ML19341A489
| ML19341A489 | |
| Person / Time | |
|---|---|
| Issue date: | 01/15/1981 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML19341A490 | List: |
| References | |
| REF-10CFR9.7, RTR-NUREG-75-087, RTR-NUREG-75-87 NUDOCS 8101230658 | |
| Download: ML19341A489 (41) | |
Text
A NUCLEAR REGULATORY COMMISSION t
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COMMISSION MEETING
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In the MLt2ar of:
BRIEFING ON STATUS OF STANDARD REVIEW PLAN DATE: January 15, 1981 PAGES:
1 - 38 AT:
Washington, D.C.
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1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
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4 BRIEFING ON STATUS OF STANDARD REVIEW PLAN e
5
--- s h
6 Nuclear Regulatory Commission g
Room 1130 6
7 1717 H Street, N.W.
g Washington, D.C.
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8 d
Thursday, January 15, 1981 6
9 Yg 10 The Commission met, pursuant to notice, at 2:20 p.m.
11 BEFORE:
y 12 JOHN F. AHEARNE, Chairman of the Commission 5
d 13 JOSEPH HENDRIE, Commissioner E
l 14 VICTOR GILINSKY, Commissioner 2
15 PETER BRADFORD, Commissioner 5
y 16 STAFF PRESENT:
as b'
17 LEONARD BICKWIT, General Counsel 5
18 WILLIAM J. DIRCKS, Executive Di-ector for Operations 5
19 SPEAKERS:
5 20 D.
SKOVHOLT, NRR 21 E. CASE 22 T. MURLEY 23,
E. HANRAHAN, OPE 24 25 I l
ALDERSON REPORTING COMPANY, INC.
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DISMm-7
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This is an unoffdf =1 c=anse:1pc of a.maacis of cha II 1:act 4
States Nucisar Ragulatory Commission held on /8, rey /C/'/
in the Commission's of31cas at 1717 E Screat, N. 7., Wadhing en.
D. C.
Tha maecing was open to public at:=#=aca and obserracion.
This. c=ansWe has une baanc ravdh, corrac:ad, or edi ad, and 12 may contain 4=c - M==.
The c anscript is 1=canded solely for ganaral infor=acional purposes.
As provided by 10 CEL 9.101, it is sac part of the formaI. or informal recari od decision of the mat:ars discussed.
T.zpressions of op1=1on in chts c=anscripe da sac secessarily reflec= fdnal datarminations or be11afs.
No p1==ddar or other paper may be. filed wi h the camLssion in any procaading as cha
- ssui: of or addressed to ar
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harmin, excepe as the C* =sion say authorf.:a.
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CHAIRMAN AHEARNE:
This afternoon's meeting is to hear 3
a summary of the status report of the revisions to the Standard 4
Review Plan.
William?
e 5
Mll. CASE:
That is essentially it.
Don Skovholt will b
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take us through the Status Report.
I think it is a continuation of G
7 some of the things we discussed yesterday, and the theme will be Nl 8
that we are still shooting for April of '81.
I hope we hear a d
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happy story.
2 10 CHAIRMAN AHEARNE:
All right, Don?
i5
'z II MR. SKOVHOLT:
Thank you, a
y 12 We are approximately at the mid-point of the accelerated S
5 13 program to revise the Standard Review Plans, and this program 4
l 14 was designed with three major objectives in mind.
May I have the n[
15 first slide, please:
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16 g
Fundmentally, to ensure that the SRP is fully congruent w
f 17 with the NRC regulations.
m 18 To maximize the reference to supplemental guidance to E
19 define how broadly stated requirements are satisfied.
By this we 20 mean, use regulatory guides or branch technical positions, or 21 anything which would help the public to understand just how a 22 requirement: has been satisfied, particularly some requirements 23 such as the general design criteria which are stated in very broad j
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24 terms.
A definition of how the requirement is met is deemed l
l 25 necessary.
l _
ALDERSON REPORTING COMPANY, INC.
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1 The third objective was to incorporate in this revision 2
effort all of the TMI-related requirements that have come into 3
being in the last year and-a-half.
4 CHAIRMAN AHEARNE:
Could I ask you, what do you mean by
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5 "c~ongruent?"
5 h
6' MR. SKOVHOLT:
To indicate in the Standard Review Plan R
7 and through that vehicle in each safety evaluation report that Al 8
every requirement of our rules which is applicable to the topic d
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under discussion at that point is indeed met, and adequately met.
E 10 CHAIRMAN AHEARNE:
So, in any kind of mapping system 11 you can transform from one to another.
Are you trying to aim at 3
y 12 ensuring that every regulation is covered in the Standard Review 5
.ag 13 Plan, or that every element in the Standard Review Plan references z
mg 14 the regulation it covers?
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15 MR. CASE:
Both.
m 3;
MR. SKOVHOLT:
We are trying to do both.
I think the 16 al 17 former is the more important one.
We want to be sure all the z
18 regulations are covered.
But on the ocher hand, every Standard E
19 Review Plan section ought to stem from a regulation or there is gn 20 some question of whether we ought to be doing it.
2I CHAIRMAN AHEARNE:
But you will, at the completion of 22 this, be certain that every regulation is treated in the Standard 23,
Review Plan.
24 MR. SKOVHOLT:
Yes, sir.
25 Now, to accomplish this program a procedure was ALDERSON REPORTING COMPANY, INC.
4 I
generated which Mr. Denton(?) issued on November 20..
Second 2
slide, please.
3 The procedure calls for the staff to, first of all, 4
develop a listing of the requirements that we want to treat.
It 5
turned out there we're 104 requirements.
And by " requirement" I 5
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6 mean a portion of our regulations - it might be a single section R
7 of the' regulation; it might be a grouping of sections that are on Nl 8
the same topic; it might be a single item such as a criterion of d
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the general design criteria.
In total, we have 104 of those.
2o 10 MR. CASE:
All of those requirements stem from regulatior,s.
i!!=g 11 MR. SKOVHOLT:
Yes.
Everything is a portion of the is y
12 regulations that we are calling a " requirement" here.
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13 Then the staff was directed that for each'of the 217 SRP 3u 14 sections they should do certain things with respect to those 2
15 requirements.
The things that they should do is, first of all, 5
g 16 determine whether or not the requirement is currently referenced as 6
17 in the SRP section; that is sort of a base-line data.
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18 Secondly, should determine whether or not the current i:
19 reference to the requirement is truly adequate.
A blanket statemer,t 20 about, " Ensure the general design criteria in 26 is met" is not 21 good enough.
There should be some mechanism to show just how the 22 requirement is satisfied.
l 23 Thirdly, they should ensure or determine whether or not 24 the requirement should be added to the SRP.
