ML20003D100

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Unofficial Transcript of 810311 Meeting in Washington,Dc Re Revised Licensing Procedures
ML20003D100
Person / Time
Issue date: 03/11/1981
From:
NRC COMMISSION (OCM)
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Shared Package
ML20003D101 List:
References
REF-10CFR9.7 NUDOCS 8103190260
Download: ML20003D100 (84)


Text

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NUCLEAR REGULATORY COMMISSION 0- ' !

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~~ w In 16e Mattar of:

DISCUSSION OF REVISED -LICENSING PROCEDURES

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DATE: Marcit 11, 1981 PAGES:

1 thru 83 AT:

Washington, D. C, ALDER $1Y ' ^t REPORTING l

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l 400 Vi_vMa Ave., S.W. Wa shi ap:n, D. C. 20 014 l

Taischena : (202) 554-2345

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I i8308190 9 l

o ATIONS 1

1i UNITED STATES OF AMERICA 2

NUCLEAR REGULATORY COMMISSION 3

+++

4 DISCUSSION OF REVISED LICENSING PROCEDURES 5j

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l Nuclear Regulatory Commission I

g Room 113t A

7 1717 H Street, Northwest g

Washington, D. C.

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Wednesday, March.ll, 1981 d

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The Commission met, pursuant to notice, at 10:05 a. m.

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BEFORE:

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JOSEPH M. HENDRIE, Chairman of the Commission ti 12 f

VICTOR GILINSKY, Commissioner 5

13 m

i PETER A. BRADFORD, Commissioner l

14 g

JOHN F. AHEARNE, Commissioner 2

15 ALSO PRESENT:

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g' 16 w

LEONARD BICKWIT, General Counsel i

17 i SAMUEL J.

CHILK WILLIAM J. DIRCKS 18 EDWARD J. HANRAHAN j'

ALAN S. ROSENTHAL 19 HOWARD K. SHAPAR k

B. P. ANTHONY COTTER 20 HAROLD DENTON KEVIN CORNELL 21

' EDWARD CASE STEPHEN H. HANAUER 22 ROBERT MINOGUE RAY SMITH 23,

RICHARD DEYOUNG 24

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DIS m m I

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_P. _R _O _C _E _E _D _I _N_ _G _S 2

CHAIRMAN HENDRIE:

If we may come to order, the 3

Commission meets this morning on a subj ect which it has not had 4

before it for, oh, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> snyway -- no, 16, 18.

We continue e

5 yesterday's meeting.

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My aim this morning is to deal briefly with the R

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possible procedural rule change matter that we were discussing X

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yesterday afternoon, and then turn to the missing chair.

You dn 9

can either j oin us or not, as you like, Bill.

We will get to you

$g 10 in a second.

g 11 Now, yesterday, looking through the charts and 3

y 12 proposals of the ---what are they -- the ad hoc group on what to 3

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13 do about the hearing process, if anything, it does look as 14 though it may be practical to compact the hearing p$ocess a 2

15 little bit and to be able to anticipate with a reasonable j

16 expectation that it will work that way, that we can get a couple w

i 17 of months out of the process, and bring it. lown to the neighbor-U 18 hood of 10 or 11 months.

E 19 Now, there were some rule changes, mostly Part 2, but M

20 at least one in Part 7, which would be useful in aiding that.

21 They are listed on page 4 of the memorandum we were working from 22,

yesterday.

23 !

It seemed to me that sentiment along the table, there 24 were a couple of us that would be willing to go ahead on an 25[

immediately effective basis with these changes, but others of us t

i

3 1I that would prefer to understand a little more clearly what the 2

impacts might be up and down the line, the effects on people.

3 It did seem that all of us would be able to agree on 4

publishing this battery of procedural, proposed procedural n

5 changes for comment, and that would allow people a chance to E

3 6 f think about them and file with us comments on what the effects R

a 7

would be and give us a chance to pick out some or all, as the sl 8

case might be.

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9 So, what I would propose this morning is that we go io 10 ahead and direct publication for comment.

We will have to hear El 11 from the General Counsel what he would recommend oy way of 5

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12 comment period, the timing.

