Text

Unofficial Transcript of 810401 Briefing on Action Plan in Washington,Dc.Pp 1-38
	ML19343C970
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Issue date:	04/01/1981
From:	; NRC COMMISSION (OCM)
To:	;
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ML19343C971	List: ML19343C970; ML19343C972;
References
	REF-10CFR9.7 NUDOCS 8104090001
	Download: ML19343C970 (40)
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In the Mattar of:

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i COMMISSION MEETING.

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Briefing on Action Plan i

I DATE: April'1, 1981 PAGzg:1 thru 38 AT:

Washington, D. C.

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.M R%X REPORTING L,

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Talachena: (202) 554-2345 810 4 0 9 0 0ots

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I UNITED STATES OF AMERICA 2

NUCLEAR REGULATORY COMMISSION 3

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4 PUBLIC MEETING e

5 BRIEFING ON ACTION PLAN h!

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Nuclear Regulatory Commission g

Room 1130 j

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.1717 H S tree t, N.W.

d Washington, D.C.

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i Wednesday. April 1, 1981 10 g

The Commission met, pursuant to notice, at 2:30 p.m.

5 11 BEFORE:

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JOSEPH M.

HENDRIE, Chairman of the Commission

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VICTOR GILINSKY, Commissioner 4

E 14 PETER A.

BRADFORD, Commiss2. rer I

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JOHN F. AHEARNE, Commissioner I

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NRC STAFF PRESENT:

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LEONARD BICKWIT 5

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5 WILLIAM J. DIRCKS 19 f

HAROLD DENTON i

20 JOSEPH SCINTO 21 DARRELL EISENHUT 22,

JOHN OLSHINSKI c

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ALDERSON REPORTING COMPAN Y, INC.

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The maecing was open en public at==ader= and obserrscian.

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The ~~*?c is *-remadad solaI7 for ganarz.L 1=fst=m**'

purposes.

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If we cou1d come to order.

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The Commission meets this' afternoon for a briefing oc

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4 the Action Plan.

It's one of those historic subjects that we e

5 haven't dealt with directly under that title for a while.

Last 5l 6

summer, as a matter of fact -- January 15.

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7 There are some issues at hand in connec. tion.with the Xl 8

Action Plan that we need'to hear about as well as general back-d d

9 ground on where we stand.

Yg 10 And, hopef'ully, then, this briefing will prepare the E

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11 way for some Commission guidance to the staff.

<m r5 12 Bill, please go ahead.

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13 MR. D RcKs:

D rrel will c rry the burden m

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But I do want to confirm what I told the i'!

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2 15 Commission yesterday about the conversion of 0737 to a rule.

g 16 That is on schedule and will be down to the Commission by April

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17 17th., And that's the application of the 0737 to operating

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19 You should have that.

There's a burden on that one, g

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So call him about it.

21 MR. DENTON:

There are thirty five items we wanted to 22 l discuss today.

This is the next wave of dated requirements and v

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23 ' we h ad sent 5054F letters to all the operating plants last fall 24 l to try to achieve voluntary compliance with those dated require-l 25, ments in a fashion somewhat similar to what occurred last year I

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about this time.

We did achieve a lot'of voluntary compliance I

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2 with those dated requiraments in a fasion somewhat similar to 3

what occurred last year about this time.

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Va Gid achieve a lot of voluntary compliance, but there 5

j were a few recalcitrant licensees.who, for one reason, wanted to n]

6 do A c differently or on a different date so what we are seeking R

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today, af ter we've explained the situation, is your concurrence X

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to move under appropriate orders to achieve compliance with the d

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next wave of TMI Action items that come due on this list of 35.

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10 That's a preface.

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k II MR. EISENHUT:

I'd just like to set the framework 3

f I2 very shortly.

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3 13 Could I have the first slide?

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This is "just a rough outline of what we are going to e

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15 briefly go through -- not going back into details.

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I6 Could we go to the second slide?

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I7 l It sort of puts things into perspective to be sure we

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18 are all talking about the same set.

This is really a slide I A

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g think we used mostly back in January.

You remember the Action n

20 Plan itself had a lot of things that were licensee-related for 2I operating plants and some NRC Action pieces.

The licensee pieces l

22 are further expanded into those that are approved, those that are 23[ going to be approved. and those that are deferred.

l 24l If you look at those that are approved for implementa-l 25 tion, 737 was the document we issued last October 30th, which had ALDERSON REPORTING COMPANY, INC.

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c number of things in it that were already issued and this was

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2 revised, clarified, et cetera.

3 We today Ere addressing one piece of that -- that is,

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those that had due datff prior to June 30th, 4

1981.

And we are

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only looking at that set.

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If I could look at the next slide which -- I don't ex-7 pect you to be able to read the numbers --

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COMMISSIONER AHEARNE:

It makes it crystal clear.

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MR. EISENHUT:

What it intends, really, to do is:

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maa ?M time.

Again, you recall:

this is sort 3

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11 of a slide we used before.

It shows the functional time, the

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' required due dates on operating plants.

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E 14 sort of a numbered c6unt of requirements that were put in place a

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15 las t January of 1980.

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16 The briefing today is really addressing the next three a

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17 columns.

There were a couple of items between October-December, y

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18 and a long list of items that were required to be due by January P

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'81.

