ML19347D453
| ML19347D453 | |
| Person / Time | |
|---|---|
| Issue date: | 02/18/1981 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML19247D563 | List: |
| References | |
| REF-10CFR9.7 NUDOCS 8103170679 | |
| Download: ML19347D453 (72) | |
Text
_ -. _ _
IfCCLEAR REGULATORY CC)GCSSICN' 4
i CO!!!!ISSION tiEETING
(
Izt the Mattar of:
PUBLIC MEETING DISCUSSION AND VOTE ON SECY-81-13 I
SYSTEMATIC SAFETY EVALUATION GF ALL CURRENTLY OPERATING NUCLEAR POWER REACTORS DATE:
February 18, 1981 PAggs:
1 - 70 AT:
Washington, D. C.
F
\\,A l
\\
J.
L j#4 TEB2 $1981 Eg M(yma
//
s p>
N ~O
(.
.-lLDEL%. %~#- (j 400 vi.T 4 a Ave., S.W. ~4"=hd'T art, C. C. 20024 Talaph== : (202) 554-2345 8108170 0
1 1!
UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
i i
4 PUBLIC MEETING g
5 DISCUSSION AND VOTE ON SECY-81-13 9
j 6
SYSTEMATIC SAFETY EVALUATION OF ALL CURRENTLY k7 OPERATING NUCLEAR POWER REACTORS sj 8
j a
c 9
Nuclear Regulatory Commission f
Room 1130 g
10 1717 H Street, N.W.
Washington, D.C.
j 11 8
Wednesday, February 18, 1981 g
12 y
The Commission met, pursuant to notice, at 2:12 p.m.
g 13 BEFORE:
l E
14 w
5 JOHN F. AHEARNE, Chairman of the Commission 2
15 l
w8 VICTOR GILINSKY, Commissioner g
16 j d
l PETER A. BRADFORD, Commissioner 6
17 ;
1 x
18 l JOSEPH M. HENDRIE, Commissioner j
M i
t i
C NRC STAFF PRESENT:
19 l g
i k
l LEONARD BICKWIT 20 !
i JOHN HOYLE WILLIAM J. DIRCKS 22.
l l
HAROLD DENTON 23 BILL OLMSTEAD EDWARD HANRAHAN MARTIN MALSCH i
ALDERSON REPORTING COMPANY. INC.
l 2
i i
NRC STAFF PRESENT:
(Continued)
I 2
EDSON CASE 3
DARRELL EISENHUT l
4 g
5 il f
j 6
a w
n[
8 d6 9
i0 10 i
j 11 a
j 12
=
9
=
l E
14 l t!
i w
i 2
15 j
16 w
!i 17 !
i l
5 18 i
=
19 !
20l l
21l 22 23 '
24l 25]
a il d
3 ALDERSON REPORTING COMPANY, INC.
m
1 UIsmw 31s is an u=cff" ' =' =z=se dp of a. :se:1:5 of 2a C=1:ad.
Sea:az Nucimar Zagulacc:7 C.
- si=n hall on. Februarv 18, 1981 in the Commissian's.officas a: 1717 E Se:as=, N. ~4., ~4ast:1 g =n, D. C.
3a maati.g: vas open :s puh t '- a: =d--a and obserra* =.
31s. =ansW: has :nc haan raviawed, cc==ac ad, or edi:ad, a=i 1: mar contain d-=--s -.
Sa==zasc=1pc is i===M sole ~7 fs= gana.t i=f==a:1:nal purposes.
As p cvidad. by 10 CEL 9.102, ': is =ce pa=
of da fo= mal or '***:=ta.L racari of decisten of de =a::a:s disc =ssed.
Izprassimus of op* ' m is -6d= =ansc=1;. dc =c: =acassa:117 raflac= f1=at da*=~-- dons or heliafs.
No p t a dd - - or ochar paper may be. filad. wi=tt -he Cc= mission. is a=7 p=caed1=g as da rasu1= of or add.assed. :s any sa aman: or a 3..a== c== aised.
hara1=, azcape as -"a Constissian =a:7 auchc=f:r.
6 S
e y
l I
l I
O
3 1
EEEEEEE1EEE S,
CHAIRMAN AHEARNE:
All right, that clears the way for 3
then moving on to the Safety Evaluation Program and discussion.
4 The Executive Director has been working hard on this after I
g 5
previous meetings and has now come back to us with I believe R
6f either a fine tuning or a modification, however you would like to R
7 propoce to describe it.
j 8
Bill, the floor is yours.
l 0
2 9
MR. DIRCKS:
I want to introduce the subject by saying z
h 10 that we have in this memorandum I have written to you and is dated s_
j 11 the 17th of February addressed really only part of the Section 110 m
i 12 of the Authorization Bill.
d 13 What we want to do is concentrate on the subject of E
l 14 particularly significant safety regulations and our reviews 5[
15 against those regulations and the SEP, IREP integration part
=
16 of the program.
We did not touch on the issue of the generic g^
\\
d 17 j rules or the generic issues or the generic safety issues that 5
18 the Bingham Amendment asked us to address because that is 5
{
19,
contained in the original paper.
5 I
20.
What we have done here I think is attempt to direct i
21 this program to what we regard as the substantive safety issues 22 !
involved.
We have done that by basing it on the issues that i
23 '
would flow out of the SEP, IREP/NREP reviews that we have contem-24f plated in the program.
Those lists of substantive safety issues 25 that would flow out of those review programs then would serve as l
ALDERSON REPORTING COMPANY, INC.
4 1
4 i
the basis for developing and identifying the particularly 2
significant safety regulations, those aspects of the particularly 3
significant safety regulations that have been identified to the 4
SEP, IREP reviews as needing additional reviews.
g 5
What I have done in this February 17 memo is lay out an N
6 essentially five-step effort which I thought would fully bring in
\\
Rg 7
and bring together the IREP reviews, NREP reviews and SEP reviews e'.
j 8
in the budget reviews and the reviews that we are required to do d
ci 9
looking against compliance with significant safety regulations.
10 Harold, I guess you can get into the details of this z_
5!
11 better and I think it would preferable for him to pick it up at 3
y 12 this point.
5 l
l 13 l MR. DENTON:
We have made several false starts in tryingf j
l 14 to develop an approach to this problem.
9 15 CHAIRMAN AHEARNE:
I would prefer you dcscribe it.
You l
l j
16 have put a lot of work into trying to construct the most feasible
- ,5
((
17 i investment.
5 18 MR. DENTON:
I think one of the simple approaches, the 19 one that came to my mind, at least when I first read the Amend-M 20 ment, was to in essence repeat for all the applications the sort 21 of reviews we do today.
In other words, one way to assure you 22 have complied with all the applicable regulations is to get an 23 entire new regulation in today and review it against standard 24 l review plans and that way you guarantee you swept everything in.
5 25 But that approach doesn't recognize at all the progress i
ALDERSON REPORTING COMPANY. INC.
[
j 5
l l
we have made in the SEP program in trying to identify the topics j
2 which are of :real safety concern.
It is more or less a by-the-3 road sort of approach.
So the approach we have here attempts to 4
capitalize on the SEP program investment we have already made and e
5 to reflect the knowledge we think we have gained through the SEP Ae j
6 program as to what the right safety topics to look at are.
Rg 7
We have identified for the Phase II SEP program 137 s
j 8
safety topics as being of particular safety significance for d=
9 that class of plants.
And those plants are being evaluated to 10 see whether they meet today's practice in this area or they have
@E j
11 some equivalent way.
m j
12 Now what this memorandum says to do is,let's assume
=
13 that the 137 doesn't reduce any for the next batch of plants.
=
E 14 Let's assume that all 137 turn out to be significant for the dk 1
2 15 first group of plants and that all those topics need to be a
=
j 16 looked at for the next batch of plants.
-s d
17 :
CHAIRMAN AHEARNE:
By the first group of plants you N
18 '
are referring to?
=e E
19 MR. DENTON:
The first 11 we are already into with 137 5
I 20 l topics.
21 l MR. DIRCKS:
Phase II SEP.
22 MR. DENTON:
So let's assume for sake of discussion 23 that that 137 are the topics which we think are partic ly 24 j safety significant.
What we propose to do then in Step 2 in the ;
25 ' memo is to associate those topics with the Commission's 3
'i
)
ALDERSON REPORTING COMPANY. INC.
+
6 f
I regulations.
If we are worried about pipe whip within containmentq that would associate with a particular Commission regulation.
2 3
And we would then make up a list of Commission's regulations.
You remember when we were first trying to make up a 4
list of particular safety significant regulations we had 85 percend g
5 9
8 6
cut and 90 percent cut and so forth.
This approach goes at it I
7 not by just looking at the regulation but by looking at has it n
j 8
been a problem in the review of these first 11 plants, d
d 9
CHAIRMAN AHEARNE:
So the regulations you would Y
10 associate it with are the existing regulations?
E 5
11 MR. DENTON:
Yes.
j 12 CHAIRMAN AHEARNE:
And it may well be that some of 13 these items will be associated with several regulations?
n 14 MR. DENTON:
Yes.
b E
is So Step 2 in the proposal would be to identify those g'
16 lists that compliance with would be of particular significance w
d 17 l to public health and safety.
18 Step 3 then --
5 19 COMMISSIONER HENDRIE:
Before you get off 2, Harold, 20 is it clear that the language of the legislation gives you the 21 flexibility to interpret in this fashion?
22 CHAIRMAN AHEARNE:
So far he is describing the program.
23 '
I think you have to let him come back to where he r. tight see that 24 legislation.
He is descriging the. program which is I think SEP,
25 ;
IREP/NREP all folded together.
l ALDERSON REPORTING COMPANY. INC.
7 1
COMMISSIONER HENDRIE:
He has just gotten through 1
2 telling you how he would develop a list of regulations considered 3
to be significant to safety; i.e.,
the Section 110 regulations.
i 4
And I have no objection to it as a working approach.
I wonder n
5 if somebody has looked to see whether the legislation --
0 l
j 6'
MR. DIRCKS:
I think what we are going to do is define R
7 what we mean by particularly significant safety regulations.
- j 8
In Step 3 we sort of pick out those, we now focus on those d
o; 9
particularly significant safety regulations and do the review.
E 10 CHAIRMAN AHEARNE:
Your question then is given the II wording in the law "-
3 y
12 COMMISSIONER HENDRIE:
Is this a fair way to make up 5
j 13 the list?
m i
I4 MR. OLMSTEAD:
I think that this is a legal interpre-l 5
9_
15 tation statute.
z E
I6 MR. BICKWIT:
Vigorous nod over here.
W I7 MR. DENTON:
Let me draw a distinction between two C
l 3
18 different ways' that make up this list that we considered in C
1 I
19 coming up with this approach.
e i
M 20 l COMMISSIONER HENDRIE:
I don't have any objection.
i II Let me just say very briefly what occurred to me that might be 22 a problem.
Legislation says regulations significant to safety 23 in our judgment.
So I think that gives us reasonable latitude, 24 and you are probably right that you can do as proposed and that 25 meets the intent of the legislation.
l ALDERSON REPORTING COMPANY, INC.
8 1i It occurred to me, suppose you have a general design 2
criterion or particular regulation which is obviously at least 3
of considerable interest from a safety standpoint but which 4
everybody has met from day one, and it has never been a problem.
5 So it is not an issue in the SEP review.
And under this procedure
=
j 6l it would not surface in the list, nevertheless you know, I don't 7
know, something like keep the fission products in the pot or j
8 something like that.
d d
9 MR. CASE:
ECCS 50-46.
- h b
10 COMMISSIONER HENDRIE:
The 50-46 might be a good one 5
j 11 because it has not been an SEP issue.
m y
12 MR. DIRCKS:
It is an important regulation.
=3g 13,
COMMISSIONER HENDRIE:
But it is not a particularly a
wg 14 significant one or whatever the language is.
t l
l 15 All right.
l g
16 MR. DENTON:
In trying to make up a list in just a w
d 17 theoretical manner without associating with any plant, you can Y
y 18 get various lists.
And 50-46 is certainly an important one of P{
19 the Commission's regulations, but we know it has been complied M
l 20 with by every operating plant and therefore I didn't see that 21 that had any particular safety significance in this kind of 22 context.
So using the 137 topics would not pick that up.
23I MR. DIRCKS:
And if we go through the SEP, IREP 24 reviews these programs were designed to sort of trace down where 25 there are significant pathways to accidents and then see what i
i ALDERSON REPORTING COMPANY, INC.
I l
9 l
j regulations are imposing themselves on these pathways.
2 MR. BICKWIT:
Excuse me, may I make just one point here?
3 In the conference report it states this modification, referring 4
to the Bingham Amendment, enables the NRC to build upon a system-l b
=
5 atic safety evaluation it is currently conducting for the oldest b
8 6
operating nuclear power plants.
I think that adds muscle to this ng 7
interpretation.
Nj 8
COMMISSIONER GILINSKY:
I am a little troubled when you d
c 9
say the ECCS regulation is not of particular safety significance.