25 In performing this exercise we were very adament that ALDERSON REPORTING COMPANY, INC.
I 5
1 the staff reviewer go back and reread each of these regulations 2
and not rely on memory; reread them, make a conscious decision.
3 Every reviewer was told that a negative determination, a determi-4 nation on his part that t'e regulations does not have to.be h
5 referenced in a section was just as important and just as subject E
6 to being challenged in the review process as a positive determi-R b
7 nation.
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So, a lot of attention was given to this.
In particular, d
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i, as far as the Standard Review Plans went, we focused on two parts h
10 of them, the evaluation findings and the acceptance criteria E
Il portions, being these were the more important ones.
3 f
I2 The acceptance criteria portion of the S'RP is a listing C
y 13 of the bases that the reviewer will use in making a judgment as to a
b I4 whether or not the applicant's proposal is satisfactory.
The a
g 15 evaluation findings is a statement that the reviewer develops for z
g 16 inclusion in the SER to demonstrate the applicant's compliance w
h I7 with our rules.
So, those two sections of the SRP were the ones a
18 that got the most attention.
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19 Now, you can see with 104 requirements in 217 sections, 20 l
the number of combinations of these things is already pretty large.
l 21 This has led to a large number of matrices being developed, which 22 I will touch on in a moment.
l 23 The next step, we did the same kind of exercise for 24 the 145 regulatory guides in Division 1; even though these are 25 not requirements they do help to understand how requirements are I
l ALDERSON REPORTING COMPANY, INC.
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satisfied.
So, for the 214 SRPs the 145 regulatory guides were I
2 looked at to make the same kind of judgment, are they in there?
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3 Should they be added?
Should the current references be amplified
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4 or modified in some way?
e 5
CHAIRMAN AHEARNE:
Don, before you get to TMI, there is
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6 still another variation.
The initial question, I am trying to get R
7 clear in my mind as to whether the staff's approach is that the Xl 8
SRP floats in the regulations or that the SRP in some way is above d
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the regulations.
2 h
10 I am not sure, it is probably just because of the short-3=
3 11 hand treatment initiated here, but it almost sounds like you are 3
g 12 treating regulatory guides as equivalent to regulations.
5g 13 MR. SKOVHOLT:
I don't mean to give that impression.
The u
l 14 SRP certainly is not above the regulations.
The regulations a
g 15 govern, and it is the regulations that the applicant must meet.
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16 The SP.P conceptually was a procedure to the staff w
d 17 reviewer this is the method he should use to handle the applicant' s N
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18 submittal to determine whether or not regulations are met.
That E
19 is the fundamental purpose of the SRP, although it has other R
20 uses as well.
21 I mentioned regulatory guides not as a substitute for 22 regulations, but as a mechanism for showing how a regulation can l
23 ;
be met.
Conforming to a regulatory guide is an option an 24 applicant has to satisfy some aspects of our regulations.
He has 25 ) other options available to him.
But if he chooses the method out-ALDERSON REPORTING COMPANY,INC.
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lined in the regulatory guide it is clear to him, and to us, and r
2 to the public, and to any other interested party just what is beinc 3
done and what is being accepted.
So, regulatory guides are very
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4 handy in that context.
5 MR. CASE:
Well, they should be referenced in the SRP.
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CHAIRMAN AHEARNE:
I was not challenging the referencing R
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the SRP, I just keep striking, trying to find, the flow should be A
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8 in a direction.'
d 9
COMMISSIONER BRADFORD:
What is the relationship, what 10 has it been up to now, between a given reg guide and the Standard E
II Review Plan section closest to it?
That is, is it fair to say isj 12 that the Standard Review Plan tells the reviewer what to look Cl f
13 for in seeing whether the reg guide has been correctly applied l
14 to this plant design, or does it just tell him to see if the reg h
15 guide has been been applied, without going much beyond that?
u iE I0 MR. SKOVHOLT:
No, basically it tells him to see if e5 h
I7 the requirement of the regulation is satisfied.
It makes a:
lii 18 reference to the regulatory guide position as being an acceptable
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way, a previously determined acceptable way of satisfying said 20 requirement.
COMMISSIONER BRADFORD:
But the plan does not tell him, say, the applicant comes in and says he has done it by a 23 technique described in a particular regulatory guide, how to 24 check. that out?
l 25 MR. SKOVHOLT:
He would have to verify that the l
ALDERSON REPORTING COMPANY, INC.
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appliennt hno indred dona what ha ccid.
Tho regulatory po ition, 2
part of the regulatory guide is indeed a step-wise listing of the 3
acceptable method.
4 MR. CASE:
To answer your question, no, it does not e
5 tell how to assure he followed the regulatory guide.
They are 3e
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6 more or less on equivalent levels, they are both satisfying the R
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7 regulations and one is not an explanation of the other.
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COMMISSIONER BRADFORD:
All right.
dd 9
MR. SKOVHOLT:
The staff also determined which TMI-10 related requirements that have been approved through a variety of El 11 mechanisms should be included in which sections of the SRP, and 3
y 12 identified these for inclusion in this revision program.
5 13 Now, those actions were in support of the three basic l
14 objectives I outlined earlier.
th' ugh, while performing this first phase, 2
15 In addition, o
5 16 the staff was directed to do additional things.
The next slide, g
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17 please.
E 5
18 The staff was told to list the pre-TMI requirements that 5
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19 had not yet been incorporated in the SRP.
There were some of these n
20 still around, there had been a 1977-78 revision program in SRPs 21 which had been largely completed, but there were still a few 22 things in limbo when TMI came along and interrupted the finalizati on 23 l of that.
24 MR. CASE:
D'o n, can I follow the chairman's line?
25l MR. SKOVHOLT:
Sure.
l l
ALDERSON REPORTING COMPANY, INC.
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I MR. CASE:
You say requirements there, but you don't have t
2 in mind regulations here, you mean staff position.
3 MR. SKOVHOLT:
You are right, it is a poor choice of 1
4 words.
I should have said " staff position" or something like e
5 that.
6 CHAIRMAN AHEARNE:
Would the reader of the Standard 7
Review Plan recognize the difference?
Kl 8
MR. CASE:
Yes.
d MR. SKOVHOLT:
I believe so, we are taking more pains f9 2
h 10 with the Standard Review Plan --
Em II MR. CASE:
That has been the question.
D y
12 MR. SKOVHOLT:
The staff was also asked to identify any
~ca 13 new positions that they would propose to include in this SRP 5
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I4 revision program for management consideration.
These would be g
15 decided on an item-by-item basis as to whether or not to include u
g 16 them in the program.
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II There was also a considerable amo: :t of reassignment of 5
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18 branch review responsibilities, primarily to reflect the NRR 5
g reorganization of 1980; and there are a number of areas where II 20 through usage we found that sections of the SRPs could be made 21 more clear, and we intend to take that up, also.