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You recall last January, when we met, the approach we I

i 22 I were following was to go with -- on operating plants, packages of i

23 ' orders, breaking of f, first, this group of items where there are 24 ; no items which require shutdown of facilities.

g 25 You will see below the line as you go on amp, we first 6

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start picking those up in July of this year. -

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2 This items were largely characterized as procedural 3

items, ' manning type items and reports ' due to the NRC.

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4 a raw re seem waion was resuired in this see.

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COMMISSIONER BRADFORD:

Darrell, are you saying those 4

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three columns don't contain items requi.ing shutdown?

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MR. EISENHUT:

That is correct.

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8 COMMISSIONER BRADFORD:

Now, af ter the first column, d

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the "previously implemented", how can there be things in that i

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11 MR. EISENHUT:

I'm not sure of the question.

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12 COMMISSIONER BRADFORD: Well, take, for example, the E

, ~N 13 first item which may require shutdown.

It's both -- it's among

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15 l column "previously implemented".

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Like 1. A. l.1 or --

W 17 COMMISSIONER BRADFORD:

Well, II.E.1.2.

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18 MR. EISENHUT:

II.E.1.2 -- do you see a little "p" 5

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19 behind it?

That means it's part of that item.

And that item i

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20 had -- I'm not sure what -- I don' t even -- I'm not sure what the 21 specific item is, but it's immaterial.

What that item had --

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22 ; okay.

It's an auxilliary feed-water system, automatic initiation.

23 ' That item had, you will recall, a control grade item that had to 24 i be put in place by January 1, 1980.

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Safety grade had to be put in place at a later time, t

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which I believe is July 1,

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2 So there are actually multiple requirements.

3 COMMISSIONER BRADFORD:

I see.

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4 MR. DENTON:

S ubsections.

5 COMMISSI'ONER BRADFORD:

Okay.

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6 MR. EISENHUT:

And that's what the little "p's" mean e

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in the handouts.

That means there are some sub parts, even under Xl 8

a sub-item, due to functions of time.

We had to keep track of d

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them, because dhat's really the way they are being implemented.

i Oh 10 COMMISSIONER BRADFORD:

Okay.

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11 MR. EISENHUT:

At this time, what I'd like to do is

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12 turn it over to John Olshinski, who will start a walk through Eo

,3 13 ' the status of where we are -- the plant status in terms of

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2 15 MR. OLSHINSKI:

Next slide, ple as e.

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0737 was sent out and we asked for 5054F responses.

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17 - We have looked at commitment to do the items technically and on 5

18 the schedule as in 0737.

We've reviewed those responses and, t

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19 overall, there's been a great deal of concurrence with the a

n 20 schedules and with the technical positions with the plants l

l 21 generally falling into the categories as shown.

l 22 We will discuss the items that have been omitted -- the 23 January 1st to June items that have been omitted just a little

! bit later as to why they are not included in the presentation.

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i 25 COMMISSIONER BRADFORD:

When it says greater than --

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1 48 plants are greater than 95%, does that include the 35 with O

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MR. EISENHU'T:

Yes.

This is really an indication of 4

voluntary complianc,e.

It helps to look at it ?.n terms of topic --

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plant topics.

There's 35'- 36 items on each plant.

There's like xa

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6 70 plants.

It really says that 35 of the plants agree to all R

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37 or 35 items -- whatever the actual number is.

And, in fact, 3j,8 as you lower the discriminator in terms of accuracy, you find i

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you pick up more and more plants.

io 10 MR. OLSHINSKI:

There are very few items that remained -

Ej 11 outstanding as far as commitment letters were concerned.

More m

y 12 detailed breakdown is the next slide.

It shows each of the 5

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l 14 technically deviated from the position in 0737 and, of course, 2

15 the schedular exceptions.

j 16 Again, the three items which we will discuss in a few s

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Most of the items, in fact, our report says are shown 5

5 18 as far as this first set of items as two asterisks indicates the H

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19 reports -- and a number of the items were something to be imple-n 20 mented at the plant -- either have a design available at the 21 plant or generate procedures and there is one hardware items which 22 we have labelea as -- those are the type of items that are amena-23 l ble for inspection by I & E at 'th'e' plants' on these items.

I 24 i COMMISSIONER AHEA E:

In general, there is an exception i,w

-4Cb bb 25 ; that they have asked for -- weeks, months, years.

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ALDERSON REPORTING COMPANY, INC.

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MR. OLSHINSKI:

In most cases, they are in the order of l.()

2 months or it's just unspecified date -- couple of months or 3

three months on the report.

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4 The general.

Now, there were a number of exceptions.

5 If I could direct your attention to dae next slide -- these are 0

the major -- were the major exceptions.

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COMMISSIONER GILINSKY:

Would you get that previous X

0 slide -

get that other slideoback for a moment?

d MR. OLSHINSKI:

Go back to the previous one?

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The previous slide, please.

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Could you identify the items 3

that involve actual changes in hardware?

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Hardware?

3 14 The actual changes in hardware is -- there's only one.

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That's item II.K.39, which is a PID controller applicable to

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It was taking the PID controller out, m

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18 COMMISSIONER GILINSKY:

The others involve changes in s

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the -- well, for example, containment isolation, I suppose, i

20 changes the logic or what?

21 MR. OLSHINSKI:

Conteinment isolation -- on that one, 22 that is a report --

23 COMMISSIONER GILINSKY:

Why do you have that listed as 24 something amenable to I & E verification?

25 '

MR. OLSHINSKI:

It's a report and a design -- okay?

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And the desien is available to plant.

Didn't ask to 2

see the design.

