ML20003A098
| ML20003A098 | |
| Person / Time | |
|---|---|
| Issue date: | 01/14/1981 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML19284C795 | List: |
| References | |
| REF-10CFR9.7 SECY-81-013, SECY-81-13, NUDOCS 8101290534 | |
| Download: ML20003A098 (89) | |
Text
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NUCLEAR REGULATORY COMMISSION
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" u @/g',i COMMISSION MEETING In the.%tter.cf:
PUBLIC Pdi:ETING BRIEFING AND POSSIBLE VOTE ON PLAN FOR SYSTEMATIC ASSESSMENT OF CURRENTLY OPERATING REACTORS i
CATE:
January 14, 1981 PAGES:
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, 1/14/81 l
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11 UNITED STATES OF AME'<ICA NUCLEAR PEGULATORY COMMISSION l
2 3
i Public Meeting 4,
i BRIEFING AND POSSIBLE VOTE ON PLAN FOR g
5 SYSTEMATIC ASSESSMENT OF CURRENTLY OPERATING REACTORS j
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Nuclear Regulatory Commission, j
8 Commissioners' Conference Room, J
1717 H Street, Northwest, 0
9 Washington, D.C.
E 10 Tuesday, 14 January 1981.
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II The meeting of the Commissioners was convened, pursuant 3
y 12 l to notice, at 2:08 p.m.
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5 13 !
DEFORE:
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14 JOHN F. AHEARNE, Chairman u
II VICTOR GILINSKY, Commissioner
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E I0 l PETER A. BRADFORD, Commissioner A
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h I7 JOSEPH M.
HENDRIE, Commissioner E
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ALSO PRESENT:
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19 l J. Hoyle, L.
Bickwit, H.
- Shapar, E. Case. B.
- Dircks, gn l
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M. Ernst, E. Hanrahan, D.
Eisenhut, and M. Malsch.
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1L P- _R _O _C _E _E _D _I _N _G _S i
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I (2:08 p.m.)
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CHAIRMAN AHEARNE:
We have a simple little paper l
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that the Staff has sent der It will probably take a few 5!
minutes to talk through, and there might be one or two items l
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reactors.
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9 COMMISSIONER HENDRIE:
Among other things.
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10 MR. BICKWIT:
Among other things.
j 11 l MR. DIRCKS:
Among other things.
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d' 12 l CHAIRMAN AHEARNE:
Among other things.
And this --
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g 13 i the Staff comes back following substantial effort at reviewing a
l 14 l what the Commission has asked them to do, trying to figure that l
15 out, after having put out for public comment some issues, and
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receiving a number of comments, and having I think spent a w
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laudable effort in trying to pull together a proposed approach 5
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18 to these issues.
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This afternoon's meeting is not a vote meeting.
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n 20l is a discussion meeting, so that we can perhaps get a better
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and ask for some further work.
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With that, I turn the meeting, with glee, over l
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1 25,
MR. DIRCKS:
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It's always a pleasure.
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1 Let me try to explain sort of a simple outline o'f t
2l what I consider the essential elements of the proposal for you, i
3 and then I'll let Ed Case and Mel Ernst undo the damage that l
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(Laughter. )
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6l MR. DIRCKS:
What we tried to do is to take the R
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approach complying not only with the intent of the requirement d
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9l contained in Section 110 of the Authorization bill, but to
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10 make some sense out of it and bring in the SEP Program we E=
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that we've developed over the past year with its natural
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14 ll Program, and to combine all these efforts into a substantive
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2 15 safetv review of the plants.
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g 16 j Using that as the basis, what we've done is to i
d 17 develop a certain number of steps:
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The first step, as you directed, is to pull C
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19 together a complete revision to the Standard Review Plan.
And i
n 20 that will be accomplished by April of this year.
21 The next step is, based on that development of the 22 revision to the Standard Review Plan -- update of the l
23 Standard Review Plan -- is to develop a list of significant 24l' safety regulations as encompassed in Section 110 of the Act.
I 25 The next step after the development of those t
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significant safety regulations is to ask the licensees, in I
i 2i a phased grouping based on the development of the SEP program, i
3I to document deviations from those regulations.
4 The Staff then would use the Standard Review Plan I
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5l as the method of determining the significance of any deviations 8
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from the regulations.
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We would hope, as we go into this program, that a
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the deviations, exceptions, et cetera, that most likely will d
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come to light we can then test against the ongoing substantive 0
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safety reviews that we're doing through the SEP/IREP Program, E
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13 l number of years.
Details of many of this, once we get beyond
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two, and three,'are still, I must admit, in some l
14 years one, 15 l doubt.
It's a new program.
It's a big program.
We would E
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hope, as we go into it, we could get some feel for not only
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5 18 significance of the safety deviations, if there are any.