22 CHAIRMAN AHEARNE:
Let me ask another question which, 23 ;
I am sorry, I should have asked at the time.
The incorporating of 24 TMI-related requirements, can you define what are those 25 I
requirements?
ALDERSON REPORTING COMPANY, INC.
10 1
MR. SKOVHOLT:
Well, fundamentally we are using NUREG 2
0737 as the basis for determining which requirements have already 3
been approved and which are under consideration for later.
I 4
CHAIRMAN AHEARNE:
How do you draw a distinction between
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5 a regulation and 07377 5l 6
MR. CASE:
Let me answer 'that.
We also correlated R
R 7
NUREG 0737 with the regulations.
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8 CHAIRMAN AHEARNE:
But they are cautious, as we all know, d
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there are some areas where 0737 goes beyond the regulations.
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10 MR. CASE:
Yes, but not many.
z 11 CHAIRMAN AHEARNE:
Not many.
But in those where it it g
12 goes beyond, how do you treat it?
5 13 MR. CASE:
I don't know the answer to that.
There are 7
35u 14 only a f(w.
2 15 CO!2iISSIONER HENDRIE:
It will treat it the same way 0
y 16 we treated the staff pos.tions when the SRPs were devised in the i
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17 beginning, and we were in fact pushing the review process forward.
b 18 That is, the SRP is a staff guidance document.
The staff feels k
19 that this is what is now required to implement that regulation, 20 this being some new elaboration.
21 People who do not r. gree with that are perfec,tly free 22 to come into the Commission's adjudicatory process, challenge it, 23 fight it all the way up the line, including judicial review.
The i
24 staff has formed a judgment and that is what they are saying in 25 this guidance document to their own people.
ALDERSON REPORTING COMPANY, INC.
11 I
MR. CASE:
There will be, uniquely, some requirements 1
2 where there is no reference to a regulation.
3 CHAIRMAN AHEARNE:
May I ask Joe a question?
In your 4
original in '75, did you have portions which went not in'to 5
j interpretation but actually went beyond the requirements of the 9
3 0
regulations?
R 7
COMMISSIONER HENDRIE:
The regulations, fortunately or a
k unfortunately, depending on your point of view --
d CHAIRMAN AHEARNE:
Weren't that explicit.
o h
10 COliMISSIONER HENDRIE: -- make a broad sweep.
Even the
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5 II general design criteria say there shall be a containment, it a
shall have adequa' gins.
In the eye of the beholder are the o"
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details which satisfy.
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CHAIRMAN AHEARNE:
But there weren't any where one I'
explicitly knew we are going beyond what the regulations require, z
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implicitly.
d 17 COMMISSIONER HENDRIE:
I refuse to answer.
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18 (Laughter.)
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COMMISSIONER EENDRIE:
Let me answer in the following l
20 vein:
There was nothing in the SRPs which I was not prepared to wave hands over in the sense of regulatio.ns then upon the books.
I 22 (Laughter.)
23;I COMMISSIONER HENDRIE:
Is that the same thing you are 24 asking?
25 i CHAIRMAN AHEARNE:
You answered the question.
ALDERSON REPORTING COMPANY, INC.
12 1
Don, as I am sure you know, we have had a fairly
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2 extensive debate on how one considers those portions of 0737 and 3
its predecessor, that go beyond the regulations.
As that points 4
out, there are very few of those, but there still are seme.
So,
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5 those can't really reference back to a regulation because that 5
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regulation would then say that, "You don't do that."
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7 MR. SKOVHOLT:
Well, for the moment, for the purpose of A
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this SRP program we are using the 737 decisions and a couple of d
o; 9
related documents, such hh'NUREd'O'696 oh emergency'pfeparedness z
h 10 and a couple others that have been approved.
We are working those i
g 11 positions into the SRP program.
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12 Now, there is a parallel staff effort going which I D
5 13 guess Joe was heading up, to try and define just which of the u
l 14 737 actions are fully supported or marginally supported through g
15 regulations.
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16 If it turns out that there are positions which are not W
6 17 supported by the regulations, I will need a decision.
I assume y
18 we will have to drop by the SRP.
E 19 COMMISSIONER HENDRIEr Or just clarify that they are g
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20 the staff's -- you know, there has never been any inclination 21 here to say that the staff could not go into a hearing and say, 22 "We think this requirement which we agree exceeds existing 23 regulations ought to be imp 1.emented on account of TMI.
The 24 Commission has reviewed it and agreed with this.
That is our 25 position in this hearing."
Those are the Category 2 items.
I ALDERSON REPORTING COMPANY, INC.
13 1
think they are going to turn out to be either zilch --
2 CHAIRMAN AHEARNE:
But I think what my concern is, I 3
think we are much more familiar with this issue than perhaps some 4
of the staff are.
T MR. CASE:
That is why we built it, as a matter of fact, b
6 started this complementary exercise.
R 7
(Laughter.)
Kl 8
COMMISSIONER HENDRIE:
Almost made it.
d 2
9 MR. CASE:
It was for two purposes.
One was your
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10 policy statement issued, and the second was for guidance of
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12 CHAIRMAN AHEARNE:
Well, what I am trying to obviously 5
5 13 highlight is that at some point in this revision you are going u
14 to have to decide and make clear what you do about those, other-15 wise you really are making the Standard Review Plan a level above f
16 the regulations.
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17 MR. CASE:
It will only be in those areas.
N 5
18 COMMISSIONER HENDRIE:
Category 2.
c 19 MR. CASE:
Right.
You have authorized us, if not 20 directed us, to take that position in hearings.
We will clearly 21 indicate that this is not supported directly by any particular 22 regulation and it is subject to a challenge.
23 MR. BICKWIT:
Mr. Chairman, in uncontested matters the j
I 24 '
Commission has taken that position in effect, and the staff comes 25 in and says, "These are the NTOL requirements."
t ALDERSON REPORTING COMPANY, INC.
14 1
CHAIRMAN AHEARNE:
I understand that.
2 MR. BICKWIT:
We understand that, and we are looking 3
beyond the regulations.
4 CHAIRMAN AHEARNE:
I am just trying to get clear in my
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5 own mind the transformation regulations.
h l
6 COMMISSIONER HENDRIE:
Furthermore, I am not sure as a R
7 practical matter how long we really need suffer with a group of M
8 Category 2 requirements which are identified by all of this as d
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going beyond the regulations.
Once we get that identification 10 and a briefing from you on it and think about it, it seems to be j
11 sensible for us to move ahead and start a rule-making proceeding u
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12 on the Category 2 requirements.
5 13 CHAIRMAN AHEARNE:
Maybe graphs, etc., are under way.