10 It seems to me the more reasonable approach is to say that this j
11 is something we have reviewed pretty thoroughly across the board 3
y 12 and we know the answer, and it would be pretty easy to put the 5
d 13 answer into whatever document you came up with.
E i
l 14 MR. DENTON:
It is, and it is just one more piece of 2
15 work though in trying to get the maximum safety gain.
We know j
16,
in another part of our operation that that has been reviewed and d
i l
17 i documented for all plants.
So you could extend it.
l i
E 18 COMMISSIONER GILINSKY:
I think it would be pretty easy 5
19 either to check a box or reference a document or whatever because 6
20 that is an area that we have gone over pretty thoroughly.
21 MR. DENTON:
But see, that goes back I think to the 22,
first way that we started out trying to approach it which is make 23 '
up the regulations more or less in isolation and try to check off 24 those that are of-particular safety significance.
And there we i
25 ll got into 85 percent of the regulations or 60 percent or 100 percenG
)
i ALDERSON REPORTING COMPANY, INC.
10 I
and we had trouble drawing a line in isolation of any particular 2
case.
3 CHAIRMAN AHEARNE:
Please, could I ask that Harold at
[
4 least finish describing the approach, then we can go back and I
5j unfold the approach as to whether or not --
s
]
6 ll MR. DIRCKS:
He's almost three-fifths through the list.
7.
7 MR. DENTON:
Well, the distinction is that how you start j
8 isn't that important on this first stage of review with these j
d 9
11 plants, because I would expect that these 137 topics might
,z h
10 well associate with 85 percent of the Commission's regulations a
j 11 because of the way they branch out among the regulations, for 3
y 12 example.
E y
13 COMMISSIONER BRADFORD:
But associated with it doesn't
=
i l
l 14 mean cover it in full?
You might pick up a piece here or there.
2 15 MR. DENTON:
That would be Step 3 then.
If they 5
g 16,
associate at all with it, it gets listed as a regulation.
l 17 l Then in Step 3 we quote the exact words from the Act:
N l
18 each licensee be asked to describe the extent its plant complies a
19 l.with these rules and regulations, including an indication where a
M i
20l such compliance was actlieved through the SRP criteria or equivalentf 21 and where achieved by equivalent means.
22,
So for any regulation impacted by these 137 topics he i
23 has to state the extent to which he complies with those regula-24 ; tions and whether or not it was done with the SRP or by equivalenth t
25 means..
i l
ALDERSON REPORTING COMPANY, INC.
i
(
ll COMHISSIONER BRADFORD:
Let's see, the regulation in its
)
2 entirety now reads --
3 MR. DENTON:
Yes, the regulation in its entirety, he is 4
making a statement as to whether he complies.
I have tried to g
5 quote the Act exactly the way it said in Item 3.
R 8
6 COMMISSIONER BRADFORD:
He makes a statement whether he 1
I J"
7 complies and then he also explains how he complies to justify I
n' j
8 deviations?
dd 9
MR. DENTON:
He describes the extent to which it 10 complies with these rules and regulations including an indication 3
5 11 where it was used by SRP reg guides sort of methods.
g 12 But that is the sort of thing that we obtained from y
13 Sequoyah and a number of other plants last year.
In other words aj 14 what an old plant would say, I presume against a given GDC, is 2
15 that they complied with this criteria, GDC 4, they didn't use 5
g 16 current reg guides and standard review plans and so forth, they w
y 17 i did it by equivalent means, pages 50 through 100 in the SER.
5 f
IS '
In other words that would be their assertion that they did it 5
{
19 l by an equivalent means.
6 l
20 !
Now for these same topics though, the same 137 topics, 21 Step 4 of this procedure, for those topics we are going to compare 22,
how they comply in those particular topics using the standard i
i 23 review plan as the first guide.
24 l Let's take pipe whip within containment which we know 25,
is a safety topic for old plants.
It wasn't a part of the review l
i ALDERSON REPORTING COMPANY, INC.
12
)
s 1 !
at the time.
So that would identify a given regulation that under 2
Part 3 he would have to say how he complies with.
But for pipe 3
whip criteria itself we would go to the standard review plan 4
that covers pipe whip criteria, and that would be Step 4.
3 5
So for every topic we would then use the standard review 8
6, plan but only for those topics.
So that would be only for the R
7 subparts of the regulation.
A j
8 COMMISSIONER BRADFORD:
So as to the particular topic d
=;
9 you get a comparison with current requirements, but as to the zog 10 rest of the regulation the comparison is to the criteria in effect E=
4 11 at the time of licensing or the current criteria?
E y
12 MR. CASE:
No comparison.
El 13,
CHAIRMAN AHEARNE:
The topics you are talking about are i.
m 5
14 l the 137 topics?
j j
15 i MR. DENTON:
Yes, yes.
x l
i j
16 CHAIRMAN AHEARNE:
And for those 137 topics you would w
{
17 :
then, your assumption is there are sets of SRP acceptance b
18 criteria which will match in some mapping to those set in the P
g 19,
issuance.
5 20 MR. DENTON:
Right.
21 l
Suppose that were the only topic that went to the GDC 22 about missiles, so we would get a general statement of compliance i
l 23 with that GDC which would include turbine missiles and tornado 24 i
missiles and all kinds of missiles, and he would say he meets the 1
25 GDC by an equivalent means, see his early application.
We would ALDERSON REPORTING COMPANY, INC.
13 I
accept that as a general statement of how to find compliance with I
2 that whole part of the regulation.
But we know from doing our 3
program that we are only interested in the element in there, which 4
is pipe whip which we are very interested in, that Step 4 would e
5 require that for each topic that we have identified in this 5
3 6
process he compare how closely he compares with the standard R
7 review plan, and based on how close he compares would kick off X
j 8
our review.
d n
9 That is really the way we are doing the SEP program.
i h
10 In these 137 topics in Phase II the beginning part of the review Ej 11 is to use today's standard review plan.
And to the extent he 5
y 12 complies, it helps focus the review in evaluating the differences.
13 But we would not pick up all the regulation affected by that l
14 topic.
2 15 CHAIRMAN AHEARNE: Your description in the last sentence E
j 16l of No. 4, does that imply that there is a presumption that the I
d 17 j licensee is required on all of those issues to meet the acceptance a!
18 criteria of the current SRP?
E i
g 19 l MR. DENTON:
No.
The presumption is he is required to M
20 identify and describe the differences between what he did and l
21 I the-SRP.
And we use that as a point of departure so we can focus 22 the review.
In other words that is something we just need to i
23 '
know'in order to know how to get into the comparison.
24; CHAIRMAN AHEARNE:
You say in No. 4 " developed from 25,
SEP, IREP/NREP reviews," but previously you are speaking only i
ALDERSON REPORTING COMPANY. INC.
14 i
of the SEP Phase II.
2 MR. DENTON:
Well, then this would be a stage review.
3 In other words what I would propose to do is use all our knowledge, l
4l SEP, NREP and IREP and approach the plants in stages of, say, ten e,
5 at a group.
Remember we proposed a stage progrars.
9 i
3 6l CHAIRMAN AHEARNE:
Ett are you saying then that instead e
R I
g 8
7 of, what you described in 1 and 2 and 3 were linked directly to j
8 the 137 items that have come out of the SEP?
dn 9
MR. DENTON:
That is because we haven't had enough i
Ch 10 running time on NREP/IREP yet to identify those. issues.
i_
5 11 '
CHAIRMAN AHEARNE:
Are you saying then that you would
<m J
12 add to 1 and 2 and 3 any additional issues that would come up z=m E
13 out of IREP/NREP?
E l
]
14 l MR. DENTON:
That's right.
They might add issues or l
l 2
15 they might drop issues out once we got into a probablistic E
j 16 assessment of their significance.
A y
17 i So these issues would then be sent to the next batch 5
18 of ten.
So while the next batch is working on doing these tasks 5
I 19,
we would be reviewing what came from the previous batch.
And I M
l 20 envision that the list of 137 would drop to 90 for the next 1
21 batch, because the plants as they get closer to us in time should i
22 [ have fewer issues of particular safety significance that weren't l
23 '
picked up in the review, all the way up to yesterday's license 24 which would wander all the way down.
25 So I see that the number of topics that we would review i
h ALDERSON REPORTING COMPANY, INC.
15 I<
under this scheme would start with 137 or so and then, except i
2' for minor adjustments in a staged fashion, would shrink down 3
so there would be very few topics to review against the plants 4
of most recent vintage.
So it presumes that the compliance e
5 issues or the items of particular safety significance diminish b
j 6
with time and the age of the plant.
Or -he more recent the plant,l 7l R
R the fewer issues we have to look at.
Kl 8
Therefore, our manpower requirements start off and then d
o; 9
diminish as we go through.
Now we know for example that pipe 3
10 whip came in to be an integral part of the review I think in 1974.l II So I would expect by the time we are getting plants of that 3
y 12 vintage that issue should then become moot and would not be an Ea 5
13 issue. carried forward from that time on.
i 1
m 1
5 I4 So it attempts to capitalize on the growing nature of
$j 15 our review rather than just an all-out recycle through.
=
E I6 MR. DIRCKS:
It is a way to get at those safety w
h I7 l significant regulations which I think in our previous proposals E
I 18 j it.was more of an arbitrary cut than this proposal.
z I9li n
MR. DENTON:
So for plants in the last few years there 2n l
20l should be very few items still left, 21 COMMISSIONER BRADFORD:
But that was always the assump-1 22 tion I think, that the process would be a narrow one.
And I 23 l suspect in f act that whether you used one of the earlier formula-24 tions or this one, you would get to the same number of issues for 25, the later plants eiEher way..
That is,the more experien.ce you havo 3
i ALDERSON REPORTING COMPANY. INC.
16 1I the fewer issues.
The difference is in the early stages, not in i
2l the late stages.
3 CHAIRMAN AHEARNE:
Let's see, ycu would be in effect 4
defining "of particular safety significance."
It appears to me e
5 that you are saying that there are some items in which there is hj 6
a question of whether that is adequately done in a given plant R
7 and that is what is of particular safety significance --
Al 8
MR. DENTON:
Yes.
d c;
9 CHAIRMAN AHEARNE:
-- as oppsed to:
here is a regula-z h
10 tion which addresses an item which is of particular safety i
j 11 significance for all plants.
I 12 MR. DENTON:
That is the distinction.
4 13 We really started this way with the SEP program.
We m
5 14 looked at all regulations and came to some judgments about which 15 ones had to be looked at in this first batch and that is how we j
16 got down to the 137 topics that would be of particular signifi-w y
17 !
cance for this group of plants.
And that doesn't include 50-46, z
18 which taken in isolation is important but doesn't affect --
c8 I9 CHAIRMAN AHEARNE:
I see that.
9 i
M 20 Now you had previously in SECY 81-13 given a resource 21 ;
requirement which addressed SEP Phase II, Phase II, IREP/NREP, 1
22 Section 110 and then you have dollars and people.
23 '
MR. DENTON:
Yes.
24 l CHAIRMAN AHEARNE:
I suppose one could say that that 25 is a resource allocation that can go with any program.
That is i
i ALDERSON REPORTING COMPANY. INC.
I 17 1
1 the people that you would have available and so you would put that 2
on and then whatever the program is, the timing would depend upon 3
this for completion.
4 MR. DENTON:
You could arbitrarily make that assumption.
g 5
CHAIRMAN AHEARNE:
Are you saying that you have a 8
j 6
different --
?.
6 7
MR. DENTON:
We haven't worked out a final one, but it 1.
j 8
is my view that doing it this way would reduce the initial l
d o;
9 prioritization of issues, for example, which was going to be done 2
h 10 more or less in the abstract, and we had assigned people to.
And E
j 11 also it doesn't show the, in other words if we stage out the is t
y 12 number of plants as shown in the graph we will need diminishing
~
9 13 number of staff becausa the number of topics will keep dropping 1
l 14 down.
2 15 So I think it could be accomplished with less than the g
16 51 and I would propose to do it, start with the 39 which is what
- d i
17 is being worked on.with 137 issues --
f 5
18 CHAIRMAN AHEARNE:
Which is in the Fiscal '81.
The 39
_r.
19 addresses '81.
20 MR. DENTON:
Right.
l 21 !
We would add in the IREP/NREP part of the staff but 22 give less and less resources to it over the years, because that 23 f is not what we had originally proposed which is more or less a 24 constant level.
25 CHAIRMAN AHEARNE:
But you would feel then the SEP i
ALDERSON REPORTING COMPANY. INC.
18 l
I portion, SEP, IREP/NREP would be reduced, the same?
2l MR. DENTON:
I think it would be flat during the first 3
few years as we were working through plants that had 137 numbers 4
of issues outstanding, and then for the 84-90 it ought to get e
5 wrapped down considerably.
h 3
0 CHAIRMAN AHEARNE:
Not IREP/NREP though.
^e.
b 7
MR. DENTON:
The IREP/NREP would stay that level of six Xj 8
but the number of issues that we would have to deal with to d
y 9
resolve would go down.