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19 l I think that that was the purpose that the E
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20l Commission intended in the SEP Program, and that was the 21l purpose in the IREP/NREP Program.
4 22 !
COMMISSIONER BRADFORD:
Bill, what do you mean when l
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l you say, "if there are any"?
I mean, you don't doubt that 24j there are plants that are not in full compliance?
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MR. DIRCKS:
- Well, I'.m sure, like in everything, I
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there will be deviations not only from the regulations, l
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because of the age of some of these plants, but I'm sure e
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i 5l findings, I'm sure, as we go through the SEP/IREP Program.
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But I think the whole thing has to be played R
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8' COMMISSIONER BRADFORD:
Oh, I agree with that.
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That's my simplified notion of the E
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proposal we're making today.
We have also made this proposal E
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h 'll l with some due regard, Mr. Chairman, on the resource require-3 i
j 12 ments, not only from our own Agency standpoint, but from the
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But again, I think what we tried to do is tie the E
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17 somewhat related to the findings not only of the review against I
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regulations, but against review of the plants themselves as we i
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get into this new program.
M 20l Ed, that's my few remarks.
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4R. CASE:
I think you summarized it well, Bill.
h 22 [I I won't add anything, recognizing this is likely to be a j
i 23 somewhat controversial, if not complicated, subject.
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24 So I will turn it over to Mel for a short briefing, i
25,
and we rely mostly on questions to bring out any problems the h
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Commissioners may have.
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Mel?
3 MR. ERNST:
Well, we de have a few slides, and l
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4 hopefully a reasonably short briefing just to give you an I
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overview of the elements of the program.
9 6l (Slide.)
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The first slide is a little bit of a background sj 8l reminder of where we've come from.
Public Law 96-29 5 does d
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require two things that we're speaking to this afternoon:
ze 10 One is the development of a plan for the Systematic Evaluation 5
j 11l of Operating Reactors.
And the second -- that's in subsection 3
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12 l 110 (a).
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13 l 110 (b) (1) and (2) have some documentation require-i l
14 l ments which are additional, or items that must be considered 5
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as a minimum in the development of this plan.
That is,
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significance.
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18 COMMISSIONER GILINSKY:
You wouldn't have the exact c
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language there, would you?
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l 20l MR. ERNST:
I'm not sure that we have it in the i
21 i package here.
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MR. BICKWIT:
I have it here.
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CHAIRMAN AHEARNE:
Len?
I 24 l MR. BICKWIT:
110 (a), you want?
25 COMMISSIONER GILINSKY:
Well, if it's not very i
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II long.
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2l MR. BICKWIT:
It's not too long.
3 i "Of the amounts authorized to be appropriated l
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pursuant to Section 101(a), such sums as may be necessary g
5 shall be used by the NRC to develop, submit to the Congress, N
j 6l and implement as soon as practicable, after notice and l
7l opportunity for public comment, a comprehensive plan for the f8 systematic safety evaluation of all currently operating 4
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utilization facilities required to be licensed under Section I
10 10 3 or Section 104 (b) of the Atomic Energy Act of 1954."
II (b) is somewhat longer.
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12 CHAIRMAN AHEARNE:
Go ahead.
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MR. EF.NST:
(b) (1) and (2) are the pertinent ones,
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5j 15 ll MR. BICKWIT:
"(b)
The plan referred to in z
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17 current rule and regulation in compliance with which. the
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II j Commission specifically determined to be of particular I9 significance to the protection of the public health and M
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"(2) A determination by the Commission of the 22 l extent to which each operating facility complies with each i
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rule and regulation identified under paragraph (1) of this
- l subsection, including an indication of where such compliance t
25 was achieved by use of Division I Regulatory Guides and P
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1l Staff Technical Positions, and where compliance was achieved l
2j by equivalent means."
I 3l And (3), (4), and (5) relate to generic safety l
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5 MR. ERNST:
On September 9 th, we --
9 8
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CHAIRMAN AHEARNE:
Could you, since we are now a
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7' focused, at least for the moment, on the Public Law, could 8
8 you describe was the issue addressed in any appropriations 5"
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bill?
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10 MR. ERNST:
It was in the Fiscal ' 82 bill, wasn' t z
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it?
d 12 MR. DIRCKS:
We haven' t had a bill, yet, in 3-S 13 i Fiscal
'82.
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E 14 MR. ERNST:
I mean --
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2 15 j MR. DIRCKS:
I don't believe it's been -- we have E
g 16 not made a request.
We have in the -- we have ongoing l
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17 resources devoted to the SSP Program, and I think we have i
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5 18 i indica *.ed a desire to use' that also for the IREP Program.