14 One of the things we tasked out of that whole flow of many items g
15 was to develop requirements.
a 16 MR. CASE:
And this under the bills will indicate that g
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17 all those rules are under way.
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18 CHAIRMAN AHEARNE:
Right.
P 19 MR. SKORHOLT:
Well, the information generated in this 20 first phase on these 217 sections was enormous in volume and we 21 tabulated it different ways.
The next slide is just an example 22 of one page of one of the matrices.
23 This particular ones shows numbers of SRP sections 24 across the top, and then down the left side on the ordinate there 25l are regulations.
As you see, sometimes there are si'ngle sections ALDERSON REPORTING COMPANY, INC.
15 1
of Part 50 or Part 20; sometimes there are groupings of sections, 2
and et the bottom of the page you start off on the general design 3
criteria.
t 4
The doodle marks in the page I don't plan to go into,
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5 it is just a series of code symbols that we developed to kaep track E
6 of what is being proposed in a short-hand manner.
But we have R
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several dozens of pages like this and matrices.
Kl 8
MR. CASE:
What generally the symbols say, it has to be dd 9
improved in this area.
You might explain.
i h
10 MR. SKOVHOLT:
Oh, yes.
The symbols reflect the Ej 11 information that we generated earlier, the regulation exist or D
12 does not exist; it should be modified because it exists but not b
13 well enough; or it should be added.
5 l
14 COMMISSIONER HENDRIE:
The SRP should be adjusted.
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15 MR. SKOVHOLT:
The SRP should be adjusted to show the U
16 requirement.
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17 I think a slightly more understandable chart is the E
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18 following one.
The next slide, please.
0 19 This related particularly to the first of the objectives, X
20 the congruence with regulations where we have tabulated for each 21 SRP section with findings as far as what ought to be done and 22 what exists in terms of references to rules and regulatory guides.
l 23,
For illustration, just taking the top line for SRP l
24 Section 3.9.6, which is handled by mechanical engineering, they 1
25l indicated that there are currently five references to the ALDERSON REPORTING COMPANY, INC.
1
16 1
regulations in the acceptance criteria portion.
2 There is one other that should be added, and all five of 3
the existing ones ought to be modified to be made better..
4 The evaluation plannings, there are six curreritly 5
referenced and all six of them should be modified.
There are no k
0 regulatory guides existing in this SRP section, nor are there any G
7 that are applicable to this subject matter.
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8 The other numbers are.all on the same lines, and there d
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are many pages of this.
I have totaled them up on the next page 2
10 to try to give an appreciation o'f the impac't of what doing this
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11 exercise will accomplish.
For the 217 sections - and I might say, Ls
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12 these are preliminary numbers - the numbers are going to change, S
13 5
of the references,as the writing is done and different decisions u
14 are reached.
But as far as order of magnitude, I think this does 15 the trick nicely.
d 16 In the 217 sections there are currently 420 references as h
I7 to rules.
And by references I mean actual citations of the a
18 section number or criterion number.
There should be added 459 h
I9 references in the acceptance criteria.
g 20 Now, that number can be misleading if you don't appreciate 21 what it means.
In virtually all c'ases the subject matter is j
22 there.
The requirement has either been discussed, or it has been 23 ; paraphrased, or it may even have been quoted.
But unless there 24 was a citation to it we say it needs to be added. There are 157 25 ' modifications, and then the numbers in the other columns are the l
l ALDERSON REPORTING COMPANY,INC.
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same way.
2 So, we will be either approximately doubling or trebling 3
the number of' citations through this exercise which, I think, will i
4 more clearly establish the congruence to the regulations.
The-5 congruence already exists to a very high degree, but this will l
6 improve the situation.
7 CHAIRMAN AHEARNE:
My point again, there will at some Xl 8
point then also be something that would enable you to go down d
c 9
through the regulations and simply verify, as your matrix says, 10 that the regulations are referenced everywhere.
II MR. SKOVHOLT:
Yes, sir.
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12 Newi as far as.'what does this mean in terms of the s
13 j
changes to the SRPs - next slide please - we characterized it 14 this way, based on the initial scoping sexercise:
About 126 of l
15 the existing SRP sections will only have references to rules, a
j 16 regulatory guides, and TMI-related items added to it.
Since these as h
I7 are considered to be already approved documents, it would be an a
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18 easier exercise than the one which involves new changes.
l E
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Ten sections will have the basic kinds of changes plus O
editorial or clarification needs that have been identified.
Six 21 sections will have the basic changes on rules and TMI, and 22 result comments that have been received because these six sections have bn.en published as proposed Standard Review Plan revisions, public comments have been received on those.
25 I i
Another eight sections will have the basic changes plus, ALDERSON REPORTING COMPANY. INC.
i 18 i
they will be're-arranged or re-assigned largely because of the 2
NRR reorganization, but partly because of new subject areas, 3
particularly in the human factors area which was nct previously an 4
explicit part of the review.
There will be 67 which are proposed to have either new
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6 or revised regulatory positions put into them.
These 67, of R
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course, are going to be the ones that get the major attention in 8
the management review process.
dd 9
We do not plan to introduce any new or revised position i
h 10 that has a substantial impact into this revision effort.
In order E
j 11 to get a complete, effective, revised Standard Review Plan in April D
d 12 of'1981, we must go directly to the effective publication route E
and not go through the public comment process.
13 E
E 14 We feel that any new position of substantial impact u
2 15 should go through the public comment process.
So, we will just U
16 hold that until the next revision effort which will begin after sW G
17 April.
E 18 CHAIRMAN AHEARNE:
Don, I am really ignorant in this b
19 area so, if you could explain to me.
When you go on public 20 comment for a revision of the Standard Review Plan, in what way 21 is that couched,.that this is a proposed way that the staff will 22 use to review against regulations X, Y, Z?
23 MR. SKOVHOLT:
No, it has not been.
It is a fairly new l
l l
24 policy.
First of all, initially the Standard Review Plans did not l
25 Igo out for public comment, they were just published.
In mid-1978 ALDERSON REPORTING COMPANY, INC.
19 I
the office changed its policy and said, "We are going to publish 2
these as proposed," very similar to the regulatory guide process.
3 The ones.that have been published have not been labeled for 4
interim use, they have just been published as proposed.
5 MR. CASE:
And this was before the' importance of
$6 connecting them with the regulations was made evident, but it was
^<.
R 7
in the context that this was going to be a new revision of the Nl 8
Standard Review Plan and we felt that everybody understood the dd 9
context in which the Standard Review Plan was used.
How many did i
h 10 we do that way, Don?
Ef 11 MR. SKOVHOLT: 'Six were proposed.
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12 MR. CASE:
Before TMI, this was all pret-TMI; was it S
13 not?