- e 10 CHAIRMAN AHEARNE:
And the SEP, you would expect to also 15 4
II follow that same path that is outlined here or would you expect is
(
12 it to drop then in the out years?
^3 MR. DENTON:
I would expect it to drop in other words g
13 g
l 14 if this approach is adopted.
15 COMMISSIONER BRADFORD:
Do you mean drop compared to i[
16 the initial effort or drop compared to the average you projected w
h II !
in the earlier paper?
b 18 CHAIRMAN AHEARNE:
I was speaking with respect to this E
I' i' j
list.
Here the effort increases.
O COMMISSIONER BRADFORD:
Right.
Well, let me tell you I
what confuses me about that.
I would have said that under either 21 22 formulation, as you got to the years 1985 to 1990 you would be 23 making your decision on the basis of concrete experience rather than the initial list.
That is, the review of"the SEP plans and 24 25 then maybe the next ten would have showed you what the troublesomet:
ALDERSON REPORTING COMPANY, INC.
19 1I areas were.
And you would have focused in on those whether you.
2 started out with 137 or whether you started out with 85 percent 3
of the regulations.
4 And I can't see why the effort would be any different g
5 under either proposal for the last five years.
I can for the 8
6, first five, because if you are starting out with a more limited 9
7 effort here obviously it is going to take fewer people and you
%l 8
won't have to put much effort into defining safety rules.
dn 9
But then once experience becomes the governing factor i
h 10 I should think it would look the same for either approach.
j 11 MR. DENTON:
I think there are several ways to look at y
12 it.
Some issues though that we are taking a lot of time on now E
13 were picked up eventually in the chronol'ogy of our reviews and l
14 shouldn't take effort for plants licensed after 1972 or 1975.
So 5
2 15 there should be some dimunition of some very sticky issues.
g 16 ;
Take seismic, the early plants were far differently 2
i 6
17 ;
built than the more recent ones.
So the level of effort to do a 18 seismic review should diminish.
=
C 19 l Areas which are continually sticky throughout will take g
n 20 the same amount of effort all the time.
21 I MR. CASE:
The problem is, Harold, the SEP and the 22 numbers in that previous were based on a reduction already from 23 the 137 to approximately 70 or some number like that.
So you i
24 ;
shouldn't take advantage, take credit for that reduction twice.
25 I am afraid you are doing that.
In other words you took into ALDERSON REPORTING COMPANY. INC.
20 I
I account in preparing the table or the other way of doing it, the 2
fact that the issues --
3 COMMISSIONER BRADFORD:
It would narrow it, yes.
4 MR. CASE:
Perhaps not quite as much as this approach.
e 5
CHAIRMAN AHEARNE:
But your previous SEP really didn't h
j 6
narrow it much at all.
In fact it increased.
The previous table R
I 6.
7 increased.
Ml 8
MR. CASE:
I know, but there are different kinds of d
i C!
9 plants involved over the years.
We have a level of effort over 5g 10 the years, but what doesn' t show is how the number of reviews N
5 11 varies over the years, is l
12 CHAIRMAN AHEARNE:
Yes, that is true.
5 5
13 MR. CASE:
Because the SEP Phase II has taken three or a
l 14 four years --
MR. DENTON: We had 38 staff years budgeted for this 15 j
16 in Fiscal '82, in the Fiscal '82 submission now pending before s
g 17 I
the Appropriations Committee for the SEP, IREP/NREP portions of I
h 18 this whole program.
c t-19 CHAIRMAN AHEARNE:
In other words that is different 20 than what you sent out.
21 MR. DIRCKS:
If you look on page 7 of the staff paper, 22 what we are talking about with this thing --
23 CHAIRMAN AHEARNE:
Right, you were suggesting shifting 24 some of those out of IREP/NREP and then adding other people.
25 MR..DIRCKS:
I think what we are proposing here is that r
ALDERSON REPORTING COMPANY, INC.
21 I
we stay at the 38 level for '82 and carry out this program this 2
way.
3 CHAIRMAN AHEARNE:
What I have to try to understand 4
though is that we have an SEP program, an IREP/NREP program, and a
5 a Section 110 program.
Now your previous proposal integrated b
8 6
the three of them.
What you come back in is a proposal which e
9 R
7 sounds like how you are going to use SEP or IREP/NREP and handle 5nj 8
the Section 110 requirements.
dd 9
So is it fair to conclude that I ought to then take the i
E 10 SEP, IREP/NREP program that you proposed previously and say that E
g 11, is the SEP, IREP/NREP program on which this program is going to a
j 12 be based?
=
{
13 MR. DENTON:
If I followed you I think the answer is E
i l
14 yes.
c 2
15 CHAIRMAN AHEARNE:
Let me say it in a different way g
16 then.
Here I have this table in 81-15.
It is broken into' d
1 d
17 i sections:
SEP, IREP/NREP and Section 110.
Here is a new l
5 i
l M
18 proposal on Section 110.
f 19 MR. DENTON:
Right M
l i
20 CHAIRMAN AHEARNE:
What I am really asking is, inherent 21 in here are some people and dollars, and can I replace the lower 22 portion with what is represented by your proposal and keep the l.
l 23 '
upper portion the same?
So would that accurately represent the 24 resources to be allocated to SEP, IREP/NREP?
25 MR. CASE:
What is the lower portion?
)
ALDERSON REPORTING COMPANY. INC.
1
22 1
CHAIRMAN AHEARNE:
The lower portion was Section 110.
2 MR. CASE:
The only thing that would vary would be the 3
Section 110.
4 CHAIRMAN AHEARNE:
That is what I am asking.
5 MR. CASE:
I would say essentially yes.
=
h j
6 MR. DENTON:
I was going to say essentially the same 2
7 way.
Let's suppose there is no diminhtion of issues through the Aj 8
review.
Therefore we would have to keep the level of effort, the d
d 9
32 man years or so that we are now putting in SEP plus the six i
h 10 man years IREP/NREP would continue all the way through each j
11 stage.
In other words if we vere not able to narrow the --
a j
12 CHAIRMAN AHEARNE:
But this does assume a diminution
=l 13 because there is 32, 30 and 21.
8 l
g 14 MR. DENTON:
That is correct.
2 15 So whether it goes down that rapidly or not will
- z 16 depend on how rapidly the issues drop and whether as Commissioner g
w d
17 '
Bradford said the tough issues keep it up high.
18 CHAIRMAN AHEARNE:
So then is it correct that if we were to not go forward with the 110 section but to go forward 19 j g
M 20 with the rest of the program, we would be using 32, 30, 217 21 '
MR. DENTON:
That's right, if the dropped of that fast.
22 CHAIRMAN AHEARNE:
Yes.
All right.
1 23 '
MR. DENTON:
I would be more inclined to carry a 38 24 '
for another year and try to learn what was really happening and j
25 diasproject it on out.
Put the equivalent level of effort --
ALDERSON REPORTING COMPANY. INC.
l 23 l
1 CHAIRMAN AHEARNE:
For the Phase II?
2 MR. DENTON:
No, I would drop the entire bottom part of 3
the chart.
4 CHAIRMAN AHEARNE:
Well, you don't have that choice.
g 5
MR. DENTON:
I would propose to put in '82 the kind of E
3 6
effort that the SEP plus IREP/NREP would add up to and see where R
I 7'
it goes.
X j
8 The only reason I say that is it is hard to project c.5 c
9 what the 137 will go.
E 10 CHAIRMAN AHEARNE:
Are the 38 people that well i
II identified between SEP and IREP/NREP or are they just a block of is
(
12 people 7 E
5 13 MR. DENTON:
I think they are just a block of people a
14 in size.
=
15 MR. DIRCKS:
I think what we are trying to do here is i[
I6 give you our concept of how things should work.
We haven't put, as h
I7 and within a personnel ceiling.
It is our feeling that it would 5
18 l
mean less resources to do this work from our side.
And I would II g
feel,although I don't know whether we have done any calculation 20 on what the impact would be on the utilities, but the general i
II feeling is it would be a substantial reduction of effort on that 22 f side.
23 So what we are trying to do is propose a program that 24l would make sense from a safety standpoint and from the point of
-economics.
i 1
f ALDERSON REPORTING COMPANY. INC.
24 h
i 1!
COMMISSIONER GILINSKY:
How does the amount of work l
2l done by the NRC and the utilities compare, in other words for 3
every man year here?
4 MR. DENTON:
Remember the SEP program got started on g
5 the assumption that we would assume the burden of making these P.
6 comparisons between today's practice and actual practice.
So we 6
7 paid for consultants to do the comparisons of seismic design and M()
8 so forth.
Once a program is going, the way we. propose it, it d
=;
9 shifts it back to the way we do reviews now.
z h
10 MR. DIRCKS:
And there are a number of IREP reviews Z
4 II going on right now with the plants and I assume on several 3
Y_ I2 Phase II plants.
So they have that information.
13 CHAIRMAN AHEARNE:
That'was based.on the assumption that E
5a l
14 the licensees would be picking up the methodologies developed
$j 15 under IREP.
x E
I0.
MR. DENTON:
So I think after the first batch or two of d
l l
h I7 l Plants we ought to be clearly into one where they do the bulk of l
z 18 the work, both the NREP and all the other aspects.
G I9 'l COMMISSIONER GILINSKY:
Where does SEP stand now?
l g
20 MR. DENTON:
Let me ask Darrell Eisenhut.
I think by II late summer or fall we are to complete a considerable number of those topics for that batch of plants.
3' COMMISSIONER GILINSKY:
This is the first batch of 11?
{
- l MR. EISENHUT:
The first batch of 11.
I seem to think 25 about 40 percent is the number of the total topics that are now l'
il ALDERSON REPORTING COMPANY, INC.
25 I
done, and we are due to have the lead plant pretty well resolved i
2 down to where we will have completed all the topics in the lead 3
plant sometime later this year, midsummer I believe.
4 COMMISSIONER GILINSKY:
What was the effort involved in a
5 that?
E j
6 MR. EISENHUT:
The total manpower under this program?
R 7
The program has been running about, it was budgeted at 32 man N
i j
8 years.
Now this is the third year I believe.
Those people were d
d 9
not all, that is exactly the point.
It was budgeted at 32 plus 10
$1 million and contractor help, 10, 11, 12 people.
It was E=
4 11 probably running at about half of that in terms of actual people.
B j
12 COMMISSIONER GILINSKY:
On the average.
=3 13 MR. EISENHUT:
On the average,actually putting into the 5a m
E I4 program.
N 15 COMMISSIONER GILINSKY:
Over how many years?
y 16 MR. EISENHUT:
This is-the third year in the program.
W I7 MR. DENTON:
A major part of this effort has been in i
z
{
18 the seismic review.
I P"
19 MR. EISENHUT:
That is right.
The single biggest part e
i l
20 of the prograa has been the development of the seismic methodology l 2I COMMISSIONER GILINSKY:
And what does Phase II entail?
22 l MR. DENTON:
Phase II is the review of 11 of the older 1
23 l plants in these 137 issues, which was sort of the results of 24 l starting --
25 COMMISSIONER GILINSKY:
I see, this is Phase II.
ALDERSON REPORTING COMPANY. INC.
26 1
MR. DENTON:
This is Phase II.
Phase I was development 2
of the program.
3 COMMISSIONER GILINSKY:
Development of the program, 4
okay.
e 5
MR. DENTON:
Phase II had, I think there are six of the k
6 11 plants, remember,have POL licenses.
R d
7 COMMISSIONER GILINSKY:
I am sorry.
I was a phase M
j 8
behind.
d d
9 And where does IREP stand?
I keep asking this and Y
10 forgetting, so bear with me.
E j
11 MR. DIRCKS:
There are six plants.
k I
12 CHAIRMAN AHEARNE:
And the first report is due out 4
g 13 somewhere in May?
i
=
m 5
I4 COMMISSIONER GILINSKY:
And how much effort do those
{
15 involve?
=
y 16 MR. DENTON:
That is being done through research and w
(
17 l contract dollars largely, and we are putting people into it.
E m
18 i I don't have the resource number.
5 l
g 19 l CHAIRMAN AHEARNE:
That doesn!t show up on your table.
M-20 MR. DENTON:
That's right.
2I COMMISSIONER GILINSKY:
Is that being done largely by 22 us?
Is that the difference between IREP and NREP?
23 MR. DENTON:
Yes.
24 l CHAIRMAN AHEARNE:
IREP was to develop, take a set of i
25 plans and try to develop a methodology that could be used.
l ALDERSON REPORTING COMPANY, INC.
I l
27 1
MR. DENTON:
So that we could issue instructions.
2 COMMISSIONER GILINSKY:
And how well defined is NREP?
3 What does that stand for?
4 MR. DENTON:
National, with the idea being that IREP, r
e 5
after the first plants we would be able to write down what a good h
j 6
reliability assessment would contain.
And then all plants as they K
d 7
came due here would be asked to do the same thing.
