with your 10 last 11 MR. DENTONs These are the only active CP 12 applicants.
13 CH AIRM AN AHEARNE:
At the moment active.
14 MR. DENTON:
Yes.
15 CHAIRMAN AHEARNE:
Any other questions on the CP?
16 Were we to approve this approach, then -- I think this is an l'7 accura te summary, then, of what you have been sending in, 18 all these various papers -- you would then prepare a 19 notice.
I guess you would prepare two things: a sta tus 20 report that we forward to the Congress in order to meet that 21 ceadline by the end of September.
ZZ MR. BICKWIT:
Ninety days.
23 CHAIRMAN AHEARNE:
And then second, the notice for 24 public comment of the approach. Is that correct?
25 MR. DENTON:
Yes.
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46 1
MR. CASES Remaining to be decided is how one 2 migh t implement this approach.
Would you do it by tech spe c 3 changes, policy statement, a rule change?
We have a number 1
4 of options to consider, and it is germane to --
5 CHAIRMAN AHEARNE:
We have a law which requires us 6 to --
7 MR. DENTON:
Get public comment on the Bingham.
8 MR. CASE It requires us to do something on 9 operating plants.
It does not specify how much should be 10 done by licensees and how much by us.
11 CHAIRMAN AHEARNE:
And also how we would impose 12 that request.
I guess for myself I have not been able to 13 see clearly that distribution, so I would prefer to have 14 th a t as something to get comment upon, what approach to take.
15 MR. DENTON:
We would also be issuing the 16 near-term CP document.
I'7 CHAIRMAN AHEARNE:
Yes.
It seems to me --
18 MR. DENTON :
At the same time.
19 CHAIRMAN AHEARNE:
It is essentially a program of 20 how we are going to review across the board.
21 COMMISSIONER BRADFORD:
Yes. I suggested in my ZZ memo that it be done by tech spec.
I don 't have strong 23 objection to waiting until the ebd of the comment period if 24 you have that preference.
That will mean, though, that some 25 licenses will be issued during the comment period, and the e
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i 47 1 opportunity to do it by tech spec in those licenses, we l
2 would have to revisit those licenses.
We would go back to l
3 those and put them on the same footing.
4 CHAIRMAN AHEARNEs Yes, that would be my 5 understanding.
6 COMMISSIONER HENDRIE4 That contemplates hearinos 7 in each case?
8 COMMISSIONER BRADFORD:
I would hope not.
9 CONNISSIONER HENDRIEs There are hearings, right, 10 in sach casa.
11 NR. BICKWIT That is true.
12 HR. CASES Rulamaking is another option.
)
13 C05NISSIONER BRADFORD:
We could put the tech 14 spec s in now.
15 COMMISSIONER HENDRIE It is a little difficult 16 for 70 operating plants.
I'7 COMMISSIONER BRADFORD:
I am not talking about the 18 operating plants.
19 CHAIRMAN AHEARNE:
He is talking about the ones 20 that would bw coming up.
I would really prefer to receive 21 consents on it, and I guess in general if we lay this kind 22 ef requirement across the board, naively I would approach it 23 on a rule.
There seems to be a general rule that we would 24 then be applying, but I am not sure.
25 COMMISSIONER BRADFORD:
Is there any difficulty ALDERSON REPORTING COMPANY, INC.
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48 1 in doing it as a rule at the end of the comment period on 2 rhe proposed program?
I suppose as long as it is clearly 3 noticed that the Casaission is considering doing it, among 4 other ways, in the form of a rule --
5 CHAIRMAN AHEARNE:
We certainly have a substantial 6 --
7 MR. CASES Are you raising 8
]
COMMISSIONEE BRADFORDs Do it right.
9 MR. CASES Do it right, meaning it is not 10 necessary to have further public comment on the proposed 11 rule.
12 COMMISSIONER BRADFORDs Yes.
13 CHAIRMAN AHEARNE:
Victor.
14 COMMISSIONER GILINSKYs No further questions.
15 CHAIRMAN AHEARNE:
Joe?
16 COMMISSIONER HENDRIEs Several. I am afraid if we l'7 convert this af fair into a rule ultimately, in what way does 18 that then imbue all of the assorted staff positions and 19 regulatory guides cited in the standard review plan with the 20 properties of regulations?