What that particular item asked for is a re-3 setting of the containment pressure isolation set point to the

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4 lowest set-point that's compatible with operations, basically.

5 They will have the design of how to do that at the plant.

It's 5

0 not to be implemented, I believe, until 1 July.

The design n'

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7 changes they're going to undertake to -- or the resetting changes n]

8 and the procedure changes are supposed to be available at the d*

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plant now, and we are to have a report on it.

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COMMISSIONER GILINSKY:

You said a set-point.

Does

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3 12 MR. OLSHINSKI:

There should not be any hardware 3

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COMMISSIONER GILINSKY:

But you were talking about a

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2 15 design.

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MR. OLSKINSKI:

Well, I should have said " procedures".

6 17 I think that procedures will have to be modified.

az 18 COMMISSIONER GILINSKY:

And what's -- RCIC section.

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.,3 MR. EISENHUT:

Before you leave that point, there's 20 another piece of that -- but you certainly may be used to that, 21 and that is that all licensees, by 1-1-81, had to submit a state-I 22!

ment that the purge valves were meeting containment system 6.4 ;

23 anyone that falls into that category is sealed and verification 24 -

l that it's sealed is performed every 31 days.

l 25 So, although what they send us is just a statement l

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commiting that, in fact, they are doing this.

It is something

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2 that I & E can certainly go out and verify that, in fact, they 3

are doing the plant.

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4 COMMISSIONER GILINSKY:

Well, to change in procedures 5

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-- in the way they are using --

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6 MR. EISENHUT:

The equipment.

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It may not be necessarily a change in the purge valves.

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8 They could have been doing in all along.

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9 COMMISSIONER GILINSKY:

Right, okay.

Eg 10 MR. EISENHUT:

So, in some plants, it is potentially E

11 a change and it is potentially a change that I & E can audit.

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12 COMMISSIONER GILINSKY:

The RCIC section -- could you S

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14 MR. EISENHUT:

Implement procedures and document j

15 verification of the change.

They have to implement a new pro-

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w I7 l MR. OLSKINSKI:

Yes, I believe it's the realignment of a

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18 RCIC -- IC section.

So it's a procedural change, basically.

P" 19 COMMISSIONER GILINSKY:

And the radio iodine monitoring g

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-- I assume it's monitored.

2I MR. OLSKINSKI:

It's a -- have available at the plant 22 a description for iodine sampling reports to us and acceptable

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, sampling criteria where, in 0737, ~ the information that we had 24 asked for as a results of 0737 were any deviations or justifica-25 tions for deviations from the 0737 position.

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So what they've got is a description of their ~fodine '

2 sampling -- how they would go about it -- available at the plant, 3

meeting the 0737 guidelines.

I) 4 COMMISSI,0NER GILINSKY:

Thank you.

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MR. OLSKINSKI:

Yes, sir.

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Although there were now types of exceptions identified X

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to date -- you skipped one.

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Now, this '-- back to this slide.

Although there were o

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some individual exceptions on individuals plants, in general,

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these were the types of exceptions in which we had basically the d

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greatest numbers of exceptions -- one technical on the common E

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refereiice level and three schedular items as far as accident E

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ins trumentation, inadequate, ore cooling instrumentation and ir 15 j

control room habitability items.

T 16 COMMISSIONER AHEARNE:

On that II.K. 3. 27, that was the d

17 only one that was a technical exception?

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MR. OLSHINSKI:

Yes, sir.

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COMMISSIONER AHEARNE:

And you indicated you are not 20 on -- what are you doing there?

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MR. OLSHINSKI:

Well, the ones that are shown here 22 listed on this page are, in fact, the ones that we do not that I agree with the technical exception and there have been discussions 24 '

i with the owner's groups on this and letters going out to them to l

25 { indicate deat, in fact, the common reference level requirement l

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ALDERSON REPORTING COMPANY, INC.

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need be put in place.

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2 The others were basically items in which the licensees 3

chought they may have deviated with the 0737 position and the

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4 staff has reviewed that and found that, in fact, they meet the

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5 intent of the position or meet it to the staff's criteria.

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6 Next slide, please.

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MR. EISENHUT:

I'll make an observation of the last A

8 slide before we leave it.

The reason stated there for the -

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9 scheduled delays -- that is:

the design work is taking longer; Y

E 10 the NRC underestimated the job - ' those really are sor~t of typical E

5 11 of the other schedular deviations you run into.

By and lasge,

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12, you know, tha utilities came back in these specific cases where z

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13 you see the numbers before and there are a few of them that just E

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14 ! presented'some reasonable arguments.of why it may take them two da 2

15 months longer than a normal date but, by and large, sort of a g

16 voluntary compliance, so to speak, has been very good.

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MR. OLSHINSKI:

Next slide on number of items.

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18 Now, because of the number of plants and number of l

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19 requirements -- as we said before, this large number of items n

20l basically -- a little over 2,000 items -- if we break those down 21l and looking at the responses at to when the items will be com-i 22 i pleted -- this

_s time breakdown with, in fact, most of the items i.

23 i having been completed by 1-1-81 with all the items being completed I 24i by 30 June, '81 of this set.

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25 COMMISSIONER BRADFORD:

Okay, so the "after June 6" --

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I ALDERSON REPORTING COMPANY,INC.

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excuse me, the "after June 30, 1981" column reflects only items deferred over into that period $

It doesn't include the nun'ber of

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items that have always been scheduled.