5m l
14 MR. SKOVHOLT:
Well, they were all written before TMI, n
2 15 but some of them got published afterwards.
d 10 But I think this is an important point and we do want 2
g 17 to preserve the policy of getting public scrutiny on things of w
18 significance.
But we also have to get this Standard Review Plan e
19 up to date because the longer it stays in its current situation 20 it is not accomplishing its purpose.
21 COMMISSIONER BRADFORD:
In the longer run, do you see a 22 need for both reg guides and the Standard Review Plan?
Would it 23, be possible to say in the Standard Review Plan it is an acceptable 24 way of doing things to do the following?
i 25 MR. SKOVHOLT:
Well, it would be theoretically possible.
I AL.DERSON REPORTING COMPANY, INC.
20 1
It would erlarge the scope of the Standard Review Plan enormously 2
if all the contents of reg guides were published in them.
3 COMMISSIONER HENDRIE:
I think they are really comple'-
I 4
mentary documents.
The Standard Review Plan is a direction.to the 5
reviewer saying in a given section, "Here is how you go about g
9 3
6 reviewing it; here are the bases, and here is a proto-typical
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7 evaluation of finding that you ought to be able to come to."
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from which the whole things flows, but reg guide has more detailed, i
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11 way to do it that is acceptable."
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12 Now, the standard review plan started out and we found S
a number of areas where there were not reg guides that one could 13 5u g
14 reference, but where the staff pretty well made up its mind was e
15 at least one acceptable way of coming out, and so there were a d
16 batch of things we created, branch technical positions which were w
6 17 then often attached as appendixes to individual review plans.
S 18 Over time one would hope that the branch technical 19 positions would become reg guides and just be referenced, but a
20 they are not quite the same kind of document.
I think they really 21 are complementary rather than duplicative.
22 CHAIRMAN AHEARNE:
The branch technical position does not go through the same kind of a review that the reg guide does.
23 24 COMMISSIONER HENDRIE:
No.
When we put those things 25
! together in '73-4 and finally got them out in '75, there were a ALDERSON REPORTING COMPANY, INC.
21 I
whole batch of positions the staff had taken on some cases, or 2,
positions they were getting ready to take on the next case.
3 The reviewers, the engineers had made up their minds what they 4
thought was one good way of doing it.
We just cranked those things e
5 in every place we could get them written down.
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6 MR. CASE:
And in theory, after that, all approved R
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branch technical positions were either by reference in the Standard.
Xl 8
Review Plan, or were not approved.
They should not be used now.
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CHAIRMAN AHEARNE:
Has there been any tendency to, as i
h 10 J6e said, toftransform those into regulatory guides, or has there El 11 been a reluctance or a desire to use branch technical positions?
D y.12 MR. CASE:
There is a general feeling on the standards S
13 part that branch technical positions are a little bit too detailed 5u l
14 for regulatory guides. So, there have not been many that have g
15 made reg guides.
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16 COMMISSIONER HENDRIE:
Some of them have gone across, d
6 17 MR. CASE:
Yes, a few have.
But those that are under M
18 the Standard Review Plan are used with the same effect as a 5
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19 regulatory guide.
But we try, from a management standpoint, not n
20 to int branch technical positions, new ones, be created and used 21 except through the Standard Review Plan process.
As an amendment 22 or a change to a Standard Review Plan a branch technical 23 position might be approved, but make it go through the public 24 comment process.
25 I So, we have tried to discourage, if not prohibit branch ALDERSON REPORTING COMPANY, INC.
1
22 I
technical positions that were just developed by the staff without 2
any management' reviews, any additional ones, nor public comment.
3 MR. SKOVHOLT:
One other item that is relevant to 4
Commissioner Bradford's question, though, is one item we,did start e
5 to explore and which has sort of been put on the shelf because b
6 of this crash revision program.
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7 We had initial dicsussions with the Office of Standards Xl 8
Development to try and come up with some kind of meclanism where do 9
as a regulatory guide is published - either a new guide or a new
,z 10 revision - we can somehow simultaneously republish the associated
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g 12 closely together.
5 13 COMMISSIONER BRADFORD:
With regard to the '67 revisions, 5a l
14 when you say that there will be nothing new in the."e, do you mean,-
U 15 for example, the TMI requirements are in a sense new.
d I6 MR. CASE:
They are not in that category.
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17 CHAIRMAN AHEARNE:
They are proposed SRPs.
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18 MR. SKOVHOLT:
There will be a number of things.
E 19 COMMISSIONER BRADFORD:
What I am after is, does "new" 20 there~really mean something that we have not been doing up to 21 or does it mean things that we may have been doing in the now; 22 form of branch technical positions, or something?
23 MR. SKOVHOLT:
The staff proposals include both kinds 24 of items.
Now, this is where the management review and decision 25 as to whether or not we want to include it in this revision effort ALDERSON REPORTING COMPANY, INC.
23 1
is going to come in.
But tihe kinds of things in this category 2
might be positions that have been applied in the last four or 3
five cases, that just had not found their way into the Standard i
4 Review Plan yet.
So, they are new in the sense they are not in 5
the SRP, but they are not truly new from the standpoint of a j
6 regulatory posture.
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7 Other things, such as co-case rulings,.like the'SME.
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Once they make a co-case determination it is generally accepted.
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10 But there are also some proposals from the staff to 5
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actually add new and perhaps radically different requirements and, o
f I2 I am sure a number of these are going to be screened out and held ca 13 5
for the next revision effort because they are too substantive u
l 14 to go through this process.
15 MR. MURLEY:
Can I make a point along those lines?
ij 16 The '67 items, I think it is important to point out, al h
I7 when you take the old Standard Review Plan and the new one, they x
IO will look significantly different.
To someone who has not g
followed the staff actions over the years it is going to appear 20 i
to be a giant ratchet.
21 But the fact is that these are meant to be changes that 22 have been used in the past.
I think our rule of thumb is applied l
on three cases; is that right?
I MR. KSOVHOLT:
Yes.
MR. MURLEY:
So, if it has been used by the staff'on l
l l
ALDERSON REPORTING COMPANY, INC.
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at least three cases, it will show up here and therefore document 2
staff practice.
But there are going to be significant deviations
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4 CHAIRMAN AHEARNE:
Joe, I gather from what you have 5 ll said on other occasions., that that philosophy was underlying the h
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original ones.
R 7
COMMISSIONER HENDRIE:
Yes.
Kl 8
CHAIRMAN AHEARNE:
And then some.
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MR. CASE:
But even more, in Commissioner Hendrie's 10 version, there was an outreach and there will be in this one.
E II COMMISSIONER HENDRIE:
There wasn't any limitation to u
y 12 having only things we have done on three cases.
Some of these 5
5 13 three cases come up at the next three future cases.