21 MR. BICKWITs I do not think it would. I think it 22 would be contemplated that the rule would describe your 23 procedures f or applicants and reviewers, but it would not 24 change the nature of requirements which did not have the 25 force of rule into requirements which did have the force of l
i j
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49 1 rule.
2 MR. CASE:
I think not legally, but I think it 3 would put even more pressure on applicants to follow the l
4 staff's recipe.
i 5
CHAIRMAN AHEARNE:
I would guess that af ter we lay j
6 out this kind of program in which everything is going to be i
7 compared against, deviations measured against, that that is 8 going to be a substantial pressure.
9 COMMISSIONER HENDRIE The second question is, the 10 summary paper which Commissioner Gilinsky's office prepared 11 and which is very good, I think, I commend your staff.
You 12 seem to have patched it all together in a couple of pages.
13 We talk about licensees will be required to identify and
.14 justify all deviations from the revised SRP.
15 Harold's -- the advance paper I got talks more 16 about requis tions, about licensees conforming to l'7 regulations.
Each licensee would be required to evaluate 18 its opera ting plant against these regulations and determine 19 the extent of the plant's compliance, including an 20 indication of where such compliance was achieved by the use 21 of Division I reg guides and staf f positions where 22 compliance is achieved by other equivalent means, et cetera.
23 There is a thrust in the staff paper that the 24 emphasis is on regula tions.
In the short table we keep 25 talking about the revised standard review plan, or ALDERSON REPORTING COMPANY. INC.
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50 1 occasionally the existing standard review plan, and much the 2 greater weight of just sheer documents that you have to deal 3 with.
4 When you look at the standard review plan, these 5 are the guidance documents, the guides, the staff positions 6 and so on.
Now, "ince no plant was constructed and put in 7 operation yesterday but the regulations, the guides and the 8 staff positions sort of change with time, every plant far 9 and near will have deviations from the standard review plan.
10 You cannot very well have conformed to a staff 11 position which was not enunciated at the time you got your 12 license, and the staff ha's not found it necessary or 13 appropriate since licensing to go back and ask the licensee 14 about that new requirement.
Then obviously he vill have to 15 speak to that in this document.
16 So I am curious as to what sense I ought to carry,
~
\\
17 like licensee will be required to identif y and justify all 18 deviations from revised standard review plans.
What sense 19 do I carry from that? Are we asking these people to address 20 every line of every regulatory guide and staff position that 21 is on the books ss of next April when the revised SRP comes 22 out?
23 If that is the case, where did the thrust of 24 significant safety relations, which is certainly the 25 standard of the Bingham amendment go, and are you really l
l l
ALDERSON REPORTING COMPANY, aNC.
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51 I contemplating that extensive a piece of paperwork?
2 CHAIRMAN AHEARNE:
To be fair to Commissioner 3 Gilinsky's staff summary, the revised SRP really comes from 4 the NRR plan that they had originally submitted.
5 CONNISSIONER HENDRIE:
I recognire that, but let i
6 us have some discussion about our intent with regard to the 7 degree of reading of fine print.
If you stack up all of the 8 reg guides and staff positions and then ask one of the 9 operating plants with an OL that is five years old or more 10 to discuss deviations, what you have asked them to do is, in 11 effect, to discuss literally every sentence of every guide 12 and staff position.
13 It is a monumental push to what I will call 14 regulatory extremes, the kinds of places that the system 15 tends to go in order to show great diligence on the part of 16 their reviewer and so on.
You are asking for a staggering 1:7 amount of paperwork, and I a m less than convinced that it is 18 contributing enough to safety to be worthwhile at that 19 extreme.
20 I think we are going over the next couple of years 21 to get the maximum effect from a safety standpoint out of 22 the IREP and NREP examinations if these plants where you try 23 to identify, in fact, what features of the particular design 24 leave you vulnerable above the general level to significant 25 accident seguences.
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I think the exercise we are engaged in here, while 2 useful in a regulatory documentation sense, is less apt to 3 come to grips with and deal with significant safety problems 4 than initiatives that come in from that other route, sort of 5 engineering examination of the plant route.
6 What I am getting around to saying is I hope I 7 could hear some lan'guage that this thrust does not intend to 8 become the greatest piece of paperwork going on next year in 9 regulation, but tries to keep its direction pointed to 10 safety significance and not to the dotting of every "1"
and 11 the crossing of every "t."
11 COMNISSIONER BRADFORD:
The staff will have to 13 address a part of that concern, but I would think the IREP 14 and NREP efforts would have been much easier to undertake if 15 we had, in f act, proceeded on this basis.