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have not made a specific estimate of the amount of resources M
i 20l needed for the documentation of deviations from regulations.
1 21 We have not done that, yet.
22j I think we have instructions, though, that once we 23,
have identified the resources needed for that, we should come i
24 :
forward with an estimate.
25 CHAIRMAN AHEARNE:
But it was not spoken to in any 4
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appropriations bill that you know of?
l 2l MR. DIRCKS:
I don't recall one.
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COMMISSIONER IIENDRIE:
Didn't the '81 Appropriations j
4 bill precede the euthorization bill?
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5i MR. BICKWIT:
This is the ' 80 authorization bill.
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6I MR. ERNST:
This is the '80 authorization bill.
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Oh, this is the '807 s
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MR. BICKWIT:
Right.
And the ' 80 authorization --
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'80 appropriations bill certainly preceded that.
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MR. DIRCKS:
But the '80 and '81 almost tied each z
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CHAIRMAN AIIEARNE:
The '80 authorization bill came 5
13j around the same time as the '80 appropriations bill.
l 14 Okay, go ahead, Mel.
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15 MR. ERNST:
September 9 th, Staf f sent SECY-80-414 x
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17 l 90-day status report to Congress, which was required by
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19 l The Commission then sent the 90-day status report, M
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20 as modified by the Commission, to Congress on September ? nth, 21 1980.
And on October 9 th, 19 80, there was a proposed rule 1
I 22 on documentation of SRP deviations published for public l
23 comment.
t 24 j This rule included not only document.ation require-25 ments for operating reactors, but also for plants in the i
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Il licensing process for cps and OLs.
1 2l The Staff briefed ACRS on October 7th and 10th I
l 3l regarding the plan proposed in SECY-80-414, and ACRS sent some I
4 comments to Staff, and we responded to the ACRS.
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5l The public comment period on the proposed rule H
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regarding documentation of deviations ended on November 24th, R
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and I quess there were over 34 commenters -- 34 at the time
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we assimilated the comments; I mink some more have come in d
i 9i since on that particular rule, and we'll get into that later.
3 10 COMMISSIONER GILINSKY:
Now is the proposal that z=
l lI l is presented today in response to --
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N I2 I MR. ERNST:
Public comment, and some Staff consid-5 I
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eration.
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15 l the law on an evaluation of the extent to which reactors I
si I0 l comply with requirements?
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II MR. ERNST:
That's part of it.
Part of the Staff 18 l l
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paper is a proposed final rule -- not in good legal P
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terminology, but at least conceptual; it has not had the 20l legal language applied L it -- which would satisfy Section 2I 110 (b) (1) and (2), in addition to putting documentation requirements on plants in the licensing process.
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23 In addition, the paper covers the proposed plan I
j for reviewing the safety of operating reactors, which is certainly far broader than just documentation against the
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regulations.
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COMMISSIONER HENDRIE:
But the proposed rule as it 3l was when it went out for comment goes considerably beyond j
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the requirements of Section 110.
I remember the extended l
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discussion we had here --
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MR. CASE:
In terms of scope of the reactor --
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MR. ERNST:
In terms of documentation.
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3 COMMISSIONER HENDRIE:
Well, it talked about the n
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9 SRP, instead of safety significant regulations --
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Yes.
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on the one hand; and 16 E
11 COMMISSIONER HENDRIE:
'i 12 talks about the full set of machines, rather than just reactors z
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14 l MR. ERNST:
Yes.
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15 The reason for being broader, as to number of plants, s
j 16 is because we're meshing the NPR Office Letter 9 requirements, x
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18 l Standard Review Plan, with the Bingham requirements for 5
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documentation to make one package.
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- 0 l CHAIRMAN AHEARNE:
I notice in your background 21 here you don't talk about Office Letter No. 9.
12 >
MR. ERNST:
I probably should have put that in 22 l there.
We do cover Office Letter No. 9 later in the discus-j l
24 I sion.
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25 CHAIRMAN AHEARNE:
Okay.
There had been, I guess i
~t ALDERSON REPORTING COM,PANY, INC.
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Somehow I had maybe an i
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3 Office Letter No. 9 had fallen in the crack somewhere un*4' 4
this issue started coming back around.
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MR. ERNST:
I don' t think that's exactly -- I think ii+g 6!
there have been a lot of plant delays, and one might say a
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No. 9, perhaps in retrospect sitting here today, maybe shouldn't d
9 have been.
But I don' t think that any of the plants that E
10 should have been covered under Office Letter No. 9 weren't.
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12 MR. CASE:
Well, it was no doubt put in the back-Ei l
13 ground because of Three Mile Island, among other things --
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Yes.
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-- and as we resumed licensing after i
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And one of the results of that attention was the i
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M 20'l in the Federal Register -- which in fact moots Office Letter 9.