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MR. OLSHINSKI:

That's correct.

There wasn't any -- we 4

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had some April 1 items that went to that late and there weren't bj 6

any items, I don't believe, in June.

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COMMISSIONER GILINSKY:

Not after Juna 30.

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8 MR..OLSHINSKI:

But it doesn't count anything after d=

9 June 30, that's correct.

i o$ 10 Next slide.

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COMMISSIONER BRADFORD:

So dhat, let's see:

as of Jan-

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12 uary tst, then, I would say that almost all the items that were 5=

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13 due to be completed by then were completed?

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14 MR. OLSHINSKI:

That's correct.

That's anout 90% of the d

15 items that were required to be completed, you know, by that time N

have been.

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17 COMMISSIONER LaADFORD:

That's a fairly substantial 18 nwnber of items.

=H" What kind of verification have you all done?

When you X

19 l 20 say something is completed, does it mean just that the paper is 21 in-house or that, you know, that we've really checked through it 22 and made sure it's satisfactory?

23 MR. OLSHINSKI:

As I said, our information, as far as 24, this presentation goes, is based on the licensee's commitmc-t I

25 th at, in fact, he agreed with the item and, in f act, would do i

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that item by that period of time.

COMMISSIONER BRADFORD:

I see.

So that, really, is r'}

unverified, then.

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MR. OLSKINSKI:

That's correct.

4 MR. DENTON:

Why don't you go to the next slide?

We e

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y propose to follow up on that point.

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. MR. OLSKINSKI:

In the presentation, the licensees that S

I basically have agreed to do the items within a particular period 8

9 of time -- such as a proposal to issue' orders -- an order to 9

i 10 pr vide an enforcement basis for that -- confirmatory orders E

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requirement, the proposal would be'to confirm all 1-1-81 items d

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3 with the exception of II.D.1 as being done by 3-31-81 by the end m

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o f March.

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COMMISSIONER BRADFORD:

We're going to issue an order 15

'd n April 1st rdering everything to be done by the end of March?

16 SA (Laughter. )

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18 MR. OLSHINSKI:

No.

It's a confirming --

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MR. EISENHUT:

Let me comment on that.

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E CHAIRMAN HENDRIE:

Talk about stern regulations.

20 MR. EISENHUT:

The package was put together more than 21 i a few days ago 'whenever we were drif ting along before the P-31.

22 23. The principle here -- let me talk about for a second -- rather than the specific date -- is:

the utilities that have committed 24 i

t meet something we think is reasonable -- and " reasonable" being 25 ii ALDERSON REPORTING COMPANY, INC.

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having all items completed by June 30, '81 and basically having

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2 the January 1,.

' 81 items all completed by March 31 -- we would 3

confirm that by order.

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4 That's all we'd be intended to do.

The actual legal mechanism, we're going to be working out with our -- with ELD to a

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work the right vehicle.

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7 The point is:

there's a set of plants, which I'll call X

8 8

" good guy" plants.

They, in fact, have, we believe, made a good a

dd 9

effort to try to meet the intent of these requirements.

A lot jc H

10 of them have discussed it with us and we've exercised some flexi-

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For example, the first big piece of flexibility w6 had

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was:

those items where 737 said that the report had to be in-by E

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1-1-81, we found that many of those utilities came back and said:

M 9

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I'll get it to you by the middle of January; a few said: I'll get x

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it to you in February; and a few more said:

in March.

d 17 '

And we decided that most of those were reports analyzing i

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a 18 things -- evaluating approaches, so we cut it at March 31 and l

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19 said:

if it's in by March 31, it's all right.

l 20 The second piece is those two or three items that had dates later than March 31.

We put a drop-dead cut-of f date of 1

l 22

! June 30 and said that everything's got to be done by June 30.

23 i And, if they commit to do th a t, that's fine with us.

i 24 '

MR. DENTON:

The same approach we followed last time.

25 People who voluntarily meet the dates get confirmatory orders; l

ALDERSON REPORTING COMPANY,INC.

.16 I

the ones that have 'not been able to convince us that they could

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2 defer it way out in the future or just d;.dn' t want to ch) it would 3

get a more positive order to do it.

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4 And some didn' t give us a commitment in some cases, 5

which is the next slide.

Again, don't concentrate on the exact

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6 words.

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7 COMMISSIONER AHEARNE:

Wait, wait, hold it.

Kl 8

MR. OLSHINSKI:

Sure.

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9 COMMISSIONER AHEARNE:

The II.D.1 which, I guess is --

zog 10 MR. EISENHUT:

We'll be back to II.D.1 in just one z

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I2 COMMISSIONER AHEARNE:

You will be back?

5 N

4

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MR. EISENHUT:

Yes.

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The next page is sort of the other half of what Harold j

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15 just mentioned.

Those plants that have yet to give us a firm 2

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I6 commitment following those general ground rules I just stated --

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h I7 ! we would, in fact, go with the more positive order -- again, the 3

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actual vehicle of what it looks like -- whether it's an order G

l l9 g

for modification or show-cause would vary, perhaps, even from n

20 plant to plant.

2I ;

MR. DENTON:

They all have different issues that they 're 22 [ taking exception to -- different schedules.

So there would have

'3 3 to be some tailoring of the vehicle to their whatever-ir-is that 24 ' they don' t want to do on a given date.

But we jus t wanted to l

25 j show you the two groups of utilities.

d ALDERSON REPORTING COMPANY, INC.