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14 (Laughter.)
n 15 COMMISSIONER BRADFORD:
Let's see, if I have understood t[
16 that - the three cases - correctly, it is, I think, a little d
17 different than the definition of the Standard Review Plan that a
18 we approved, the revised Standard Review Plan that we approved on 5
19 the last go-round, which was going to reference all documents 20 and all staff positions.
21 MR. CASE:
Yes.
But unless something has been approved 22 by management, it is not a staff position.
So, I think they are 23 completely consistent.
24 COMMISSIONER BRADFORD:
I see.
It may be used in 25l practice, but it is not a staff position until then.
Okay.
I 6
ALDERSON REPORTING COMPANY. INC.
25 I
MR. SKOVHOLT:
Phase 1 was to gather all the information 2
as to what ought to be done in this program.
That is what I have 3
addressed so far.
4 Now, the next slide will get to Phase 2, which is the e
5 "doing" of it, the rewriting of these things.
This actually 5
l 6
started in the fall.
The primary responsibilities are on a G
7 primary review branch to handle its sections in consultation with Xl 8
the secondary review branch, or branches, as appropriate.
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9 MR. CASE:
You*might' explain-that, primary, secondary.
2 h
10 They are not duplicating each other.
El 11 MR. SKOVHOLT:
No, no.
The Standard Review Plan talks D
g 12 about a technical topic, or it might be a system of the plant S
5 13 or particular kinds of calculations, what have you.
u l
14 Many times performing the work under that Standard Revieu g
15.
Plan is all within a single branch.
The branch has the expertise a
f 16 and has the assignment to do that kind of thing.
So, in that e
6 17 case that branch is the primary review branch and there are no y
18 secondary reviewers.
e 19 g
But in other cases the subject matter cuts across n
20 disciplines and more than one of the technical review branches is 21 needed.
So, one branch is designated as primary and the others 22 are designated as secondary reviewers, each within a clearly 23 i defined scope of evaluation.
They feed their inputs into the 1
24 primary branch so that the project manager is given a coordinated 25 package.
ALDERSON REPORTING COMPANY, INC.
26 1
This first step, though, in magnitude, there are over 2
a hundred different technical reviewers working on this thing 3
among these 217 sections.
These people are in 25 different branche s.
/
4 MR. CASE:
That has its virtut,, too.
One could conceive e
5 of a program where you just gave it to one fellow in each branch 5
l 6
and that would be his opinion as to what the current review R
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process is and what ought to be done.
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8 We didn't put any limitations on how it should be d
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done and, as a result, we have a hundred' people involved which,lI z
h 10 think, is a fair representation then of the rank and file and their 11 view of the review process, which is important in this effort k
y 12 because ultimately - and I do not think we will be able to make 5
5 13 it in this revision because, as Don pointed out, we won't get all u
l 14 of the proposed positions in.
15 I want to get the Standard Review Plan in a shape that g
16 it is not only a necessary document for staff purposes, but a w
h 17 sufficient document.
Now, this is just, in effect, a staff a
f 18 discipline document where our requirements will be only these
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g given in the Standard Review Plan.
20 CHAIRMAN AHEARNE:
By sufficient, then, you would mean 21 from the standpoint of NRR meeting the regulations would be 22 synonymous with meeting the SRP.
I 23 MR. CASE:
Well, I see a lot of advantages in this 24 document.
I think the people working on it are very enthusiastic.
25 I think it is going to get it up to date, a much more workable ALDERSON REPORTING COMPANY, INC.
1
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27 1
document, and it has a lot of uses for the future if properly 2
put together.
I think this procedure will do it.
3 MR. SKOVHOLT:
To assist and guide the efforts of these t
4 hundred and some people, the Division of Safety Technol6gy
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5 performs this guidance and tries to exercise the QA function, 3
0 and is of course working very closely with OELD in developing 7
the guidance and the sample words.
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O When the branche's have done their work it is passed d
o; 9
up for approval by the division directors of the primary and 2
10 secondary review branches.
Then it comes to a focal point in 3l 11 Safety Technology where there is an independent review of these D
g 12 sections, particularly with respect to the new or revised 5
5 13 positions, the last category on the previous slide, to make the u
b I4 judgments as to whether or not a) the new revised positions are 15 indeed desirable at all; and b) whether or not they be included a
y 16 in this revision effort or held for the next one.
el II The Director-of Safety Technology and then subsequently a
II the Director of the Office of NRR will approve those things.
E II As far as the schedule for doing these things, which j
g 20 is, I am sure, of great importance to you, it is after Step 2 21 when the division directors have approved these things that we 22 really come to a focal point where we can exercise control.
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1 ALDERSON REPORTING COMPANY, INC.
28 I
MR. CASE.
'fhy don't you put the slide up?
2 MR. SKOVHOLT:
Okay.
Put up that slide that is labeled 3
" extra," please.
4 (Laughter.)
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This is really the same thing that was H
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on the previous slide, but it is slightly more complicated.
If 3
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" Review and approval by section leader, branch chief, AD
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10 also gets cycled through the secondary review branch, SRV, if E
E Il there is one.
Otherwise, it goes directly to the License and ir f_
12 Guidance Branch in DST.
S 5
13 The milestone I am focusing on is when that document a
l 14 gets handed into the License and Guidance Branch.
h 15 MR. CASE:
Don, what I really meant was that slide that U
if 16 has the number of sections per week.
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I7 MR.'SKOVHOLT:
Oh, no, I did not have that on a slide.
18 Essentially, what. it provides is, beginning with the first h
I9 r
week in January and extending into the first week in March, if n
20 we are going to meet the April publication schedule that we are 21 working towards, we will need about 23 sections per week - give 22 or take - flowing into that milestone, beginning with last week.
23 Based on our first week's experience we are slightly 24 behind that.
We have five, rather than 23.
I 25 CHAIRMAN AHEARNE:
Hopefully, you are going to build on itc ALDERSON REPORTING COMPA NY, INC.
29 1
MR. SKOVHOLT:
We are going to try to pick it up in 2
the stretch, I think.
3 ME. CASE:
Well, it has just gotten to the point where 4
we can st' art measuring progress.
Harold and I are going to get a
5 together with the division directors and see where we are; where 5l 6
the hold-ups are, what can be done abouu meeting this schedule.
R R
7 COMMISSIONER BRADFORD:
What is the good news you 2l 8
mentioned?
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9 MR. BICKWIT:
The April '81 date.
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10 CHAIRMAN AHEARNE:
The good news is the thoroughness 3l 11 with which the process is being done.
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12 MR. CASE:
Yes, I think so.
This is an opportunity for 5g 13 the Commission to provide guidance as to how important it thinks u
l 14 it is, in meeting this date because I am not here to say to you 2
15 that just by meeting xif the division directors they are going to g'
16 find new people to do this work and it will be done at the expense as
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18 CHAIRMAN AHEARNE:
Well, I think it is a little early E
19 yet --
20 MR. BRADFORD:
For Ed Case to start his speech.