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2I CIIAIRMAN AHEARNE:
Right.
MR. ERNST:
And that's in general the background.
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If there aren't any further questions on general background, 24 I will go to the next slide.
25 (Slide.)
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ALDERSON REPORTING COMPANY, INC.
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1l I think it might be simpler to at least -- to 2
discuss the Section (b) (1) and (2) requirements firs t, and 3I what we are now proposing doing to the rule that was published i
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4l for public comment.
So that would be the next subject for i
5l discussion.
ee 6l The slide describes the differences from the E
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proposed rule to the rule that's suggested for final implementa-A j
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- tion, based in large part on comments received as well as d
c; 9l Staff reconsideration of some of the germane issues.
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y 12 l against the Standard Review Plan, but I think it would clearly g
13 l imply a one-to two-year kind of time frame, a reasonably i
l 14 l pronet response.
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The rule has been modified to spread this response
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16 i over approximately a seven-year period, reflecting two things, d
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One is that the burden on the industry would be 5
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18 so substantial, if every reactor were required to be evaluated i
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I9 l in the same time frame, that it would really stress the
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I 20 available manpower and could well be a detriment to safety, I
21 in looking at other things, other requirements, other lessons l
22 from TMI.
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Secondly, realizing that we had an ongoing safety 1
24 review program -- namely the SE --
5 COMMISSIONER BRADFORD:
Let me stop you on one, for-t i'
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ALDERSON REPORTING COMPANY, INC.
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a minute.
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2l MR. ERNST:
Yes.
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COMMISSIONER BRADFORD:
If I were the owner of a j
i 4l plant currently in operation, not one of the -- at least one l
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that goes back a little while, would I then owe a different e
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j 4j set of responses on a faster timetable to comply with e
7 Bingham Amendment requirements than I would with this effort?
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MR. CASE:
No, no.
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9 COMMISSIONER GILINSKY:
This is the Bingham i
10 requirements ?
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COMMISSIONER BRADFORD:
This is the whole thing?
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12 MR. CASE:
This is the whole ball of wax.
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13 i COMMISSIONER BRADFORD:
They will all be done in I
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14 l the context of the seven-year period?
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15 l MR. CASE:
Yes.
5 16l MR. DIRCKS:
Let me expand on a couple of other 3
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I 17 j reasons why the time frame was expanded.
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the SEP Program.
That was important, too.
5 20 !
CHAIRMAN AHEARNE:
SEP and IREP and NREP.
i 21l MR. ERNST:
Right.
22 i MR. DIRCKS:
IREP and NREP.
3 l
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The second this is, even if the resources were 24 available and we got the responses. in from the licensees,
25 there would be, I don't think, any way in the world we would l
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ALDERSON REPORTING COMP _ANY. INC.
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15 1l have enough resources to review the responses that came in.
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2i CHAIRMAN AHEARNE:
Yes.
I was kind of wondering.
3 You mentioned, Mel, the big burden on the industry to --
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MR. ERNST:
Well, I had gotten to the first reason e
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before I had to respond to --
8 3
6 CHAIRMAN AHEARNE:
I was afraid you wouldn't get G
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(Laughter. )
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9l MR. ERNST:
You're reading my notes, I thir:k.
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10 (Laughter.)
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11 COMMISSIONER BRADFORD:
There's nothing in the 3
l I2 l Bingham Amendment that requires a faster response than that?
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MR. CASE:
No.
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5 I4 MR. SHAPAR:
The plan is the only thing that's tied 5j 15l to time, and they have no plan.
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16l MR. ERNST:
There certainly is an implication that
-A 17 one should pay heed to a reasonable response to this.
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18 COMMISSIONER GILINKSY:
I must say, I interpreted y
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that amendment to require a response in a rather shorter n
20 period of time than seven years; and also for it to be not t
21l an engineering exercise, but basically a clerical exercise.
22 MR. CASE:
But you can' t do the clerical exercise 23 :
unless you do the engineering exerciso.
24 !
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I guess I don't understand 25 i
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The engineering part of it --
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Well, it seems to me --
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Current.
That's right; it's specific 24 i
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Let's -- Let us -- I would j us t 6
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proposal of what they would propose.
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Nell, I told 21l you so.
Here we come with this enormous freight train, and 22 ;
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We were trying to.
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I think I always made clear 21 that I thought it was basically a clerical exercise.
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And I think we were told to fold in 21 the whole thing.
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Yes.
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That's right.
24 CHAIRMAN AHEARNE:
I would like,.though, if we 25 could, to hold the repeat of this argument in abeyance, or at l
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The existing Standard Review Plan.
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In transition.
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During the transition.
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We never really got into 25 the transition phase.