I

I 17 1

MR. EISENHUT:

Which, again, is the same philosophy we

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2, used, last January when we went through the last iteration.

The 3 'dro p-dead, then, I believe, was about June 1st.

They w'ere talking

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4 June 30th and just waived the requirements.

e 5

Now, John, there's three or four other specific items h

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we're going to talk about on the next slide.

R 7

MR. OLSHINSKI:

One thing.

As we've gone through, the X

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fact that most of these items that we've been talking about are d

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E, re po rts.

10 We mentioned the one hardware item and there are a few E

11 procedural items and most were due 1-1-81.

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12 plants -- the different categories the plants fell in, again, were 5

j 13 based on reports that -- by the end of March being acceptable for

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14 the 1-1-81 items, with 6-30-81 being the last acceptable date.

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15 Those were the general guidelines.

Because there were x

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16 some April requirements -- mid-April and the beginning of April I

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17 I requirements and we found that, again, reports that those being 18 submitted by June 30th, '81 would be acceptable.

There were a 19 g

few exceptions in general to this and one of those -- the first n

20 of those is 1. AJ1.3, Shif t Manning overtime, which was a -- 1-1-81 2I was a -- we don' t intend to, at this point in time, address in the 22 orders.

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l 23 MR. DENTON:

This one is giving us some difficu'ty 24 l coming to grips with.

And I've asked Steve Hanauer to discuss 25 i where we s tand.

And th'ere's no doubt in our mind about the i

ALDERSON REPORTING COMPANY, INC.

L

18 1

principle of minimizing overtime.

But exactly how we --

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2 COMMISSIONER AHEARNE:

You are talking about the 3

licensees?

()

4 MR. DENTON:

Yes.

In fact, just going through "over-

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5 time", I can appreciate what problems some people have on the 3

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6 details.

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MR. HANAUER:

I guess I'll have to say:

you see before X]

8 you a somewhat repentant. prescriber, d

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10 MR. HANAUER:

Over the last couple of years, we have, E

4 11 ir fact, issued several prescriptions for overtime, the princi-3 6

12 ples of which were correct.

We found that, in a number of plants,

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overtime was a way of life.

The operators felt, with some con-13 am E

14 siderable justification, that they were overworked -and over-w 2

15 pressed.

5 16 And so we have, in several different w&ys, using 3W 6

17 several different vehicles, including an I & E bulletin and, l

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k 18 most recently, in the 0737 document, issued what we fondly i

5 19 described as requirements or guidelines for overtime.

20 In each case, the licensees we've talked to -- and now 21 most recantly the reports from the licensees in response to the 22 letters Darrell described have subscribed, along with us, to the 1

23 principles of keeping control over overtime and not overworking i

i l

24 j the people whose judgment and actions are important to safety.

l 25 However, what we have, in my opinion, managed to prove i

i ALDERSON REPORTING COMPANY, INC.

19 1

is _that we don' t really understand plant operation and -the.. _

4 1

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detailed workings of overtime as well as we think we have.

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And our latest guidance, analogously but not exactly the same as

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4.nur previous ones, turned out to have words in it which, when e

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6 is our extension of our concern to other than just the control R

8 7

room crew.

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We want other people who work in safety equipment not d

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to be too tired to work on it correctly.

Coupled with our require-i i

h 10 ment originally thought of just for the control room crew that the l z

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11 overtime beyond our guidelines be approved at a high level has I

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12 resulted, as one licensee pointed out to us, in the requirement 4

13 for the shif t supervisor -- if you took it literally -- to assign l

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-- the plant superintendent, ra ther, to sign between two and 400 2

15 overtime chits a day.

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16 We think there are more important things for this plant i

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17 superintendent to do.

And so we want to modify it.

But,. instead 5

18 of issuing yet another set of detailed prescriptions, we would l

5 19 like to stand back a little from this approach and to use the n

20 rather t eful things which have been written, not as prescriptions l

l 21 to be embombed in an order, but as guidelines to be used in re-22 l viewing applicant's overtime administrative programs, which all l

J l

l 23 ' applicants aver that they have.

l 24l We, therefo re, propose not to enforce the good things 25 and absurdities in our latest write-up by means of detailed orders, l

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ALDERSON REPORTING COMPANY, INC.

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20 2

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._~j MR. DENTON:

Part of the difficulty,'Iethink, is:..wr l

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2 do feel it's important that there be adequate manning at the stations.

And this is part of the problem that's driving the 3

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4 overtime question, that, as we try to impose tighter and tighter I

5 vertime restrictions, it increases the number of people that e

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6 mus t be at the site.

And that's our goal.

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Yet, it's very difficu~ t to do that overnight and it X

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has to " ramp in" and gets into all kinds of complexities without d=

9 prescriptive apprcach.

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0 10 I'd like to try to rethink this and maybe, by the next c

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11 wave of orders which comes due, starting in the June time-S c

12 frame, to be able to put a little more definition on this than 5o d

13 we've managed to do with the five efforts in the past, to prescribe oa E

14 overtime,

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15 It's a very important issue but, normally, what we are 5

16 finding is:

with the present overtime words daat are in 737, g

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6 17 when someone comes to us with a specific and describes how they 5

18 failed to meet it or what they would propose to do as an alterna-Eb tive, we generally find that acceptable.

So it seems to me we 19 8"

l 20 are accepting a lot of hand-tailoring about those requirements 21 in most cases and that says that we still haven't refined the l

22 language or the requirements well enough to dignify it by an 23 iorder.