21 (Laughter.)
22 CHAIRMAN AHEARNE:
You know, you have had your first 23 week's return and, as I think either you or Harold mentioned l
24 yesterday, the first week did not match the average that you 25 ! expected, but you got to see what the system is shaking out.
I L ---
ALDERSON REPORTING COMPANY,1NC.
30 I
would guess that Bill will monitor that and, if in the next couple 2
of weeks it looks like things really are running into snags, then 3
he will ask us to decide.
4 MR. SKOVHOLT:
I think I have a pretty good finger on
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5 the pulse of the reviewers.
I talk to a dozen of them every day 5
6 and frankly, their problem is, what is most important.
They are R
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not getting done what they had planned and expected to get done X
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because their branch chiefs or section leaders are coming along d
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say'ing, "This case has slipped, we have to get it going," er i
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So, the problem is there.
El 11 CHAIRMAN AHEARNE:
William will look at that.
D y
12 MR. DIRCKS:
I had not heard about these problems 5
5 13 until yesterday.
They have accelerated today.
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14 (Laughter.)
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15 MR. DIRCKS:
I think that is something we will have j
16 to straighten out.
W 6
17 CHAIRMAN AHEARNE:
Why don't you look at it.
5 18 MR. DIRCKS:
Not only in this area, but if there are O
19 problems in any other areas.
gn 20 COMMISSIONER BRADFORD:
Can you give us a description of 21 what the competing goals seem to be?
22 CHAIRMAN AHEARNE:
I guess a very simple one of the 23 competing issues is that there are a bunch of plants that also l
24 ar,e being reviewed.
Obviously, the peop.le who are most 25 knowledgeable on how to review plants are those that are asked bota ALDERSON REPORTING COMPANY, INC.
31 1
I to review plants and also to revise and update the Standard Review
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2 Plan.
3 COMMISSIONER BRADFORD:
I am sure that is one of the 4
problems.
e 5
MR. DIRCKS:
It is across the board, the issue and the h
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action plan, the business on the unresolved safety issues.
7 MR. CASE:
I think it is principally a case of Xl 8
competition.
Y-o 9
CHAIRMAN AHEARNE:
I don't think this is the right
,2 10 place to try to adjust resource allocation.
Bill, if you will E
Q II look at that, itj 12 MR. SKOVHOLT:
That completes the presentation.
s 13 COMMISSIONER BRADFORD:
I thought that was the wrong 5u l
14 back-up slide.
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15 MR. CASE:
He does not have that one.
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I6 COMMISSIONER BRADFORD:
Oh, I see.
ad II CHAIRMAN AHEARNE:
Joe?
m 18 MR. CASE:
It just shows which branch has to deliver E
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how many Standard Review Plans on what dates, and then add them 20 all up per week, and generally shows an average of some 20 per 1
21 geek you have to get out between now and March in order to get 22 the job done.
23 CHAIRMAN AHEARNE:
Peter, do you have questions?
M COMMISSIONER BRADFORD:
Let's see.
Is the job turning out to be in any other ways different from what you had expected?
ALDERSON REPORTING COMPANY, INC.
32 1
1 It is, I guess, foreseeable that there are going to be resource
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2 crunches.
Is it in any other ways different or modified from the 3
way the Commission described it a couple of months ago, three t
4 months ago?
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MR. SKOVHOLT:
Not to my knowledge.
It is trying to E
6 give you exactly what you are looking for.
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7 (Laughter.)
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8 COMMISSIONER BRADFORD:
There have been a number of d
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briefings that went less well.
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10 MR. DIREKS:
I think in fairness, as you get into it,"
j 11 the practicalities come into play.
I guess, Don, you were talking u
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5 13 sifting through various statf opinions and proposals, and screening a
l 14 out.
That is always more difficult in practice than it is in U
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16 COMMISSIONER BRADFORD:
I was going to ask about that.
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17 Can you describe a little more the management review process that
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18 will go into deciding?
Is it as simple as saying, "Has this E
19 been used in three cases,- and if so, it's in.
If not, it can't 20 come in yet."
21 MR. CASE:
I doubt it is that simple.
That will provide 22 f
the general breakdown, and then there will be arguments on the 23 other side of that question.
Even though it wasn't, we really l
24 are now completely convinced it has to be done.
Everybody else 25 !
agrees with this.
You will get those kinds of shades.
l ALDERSON REPORTING COMPANY, INC.
33 1
COMMISSIONER BRADFORD:
And then that decision gets 2
made ultimately where, at your level?
3 MR. CASF:
Yes, it will ultimately be made by Harold, 4
based on recommendations from the reviewing branch and its e
5 division director, and an independent review by Safety Technology.
5l 6
So, there are competing forces involved.'
Through that G
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the matter.
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9 MR. BICKWIT:
I am still not clear exactly what this z
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Does it include situations where pou.have E=*
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5 13 to have to revise the plan to make it congruent?
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i 14 MR. CASE:
No, no.
15 MR. BICKWIT:
Does it include a situation where the d
16 staff position is one that you need to revise the SRP, but you w
h 17 have not put that out for comment?
b 18 MR. CASE:
That would be one of those who had put it P"
g '19 in that category for further consideration.
l 20 MR. BICKWIT:
Is the staff position then applied to the 21 new OLs, even though the plan is not revised?
22 MR. CASE:
Not without further management review of I
23 the position.
You get into all kinds of categories where you 24 will say, "Well, okay, pending further review, you can use this" 25 '
because you have to get on with cases, you can't stop the whole ALDERSON REPORTING COMPANY,INC.
34 1
Process.
Some will be like that.
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2 MR. BICKWIT:
My only concern, I guess, is that if the l
3 staff is of the view that certain things ought to be done with 4
respect to the new OLs, it sounds to me imprudent not to have it.
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5 done because you want to get public comment on it before it is Hj 6
done.
W'll, they are more things that you would 7
MR. CASE:
e Xl 8
handle on a case-by-case basis.
There is no set, approved way d
d 9
with no further argument.
There is more a case-by-case approach i
h 10 until you get the opportunity to change the standard.
11 MR. BICKWIT:
I was just concerned about the represen-d 12 tation that with respect to these 67, they are not going into E!
the SRP,because you want to get comment on them before they do.
13 5
l 14 MR. CASE:
Therefore, I am not in a position where I n
2 15 can say to the staff, "These are not only necessary but sufficient 5
16 conditions.
Here was an area that we wanted co advance further dw 6
17 and didn't get that far.
So, you have left it case by case, so E
18 I can't sign off without that area being resolved."
E 19 COMMISSIONER HENDRIE:
It is not that the 67 are not R
20 going in the revision, they are going in the revision.