16 COMMISSIONER HENDRIE:
If we had this in place 17 now, it would have made very little difference, I think, for 18 IEEP and NREP unless said ef fort had resulted in system 19 design changes or operating procedure thanges.
20 COMMISSIONER BRADFORD:
It would have provided, I 21 think, a rather greater detailed knowledge about what was 22 actually th e re.
23 COMMISSIONER HENDRIE:
I am sorry, I do not agree, 24 no t to the extent that you really need it for the I3EP.
25 COMMISSIONER 3RADFORD:
The second point, the l
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53 1 staff proposal talks about identifying and justifying 2 deviations from the revised SRP in accordance with the 3 Bingham amendment plant as approved by the Commission.
I 4 had taken tha t to im ply that there would be a carryover in 5 terms of the safety significance language.
6 However, we wound up applying that in the Bingham 7 context, we would also be applying -- I think that was one 8 of the points Ed stressed pretty strongly at the last 9 seeting in terms of the staf f assessment of manpower, 10 depending on that.
11 CHAIRNAN AHEARNEz I think that latter point more 12 addresses your concern.
That is acceptable to me, and I 13 gather it is acceptable.to you.
1 14 COMMISSIONER BRADFORD:
Yes.
15 C05HISSIONER HENDRIE.
One last comment.
I don't 16 know quite who is best to deal with it.
What sort of I'7 commitments, directions or whatever do we have f rom the 18 Appropriation Committees about Bingham amendment resources?
19 I seem to recall that we carved that apart and said when we 20 know what it is, we will be back to you.
21 CHAIRMAN AHEARNE:
We have never addressed 22 clearly in the current appropriation there were no funds 23 iden tified because the Bingham amendment came in the current 24 authorization which passed after the appropriation.
As far 25 as the one we have gone into 05B with, as you recall, after 6
ALDERSON REPORTING COMPANY, INC.
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Su 1 extensive debate here at the table,,ve did not ask for any 2 specific resources for the Bingham amendment.
3 I think if we do go out for public comment on 4 this, we will probably continue to be a little premature 5 since the SRP aspect of it Harold has said he could 6 accommodate withing his resources.
7 COMMISSIONER HENDRIE I am thinking about the 8 further steps past the SRP.
9 MR. CASE:
As far as I know, there are no signs, 10 signals or words f rom any of the congressional committees as 11 to how much should be expended on this effort.
12 CHAIRMAN AHEARNE:
I would guess in the testimony 13 next spring we would have the opportunity to address both 144 what we are doing and how much in the way of resources we 15 think would be appropriate, and there is no way we would be 16 getting any additional action f rom the Congress or l'7 additional resources before then anyway.
18 MR. CASES That is true.
19 CHAIRMAN AHEARNE:
Anything else, Joe?
20 COMMISSIONER HENDRIIs No.
21 CHAIBMAN AHEARNE:
Anything else?
22 COMMISSIONER BRADFORD:
Just a couple of what I 23 hope are clarifications.
There is a sentence in the summary 24 that the revised SRP would be substantively similar to the 3 existing SRP, with the exception of documenting the 4
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55 1 relationship between the SRP provisions and the NRC 2 regulations.
3 I had understood that the revised SRP went 4 somewhat beyond that and picked up other documents currently 5 used by the staff.
6 HR. CASES Yes.
7 COMMISSIONER BRADFORD:
It does.
8 MR. CASE We define revised SRP, as our footnote 9 2 on the piace of paper that l
10 COMMISSIONER BRADFORD4 Right.
11 HR. CASES Whether that is substantive similar or 12 not, I will leave that up to you.
But I would describe it 13 as I did in the footnote.
l 14 CHAIRMAN AHEARNE4 I believe that was the wish of 15 Commissioner Gilinsky.
16 COMMISSIONER BRADFORD:
As long as we are still 17 working with the definition of revised SRP provided in the 18 staff document as of last time, th a t is fine.
19 COMMISSIONER'HENDRIE:
That is the way I have 20 understood it.
21 COMMISSIONER BRADFORDs Yes.
No, nothing else 22 with regard to either this or the staff presentation. A i
23 think in one way or another, we have picked up three of the 24 four covering points in my September 11 semo.
j 1
25 Could you talk a minute about the treatment of ALDERSON REPORTING CCMPANY. ;NC.
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56 1 second units on a site where the first unit is already in 2 operation?