24 i COMMISSIONER AHEARNE:

When a licensee -- let's say a 25 licensee says:

I have so many operators, I can either meet your l

ALDERSON REPORTING COMPANY, INC.

f.

21' 6

4 1

overtime ouldelines or your manning guidelines, whichever.

do you 2 want me tc run with a full crew of tired operators or a shorter i

4 3

crew with fresh operators?

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4 What do y.ou say?

5 MR. DENTON:

Normally, it isn't all that stark. but, in e

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a few cases, it is.

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7 MR. HANAUER:

In a few cases, it has been that stark.

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8 In one case, we were fairly close to delaying the start of a new d

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plant because we didn't really have enough people.

Our approach zo E

' in general has been to insist on the re. quired number of people 10 Il and then to investigate whether they would become acceptably

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12 tired or unacceptably tired but, more to the point, to insist

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5 14 on board within times that are not altogether at his disposal, le i

g 15 but to upgrade his program very substantially in some cases.

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16 COMMISSIONER AHEARNE:

So that the numbers of opera-

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x MR. RANAUER:

Yes.

In operating plants, the required

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19 increase in the nudaers is not effective as a requiremera until l

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l 20 July,1982 and this is the reason.

The biggest crunches have 2I come in the newly licensed plants.

22 MR. DENTON:

It will leave us witPout a fully enforceabic J

i 23 overtime requirement on the street, although there are many docu-l 24 men t.e that give guidance.

I 25,

I don' t know of anyone who doesn't eschew overtime as a ALDERSON REPORTING COMPANY. INC.

4 22 i

1-generml' principle but they would like to have the flexibility of

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2 sometimes beyond what we manage to write down.

1 i

3 MR. HANAUER:

I think that this is the case.

I think

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4 that we have tried to be too specific and that there are different 5

styles of personnel management and thcee that are acceptable 5

l 6

should be accommodated.

Rg 7

COMMISSIONER AHEARNE:

But remember that -- Joe -- that Ml 8

it was driven by -- there were an increasing number of plants d

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9 in which overtime was becoming just the standard norm, driven iog 10 harsely, I think, by the operators themselves, because daey like 3j 11 that extra pay.

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d 12 CHAIRMAN HENDRIE:

Well, I think what Steve is heading 3

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13 towards is to try to, at the least for the moment, to adjust the

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14 control of guidance that we provide to sort 'of pull it up one 2

15 level -- not have it so detailed -- make the principle clear and E

16 have some flexibility to look at individual schemes that go in 3

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17 l the right direction, and accept them.

N 18 COMMISSIONER AHEARNE:

I have no problem with that.

My 3

19 point I wanted to reaffirm -- that we still think that large n

20 amounts of overtime for operators is something to be avoided.

21l Certainly, the -- as I recall, Steve has had. one study done' for i

22 t him in which it seemed to bear that out.

23 MR. HANAUER:

Yes.

24 l CHAIRMAN HENDRIE:

I think that's clear and I don't i

25 think anybody is headed differently.

t ALDERSON REPORTING COMPANY, INC.

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.23

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MR. DENTON:

I think we ought to continue.to look at

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2 it on an ad hoc, case-by-case basis.

3 MR. OLSHINSHI:

II.D.1 was another one I wanted to call

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4 out as different from the different guidelines.

5 CHAIRMAN HENDRIE:

Excuse me.

I'm sorry to interrupt 5l 6

the forward progress.

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7 Coul'd you commt M.

Steve, as long as you're here and M

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8 upright and, you know, coal-fired and so on:

are you goint to d

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be able to examine them at a rate compatible with bringing people iog 10 in to keep the licensing of working force up to the needed E

g 11 strength.

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12 MR. HANAUER:

That issue is still in doubt.

We are E

^N 13 pulling all strings available to us to get more resources into l

14 that program.

2 15 COMMISSIONER AHEARNE:

When the freeze went on and you g

16 had offers out -- when the freeze went off, were those people w

g 17 still willing to come?

18 MR. HANAUER:

No', sir.

In only one or two cases.

5" R

You know, we lost what might have 19 CHAIRMAN HENDRIE:

20l been the work-force increment to make it go.

And I had some 21 inkling the other day that it was sort of touch-and go and we

~22 may have to reconsider -- look' for some way to get through a 23 L period which we siznply do not have the capacity to administer 24 I the exams we'd like to administer -- keep the licensed work-force 25 ' at the needed level.

I ALDERSON REPORTING COMPANY. INC.

24 j

MR. KANAUER:

We are already in that situation. :We

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2 are perilously close to the situation where we lack the resources v

3 to examine the statutrily required examinations.

We have one

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cadre of half a dozen people at one lab just now beginning to 4

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give examinations.

We started that some months ago.

We,are 2nj 6

starting the same program at two other labs.

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Groups of, if you like, " contract examiners" as a

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We are also recruiting, but d

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If the lab forces get up to speed E

5 11 pretty quickly, is that going to make it for you, do you think?

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12 MR. HANAUER:

Yes, with some dislocations and delays.

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E 13 COMMISSIONER AHEARNE:

I would like to ask Secy to

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14 whatever comes out of this meeting, SRM, to note that, in the du 5

15 next report, which I guess will come some time after June, that 5

16 this issue of overtime be at least addressed again, because you 3

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17 ! said you were pulling off and re-thinking.