Ml 8
MR. DIRCKS:
That is where we have involved the IEEE, dd 9
the ANS and ourselves and I don't know who else in developing b
10 this approach.
E j
11 MR. DENTON:
Now a number of plants have already begun 3
y 12 to do their own sort of risk assessment in anticipation of NREP 4
g 13 coming due, a
m i
14 COMMISSIONER GILINSKY:
Now how does this relate to the l
.j 15 requirements on, for example, CP applicants to complete r'eliabil-16 :
ityfassessment or risk assessment?
Would they be doing their s
g 17,
NREP analysis or something different?
18 MR. DENTON:
The difference mainly is for these plants P
"a 19 the plants are all built so all I can do is assess the way it
.4 20 turned out.
For the CP plants it should guide the design of 21 systems.
22 COMMISSIONER GILINSKY:
I see.
So this is really for 23 the plints that are already built and would go back to the other 24 l plants that you would be picking up the analysis that they did 25 ;l before they were built.
4 i
ALDERSON REPORTING COMPANY, INC.
28 1
MR. DENTON:
Yes.
i 2
I see NREP here as identifying outlines.
3 MR. EISENHUT:
I was going to sort of second what l
4l Harold said.
First you remember that there was a Crystal River e
5 IREP study which was begun a year or so ago.
M9 l
6l CHAIRMAN AHEARNE:
Is that finished?
R ji 7
MR. EISENHUT:
I don't think it is officially finished.
j 8
It will be the lead.
Hopefully it will be the first one completed.
d o
9 We cut from the six back to the four and those are targeted to be Y
10 wrapped up sometime later this year.
?-
j 11 Now in addition the utility own their own.
It started S
I y
12 l with the Indian Point Zion exercise.
Remember the industry on 13, their own undertook to do a large number of reliability studies,
(
=
l 5
14 sort of really closer to a WASH-1400 study than really just an m
l 2
15 IREP study.
Plants like Limerick have undertaken at our i
y 16 ! encouragement to do a fullblown WASH-1400 study, and probably g
e I
d 17 another half dozen of the OLs are right now doing that.
i h
18 The task that we laid upon the cps or we would be by 1
C 19 the proposed rule, the first item would be to put on and ask them M
20 to do basically a WASH-1400 type study and whatever fell cut of i
1 21 that study, to integrate it back into the design of their plant.
22 And they had to have the results of that study back to the staff I
23 I within two years.
We elected two years because that would be 24 l early enough in the overall design such that it would be the b
25 benefit of improving the plant design.
4 ALDERSON REPORTING COMPANY,INC.
29 1,
So there is a large scale number of things going on.
l 2l They are not really, any one of those or not one of them actually 3
is what we would look at as the NREP program, which would he just 4
a followup to the IREP program based on the methodology that came e
5 out of the IREP program.
An 6,
CHAIRMAN AHEARNE:
But a big difference, as I understand i
g-8 7
it, is instead of we doing it --
n' j
8 MR. EISENHUT:
Absolutely, that is right.
dd 9
COMMISSIONER GILINSKY:
And how long would each of zog 10 those take about?
E 11 MR. EISENHUT:
I don't think we have really targeted 3
i 12 a time.
I would imagine that to do an IREP would probably be a 3
(
j 13 year or so.
But if you look at it, it is stretched out over some l
14 l period of time.
NREP is really laid back on the operating plants
,2 15 and it goes, on this program I think we had the six man years as
,x j
16 I remember all the way through 1990.
So it would be running in M
N I7 i parallel.
I w
18 '
CHAIRMAN AHEARNE:
Do you have any more to say?
m P"
19 MR. DIRCKS:
I think what we will do is, getting back g
y 20 to the staff resources, take the 38 as a ceiling and we can 2I perhaps reduce that to some extent.
But 38 would be the amount 22 that we are asking for in 1982.
23 l MR. DENTON:
I think just to close up, my planned 24 [ presentation would be to focus on this last chart which sort of 25 '
showed what I meant by staging, and the next group of applicants s
i i
ALDERSON REPORTING COMPANY. INC.
30
(
1. ahead of the group under discussion today would be assessing their l
2l compliance with the rules and the SRP for whatever the topics 3
were while we were finishing the review of the previous stage.d 4
plants.
And so it would end up then a staged manner to keep I
1 I
e 5
resources fully occupied and always have the next group of b
6 applicants at work on something to submit.
j R
7 COMMISSIONER GILINSKY:
Why wouldn't they want to do A
j 8
it earlier?
I dd 9
MR. DENTON:
Well, you could have them, let's take i
1 o
10 should Sequoyah do all 137 issues today, you could do that and 3
l 11 lay it on today.
But all 137 no doubt will not apply to Sequoyah.
3 I
12 We will find that it drops down to just a very few for the most 5
(
d, 13 recent vintage.
And it is just to work through that process and
=
l 14 capitalize on each stage.
w g
COMMISSIONER GILINSKY:
Wait a minute.
When you are 15
=
d I0 talking about IREP/NREP, are they staged the same way?
A N
I7 MR. DENTON:
In our scheme here they would be a staged se 3
18 part of review so that the topics that were identified would, P
g I guess we haven't reached way out in time to see when NREP would 19 n
20 really come in.
But obviously you would use risk assessment 2I techniques to help you resolve the safety issues related to those 22 topics.
I CHAIRMAN AHEARNE:
I think in NREP we begin to run into, 23 24 l we have to decide how much review does the NRC do of the product 25 because then we ru., into problems with our review times.
And i
e ALDERSON REPORTING COMPANY, INC.
1
31 I
I then realistically at the moment there seems to be a finite pool 2l of people who are competent to do this kind of work.
If we say 3
everybody has to do it in one year, there just aren't that many 4
people around.
e 5
MR. DENTON:
That's right.
A f
6:
COMMISSIONER GILINSKY:
-- decide whether they have to i
R
(
7 do it.
If you are running a plant and this is a pretty valuable s
j 8
thing to do, which I hope it is if we are going to require it, f
a d
9 then wouldn't you want to do it pretty early so you could get N
10 a pretty good understanding of the problems?
z 1
=
l j
11 MR. DENTON:
But I think it i: Ts John said, that s
y 12 every practitioner of the art is already at work in this.
E g
13 MR. CASE:
I would just like to add a bit or maybe m
14 argue a bit on what Bill said.
I disagree completely on that.
5
$j 15 CHAIRMAN AHEARNE:
Why don't you use the mike?
m j
16 MR. CASE:
The 38 number that Bill mentioned is s
(
17 currently in tF-budget for IREP/NREP and SEP.
I think it may be I
i w
i 3
18 a little tigh.
ceiling for doing this revised proposal, for c8 g
I do believe tha
_.te answers to Step 3 have to be given at least 19 E
20l some review by the NRC staff to assure that some of the regula-l 21 !
tions don't need exemptions, for instance.
I i
j 22 !
So there is a small part of the Section 110 that has 23 to be added to the IREP/NREP, SEP in any event.
I would estimate l
1 24l it would be about five man years.
25 CHAIRMAN AHEARNE:
Unless you slip.
?
I i
ALDERSON REPORTING COMPANY, INC.
l 32 y!
MR. CASE:
Unless you slip, yes.
But I do believe we ought to come back with a more 2
3 rational number.
4 COMMISSIONER GILINSKY:
Let me go back and ask, I should e.
5 have done it before, why is it not sufficient for satisfying the 9
l 8
6: requirements of this Section 110 to produce the matrix we have e
1 g
8 7
talked about here from time to time?
On one side you have the
\\
,~
f8 requirements and across the other is the plants and then in the d
d 9
boxes in effect you have put the basis on which each of these 8
10 requirements was satisfied.
That it seems to me would tell you, E
i 11 would give you the answers that that mmendment is asking for.
E d
12 MR. DIRCKS:
Haven't we touched on that in Step 3 here, 3
i
=
j 13 each rule and regulation that we have identified as particularly l
=
l l
l 14 safety significant?
t 2
15 COMMISSIONER BRADFORD:
The real answer is that you u
z g
16 l can't do it because for current regulations you don't know how M
i d
17 f or whether the older plants would meet them.
l 18 COMMISSIONER GILINSKY:
You would say that,for a certain E
i
[
19 ;
requirement you would say --
H 20,
COMMISSIONER BRADFORD:
I mn sorry.
I don't mean I
21 current relations so much as current reg guides, branch type --
l l
22 !
MR. DENTON:
It has been the practices rathe r than the l
I 23
- regulations that have changed more over the years.
But Step 2 24 I would get for those regulations which were, and I think that would.
Ii 25 j be the bulk of our regulations in this first program.
We would h
ALDERSON REPORTING COMPANY. INC.
33 l
l 1
get from the licensee just what the Amendment required.
2 COMMISSIONER GILINSKY:
Maybe I didn't understand your 3
proposal.
Is what you would compile, would it be in effect the 4
clerical task or a technical task?
In a sense would you be doing g
5, engineering analysis to decide --
H I'
g 6
MR. DENTON:
That is the sort of five man years that Ed R
7 suggested we might put on it.
I would not put much effort on j
8 their response to our Step 3 items unless we noticed wide, wide d
9 9
departures and we failed to comply.
In other words Step 3 flat 3
10 out asked him to describe the extent to which he complies with E
h 11 these rules and regulations and an indication of where it was 3
y 12 done by SRP.
=
13 So in those instances where he said he doesn't comply
=
I4 i l
we would have to do some level of effort looking.
Now if he says l
c i
=
i g
15 '
he complies --
=
g 16,
MR. CASE:
The five man years is a half a man year per M
h I7 plant, you understand.
There are ten plants being reviewed in a E
18 l 3
j year.
Five man years with ten plants is only half a man year ch i
3 I9 l per plant for that step.
So you have to look and just to look n
20 at them I think would take half a man year.
i l
i II l CHAIRMAN AHEARNE:
You are saying it would take cne 22 l professional six months to review the response?
4 23 MR. CASE:
Yes.
24 1 CHAIRMAN AHEARNE:
How many years do you figure that i
25j' that level of response would take to generate?
J ALDERSON REPORTING COMPANY. INC.
34 1
MR. CASE:
That is a much different question, because 2
I understand that licensees don't have a ready answer to the 3
question to the degree to which they comply with the regulations, 4
and they may have to do a lot of engineering work.
s 5
COMMISSIONER GILINSKY:
That is what I am asking.
Are E
6 you going to be requiring engineering analysis or is this just a R
R 7
statement of the basis on which a certain requirement or regula-
%l 8
tion was meant?
I would think it would be the latter.
d c
9 COMMISSIONER BRADFORD:
But it has to be in the present i
Cg 10 tense.
It is "is meant" rather than "was meant."
E h
11 MR. CASE:
The active part is for them to state to a
y 12 the NRC, to identify the extent to which they meet the regulations
=
(
h 13 COMMISSIONER GILINSKY:
But in some cases they met the m
l 14 regulations on the basis of an older interpretation.
I
$j 15 MR. DENTON:
And they would say that.
a l
g 16 COMMISSIONER GILINSKY:
Now is it enough for them to M
g 17 ;
say that?
Or do they then have to analyze the plant in terms of 18 a new regulation discovered?
You know, 63 percent of xa:s is j
1 G
19 l
g required by the new interpretation.
M 20 MR. DENTON:
What we are proposing is that under Step 3 1
21 '
it is enough for them to say whether they do or not and whether 22 i or not they use, in other words Step 3 is sort of a listing or I
23 a matrix approach, as you said, and they can put as much or as I
I 24 '
little effort into it.
2 25 And then Step 4 says the only ones _ that we are ALDERSON REPORTING COMPANY. INC.
35 1. especially interested in are those topics that point, that came l
l
\\
2 out of the SEP in previous reviews where we know we are likely to I
3 find problems and there we will need an engineering evaluation to 4
show how you comply with today's criteria.
e 5
COMMISSIONER BRADFORD:
Go back to Step 3 for a minute A
I a
6 as to the example you were using earlier, pipe whip versus 7.{
7 missiles.
Take an area which is not part of your 137 items.
n'l 8
What exactly are they going to give you with regard to, say d
d 9
tornado missiles is brought in as part of the answer to the Y
g 10 general design criterion on missiles, but it isn't anywhere in E
I l
11 the 137.
They are just going to tell you here is how we meet j
12 current staff practice on tornado missiles?
E j
13 MR. DENTON:
I read 3 as being mainly a one-page
=
l l
l 14 l answer per regulation.
b i
=
t 15 COMMISSIONER BRADFORD:
But is it phrased in terms of t
l g
16 l current requirements --
l W
i d
17 l MR. DENTON:
Yes.
l
{
18 !
COMMISSIONER BRADFORD: -- or past requirements?
If it E
l g
19 l is current then how are they going to be able to do that?
M 20 MR. DENTON:
All they do is say whether they meet it 21 or not.
They don't have to give, the way I read the Amendment 22 l all it says is indicate where acmpliance was achieved by today's 23 regulations or not.
So that could be a check or an X.
l 24 i COMMISSIONER BRADFORD:
But compliance from any of 25 these plants wasn't achieved.