I understood those would be treated as if the 3 license had been issued at the time.
4 HR. CASE 4 If yoiu collapse Groups 2 and 3 to one 5 group, it is no longer applicable.
6 COMMISSIONER BRADFORDs Okay.
7 MR. CASE:
Anything that comes after 1/1/82 gets 8 the full treatment, and anything before that time gets no 9 treatment until after licensing.
10 CHAIRMAN AHEARNE:
I would think we would treat it 11 independently.
12 CONHISSIONER BRADFORD:
Okay.
One of the more 13 difficult issues, and I would think it is best probably to 14 treat it at the end of the comment period, is what to do 15 with a situation in which the licensee in effect is coming 16 back and saying the deviation is justified by the fact 17 whether we are talking about a regulstion or reg guide -- by
^
18 the fact that the plant is grandf athered.
19 I think there may be some situar. ions in which we 20 would still want to require further analysis, and there will 21 be other situations in which the burden falls back on us.
22 CHAIRMAN AHEARNE:
If I understood the 23 justif.ication language, to really require much more than 24 saying grandf athered 25 MR. CASE:
For informal staff guidance documents, ALDERSON REPORTING COMPANY, INC.
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57 1 but not for Commission regulations.
2 COMMISSIONER HENDRIE:
Unless there has been a
3 specific exemption, as there has been occasionally for one 4 of the features of one of the appendices, like Part 50.
S They have to meet the regulations, and I think they can 6 legitimately say, you know, we meet Regulation 42 because we 7 do the following things.
8 COMMISSIONER BRADFORD:
Supposing they do, in 9 fact, say we meet 50.55(A) because we are exempted f.om it.
10 CHAIRMAN AHEARNEs I would q.tess consistency will 11 end up requiring 12 COMMISSIONER HENDRIES If there is a formal 13 exemptin, there will be a safety evaluation that goes wl.th 14 it.
15 CHAIRMAN AHEARNE:
Tha t is it.
'de can require to 16 have each of those justifications --
1'7 COMMISSIONER BRADFORD:
Cne way or the other.
18 COMMISSIONER HENDRIE:
I think that is the case 19 where there is a formal exemption to the regulations, isn't 20 it?
21 MR. SHAPAR:
There is usually an analysis. But 22 what if the regulation itself grandfathers in itself 23 existing plants? How do y u plan to treat that?
24 CHAIRMAN AHEARNE:
I wculd guess eventually there 1
25 will be an analysis.
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MR. EHAPAR:
On a continuing basis.
2 MR. DENTON:
There are no t many like that.
3 COMMISSIONER BRADFORD:
I am inclined to agree 4 with John at this point; but I think that is one of the 5 reasons we vill not settle it until the end of the comment 6 period.
If we have agreed it is a safety-significant 7 regulation and if all we have is a statement that it does 8 not apply to this plant because the plant is Jtandfathered, i
9 I think I would like some kind of an evaluation beyond that.
10 MR. CASE:
Perhaps it could be done generically.
If I think it is possible that I could show you reasonably that j
12 all the grandf athers in the regulations are not significant 13 from a safety standpoint.
144 COMMISSIONER BRADFORD:
Those will get screened 15 out through the process.
16 Mq. CASE:
Not necessarily.
But the l'7 grandf athering might not be important.
18 MR. SHAPAR:
The grandfathering was done as a 19 generic matter. I would think the cure fo r it would also be 20 generic.
21 COMMISSIONER BRADFORD:
Possibly.
22 CHAIRMAN AHEARNE:
Any other questions?
23 COMMISSIONER BRADFORD:
No.
24 CHAIRMAN AHEARNE:
I guess I still have that open 25 question in the back of my mind. It is not obvious yet to ALDERSON REPCRT1NG COMPANY, INC.
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1 59 1 the overall safety significance of this approach, but I 2 would vote for saying this is the approach that we are 3 proposing to take and putting it out for public comment.
4 COMMISSIONER GILINSKY:
Aye.
5 COMMISSIONER BRADFORDs The revised SRP F:tould be 6 completed within six months, entirely apart from what is 7 going out for public comment.
Those two propositions were 8 the ones I urged in my last memo.
9 CHAIRMAN AHEARNE:
Vic?
10 COMMISSIONER GILINSKY:
I said aye.
I was 11 agreeing with your proposition and your comments.
I am in 12 f avor of the proposition.