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How much in the Standard 3[
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I agree with you, Vic.
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Well, one thing, that's why we 22 stressed this tying together of the SEP/IREP/NREP in this i
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What concerns me is that --
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I think the program we ' re talking --
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God knows what will happen to it.
23 MR. ERNST:
Yes.
But the program we ' re talking --
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It will outlive us all.
25 COMMISSIONER GILINSKY:
It will outlive us, 4
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The program we're talking about, t
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Well, the SEP alone --
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Just that there's a Biblical l
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All right.
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I see.
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No more than --
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No more than the criteria.
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-- the broad criteria we've listed there.
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Joe signed that letter, did g
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You know, it sounds like --
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And it does make some sense to take a i
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o see what has changed over time.
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It so nds like you are going to e
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At least you know the basis.
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COMMISSIONER GILINSKY :
Let me ask you, Point On'e l-I 2;
there says that " responses" will be spread out over a -- or i
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A year or so.
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A year, a year-and-a-half.
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A year, a year-and-a-half after their 1
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I thought the answer to that
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Well, there is the documentation part, 24 ;
which is the law.
But as Commissioner Gilinsky --
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Well, a subset of it, at
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Why.can't you put out a list 25,
of plants for which the SER is scheduled to be issued by April i
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Cause the slip.
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The. Staff could threaten to slip.
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The best handle on the case might be--
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Always thinking of those weap'ons.
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23 ;
CHAIRMAN AHEARNE:
NRC.
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-- on NRC.
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That's right.
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We have not launched NREP, yet.
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No.
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You put funds in the '82 budget for it.
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We've approved the concept.
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Yes.
The approach here -- correct 21 me if I'm wrong, Bill -- you are trying to take those pieces 22 -
that did relate, and try to get an integrated program.
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Yes.
24 MR. AHEARNE:
Okay,-go ahead.
I 25 MR. ERNST:
That's all I would have on the proposed i
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Commissioner Bradford had --
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That is April of '81.
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A hint?
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It started a week ago, and you have to 5
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Okay.
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It's hard to tell, but it wasn' t -- I l
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I think both statements are true.
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Not quite.
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The proposals; right.
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Shorthand for legalese.
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So you may have to go --
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You understand the concept, and I would l
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That is another issue.
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COMMISSIONER BRADFORD:
How do you handle that?
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Just from time to time amend it.
l 25 MR. SHAPAR:
Just as you amended in the Revised i
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Yes.
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That's the direction I'm going to, as a j
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The Standard Review Plan 25 tells you what the Staff's position is going to be in terms of 2:
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Anything else?
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The next slide --
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Yes.
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"No"?
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To what question?
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Will there be a SEP program apart from 1
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As a conceptual thing.
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It would approve a concept.
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And it also brings in NREP.
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Where do we stand with SEP?
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I think, overall --
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There were 13?
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Out of a total of 11 plants.
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Out of a total of 11.
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'81?
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'81.
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Thank you.
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Darrell, before you sit down, 4l I
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I know that you had an Acting h'
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Okay, Mal.
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What's the page?
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Is this Table l?
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I think so.
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Table 1, now, is the Criteria A.
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We went with the same -- wait.
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The same three columns.
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Which one was that?
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Yes, it was.
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I see.
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A single group.
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A single group.
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What completes the program?
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I don't quite understand your concern.
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There are 38 in the budget for an SEP I
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Yes; right.
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Yes.
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And for NREP/IREP combined.
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Correct.
But as far as Section
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There is nothing for it.
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So at least we explicitly, at 5
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I think the increment we're talking-I 23 '
about is this "13," the number 13 staff years, and about 24 MR. ERNST:
About $600,000.
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Yes.
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-- so the 13 doesn' t jibe with the 21, 24 [
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It's to get i+. underway.
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To get it underway.
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Right.
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Man-years.
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Well, I j ust don' t know about NREP.
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So your four to six at the moment 23 is the 110 --
24 MR. CASE:
So if I left that out -- yes, because I 25 think most of the work is understanding and analysis, and I
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22 MR. ERNST:
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There are a lot of consul-4 tants that may do very well.
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It's not a request for more.
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I see.
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Okay?
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Peter, please, dou ; misinterpret--
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And it's not --
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22 I CHAIRMAll AHEARNE:
-- I do not think the Staff has 23 gone beyond what the Bingham Amendment leads you to, in no way.
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Let me make --
23 COMMISSIONER BRADFORD:
I wasn' t thinking. about --
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To the extent it goes beyond operating s
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Can I sneak a question in?
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Absolutely.
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25 the SEP Phase III effort will want to do with that plant, j
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To give you some thinking ahead on Phase 2'
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Peter?