5 5

18 MR. OLSHINSKI:

On II.D.1 -- dae reason it's lis ted

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19 here -- this is another item we di dn' t follow the general guide-x 20 lines given above in that the flock-valve test program -- st 21 of that program -- will review what was originally a 1-1-81 22 l item, now to be submitted by 30 June,

'81.

I 23!

COMMISSIONER AHEARNE:

What had been the problem?

24 =

MR. OLSHINSKI:

Dick will talk about it.

25 MR. VOLLMER:

This is a partial on the II.D.1 requirement i

i ALDERSON REPORTING COMPANY, INC.

i

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'I which discusses safety relief valve testing including block valves.

h 2

M st of the program is proceeding on schedule and we would get 3

the test results and plan specific evaluation by July 1 of this I) year on the safety -- on relief valve testing and its specific 4

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5 application on each plant.

E 6

Now, the block valves in general will be utilizing the 7

same facilities that the safety relief valve testing is being 8

conducted on right now so the facilities are tied up, d

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In addition, there are a number -- there are a larger i

h 10 number of permutations and combinations of valves -- i.e.,

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5 11 operator and valve, that can be used for the block-valve applica-d 12

' tion for the safety relief.

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13 So it's been difficult for them to pull together a s

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14 ' program at this point in time and get all licensees together and d

15 agree on a specific program.

16 We don't believe that the postponing the program com-3e j

g 17 mitment to July 1 will effect the end date that's already in l

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18 the Reg 073 7 o f July 1 of ' 82 for accomplishing it and getting E

19 our evaluation, so we don't think it will impact the real meat 8n i

20 of it.

21 As you are well aware, they already have conducted some 22 ! block valve testing but that has been done strictly without any I:

l 23 particular program direction and program guidance from us, 24 certainly.

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25 MR. OLSHINSKI:

Another item -- 382 -- is in 0737 during 1

l.

ALDERSON REPORTING COMPANY. INC.

l

I 26 1

dhis time period, but it's not -- we don' t intend for it to be

()

2 in the order since it's included in the rule and III.A.12 re-3 quires a response that's in fact due this month.

And those m

4 have not been reviewed yet, so that we don' t intend to put those

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5 in this set of orders.

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MR. EISENHUT:

And, of course, that was EOF location Rg 7

TSC location.

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8 That concludes our presentation.

As we stated, our d

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approach would be to go forth, follow this approach to either Y[

10 issue some form of orders on the items mentioned to make them E

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11 in an enforceable package that we could follow up on and sort 3

('12 of set forth the requirements so that we can, as far as licensing

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14 COMMISSIONER-AHEARNE:.When I looked at the plants that ab i

15 received show-cause orders and those which received confirmatory

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y 16 orders covers 63 plants.

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Now, I guess I'm puzzled by --

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18 MR. EISENHUT:

There 's a dis tinct possibility there's l

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19 an oversight.

We'll make sure we do them all in one category 5

20 or number.

21 The intent is this covers all operating plants.

It does not include the new plants, you realize -- tha t is, the Se-22 l

23 quoyah ones, the North End Twos, the Farley Twos, et cetera, be-i 24 l cause we took care of those plants -- these plants -- these items 25 in a licensed condition and any change requires an amendment I

l ALDERSON REPORTING COMPANY, INC.

1 27 i

already.

()

2 So you subtract those,.and you subtract the TMI-2 's and 3

subtract the TMI-l's, et cetera.

4 COMMISSIONER AHEARNE:

Singular.

5 CHAIRMAN HENDRIE:

It comes out about right.

We've got 5l 6

four in that category.

R 2

7 MR. EISENHUT:

That's right.

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3 CHAIRMAN HENDRIE:

So 63 and 4 is 67.

TMI-2, Reston-l.

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9 MR. EISENHUT:

Humbolt Bay.

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10 CHAIRMAN HENDRIE:

IP-1 is no longer on the list.

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11 MR. EISENHUT:

IP-1 is no longer on the list.

d 12 COMMISSIONER AHEARNE:

Humbolt isn't, either.

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9

(t 13 MR. EISENHUT:

There may be one or two missing.

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14 CHAIRMAN HENDRIE:

Somewhere out there.

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2 15 One of these days, one of Cummings ' investigators 16, will part the bushes and, on the top of this hill, and peer into 3W l

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g 17 ' the valley and say "Yikes!"

l 18 (Laughter. )

=H" 19 CHAIRMAN HENDRIE:

And then Harold will be in for 8

20 another step increment to his budget.

21 Any comments?

22 MR. DENTON:

We want to move 35.

i l

23 4

. COMMISSIONER 3RADFORD:

Maybe I've missed it, but I l

24 still don't have a good feel for the point at which the NRC will l

25 have, on some basis, gone through all the responses that are i

i ALDERSCN REPORTING COMPANY. INC.

l

I 28 I

in-hand and be able to say that we are reasonably confident that 2

what's been committed to has been done adequately.

3 MR. DENTON:

Well, let me answer this way:

that, once 4

we issue, for example, a confirmatory order, then I & E can 5

selectively audit the implementation of that order and I guess I h

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-- I would assume it would be wrapped into their normal inspection Kl 8

schedule on some frequency.

d MR. EISENHUT:

Jim Sniezek is here to address those 0

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What we are doing is basically within a

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two months of the licensee's commitment date -- it is our inten-3 m

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tion to verify technical inadequacy of what the licensee did, and E

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I don't have an update right now, but the last count -- the things h:

hI that were to be done -- committed to by January 1st, we have veri-

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d fled approximately 80% of those as having been completed.

v5 COMMISSIONER AHEARNE:

That's the 1990 items.

x

!il 18 MR. SNIEZEK:

Yes, sir -- that which includes, as I

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j 19lI recall, Category A items that were carry-overs from before 20 January, 1981.