They have never been measured i
I i
i ALDERSON REPORTING COMPANY. INC.
j L
36
\\
1 against current requirements.
2 MR. DENTON:
So they would put an X there.
3 COMMISSIONER BRADFORD:
What does the X mean?
4 MR. DENTON:
That we didn't do it by today's methods, e
5 I would propose to accept that except for those topics A
N 6I that we have identfied as being special interest.
And there I
^n
[
7 would want to get into engineering evaluation using the SRP.
n' j
8 COMMISSIONER BRADFORD:
I am going to want to get into dd 9
that a little later because it is crucial on whether the 137 is it 10 really the right list.
E_
j 11 MR. DENTON:
I read the regulation as not requiring y
12 any engineering analysis.
All it says is describe the extent to E
(
13 which you comply with the rules and regulations including an a
g 14 indication where such compliance was achieved by today's g
15 practices.
So that doesn't --
z l
j 16 COMMISSIONER BRADFORD:
So in many cases that X is A
d 17 i really going to mean:
don't know, we don't know the extent to Y
\\
1 18 which we comply with today's practices.
A
{
19 '
MR. DENTON:
That's right.
M l
20 Now I would propose that we not spend a lot of time on l
21 those ones unless we had something like the pipe whip issue 22,
buried in there.
l 23 '
COMMISSIONER BRADFORD:
Right, unless they are safety f
24 l significant.
I agree with you as long as one can be absolutely 25 sure we have the right list of safety significant requirements.
l i
ALDERSON REPORTING COMPANY, INC.
37 i
1 That is, there was always going to be an area where we weren't I
2 going to pursue in any detail the question of the extent and 3
nature of compliance, and it was always that area where we 4
decided it wasn't safety significant.
What we have done here is s
5 just to broaden --
R h
6 MR. DENTON:
There is no way to guarantee it though, E
{
7 short of doing it all.
j 8
COMMISSIONER BRADFORD:
I do want to ask more about dd 9
the 137 items in terms of their sufficiency, but I didn't mean i
Og 10 to distract too far from Victor's earlier question.
E I
COMMISSIONER GILINSKY:
Do I understand you correctly j
11 l 3
i j
12 i to say that the Section 110 requirements are meant by Steps 5
j 13,
1, 2, 37 14 MR. DENTON:
Yes, and I am saying the Step 3 doesn't
=
t 2
15 '
give enough substance for us to evaluate whether the fact that l
j 16 f they didn't meet it by today's methods is important or not.
So t
w d
17 !
I don't know how to evaluate that X when they put in that they 5
l l
E 18 '
didn't mean --
r l
P i
{
19 l COMMISSIONER GILINSKY:
You don't want just a yes, no.
M 20 You want the basis on which' it was approved, and they might say 21 the 1974 standard or something like that or reg guide one point 22 something or.other.
l 23 '
MR. DENTON:
Right.
l 24l COMMISSIONER BRADFORD:
But that doesn't answer the 1
25j requirement of the Bingham Amendment, which is its n.ationship
?
[
ALDERSON REPORTING COMPANY, INC.
=
38 l
I to the current.
It is nice to know on what basis it was approved.
2 COMMISSIONER GILINSKY:
That could be the sense of the 3
Bingham Amendment.
4 But anyway I guess what I would say is rather than get I
g 5j into a gargantuan program which we may lose control or our R
6l successors lose control or may bog down in various ways, I would R
7 propose that one approach this sequentially and take a little bite
%l 8
and see where that leaves us.
d ci 9
CHAIRMAN AHEARNE:
What does that leave you?
I h
10 COMMISSIONER GILINSKY:
Just going up to Step 3.
g 11 CHAIRMAN AHEARNE:
Now if you just went up to Step 3 3
y 12 though and you finish Step 3, there is one issue of whether it
=f 13 meets the law.
The second issue would be what the significance
=
j 14 l is in' going just up to Step 3.
5 2
15 COMMISSIONER GILINSKY:
Then you would look over what 5
g 16 :
you have and decide where you want to go from there.
I think --
d I
(
17 l MR. DENTON:
I think in our scheme Step 4 is the SEP
\\
{
18 '
program.
Where there is an X in their column they don't meet it A
h 19 '
by today's systems.
We don't look at all Xs.-
We only look at n
20 those that we have identified to be of special interest.
21 COMMISSIONER BRADFORD:
Is this on this subject?
22 CHAIRMAN AHEARNE:
Yes.
This is sort of late mail 23 '
addressing the debate that was just occurring over here on my i
24l left.
It is a letter from Mr. Udall, and it says:
25 "It appears that the proposed plan for Dmplementation od d
il ALDERSON REPORTING COMPANY, INC.
l 39 l
l I the requirements of Section 110 of P.L.96-295, the Commission's 1
2 authorizing legislation for Fiscal Year 1980, would entail 3
substantially more effort than I had envisioned," that is Mr.
4 Udall, "when we adopted the language that was eventually e
5 incorporated into law.
While I~have no firm position regarding 0
6, the rule now being considered by the Commission," I am not sure R
g 7
which rule he means, "as the means through which the requirements
%l 8
of Section 110 would be met, I believe it important that the dd 9
Subcommittee have the opportunity to hear testimony concerning io g
10 the rule prior to the Commission deciding on its adoption.
E g
11 "I would hope, therefore, that the Commission will 3
y 12 defer its decision on adoption of the rule," he means the Program, 5
y 13 I guess, "until the Subcommittee has a hearing -
i 14 '
' ~COMMISSIONEE GILINSKY:
But it has been put out in 2
15 proposed rule form.
j 16 CHAIRMAN AHEARNE:
" -- until the Subcommittee has a l
d 17 i hearing which will be set for February 27 if the Commission's s
i 18 schedule permits, or, if not, as soon thereafter as possible."
E.[
19 COMMISSIONER BRADFORD:
Well, there was never any 5
20 danger of our meeting that one I don't think.
21 CHAIRMAN AHEARNE:
All right, Victor.
22 COMMISSIONER GILINSKY:
Well, I can't top that.
23l (General laughter.)
24 MR. DIRCKS:
Harold was going to make a point that the 25j whole thing is built on the concept that we are going to have an d
)
ALDERSON REPORTING COMPANY,INC.
40 o
1 integrated program here.
We have got to comply with the require-2' ment but we are also going to tie it back into tha ongoing SEP, 3'
IREP programs.
So one feeds into the other.
4 Step 4, Item 4 on this memo will set the stage with e
5 Phase IV or Phase III of the SEP program as it conta.nues down the P.
3 6
line.
- r i
M.,
7 MR. DENTON:
Step 4 would be the issues which we are X
j 8
really concerned about, their not meeting today's techniques, d
i
- [
9l and we would spend efforts to bring them up to today's style or
?
5 10 an equivalent means.
So it would give some body to the X in a 3
]
11 column that we might get in Step 3.
At least that is the way I 3
y 12 envision it working.
,=
E 13 COMMISSIONER GILINSRY:
Ecw well defined is the NREP
[
E t
x g
14 p"osens at.this point?
Do you know what the requirements are?
u
!E E
15 MR. DENTON:
No.
It is intended to be the program tait l
- s j
16 flows from IREP, and since IREP has not come to a completion we e
!5 17 don't really, I couldn't say it is well defined.
It would be a
[
ti v.
E 18 risk study program that we would lay on people to do in these t
i:
{
19 matters and they would have to consider certain elements and i
(
M l
20 i certain sorts of systems.
But I don't think we have it well j
i 21 !
spelled out because we don't have the IREP experience yet.
j I
I 22 d CHAIRMAN MEARNE:
At least I was looking at it as a 23 l mechanism to pick up on those ceittees ' recommendations on l
4 24lbringinga ballistic assessment, a liability assessment more f
4 25 l into the actual review of plants.
And as in the case of IREP J
t ALDERSON REPORTING COMPANY. INC.
b
41 I
was not necessarily mapped directly to NREP out rather an attempt 2' to, by evaluating these specific plants, seeing how can a method-3 ology be developed.
And that is your involvement by EEE and ANS, 4! continue that develognent and the NREP picking up amongst others s
5 the ACRS recommendation of the industry.
S 6
As you recall ACRS had said that they thought that the R
7 basic concept of IREP was good but instead of just the NRC paying j
8 for a few plants that we ought to just turn and ask the industry d"
9
~.
to do everything.
10 COMMISSIONER GILINSKY:
Let me ask you, would these E
Il steps, Step 3, Step 4, be carried out sequentially for each group t
S
{
12 of plants over this seven-to-ten-year period?
Or would each one
=a 13 j
kind of march through a little bit separated in time?
x MR. DIRCKS:
Well, I think the essential concept is to I4 l
i l
E l
g 15 take them in blocks, and the output of one block is formulated I0 on the next block.
s C
17 MR. DENTON:
I would anticipate that the 137 issues E
I I0 that went into tFis first 11 plants might emerge as only 90, l
P" 19 i in other words after we have really looked hard at it, that only 8
l i
20 3 90 of them require changes in the plant design --
COMMISSIONER GILINSKY:
I understand what you are 22 l
saying.
That is further on and so on.
But let's take Step 3.
23 When would that be completed for all the plants, at the end of 24 !
l i
the program?
25 MR. DENTON:
Yes.
3 ALDERSON REPORTING COMPANY. INC.
l 42 f
1 COMMISSIONER GILINSKY:
It seems to me there is value 2
to doing that, which is a much simpler task, early for all the 3
plants and then taking a look and saying well, what is it we want 4
to do with all these plants.
I g
5 MR. DIRCKS:
Point 3 in this memo?
I think we would N
6 not wait --
2
\\
E 7
CHAIR E4 AHEARNE:
It says in each group.
i N
j 8
MR. DIRCKS:
-- would be completed.
The SEP plants dd 9
would have Step 3 done.
io b
10 CHAIRMAN AHEARNE:
What Vic is saying as a proposal is 3j 11 to take,after Step 1 and 2 you have now identified this list.
y 12 And then he is saying do Step 3 for every plant.
5:
13 Is that what you are saying?
m 14 COMMISSIONER GILINSKY:
At least asking about that.
5 2
15 MR. DIRCKS:
The problem is that every plant comes in j
16 and it is delivered to the Phillips Building, and you don't know M
i 17 ;
what we have and we can't really follow up, because the point 5
18 !. that Harold was making is for those Xs where it says don't know 5
l 19 l column, those are the points he is going to pick up on and do n
20 the intensive analysis on.
21 COMMISSIONER GILINSKY:
It seems to me you would get a 22 better idea of what it is you want to do next.
Here we have a 23 l kind of mechanical marching through all the plants and buying 24 l into a pretty extensive program.
25 CHAIRMAN AHEARNE:
I would guess just the opposite.
If L
ALDERSON REPORTING COMPANY. INC.
43 1I you are worried about what you would do next, this is buying into 2
a smaller program because, see, you could after you get this in, 3
you could really cut it off and you would have only asked a
(
4 smaller set of plints to go through that process.
You may decide g
5 after going throught that first batch that that is not an adequate l E
6 approach and you will modify it.
I guess I would be very 7
COMMISSIONER GILINSKY:
8 surprised at those --
do 9
MR. CASE:
I think he is ascribing to your comment,
- o 10 Mr. Chairman, to revisit the program after you have gone through j
11 the --
y 12 CHAIRMAN AHEARNE:
No.
He wants to go through, he
-c 5
13 wants to have every plant do this and then look.
And I am saying
(
A
=
l 14 if you --
- [
15 COMMISSIONER GILINSKY:
-- is a relatively simple x
j 16 non-technical task.
l d
i MR. DENTON:
I think the part that is difficult for the I
.h I7 l
=
l 18 applicant to do is he has to turn to someone and ask him:
was f
s" j
compliance in my 20-year-old plant comparable to today's --
19 0l COMMISSIONER GILINSKY:
I thought we decided that he 1
And he 21 would put in the box the basis on which he complied.
22 would say the uniform building code or something like that.
i 23 MR. CASE:
Not 4'
Step 3.
f COMMISSIONER GILINSKY:
That is what I thought we had 25 agreed before.
ALDERSON REPORTING COMPANY. INC.
f
l 44 1 -
MR. DENTON:
He would put it there but he needs to know l
2I where he puts it.
I mean he might strive to get a check, and so 3,
he would ask his AE, didn't you do my flood model the current way.
4 And if the answer is yes then he can get a check.
If they don't i
g know he gets the X.
So I would expect many of them might try co 5
N 6f I
establish checks.
R S
7 COMMISSIONER GILINSKY:
Why do we have checks or Xs?
A_
g 8
MR. DENTON:
Checks mean you have done it essentially d
9 the way'the stendard review plans or reg guides would do it today.i zt 10 COMMISSIONER GILINSKY:
Can't he say I used the 1962 z
5 I
4 Il reg guides?
3 j
12 l MR. CASE:
He could say that but that is not what j
13 Step 3 says.
i x
i Si I4 COMMISSIONER GILINSKY:
I thought that is what Harold E
i j
15 said earlier.
z j
16 l MR. DIRCKS:
I think there is a little bit of a view i
i C
17 i here between what Harold and I think Step 3 says.
k w
I wrote Step 3 and it is patterned exactly c8 1
l9 l the way --
m M
20!