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(Whereupon, at 3:55 p.m.,
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21 1 22) 23,
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MUCUAR REGULATORY COM4ISSICN This is 00 certify tha the attached proceecings before the U.S.
NUCLEAR REGULATORY COMMISSION - COMMISSIONERS MEETING in the matter Of:
SYSTEMATIC ASSESSMENT OF CURRENTLY OPERATING REACTORS -- Briefing Date of ?receecing:
Wednesday, 14 January 1981 Docke Number:
? lace of ?roceeding: 1717 H St NW, Wash DC were held as herein appears, anc that this is the Original transcrig therecf for the file of the Occ=ission.
JANE W.
BEACH Cfficial Reporter (Typed) m
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.v Cfficial Reporter (Signature)
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SECY-81-13 January 8,1981
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- jQ~ \\ j~ * / ' ]c ag s.- p POLICY ISSUE (Commission Meeting)
For:
The Cotanissioners Froia:
William J. Dircks Executive Director for Operations
Subject:
SYSTENATIC 5AFETY EVALUATION OF ALL CURRENTLY OPERATING NUCLEAR POWER REACTORS
Purpose:
To request Coianission approval of the issuance of the following items:
(1) a draft Federal Register notice for a final rule requiring occumentation of deviations from tne Stancard Review Plan, HUREG-75/Ud7; (2) a cetailed plan to implement the systematic safety evaluation of currently operating nuclear power reactors as a draft nuREG Report for public coluiaent; (3) a Federal Register notice announcin9 tne availability of and requestin9 cotanents on the draft NUREG report; (4) a puolic announcement on the issuance of the final rule and draft NUREG report; and (5) letters to Con-gress on the issuance of the final rule and draft huREG report.
These items are part of the staff's program to address the require-ments of Section 110 of Public Law 96-295, the NRC FY-80 Authori-zation Bill.
Background:
On September 9, 19d0, the staff suomitted an Action Paper (SECY 414) entitled " Systematic Safety Evaluation of All Currently Operating Nuclear Power Reactors" to tne Coraaission.
In tnis paper the staff requestea approval of the proposed conceptual elements of a plan designed to meet the requirements of Section 110 of Public Law 96-295, the NRC FY-80 Authorization dill. The Coraaission met on September lo,19 and 22 to discuss that paper and another related program, which will require the documentation of deviations from tne Standard Review Plan (SRP), NUREG-75/Od7, by all licensees and applicants. These discussions resulted in the issuance of the 90-day status report to Congress (Enclosure 1), as required by Section 110(c) of Puolic Law 96-295, on September 30, 1980, and in tne pub-lication of a Hotice of Proposed Ruletaaking in the Federal Register on October 9, 1980 (FR 67099, Enclosure 2).
J decause of the nexus of tne subject of the Federal Register notice K
to the requiresuents of Section 110 of Public Law 96-m, wnich s
includes tne identification of ano documentation of compliance i
Q' to the rebulations of particular safety significance, tne language in tne notice of proposeo rulemaking was chosen to track that of
n
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/,m/-
UNITED STATES
!Y
[g ImuCLEAR REGULATORY COMMISSib.,
ENCLOSURE 3 53,
- e ADVISORY COMMITTEE.ON REACTOR SAFEGUARDS
' yliZ., j' * ;
WASHINGTcN, D[ C.20555 g,
s.r October 14, 1980 d
1:i':3RN;DUM FOR: William J. Dircks, Executive Direc+r for Operations FROM:
Raymond F. Frale frector, ACR
SUBJECT:
COMENTS ON THE NRC STAFF'S PRELIMINARY PLANS FOR ADDRESSING THE REQUIREMENTS IN SECTION 110 0F THE FY-80 NRC AUTHORIZA-TION BILL During its. 246th meeting, October 9-11, 1980, the ACRS discussed with the NRC Staff their preliminary plans for addressing the requirements of Section 110 of the NPC FY-80 Authorization Bill.
The Staff also discussed this subject with the Reactor Operations Subcommittee on October 7,1980 and requested -
ACRS comments.
The Committee had the bene, fit of written comments by the Atomic Industrial Forum.
It is the Committee's view that the lists derived from Criteria II and III as currently presented by the NRC Staff do not include all the items of particu-lar significance to safety.
For. example, General Design Criterion 29 is not included.
Additional screening should be done,to ensure that all items of particular significance are included. The Committee also recommends that some other groups within the NRC Staff, such as PAS and AE00, carry out an inde-pendent review in order to increase the likelihood that the screening process This review could also be has not omitted items of particular significance.
used to establish a priority, based on risk reduction potential, in which the revies items shculd be addressed.
he Ccamittee noted your. comment on SECY 14 and endorses your intent to impl ement tight management controls to limit staff and industry effort to areas of potential safety payoff; guarding against the potential for a large drain on Staff and licensee resources that would not produce commensurate improvements in safety.