The 21 comment was that some of those may be decided that they ought not 22 to go in at this stage, and there may be some others.
23 MR. BICKWIT:
The 67 are going to go in?
24 MR. SKOVHOLT:
The 67 have been proposed.
They are 25l going to include either new or revised positions.
Some of these ALDERSON REPORTING COMPANY, INC.
35 1
we may adopt in this program, and some we may hold over for the 2
next revision, depending on the impact they would have.
3 MR. BICKWIT:
Just one other question.
I didn't under-4 stand your objective, Ed, to make this a sufficient document as e
5 well as a necessary document.
I l
6 MR. CASE:
Well, it will be used for a guidance too, if 7
you will, depending on 'how~ the guidance is applied.
I can see Nl 8
project managers using this by reviewing SER inputs if the d
o; 9
position is above that required by the Standard Review Plan, z
h 10 raising questions back through their~ management, to the reviewers' Ez 11 management as to why is'this different.
D y
12 I can see it used as, "Are the questions that you are 5
5 13 asking what SRP section are they applicable to."
You use it u
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15 significance outside the staff review process, any legal u
j 16 significance.
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No, I understand that.
But are you saying a
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18 what you hope for is a document that would be a way to comply h
19 with the regs?
20 MR. CASE:
Yes.
21 MR. BICKWIT:
Or are you hoping for a document that 22 will be the only way?
l 23 MR. CASE:
No, "a" way.
If that way is proposed, then 24 the staff's job is done by definition.
l 25 MR. BICKWIT:
All right.
I ALDERSON REPORTING COMPANY, INC.
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36
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COMMISSIONER BRADFORD:
Would that mean using the
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2 whole Standard Review Plan?
Correct me if I am wrong, but I 3
understood that at least on the reviews to date the decision would f
4 be made as to what sections were important to use for which plants,
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5 MR. CASE:
I am not quite sure how your question comes 5l 6
into it.
7 COMMISSIONER BRADFORD:
If you have a plan laid out X
j 8
and it is a matter of review of a nuclear power plant application, dd 9
as I understood it, when an application came in, historically i
h 10 there would be a meeting or various meetings, and people would El 11 decide which sections were significant for a particular plant, l
D j '12 and perhaps even within individual sections which particular S
5 13 pieces had to be actually reviewed.
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14 In some cases the basis would be that. the same system.
2 15 had been reviewed in another plant therefore didn't need to be d
y 16 reviewed here.
But for other purposes essentially the audit w
d 17 principle would apply,if a particular piece was adequate it U
{
18 would be assumed that other pieces were also adequate.
E 19 Now, with the new plan, do you see it still working M
20 on an audit basis?
21 MR. CASE:
Yes.
22 COMMISSIONER BRADFORD:
I~have confused two principles, 23 really.
It is one thing to say the system has been reviewed 24 somewhere else and therefore need not be reviewed here.
But that 25 ;
aside, it is another to say, "Well, parts 1, 2 and 3 are okay, 1
t ALDERSON REPORTING COMPANY. INC.
- - ~
s a
37 I
so we will assume 4, 5 and 6 are too."
(
2 MR. CASE:
You would still do it that way.
,3 CO!!MISSIONER BRADFORD:
You would still do it that way.
4 MR. CASE:
I thihk you might do a better audit or, even 5
given the same amount of manpower, a broader audit because there 0
are more clear ways of satisfying.
So, that does not have to be audited, and it makes that manpower which might audit that area 7
2 l
8 available for auditing'other areas.
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9 Then, if I combine that with the other initiative we z,
10 were talking about yesterday, which involves applicants identifying E
II where they deviate from the Standard Review Plan, I take another ti f
I2 task off the reviewer which is searching through their application S
g 13 trying to find this information himself, and therefore can devote h
I4 more time to those areas where they are' different from tihe
$i!
15 standard.
I think you get a better review out of that, too, a
d 16 more effective and efficient.
ad h
II CO!!MISSIONER BRADFORD:
Can you just relate the Standard z
IO Review Plan revision schedule as you discussed it today a II g
little bit to the discussion we had yesterday?
20 That is, I take it if there were serious slippages in II the updating of the Standard Review Plan, that would have --
22 MR. CASE:
I think it would have a one-to-one slip 2
to the other.
COMMISSIONER BRADFORD:
That's right, once you start 25 tying all those programs together.
ALDERSON REPORTING COMPANY, INC.
I 38 1
COMMISSIONER HENDRIE:
I assume that April 1, 1982
(
2 date we talked about yesterday may not be April 1, but is in fact 3
one year from whenever,today's, I think we talked about today's 4
around the table.
i.
5 COMMISSIONER BRADFORD:
So that this really has a more b
6 significant priority than it might standing alone.
7 CHAIRMAN AHEARNE:
Victor?
Kl 8
COMMISSIONER GILINSKY:
No.
d ci 9
CHAIRMAN AHEARNE:
All right.
Thank you, gentlemen.
2 h
10
.We are.~ going into an~ affirmation'.sessionL.We.will have El 11 td 'take: a short Break.
We went through thic more expeditiously U
y 12 than planned.
We will take a five-minute break.
S 13 5
(Whereupon, at 3:20 a short recess was taken, and u
l 14 the Commission proceeded to other business.)
2 15 U
16 dw(
17 5
bi 18 b
19 R
20 21 22 23 1
24 25 l
t ALDERSON REPORTING COMPANY, INC.
i
O NUCLEAR REGULATORT COMMIS,SION Tais is to 7.ertify that the attached proceedings before the COMMISION MEETING in the metter of: Briefing on Status of Standard Review Plan
- Date of Proceeding:
January 15, 1981 Docket Kumber Place of Proceeding:
washington, D. C.
were held as herein appears, and. that this is the original transcript thereof for the fila of the Commission.,
M. E. Hansen Official Reporter (Typed)
If =
A bn W s OfficiaI' Reporter (Signature)
U.S. f.:UO!EN: RESULATORY COMMI5510N STANDAf!D REVIEt! PLAN DRIEFIHG JAli. 15,1981 1
0'TLINE J
1.
MAJOR OBJECTIVES OF 1981 REVISION PR(XiRAM 2.
PRIMARY SFAFF ACTIONS - PHASE I A.
IDENTIFY REQUIREMENTS 11 DEVELO? MATF. ICES 3.
SUPPLEMENTAL ST/SF ACTIONS A.
IDENTIFY ADDITIONAL REQUINEMTiNTS P.
DEVELOP REASSIGNMENTS 4.
PROGRAM SCOPE A.
MATRICES B.
SRP SECTION REVISIONS 5.
SRP REVISIONS - PHASE 11 A.
PROCEDURE B.
ScilEDULE O