21 Now, what we are doing to assure, long-term, that we O

have everything, we have computerized the whole system -- for 23 l every plant -- for every Action item.

We have the item -- that 24 I

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i which is to be verified by I 5 E, the reference to the inspection 25

. procedures that are to be used in reference to the inspection part I

i i

ALDERSON REPORTING COMPANY, INC.

29 1

where the items be documented and closed out by I & E.

So, at

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2 every plant, we'll be able to track completion that we have verified.

3

()

COMMISSIONER BRADFORD:

A lot of these are studies or 4

e 5

design items.

Does the I & E verification, then, consist of 5l 6

actually reading through the studies and studying the designs f7 or does it consist of just being sure that they exist?

8 MR. SNIE'EK:

No, sir.

Most of those are reports that Z

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9 come in to NLR and NLR will be doing the evaluation.

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0 MR. EISENHUT

Let me be sure I correct -- make it

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11 clear, Jim.

Remember only 10 of the 36 items I & E is really

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each item.

Is I & E going to verify it or NLR?

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analyze or evaluate the desirability of a

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5 15 having a common water reference level, it's not really something 16 that I & E can do.

We know we've got the report from the utility, 5

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17 but your last word is the key word and that is whether it was E

5 18 analyzed adequately.

So is it an adequate report?

b 19 Now, all of the other 26 items that we have in-house, 1 En 20 think it's going to vary in time.

Those that are required -- we l

21 are on the critical path -- that is, the analysis that precedes 22 them implementing something -- we are going to be doing that on i

23 a previously laid-out program to be sure that we can analyze, 1

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24 j evaluate those reports in time that they be done on the critical 1

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The others, I think we are going to be taking a some -

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2 what longer time.

We don't have a firm drop-dead date or all 3

of the rest of the reports, which I'would venture to say is

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probably something on the order of 15 reports from each utility.

4 a

5 COMMISSIONER BRADFORD:

Is the nature of those sort of 5l 6

analyze this particular --

MR. EISENHUT:

Yes.

7 X

problem to see whether it's g

3 COMMISSIONER BRADFORD:

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9 a problem for your plant?

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10 MR. DENTON:

A lot of them come from the original El 11 bulletins and orders task force for feedwater and possibly 3

o 12 the different scenarios that have to be analyzed.

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d 13 I think we will focus on looking at those that require 5

E 14 actual implementation in the plant at first and then we'll begin a

2 15 to check.

I'm sure Westinghouse,. PWR type and a GE type and 16 depending on what we find, then, unfold more.

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R 17 But our plan is to plough through these without being 2

h 18 our priority -- the ones that actually require changes in

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l 19 procedures or plant first and then begin to review their analysea i

20 to show whether no additional changes are necessary.

21 COMMISSIONER BRADFORD:

But, of the 1900 items, I would

.22 gather that the bulk of them are within NLR.

23 l MR. EISENHUT:

That's true.

24 !

COMMISSIONER BRADFORD:

And those you haven ' t been able -

L I

i i

25, to chew through yet.

i ALDERSON REPORTING COMPANY, INC.

I

31 j

but. EISENHUT:

The pre-implementation ones, we are

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go.ing through and we are pretty well on track on those.

That 2

3 family of them where it's sort of the last group we're talking

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about -- we have not gone that far through.

f 4

a 5

One of the things we are looking at is:

where can b

8 6

contractors help us to free up some staff to look at them, et e

7 cetera?

That's part of this overall package we are working on.

8 A number of the items:

we are going to be doing something along d

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those lines.

i 10 COMMISSIONER AHEARNE:

Can I ask Jim a question?

e 3

g jj CHAIRMAN HENDRIE:

Please do.

E e

12 COMMISSIONER AHEARNE:

There have been a series of E

('S exchanger between the OIA and I&E and NLR regarding its concern 13 5

E 14 for working arrange'ments being very clear between OIA, betwaen d

M 2

15 I&E and NLR on whose responsibility to call upon what.

16 Do you now believe that you have it clearly defined --

i d

I i

17 the separation of the mechanism for defining that?

Does the 18 designee now feel comfortable that they know what it is that 5"

19 they're supposed to follow up on?

8n 20 MR. SNIEZEK:

There's no question in my mind daat, 21 working with Darrell's shop -- that we. understand who is going to 22 i follow up on what.

i 23 '

The 10 items that he mentioned, if I understand it, are 24l clearly designated in the bureau as IE follow-up items.

25,

MR. EISENHUT:

The name is on every item.

ALDERSON REPORTING COMPANY. INC.

32 I

CHAIRMAN RENDRIE:

Are you managing to keep the project 2

manager aboard on the majority of these?

V MR. EISENHUT:

That's a much more difficult question.

()

4 We 'are trying to do it sort of generically but, yes, in fact, we've 5

g actually moved a couple of our project managers into a group --

l 0

John's groop -- that are actually helping us out doing this a

8 7

because, otherwise, it's a very difficult situation working with X

E 8

a hundreds and hundreds of different items.

dd 9

CHAIRMAN HENDRIE:

ML19343C970

Text

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