The Committee would appreciate being kept informed cf additional developments in this area, particularly on the nature of com-mants received as a result of the call for public comments scheduled to begin following issuance by the Staff of the final draf t plan for addressing Section 110.
cc:
ACRS Members I
H. Centon,siRR l
F. Schroeder, DST A. Ernst, DST
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G. Zech,:;RR Ai, l
l S. Chilk, SECY
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MEHORANDUM FOR:
Raymond F. Fraley, Executive Director, ACRS FROM:
William J. Dircks, Executive Director for Operations
SUBJECT:
STAFF'S PRELIMINARY PLANS FOR ADDRESSING THE REQUIREMENTS IN SECTION 110 0F THE FY-80 NRC AUTHORIZATION BILL Your memorandum, dated October 14, 1980, provided ACRS coments on the staff's preliminary plans for addressing the requirements of Section 110 of the FY-80 NRC Authorization Bill. The Comittee expressed concern regarding the results of the staff's trial screening of the regulations using two sets of proposed possible criteria for selecting those regulations of particular safety signifi cance. The Comittee expressed the view that the resultant lists do not include -
all the items of particular significance, and recomended that other gmups, such as PAS and AEOD, carry out an independent review.
1;g g
As you know, the staff.has requested Comission review and approval of a pre-liminary conceptual plan in SECY-80-414. An importiint element of that plan on which we seek a Commission decision is the manner in which the regulations of particular safety significance would be selected. We plan further discussions of this and other features of the proposed plan with the Comission in December, following the receipt and analysis of public coments on the recent Federal Register Notice regarding our proposal to require all licensees and applicants to review their designs against the Standard Review Plan.
Prior to this discussion ~ ith the Commission, the NRR staff intends to request l
w other NRC offices to. review the results of the preliminary screening of the l
regulations. The staff also intends to utilize risk analyses, to the extent practical, to establish the priority for subsequent reviews of deviations from I
f the regulations of particular significance.
The Comittee noted that the staff's trial screenings resulted in the omission l
of General Design Criterion 29, " Protection Against Anticipated Operational l
Occurrences", from the list of particularly significant regulations. This omis-sion illustrates the difficulties inherent in any such screening process. The staff team performing the trial screening judged that, although GDC-29 appears to be quite important when viewed separately, the significant aspects of GDC-29 are addressed more explicitly in GDC's 20 through 28, and that GDC-29 could be screened out. On reflection, however, it appears that no useful purposes would be served by omitting GDC-29 from the list, since it clearly is complementary to GDC-20 through 28.
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e Raymond F. Fraley I appreciate the endorsement of the Comittee on the need to implenent tight management controls over this program. Such controls will be particularly important to exercise reasonable and safety-related constraints on the ident-ification of those regulations having particular safety significance, and in the development of priorities and schedules for the follow-on reviews of'all operating reactors.
We will keep the Canittee informed of future developments regarding the plan for addressing Section 110, and will arrange another meeting with the Comittee after receipt of public coments on the final draft plan.
(Signed)Yli!!iam J.Dircks William J. Dircks Executive Director for Operations Distribution: - T r _1 UT%
r Central Files G. Ertter-(ED0-9730)
~
W. Dircks S.' Cavanaugh
~
K. Cornell
~
T. Schultze ~
T. Rehm
~E. Telford
~
R. Minogue SEGY T. Murley C. Michelson
'E.
Case H. Denton PPAS D. Eisenhut B. Grimes S. Hanauer i
D. Ross B. Snyder R. Vollmer F. Schroeder G. Zech S. Chilk M. Ernst R. Baer M. Boyle W. Milstead
' ENCLOSURE 5
.ps ta rug'o'f
/
UNITED STATES IN RESPONSE E
NUCLEAR REGULATORY COMMISSION 3
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WASHINGTON. D.C. 20555 k' * *C%c 8
October 24, 1980 ACTION:
Denton Cys: Dircks orres oF Twa Cornell SECRETARY
~
R@
~MBoyle "
1'ltTIDgue E
MEMORANDUM FOR THE RECORD
~
E. W. McGregor, SECY b M '
FROM:
SUBJECT:
SECY-80-414 - SYSTEMATIC SAFETY EVALUATION OF ALL
.a CURRENTLY OPERATING NUCLEAR POWER REACTORS
}g (COMMISSIONER ACTION ITEM)
.M The subject paper is closed as an active Commissioner Actionitem based both o f.
1980 (SECY SRM of September 24, 1980 is attached for ready
,. ? j reference) and on anticipated future events.