13 CHAIRMAN AHEARNE:
Joe?
14 COMMISSIONER HENDRIE:
Have we collapsed Group 3 15 into Group 2 for purposes of this notice?
16 COMMISSIONER BRADFORD Yes.
17 CHAIRMAN AHEABNEs Yes.
18 COMMISSIONER HENDRIE:
Okay, I will certainly 19 agree to it going out for public comment.
We are required 20 to carry out a portion of what is proposed here by the 21 Bingham amendment, in any case.
ZZ For tha extension beyond the Bingham amendment 23 which is contemplated here, I share with John some questions 24 about the saf aty benefits versus the obvious staff and 25 industry resource costs.
The degree to which that sert of ALDERSON REPORTING COMP ANY, INC.
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b 60 1 safety benefit / resource cost ratio is reasonably high, that 2 is, fair benefit for the cost and so on, has a lot to do 3 with how rigorously and implacably the individual st'ff 1
4 reviewers pursue each licensee over each line of each guide, 5 of each staff position and each line of the SRP, which, I 6 will remind you, runs to three volumes of fine pring.
I 7 know.
I edited the whole damn thing myself.
8 CHAIBMAN AHEARNE I think we have identified one 9 of the principal reviewers.
10 (Laughter.)
11 COMMISSIONER HENDRIE4 What is proposed here 12 beyond the Bingham amendment requirements can range all the 13 way from a reasonable and orderly putting in order of the 14 regulatory houe with some associated safety benefits'wh!.ca, 15 in my own view, are not large compared to the sort of risk 16 assessment attacks on these things but nonetheless are l'7 there, all the way over to, you know, a really regrettable 18 devouring of everybody's resources in return for masses of 19 documentation which will not be that valuable.
20 So it seems to me th a t what we have has the 21 capacity to be useful at reasonable cost.
It also has the 22 capacity to be not nearly as useful as its cost can run.
23 But let us go for comment.
24 CHAIRMAN AHEARNE:
Peter?
25 COMMISSIONER BRADFORD:
Obviously, I am inclined --
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CHAIRMAN AHEARNE:
The formal vote.
2 COMMISSIONER BRADFORD:
I just want to defend the 3 proposition to say it is not my intention to drive them to 4 paperwork; but it does seem to me that the business of 5 getting the regulatory house in order a* reasonable cost may 6 well have safety significance within the confines of what is 7 being done, but certainly has safety significance on the way 8 in which future applications are reviewed and documented.
j 9
CHAIRMAN AHEARNE:
I think the Commission has 10 approved going out with this proposal.
11 I think, Harold, then you are on the hook to draft 12 the notice for the Federal Register.
)
l 13 MR. DENTON:
Yes.
14 CHAIRMAN AHEARNE.
Having now, I think, resolved 15 your issues, Peter, I would like to then move to th e 16 Sequoyah operating license, and I would move that we approve 17 it as modified earlier this morning by the revised j
18 whatever the approoriate issue was -- by Commissioner 19 Gilinsky 's modified version.
20 COMMISSIONER BRADFORD:
Aye.
21 COMMISSIONER GILINSKY:
Aye.
ZZ CHAIRMAN AHEARNE:
Aye.
ZI COMMISSIONER HENDFIE:
I approve it without the 24 modifica tion.
25 (Laughter.)
1 ALCERSON REPORTING COMPANY, INC.
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6 I
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1 C!! AIRMAN AHEARNE:
For those who are waiting, yes, j
2 we have now approved the Sequcyah license.
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3 (Whereupon, at 11: 14 6 a. :n., the mee ting was i
4 concluded.)
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ALDERSON REPORTING COMPANY, INC.
400 vtRGINIA AVE, S.W.. WASHINGTON. 0.C. 20024 (202) 554-2345
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D I D u
m NUCT ZAR REGt!.A"'ORY CO.TCS5:CN Th:. s is :: certify :ha: :he a::achec ;:receecings before :he Commission Meeting in the 23:;-r Of: Public Meeting - Discussion of Commission Program to Review Operating License Applications - Discussion & Vote 0 ate cf ?roceecing: on Sequoyah
- September 16, 1980 Occket: Nu=bec:
? lace of ?receeding:
Washington, D.
C.
'se rt held as herein appears, anc :hac this is the original transcripc thereo f for the f Lie o f the Cec =Lssion.
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David S.
Parker Official Recer:er ( ypec) l 885 e e se j
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