COMMISSIONER GILINSKY:
Len repeatedly counsels us i
2I that we don't necessarily have to go back to the author to, just 22 read the words.
i 23
COMMISSIONER BRADFORD:
If Step 3 doesn't say that, then 1
4 24l it doesn' t comply with the statute itself.
If Step 3'doesn't l
1 1
i 25 '
make you do the assessment in terms of current practice and i
i 3
ALDERSON REPORTING COMPANY. INC.
i l
45 f
I requirement, then it doesn't comply with the statute itself.
i 2
MR. BICKWIT:
The statute says you have to demonstrate 3
compliance with the current rules.
And then it says that if that 4
demonstration is by other than current practice then you specify e
5 that.
h h
6 MR. CASE:
Just say other than current practice.
R
{
7 MR. DENTON:
That is all they would have to say.
A j
8 COMMISSIONER GILINSKY:
I would expect them to say it d
d 9
was the 1974 standard or it was the reg guide 1.7 or something by 10 or other.
E j
11 COMMISSIONER BRADFORD.
But that document is just 3
y 12 useless from the point of view of taking any meaningful reg 61atory 5
(
d 13 action.
5 l
14 COMMISSIONER GILINSKY:
From the point of view of
{
2 15 getting a picture of where you are.
16 l
g CHAIRMAN AEEARNE:
I tend to agree with you, Peter.
W g
17 i That is why I think stopping at 3 isn't going to do much good.
5 l
l 18 l MR. DENTON:
We need to look behind that little statemen%(
=
I s
{
19 and we were only going to look behind in the SEP topics.
n 20 MR. DIRCKS:
Looking behind going on to Step 4 in this i
21 memo.
22 MR. DENTON:
Yes.
l i
23 CHAIRMAN AHEARNE:
Joe, you have been very quiet here.
l 4
24 l COMMISSIONER EENDRIE:
The mind boggles.
I tell you, 25, as a general proposition, going out and collecting all of the I
f ALDERSON REPORTING COMPANY. INC.
l 46 1. Step 3 submicsions at once when you know that you can't digest l
2i them sounds to me like a pretty bad idea.
As a general proposi-3 tion in regulation, don't go out and ask for things from licensees 4, if when Smy send you the package you propose to just leave it I
i 5j laying there on the doorstep.
0 l
j 6
If you haven't got something you can do with it, don't n
7' ask for it.
Or wait until you can do something with it and then j
8 ask for it.
d 9
It appears to me that just, and I must say if the z%
10 licensees can't do Step 3 easily, then it doesn't amount to much.
z Il Then it isn't worth much.
If it is going to be worth much, why y
12 they are going to have to inevitably struggle.
Here they have
=m j
13 a 20-year-old plant or a 10-year-old plant and a two-year-old 8
i I4 regulation and they are scratching their head, do I need it or j
5 i
.j 15 l don't I need it.
And inevitably there is going to be some work i
=
j 16 !
involved, and I am not sure what you do with the answers.
w I
17 At least the overall staff propsition here would j
l j
f I
y II l attempt to deal with that problem by saying, you know, each in i
I9 its turn in digestible chunks every year or whatever, so that 2
M i
20,
the available staff resource can work on it.
Wewilltakealookj 1
21 l at a batch of plants and make an overall safety assessment.
If 22 l we find we don't think the safety _is adequate, then we will do l
l 23 '
something.
But if we think the safety is adequate, then we will l
24 l find a say to wave our hands over what are then presumably technica3~
?
j 15 ) and trivial nonconformances with new regulations.
F i
ALDERSON REPORTING COMPANY. INC.
i
i 47 l
j l
I think that is probably a lot better than having 70 or l'80 or whatever packages on the doorstep, each one of which says 2
l I don't know whether I meet the following regulations.
And the 3
staff resource is only available to pick up the first ten of 4
those and go look at it in any meaningful way, and the others e
5 r.
simply lie there to form the attachments to filings of parties e
6 e
R I' who want to present petitions for shutdown of the other plants.
8 7
%j 8
I can do without that, since that compels us in fact dd 9
to devote the staff resources to the whole array of plants that 21 10 we have already concluded we can't digest all at once.
2 5
11 COMMISSIONER GILINSKY:
If this submissions is a thing
<3 d
12 with a simple task and the submissions were relatively brief and z_
d 13 indicated the basis on which the various requirements were met, 5
l E
14 i then it wouldn't be very hard to digest them either.
w i
H=
2 15 COMMISSIONER BRADFORD:
It would be hard to extract 5:
j 16 the significance.
I menn, supposing we did something like this 1
M l
17 l in, pick one of the few areas in which I know the vocabulary, 18 equipment qualifications.
What you would get for the older
?
\\
l
{
19 l plants, leaving aside the effort you made lately, would be a
l 20 l statements that they were qualified on the basis of commitments
/
6 t
21 to install equipment of high industrial quality circa 1970-71.
i I
l 22 I You couldn't begin to tell from that whether they i
l 23 ' _ really had equipment in place in the plants that met what we 24 '
now consider to be accident environment conditions.
It wouldn't i
25 j drive you in the direction of any particular regulatory action l
ALDERSON REPORTING COMPANY. INC.
48 1
because you couldn't tell enough from it.
A statement that 2l something was adequate to an older standard just doesn't in and 3
of itself produce any conclusions on which we take action today.
4 It may be all right by today's standards; it may not be.
5 CHAIRMAN AHEARNE:
I gather, Joe, you would reasonably g
n j
6 be willing to go this route; and Vic, you would ask for No. 3 to R
7 be everything to all and not at this stage commit to anything Al 8
further.
O 9
COMMISSIONER HENDRIE:
Let me amend your reading of i
C h
10 my vote, saying that if we are going to do something like this 11 that is going to have any purpose and meaning, why I think it n
(
12 has to be in the context of a reasonable look at the overall 4
g 13 safety status of the unit.
=
l m
t 14 l I would like to find some way to avoid what amounts f15 literally to a regulatory accountant's trivial adding up of do z
d I0 their books balance in a regulatory sense.
The question is do l
C 17 i l
g we judge the plant, the unit to be safe in the light of what we 1
z 18 know now.
This gets you there over time.
19 2
CHAIRMAN AHEARNE:
A qualified in favor.
M 0
1 Peter?
I COMMISSIONER BRADFORD:
I have been in agreement i
2 consistently with a staff approach that more or less fits this l
23 i frame, that is the SEP plants first and then the others later.
24 f I am not so sure about the 137 items and I need to know a little 25 bit more about what kind of a cut that is, how it meshes with l
i i
ALDERSON REPORTING COMPANY. INC.
I 49 I
safety significant practices.
2 First of all, the 137 items are based on the SEP programq t
3 When does that mean that in effect the cutoff date was?
Does this 4
mean that these requirements were all in place before 1977 or g
whatever it was when we launched the program?
5 i
MR. EISENHUT:
Would you repeat the question?
j 6
R 7
MR. DENTON:
Some regulations are being handled
~n j
8 independently of the SEP program.
Certain regulations run front d
9 and back and we are imposing them on all applicants, if that is 2
f10 what it requires independent of the SEP.
So the SEP tends to
=
II focus not on one's, say ATWS comes up and we decide certain fixes 3
y 12 are required for all plants.
That would get fixed up and down
=
3 5
13 the board like 50-46 did.
a I4 l ml l
COMMISSIONER BRADFORD:
But what I am really trying to k
g 15 get at is whether there may be significant regulatory requirements
=
j 16 imposed or changes in staff review practice that are knposed after!
l
^
h I7 the beginning of the SEP program that therefore would not be e
18 g
picked up in the 137 issues.
P "g 19 l MR. DENTON:
Yes, and we would propose to re-examine i
20 l that list each year to see what we have learned that would be 21 a delta to that original one.
CHAIRMAN AHEARNE:
To some extent, since you folded in 23 '
IREP/NREP, that ought to be picking up those items.
I COMMISSIONER BRADFORD:
It will later on but will it
't 25 for the first set of plans?
f i
ALDERSON REPORTING COMPANY, INC.
i l
50 I
MR. EISENHUT:
Another aspect of your question would 2
be to say did the original list have environmental qualification 3
on it, because it wasn't a key issue before.
4 COMMISSIONER BRADFORD:
Yes, do it that way.
g 5
MR. EISENHUT:
I don't know the answer to that question.
N 6
(General laughter.)
R R
7 MR. EISENHUT:
I was just trying to understand the Aj 8
question.
d 9
There are obviously issues, though, that could arise
~
zo h
10 or becomo of greater interest after this was developed.
And the
=
II basis of this scheme would be that you have to have a scheme to 3
g 12 build it in.
E" 13 g
I give you even better.
Suppose you go down and you m
5 I4 are through 30 to 40 plants and a new issue arises and you are 15 completely done with this program on 30 to 40 plants.
When that x
d I0 issue arises you are going to have to face the question of how w
h I7 to backfeed that issue through the entire system.
=
y 18 I think in fact for the forward-looking you can always P"
19 i j
j add it to the list.
But you have to have a well disciplined 20 system so that every new issue that comes up is forward-fit and I
in the past that you decide whether you want to back-fit or 22 back-review it.
23 MR. DENTON:
I think we say on Item 1 the list of issues 24 l j
would be reviewed annually.
They could go up or down depending 25 '
on what was learned about that issue, and it would be a delta t
I ALDERSON REPORTING COMPANY. INC.
51 8
I!
to add on to the 137.
New issues might come in that weren't even i
2 in the first l?7 and they would have to be looked at backwards 3
as well as forwards, as he said.
4 COMMISSIONER BRADFORD:
But will the SEP plant effort i
5 !
for example be concluded, that first group of plants be concluded e
h 6'
before IREP starts feeding new issues into the review process?
R 7
MR. DENTON:
It will be for these first 11 but that
- j 8
doesn't preclude us from picking it up again.
It is just that dd 9
we are unable to do NREP on these first 11.
So it would be lookea i
O 10 at solely in its terministic mode.
z t
E I
y II MR. EISENHUT:
Let me answer that to add another piece S
y 12 to that.
Every time a new issue comes up, a generic issue for
=
}
13 '
example, right now on SEP'the que'stion comes up:
do you add it
=
i 2
I E
I4 '
into the SEP or what do you do about it.
And the position we have c
=
g 15 j taken
_;n a new issue comes up that goes across the board, i
j 16 l l
we just issue it as a separate requirement to the SEP plants.
l N
I7 l It is not part of the SEP per se, but those plants are not immune N
l u
18 l because they are in the SEP.
M C
I9 l i
COMMISSIONER GILINSKY:
Where will NREP get defined or mn 20 l how will it be defined?
i 2Ill MR. DIRCKS:
How will it be defined?
I think we first h
22 l have to go through this IREP exercise and then we have to move 23 ahead with this, I guess we are doing it concurrently with the 24 i
IEEE and the ANS.
And then what we are eventually going to wind
'l 25j up with is, for want of a better term, a manual on how to do it 3
ALDERSON REPORTING COMPANY,INC.
52 i
y{
and that will be the definition of how you carry out an NREP l
2i Program with licensees.
COMMISSIONER GILINSKY:
When is that likely to see the 3
light?
4 CHAIRMAN AHEARNE:
It is supposed to be '82.
That is 5
e b
the target date, Fiscal '82.
8 6
e f7 COMMISSIONER GILINSKY:
For producing this manual?
MR. DIRCKS:
We have the contracts out with the 8
9 Professional societies and they do work with us and turn a product z
h 10 out in 1982.
2 COMMISSIONER GILINSKY:
And that is consistent with 5
11
'J 12 this schedule here?
3 13 MR. DIRCKS:
I think if we just keep re-emphasizing it, 5
it is an attempt to establish one of the significant regulations.
E 14 a
For want of a better procedure we want to go through, tie it to 2
15 N
16 a systematic evaluation program.
That is what we have been doing, mW d
17 '
an ongoing program.
He will phase in IREP/NREP as they come along but it is a method of establishing what are significant safety 18
=
E 19 regulations based on the findings of what we are getting out of X
20 the substantive safety programs.
21 I think a point, an organizational point also, what 22 we have found that I think is very important is that we don't 23 : have three separate groups doing this.
We don't have an SEP group, 24 We don't have a section 110 group.
And we don't have an IREP 5
1 25 ;
group.
I i
i ALDERSON REPORTING COMPANY, INC.
53 1
Harold in this memorandum has established the fact that I
2l he is bringing all these three things together under the 3
systematic evaluation program, an ongoing effort.
Before, I think 4j it was in about two or three different revisions.
=
5 The main thing is to not have three parallel, four b
3 6,
parallel efforts going on but to really integrate theta.
R R
7 CHAIRMAN AHEARNE:
Peter, where are you coming out on Xj 8
this?