'j Q It is SECY's understanding that the staff will submit a new papet on the subject matter for the Commission's consideration some time subsequent to expiration of the comment period on the Federal Register Notice approved on September 19, 1980..
The new paper will address the public comments received on the Federal Register Notice as well as any' remaining issues in-SECY-80-414 which were not acted upon at the September 19 meeting.
Attachment:
As Stated l
cc:
V. Harding, OCM J.
Austin, OCM H.
Fontecilla, OCM T. Gibbon, OCM T.
Case, NRR l
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,k l%q UNITED STATES NUCLEAR REGULATORY COMMISSION y } g.Jr, 3>jj 3s g
W ASHIN GTON. D.C. 20555 g
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i September 24, 1980 OFFICE OF THE SECRETARY ltEMORANDUM FOR:
William J. Dircks, Executive DirectorforOperations')c, FR0ti:
Samuel J. Chilk, Secretar
.7
SUBJECT:
STAFF REQUIREMENTS - CONTINUATION OF DISCUSSION OF COMMISSION PROGRAM TO REVIEW OPERATING LICENSE APPLICATIONS 2:00 P.M.,
FRIDAY, SEPTEMBER 19,1980, C0tttISSIONERS' CONFERENCE ROOM, D. C. OFFICE (OPEN TO PUBLIC ATTENDANCE) a 3
The Comission continued its discussion of proposed revisions to the Standard Review Plan.
The Cocrnission unanimously:
g 1.
approved publishing for coment a Federal Register Notice based on the
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attached."NRR Plan to Require Licensee and Applicants to Document Deviations from Current Staff Positions Related to Applicable Safety and Safeguards Regulations", including the systematic e. valuation of all currently operating nuclear power reactors required by Subsections 110(a) and (b) of the NRC FY-80 Authorization.
The Federal Register Notice should also raise the issue of how this plan should be implemented.
In particular, it should raise the issue of whether the licensee / applicant obligations should be imposed through technical specifications, order, rulemaking, or seme other method.
The notice should be drafted so that the Comission may, at the end of the coment period, adopt a rule incorporating the NRR plan for construction permit applicants without the necessity of further pub 11:: coc/wnt.
(NRR) (SECY Suspense: 9/26/80) 2..
directed the EDO to complete the revised Standard Review Plan in six months.
(EDO)(SECYSuspense:_ 4/1/81) requested that the policy statement on construction permits (SECY-80-348) 3.
approved August 1,1980 (requirements memorandum attached) be modified to conform to the above changes and published for'coment; (NRR) (SECY Suspense: 9/24/80) 4.
noted that Commissioner coments on the proposed 90-day report to Congress (staff revision attached, dated 9/19/80) will be submitted to the Chairman early in the week of September 22, 1980, after which the report will be submitted to Congress by the Chairman.
(OCM)
Attachments:
y As noted
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Jlg cc:
Chairman Ahearne h'
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a Commissioner Gi.linsky Commissioner Hendrie
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Comissioner Bradford i
Commission Staff Offices
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UNfif6D8ifATEs
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NUCLEAR REGULATORY COMMISSION -
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"* 8 August 4,1980 stencTuy l'EmRANDUM.FOR:
W'illiam J. Dircks, Acting J
i'h, FROM:
Samuel J. Chilk, Secret n
STAFF REQUIREMENTS - BR EFSH,h'ON NEAR TERM REQUIREMENTS FOR
SUBJECT:
CONSTRUCTION PERT 1ITS F0k Pd'./ER REACTORS, 2:05 P.M., F
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AUGUST 1,1980, COWJSSIWlERS' CONFERENCE ROOM, D. C. OFFICE (SEESECY-80-3t.8)
(OPEN TO PUBLIC ATTEttDANCE)
.3 The Cert:tission discussed the staff's prepesed policy for prcceeding with pending construction permit and manufacturing license applicatiens.
The Cc=ission,'by a vote of 4-0:
1.
approved the publication in the Federal Register of the proposed
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licensing requirements for a 45 day public ce=entsperiod.
The Notice should be modified by adding "Cer:: ants are also requested regarding the extent to which the judgments reached by the Co::sission E-en these r.atters should form the basis for instructicns to licensing.
and appeal beards in construction oermit and manufacturinc license
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3 10- O proceedings.", as the next to last sentence en page E.
(NRR) (SECY Suspense:
S/1S/80)
. The Ccmission requested:
2.
that the draft NUREG identifying Action Plan itecs a;:plicable to pen. ding CP and ML applications address the incertance of close utility-vender-architect engineer integration.
(NRR) (SECY Suspense: 8/18/80) cc:
Chair:.an Ahearne Cc=issioner Gilinsky _
Ccmissioner Hendrid *
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Cc=issicner Bradford Ccmissicn Staff Offices gQf D
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