O d
9 COMMISSIONER BRADFORD:
Let me probe it a little more.
i h
10 Bill, with how much confidence can you say that these E
l 11 137 items are the most safety significant requirements that we 3
y 12 l have?
Let me stop there.
5 13 MR. DIRCKS:
I guess it is probably more.
My feeling g
a l
14 is that these 137 items do flow from the systematic programming 2
15 that is going on today.
We probably have more confidence here j
16 j than we would just in an arbitrary cut.
W 6
17,
COMMISSIONER BRADFORD:
Right, but was that program 18 at all times fiamed in terms of the most safety significant A
}
19 questions that can be asked about those 11 plants?
M 20li MR. DIRCKS:
I think that is the purpose of the program, 21 I yes.
l 22 MR. DENTON:
I look at it, any regulation can be of l
23 particular safety significance for some type of reactor and power 24 {
level and design and that type, and it could be the most 25,
particular.
But in looking at this generation and these power t
ALDERSON REPORTING COMPANY, INC.
54 I
levels and these desigr.s, we find that with regard to compliance 2
with these regulations certain ones are more important to look at 3
than others.
And it would vary with the vintage of the reactor, 4
the size, 2ts particular design.
Issues come in and out of 5
importance at various time frames.
P.j 6
We did scan all those original in putting together R
7 this list.
I don't think the 137 should be that precise.
That M
j 8
is how many issues there still are, but it might be down to 90 d
d 9
by the time we finish or it might go up.
- i h
10 COMMISSIONER HENDRIE:
It is a good number.
You can't
!!!l 11 hardly beat that as a good number.
is j
12 COMMISSIONER BRADFORD:
Let me ask one other question 5
y 13 if I could.
What kind of a review have you done in terms of I
14 ;
how the SEP list meshes with standard review plan requirements.
15 l 5
2 That is, can you take the 137 and relate them to the updated 5
- [
16 version of the standard review plan?
w I
g 17 !
MR. DENTON:
Yes, and that is the way the issues are 18 being reviewed on these first 11 is using today's guidance.
l i:
1 19 COMMISSIONER BRADFORD:
Wait a minute.
Can you do it 20l for all of them?
i 21 l MR. EISENHUT:
Sure you can.
Sure, you should be able 22 to go down the list and right beside it write all the standard i
i 23 '
review plans.
24l COMMISSIONER BRADFORD:
You should be able to do that.
25 MR. EISENHUT:
You said the updated.
g ALDERSON REPORTING COMPANY. INC.
.~___ _
l 55 t
1 I COMMISSIONER BRADFORD:
Yes.
2 MR. EISENHUT:
Not the updated one.
You should be able 3
to do that one when we get an updated one.
But what was done now 4
is against the current standard review plan, reg guides, et cetera e
=
5 because the review is defined right up front.
It was defined as 5j 6
the review as against the current requirement, guideline, whatever
-R j
R 7
the yardstick is.
The review is against the current yardstick.
Nl 8
Now it doesn't mean you are going to upgrade necessarily d
- s 9
that yardstick that you evaluate the delta that you are comparing z
h 10 the plant against the present yardstick today.
3 k
11 COMMISSIONER BRADFORD:
Is it your proposal to take the is
(
12 137 and to do it with the updated standard review plan or to stay
=
3 13 with the present?
5 m
=
5 14 MR. EISENHUT:
Probably would have to take a look at E
15 the updated because what we would have to do is take the present j
16 SEP and lay on top of that this small delta piece to make it so
- 4 ki 17 that we can say that really does Bingham job.
3 I
{
18 MR. DENTON:
The updated is mainly to pick up the TMI E
{
19 l matters.
M 20 CHAIRMAN AHEARNE:
Let me stick in a couple of questions 21 if I can.
I am not sure who is the most knowledgeable on this 22 program at this stage.
23 -
COMMISSIONER HENDRIE:
Don't ask Ed.
He wrote it.
24 CHAIRMAN AHEARNE:
What is there different about what 25j the staff would be doing in the future with the program that you y-1 ALDERSON REPORTING COMPANY. INC.
I 56 1
I have proposed versus what they would have been doing with SEP, 2
IREP/NREP in the absence of this?
3 MR. CASE:
We had to prove the SEP.
4 CHAIRMAN AHEARNE:
Okay, what they are proposing.
e 5
MR. DENTON:
We had felt the SEP program was worthwhile h
j 6
prior to Bingham, and we would have proposed to have kept on with R
7 an SEP, IREP/NREP program type program to pick up the substantive N
j 8
safety issues that might be found through that process on the old d
9 plants.
10 CHAIRMAN AHEARNE:
Yes.
What I am trying to get at is 25 4
II what is there different about this proposal that wouldn't be, 3
y 12 what is there in this proposal that wouldn't be there were there
~c.a p
13 no 110?
l 14 MR. DENTON:
Certainly the Step 2, 3 which would tie the topics back to a regulation and require Item 3 specifically.
15 g
16 CHAIRMAN AHEARNE:
So you would have gone from the A
h 17 identification of significant items and then turned to the other z
II plants.
Y MR. DENTON:
That's right, would have sent out just g
0!
those topics probably and worked on those topics through without 21 getting the associated regulations identified.
2 CHAIRMAN AHEARNE:
Now do you see in the out years, in i
23 l this previous version you were estimating 21, 30, and then 20 per year staff resources dedicated to 110 as opposed to resources 25 dedicated to the SEP.
i ALDERSON REPORTING COMPANY. INC.
57
}
i i
l I !
MR. DENTON:
I think we just have to relook at that.
l 2
It has been a while since I have looked at the manpower and --
3 CHAIRMAN AHEARNE:
Do you think it is approximately?
4 MR. DENTON:
Yes.
e 5
CHAIRMAN AHEARNE:
I think that probably the fundamental U
3 6l problem that we are all having is we are trying to construct this y
6, 7
in something that if it is going to be resource intensive, it is N
j 8
really significant.
If it isn't significant, then it shouldn't dd 9
be resource intensive.
10 We have something here that is fairly significant, 11 resource intensive.
Do you conclude that this is of safety is y
12 significance?
5 13 MR. DIRCKS:
The bulk of the program as proposed here m
i 14 I think does carry on the SEP, IREP/NREP programs.
And I think
$j 15 the conclusion there is safety significant.
z y
16 l CHAIRtiAN AHEARNE:
See, I have to identify the portion l
W N
17 !
that was not IREP/NREP, SEP.
And I have asked him a question:
1 y
18 is it that portion which --
c 19 I MR. DENTON:
We haven't resolved the following dilemma.
n 20 Let's take a very old plant, 20, 25 years old, very low in power 21l level, very remote site.
The risks turn out to be 1/1000 of 22 Surrey'or Peach Bottom type of plant, and there is no disagreement, 23 among people who do those calculations.
At the same time it needs l
24 1 an exemption from every existing regulation.
25 What conclusion do you draw from those two studies?
i 3
il ALDERSON REPORTING COMPANY. INC.
l 58 f
l t
I 1 I In other words if you look at it merely from the regulation l
2i standpoint you can say the review was very worthwhile, we found 3
a need to grant 50 exemptions.
If you look at it from a safety 4
standpoint and you find that it is among the safest plants in g
5 the country and without meeting today's regulations, so we have S
3 6l not been able to rationalize those two different ways of looking R
7' at the results of these old plants.
s j
8 COMMISSIONER GILINSKY:
Why do you have to grant d
2; 9
exemptions?
?
10 MR. DENTON:
Because they fail to meet today's regula-z 5
y 11 tion.
3 Y
12 COMMISSIONER HENDRIE:
That is acceptable as long as 3
g 13 you don't know it.
=
x 5
14 COMMISSIONER BRADFORD:
Now we are getting into the 15 guts of the problem.
g 16 COMMISSIONER GILINSKY:
I don't understand it.
If you W
f 17 have met an older interpretation of a regulation, until the 18 l
=
Commission changes its mind you are deemed to have met the P"
I9 :
regulation, aren't you, if. it was acceptable at the time?
Often I
s M
i 20 it is argued that we can't change our mind, which I don't go along i
2I i with.
But it seems to me that until we have changed our mind 22 ) you then meet the regulation.
23 l COMMISSIONER BRADFORD:
That is.right.
That is a 24 l separate question though I think from what we are after here.
25 In fact one of the largest misunderstandings that has come out i
i ALDERSON REPORTING COMPANY, INC.
3 59
\\
l 1! of this whole effort is that somehow the Commission is now trying 2
to make a rule out of the standard review plan.
That is not what 3
seems to me to be the case.
4 What we are trying to do is to get some concrete feel g
5 for how great the discrepancy is between what is actually in the Aj 6l plants and what we have in effect through the management side 3
7 rather than the rule making side said should be there.
And it is s
j 8
only when we have that accounting that we will know whether do 9
actual concrete regulatory action is in order.
i h
10 MR. DENTON:
On the one hand you don't need the E
j 11 regulations to make an assessment of safety.
In other words if
's y
12 you had a good risk assessment for each one chat was accurate 5
13 and reliable, you would say that is what that plant represents 14 l in terms of risk and so forth.
But at the same time you wouldn't t
l
[
15 know necessarily that it conforms to the Commission's regulations 3
y 16 without the look.
1
- ^
l d
17 !
CHAIRMAN AHEARNE:
I thought what Vic was raising is l
5 l
m j
18 j you mentioned a plant which has to have a waiver from all the E
l g
19,
regulations.
And his point was that if the plant has a license, 5
i 20 say it has an operathy-license valid under the regulations in 1
l l
21 !
effect at the time, what would lead you to now require it to l
22 !
have waivers from current --
i 23 COMMISSIONER HENDRIE:
Once you have identified that f
24 l1 it doesn't meet a current regulation, somebody steps up and says l
25 shut it down and now what do you do.
Say well, our regulations I
l i
ALDERSON REPORTING COMPANY, INC.
l 60 I
1j don ' t coun t?
No, issue an exemption.
2 COMMISSIONER GILINSKY:
I don't understand this at all.
3 MR. DENTON:
I tell you what happens in normal practice 4; if that is identified is that we are forced to take action unisss I
g 5I we can grant an exemption or find some equivalent means of assur-R 6 !
ance.
In other words once it gets into the system that is the R
7 kind of finding you have to make.
Aj 8
COMMISSIONER GILINSKY:
I guess I just don't understand d
c; 9
this approach.
It is true that there will be circumstances or z
E 10 there may be circumstances where flat out does not meet a regula-e E
II tion.
But in most circumstances,I would guess almost all circum-i g
12 stances it is that it has been approved on the basis of some 3
I3 5
. former, some earlier requirement'which'has now been beefed up.
m i
s I4 '
MR. DENTON:
But very few of our regulations are ever l
15 grandfathered like that.
They are stated in a manner which are 16 g
affable at all times without going back to 1972.
In other words w
h 17 l we adopted seismic, we adopted geologic siting criteria after x
}
18 we licensed the first ten plants.
And yet it is commonly accepted P
"m 19 ! it seems that those ten plants have to comply with those types of M
\\
20l requirements that weren't even thoughtof when they were built.
21 So a big effort has gone into trying to demonstrate 22 ; equivalency.
i 23 '
COMMISSIONER HENDRIE:
I tell you what you need, Vic, 24 l and over the years I have occasionally tried to forumulate and l
l 25
!,neversucceededinthecontextofthewayweregulate,is l
n
!l ALDERSON REPORTING COMPANY, INC.
l
(-
61 1l something comparable to the FAA certification on an airplane.
It l
2 says we looked at this design and looked at it against our regula-l 3
tions and li@ility, engineering estimates of safety and every-4 thing else an,i we now stamp this design approved.
And by God, it L
g 5
stays approved until there is specific formal action to unapprove j
6.l; it in some particular.
R f
7 So you can go ahead and change your regulations all you sj 8
like.
This is still an approved design here.
You have to go back f
d 2
9 by explicit action and remove the approval in some area or other E
[
10 before that is changed.
E II Now this is akin to some of the suggestions that there is y
12 have been that somehow plant designs ought to be certified 5
g 13 powerworthy in their certificates or whatever.
If we were able l
14 to come eventually to a formulation for an operating license that 15 in some fashion that operating license was approved and notwith-g 16 l standing any subsequent change in the regulations until explicit d
I h
I7 l action was taken on it, why then these kinds of things wouldn't
=
{
18 be a problem.
(
C s
19 l But as it stands right now in principle every operating i
M i
20 licensee is operating in conformance with every regulation, 2I except for granted exemptions.
22 MR. OLMSTEAD:
No, I --
4 I
23 CHAIRMAN AHEARNE:
I think the lawyer disagrees with 24 you, Joe.
25
- MR. OLMSTEAD:
The whole area is I am afraid a little 4
I i
ALDERSON REPORTING COMPANY, INC.
62 i
l l
1l peripheral to the Amendment you are talking about.
But jusP as l
2 general administrative procedure doctrine, rules are generally 3
not retroactive.
So that if you have a prior authorization, the 4
prior authorization stays in place.
g 5
But we have a lot of different rules which provide a R
6l lot of different things and some of them grandf ather and some of g
I Some of them were adopted because of safety reasons R
7 them don't.
%[
8 in which case they are applicable for that reason.
And some of d
cf 9
them don't.
So I don't think you can talk generally.
i 10 It is possible to draft the rules so that it only E
1I applies prospectively.
is y
12 COMMISSIONER HENDRIE:
Of course, but our rules don't 4
g 13,
generally read that way.
=
b I4 MR. OLMSTEAD:
But t'. tat is because the Commission makes
- z
.j 15 l some determination they don't want them to apply prospectively.
l ii COMMISSIONER GILIFSKY:
Then why don't we say we expect I0
.s h
II !
all plants to conform by a certain date?
18 l e
COMMISSIONER BRADFORD:
Not necessarily.
l 3cI I' 4 Let me come back to my earlier example again.
M i
i 20 l CHAIRMAN AHEARNE:- Can I make an interjection at this 21l We do have a request from Mr. Udall, and it is a request point?
22 that I understood was coming.
What he has proposed is that we not take a formal action pending a hearing on this.
I see no 24 problem with making that deferral.
25 I didn't mean that facetiously.
We are under no 1
ALDERSON REPORTING COMPANY, INC.
j 63 1!
legislative mandate that we n:ust follow.
2 MR. BICKWIT:
No, you are not.
3 CHAIRMAN AHEARNE:
So I would prefer to hold on that 4
in which case I would like to close this meeting at 4:00.
e 5
COMMISSIONER BRADFORD:
I can finish by 4:00.
2 4
3 6,
I certainly agree with not taking any action at today's R
I 7
meeting, because I think it was almost inevitable that we comply M
j 8
with this request.
In fact even if it hadn't been made I don't d
9 think we would have closed this.
I 10 j COMMISSIONER HENDRIE:
If Mo had asked me I would have i
j 11 told him he needn't have sent the letter down.
3 y
12 COMMISSIONER BRADFORD:
That is my point exactly.
Ej 13 If you take the example again of the equipment qualifi-
=
l l
14 cation, I don't know that the general design criterion has r
15 changed since the day it was enacted.
But as time has gone by j
16 we have found that a lot of the stuff that we licensed under the d
I l
d 17 :
assurance that it would be high industrial quality doesn't in l
18 l fact meet all of the standards that we would want a piece of 5
19 l i
equipment to meet if it might actually have to withstand the l
M i
20 conditions of an accident.
21 l And as our staff reviewing practice has given more and 22 more content to the general design criterion, we haven't until 23 '
recently systematically gone back and looked at whether the 24 l equipment in place would actually perform the way we wanted it 25 to.
And to some extent that has only been true in seismic design i
ALDERSON REPORTING COMPANY, INC.
l 64 i
1 and in fire protection.
I I
2l It seems to me that what this exercise is about is 3
going through and systematically uncovering all of those areas 4
and deciding which ones we feel are justified and can be relaxed g
5 about and which ones we really think ought to be fixed up, because 8
3 6,
the problem has been that as the staff practice has become more g
7 specific and more informed, there hasn't been any very systematic Al 8
way of documenting and justifying the deviations from the d
=;
9 increased levels of specificity, if you will.
zO 10 It isn't that every plant necessarily has to go back 5
II l every time we change the staff regulatory practice.
But I do 3
g 12 feel it is important to have a clear idea of why that wasn't Ea 13 5
necessary for each plant at each time the practice becomes more l
14 l specific.
And that is what we haven't got in wide areas of our U
i
-j 15 overall regulatory framework.
=
E I6 CHAIRMAN AHEARNE:
I guess there is some disagreement I
d 17 I as to the ultimate need for,in a sense for resource allocation.
\\
E 3
18 COMMISSIONER GILINSKY:
Let me just ask this, ch I9 I COMMISSIONER BRADFORD:
Well, I can't dispute that 2n 20 there may be disagreement.
I would urge that it was significant II at least to get through the first step and discover what the 22 !
extent of the problem was.
COMMISSIONER GILINSKY:
Let's take the criterion on 24l control and design.
Do we not have different standards on control l'
25 '
and design?
We are'in the future going to have even more exacting 3
ALDERSON REPORTING COMPANY, INC.
i 65 f
i 1
standards on control and design.
You aren't saying, I am sure, l
2l that the older plants are therefore not in compliance with the 3
regulations, are you?
I 4!
MR. DENTON:
We don't have one that is that specific.
e 5
COMMISSIONER GILINSKY:
What is the answer?
8 j
6l COMMISSIONER EENDRIE:
I guess I am saying that that G
7 indeed could be the case, that if you looked at a particular j
8 plant under what we now would believe to be the necessary require-l d
0; 9
ments to meet the criterion on a control room, okay, you might 10 get the staff report back that said it doesn't meet the regula-11 tions.
m y
12 Now having produced that report, you now have to ask:
4 13 I and now what?
Well, now you either shut the plant down or you xg 14 justify operating it as it is in noncompliance with the regula-5j 15 tions.
d 16 l COMMISSIONER GILINSKY:
You would make a good inter-l 17 l venor.
a i
3 18 l COMMISSIONER BRADFORD:
So far what you are saying E
l e
a 19 l makes good sense.
M 20 COMMISSIONER RENDRIE:
It may be a professional oppor-21ll tunity that I ought to take.
I still have some of those i
22 l consulting engineer cards left.
23 COMMISSIONER GILINCKY:
I do too, yours.
24 !
COMMISSIONER BRADFORD:
But you are not quarreling 25 with the proposition as far as you have stated it, are you, that h
ALDERSON REPORTING COMPANY. INC.
66 l
I once you have made a finding that a plant doesn't meet a regula-j 2i tion you have to come up with some justification for permitting 3
continued operation?
4 COMMISSIONER GILINSKY:
Why do you say it doesn't meet a
5 the regulation?
I mean, it doesn't meet the current interpreta-8 i
'3 6';
tion of the regulation.
But it is not being built now.
E l
6 7
MR. BICKWIT:
It depends on what the regulation says.
A!
O COMMISSIONER HENDRIE:
Here is a GDC that says --
d*
9
~.
COMMISSIONER GILINSKY:
We interpret it differently
- c g
10 now than it was interpreted before.
_Z II COMMISSIONER HENDRIE:
It doesn't meet the current a
12 j=!
standards is what you come up against here then.
You see, as f
13 long as you haven't determined that, why there isn't the I4 'i a
problem, a regulatory problem.
There may be a safety problem.
I' COMMISSIONER GILINSKY:
What you are saying is the 16 plants can operate if we don't look too closely.
CHAIRMAN AHEARNE:
I think that is Peter's point.
=
l l
5 18 I COMMISSIONER GILINSKY:
Joe seems to be saying that too.
i l
H I
l 19 i i
CHAIRMAN AHEARNE:
I think the difference is that Joe 3
i 20 i l
is saying that he thinks that might be (inaudible) and Peter says 21 he thinks that is true in a safety sense.
22 i COMMISSIONER HENDRIE:
I think there is a regulatory i
23 '
problem here because once you identify nonconformance like that 24 I l
then you can do something with it.
You either grant them an 25 exemption or make some other choice.
ALDERSON REPORTING COMPANY, INC.
l 67 l
l 1!
COMMISSIONER GILINSKY:
But we are tossing common sense l 2i out of the window, it seems to me.
)
l 3
COMMISSIONER HENDRIE:
I am trying to drag it in.
4l (General laughter.)
i l
e 5i COMMISSIONER GILINSKY:
Let me go back to your airplane 0
3 6;
example where airplanes were approved with two independent R
7 hydraulic systems.
Some of che: new ones have to have four.
But a
j 8
you wouldn't approve any one made with two but the older ones d
- [
9 still fly.
3 10 COMMISSIONER HENDRIE:
Under the nuclear regulatory i
j 11 scheme de.two hydraulic system unit airplanes wouldn't fly 3
j 12 passengers.
5 I
13 j CHAIRMAN AHEARNE:
What Joe is saying is the NRC has 8
i l
14 h never explicitly addressed in a clear statement how you apply b
b 15
]
retrospectively regulations,
=
j 16 COMMISSIONER GILINSKY:
I think in practice we would
(
17 behave like the FAA in --
18 '
COMMISSIONER HENDRIE:
Yes, yes, yes, in part at least.
h 19 i I agree absolutely.
aM 20 l COMMISSIONER GILINSKY:
We describe this as being 2I something different.
What we need to do is bring these two 22 l together to a common sense result.
23 '
COMMISSIONER HENDRIE:
Yes, yes.
I would leap to join 24 that effort.
And as I say I have thought occasionally about 25 ways to frame a' context for an operating license which would give ALDERSON REPORTING COMPANY. INC.
68 i
l l
1f it that, what do I want to call it, that continuity or internal I
2j integrity so that it is valid until you come along and you say 3
there is areason to change it and w herewith change this 4
particular one.
=
5 COMMISSIONER BRADFORD:
I think the problem is not in h
I 3
6l the license though.
I think it tends to be more in the backfit i
it 7
practice, that as long as you document your reasons for not
- n j
8 I backfitting a change in staff practice and as long as those d
l ci 9
reasons are good and sufficient, then you ne'rer have to reduce j
2 c
L i
10 it to question.
II COMMISSIONER HENDRIE:
That's right.
But typically we 3
y 12 go ahead and bang rules into place and requirements go into 2i regulatory guides without having determined and written down g
13 !
I 5
14 l what in fact the application to prior cases is going to be.
m j
E I
j 15 l COMMISSIONER GILINSKY:
Don't we have to do that now?
z j
16 Isn't that a requirement in all our --
l 2
i h
I7 COMMISSIONER HENDRIE:
For many years out there I can
[
z i
}
18 l remember in the staff we solemnly swore to each other we would c
19 l never impose another requirement without saying explicitly what 20l each prior plant had to do about it.
And again and again and 21 again it turns out boy, is that a hrrd job.
That is harder than 22 writing the new requirements.
You normally throw up your hands i
23 '
and say we will figure it out when the time comes somehow.
24 COMMISSIONER GILINSKY:
Certainly we have been doing 25 that in the rules.
Il l
ALDERSON REPORTING COMPANY. INC.
1 1
69 1
MR. BICKWIT:
I haven't witnessed us failing to do it 2
in a rule.
You are right.
It is usually the hardest question.
3 CHAIRMAN AHEARNE:
My experience would be. tith Len, 4
that we I think may just see part of the iceber,,
e 5
Well, I would guess we will have an opportunity to look 9
3 6
at'some testimony on the explanation of this proposal somecime g
7 in the next few weeks.
And hopefully at that stage at least all j
8 of the staff who are testifying will be in agreement on this is d
c; 9
what it means, at least.
That would be a goal to be achieved.
IO I gather that the sense I have is that Vic would prefer E
II to stop at Step 3 and collect all of them.
Joe somewhat reluc-is j
12 tantly would probably go along with your proposal on the basis
=3 5
13 l that it may be not gaite getting'directly at the most important
=
i
- A l
E I4 things but at least has a workable semblance.
Peter, I think E
l 15 I would characterize yours as that you might be willing to I
if 16 accept the staff approach but you have some concerns on whether us h
I7 enough of the significant items are identified at the beginning.
{
18 l COMMISSIONER BRADFORD:
That's right.
My conc.arn goes E
19 g
almost exclusively to whether we can be confident that the 13'? are a
20l really the answer to the safety significant requirements.
21 The rest of the approach is --
22 CHAIRMAN AHEARNE:
I find myself I guess much closer 23 l in agreement'with Joe in the sense that I think it is approximate =>
24f ly acceptable approach.
I am still concerned to make sure that
.25 when we allocate resources we allocate among things that are of i
ALDERSON REPORTING COMPANY, INC.
g 70 I
l l
1 ;
real significance.
But I don't see how we should really go any l
2 further today.
3:
Thank you very much.
I i
4l (Thereupon, at 4 :00 p.m., the hearing was adjourned. )
i l
l e
5i 9
i l
j 6l
?
7' 8
8 c.
Od 9
i o
g 10 Z
g 11 r
a i
I d
12 Z
l
~
5 13 l
[
=
E 14
{
tt
(
=
2 15
- s 3
$m d
17 l
[
E i
18
=
19 i
s l
20 21,
t
'l I
22 23 '
24j 1
25l
- t
- g ALDERSON REPORTING COMPANY, INC.
e' O
NUCLEAR REGULATORY CO.5C4ISSION This is to certify that the attached proceedings before the I.
NRC Commission Public Meeting in the matter of:
- Date of Proceeding:
Feburary 18, 1981 Docket llumber:
Place of Proceeding: Room 1130, 1717 H St.
were held as herein appears, and that this is the original transcript thereof for the file of the Commission.,
Judith F. Richard Official Reporter (Typed) ulli,k.
/ k-
,0fficial Reporter (Signature) l l
l l
l 9
L
_