5 j

13 I I think, assuming that we can agree to go in that

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l 14 direction, that the supplementary information that accompanies b

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  • the proposed changes ought to point out what we have in mind, T

16 basically, namely that we are trying to provide a framework in 3

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p 17 which the hearing process can proceed more expeditiously; on w=

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18 '

the other hand, I think it would be fair to say, it is not our

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19 ;

intention to degrade the quality of those proceedings or their n

20 :

ability to deal fairly with issues that are properly brought into l

21 '

them.

22 John?

I 23 '

COMMISSIONER AREARNE:

Well, there are basically five 24 ;

changes, or six, the conforming.

As I said yesterday, I would 25,

be willing to go to make them all immediately effective, and I i

.ALDERSON REEORTING COMEANY. INC.

4 I

wondered, Vic had not taken a position.

He wanted a chance to

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think through them.

I wondered whether perhaps he might not be 3

willing to go, if not with all of them immediately effective, 4

perhaps with most of them.

My sense was that perhaps only

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5 number A was the ons that might have caused the greatest 5

5 6

concern on Peter's part for asking for comment, and perhaps we R

7 could at least agree to do the others.

X j

8 COMMISSIONER GILINSKY:

Actually, that is the one that d

d 9

I would like to hear comment most on, too, and the one where I i

h 10 think the effect is least clear, at least in my mind.

But I El 11' think it is better to go out for public comment on all of them, m

y 12 and that is what I would propose.

5-13 CHAIRMAN HENDRIE:

Good try, John.

Thank you.

l l

14 Peter, you were nodding toward this general proposition 2

15 yesterday _ afternoon.

John and I would be glad to have you join 5

g 16 us in immediately effective motions, but I think you would w

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prefer -- I read your feelings as preferring to go for comment.

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18 COMMISSIONER BRADFORD:

I would.

5 19 CHAIRMAN HENDRIE:

What sort of timing?

3 20 MR. BICKWIT:

My thoughts were that you ought to move 21 very expeditiously here, and since our original suggestion was 22 to go effective immediately, what we would suggest now is that 23 we have a notice from the secretary going directly to all the i

24 parties,.and that we ask for comments to be filed 20 days after 25[

that notice is sent.

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5 1I Simultaneously with that process, we would suggest a I

2' publication in the Federal Register and ask for comment 15 days 3

after publication in the Federal Register.

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4 CHAIRMAN HENDRIE:

Commissioners' comments?

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COMMISSIONER BRADFORD:

Dc we have complete discretion b

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on comment periods?

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MR. BICKWIT:

Under the APA, yes.

And cur view is that n]

8 since you could make thene effective immediately, yes.

Since you d

9j could make them effective immediately, you have total discretion ie 10 in this area.

Even if comment were required, this is compatible 3l 11 with the APA's provision on comment.

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11 COMMISSIONER BRADFORD:

What do we normally allow?

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g 13 Thirty days?

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y 14 MR. BICKWIT:

Thirty or forty-five.

I think 45 is more 5

2 15 like it, y

j 16 COMMISSIONER BRADFORD:

What is the purpose of asking

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17 for comment in 20 days from the parties and 15 in response to the y*

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18 l Federal Register notice?

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19 l MR, SICKWIT; Well, it would come out about the same.

n 20 The idea is that you assume five days mailing time, so it is 21 20 days after mailing, which means that the parties would 22,

probably only have 15 days to reflect on the matter.

Everybody t

i 23l else who gets their notice by Federal Register would have 15

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24,

days also.

25 COMMISSIONER GlLINSKY:

What do these limits mean?

Do i

i ALDERSON REPORTING COMP ANY. INC.

6 1I they mean that a comment has to be postmarked by a certain date?

i 2!

MR. BICKWIT:

That is right.

And I think under our 3

proposal we would make it plain that we intended to stick with I,

4 that.

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CHAIRMAN HENDRIE:

Actually, once you deliver up the

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6 text to the auchorities of the Federal Register, why, it takes 7

several days for it to appear, a week, something like that.

So, Al 8

if on a given day you mail from here to people and also march to d

9 the Federal Register, why, they will get it in the mail and it i

h 10 will be published in the Federal Register about the same time.

2 l

11 MR. 3ICKWIT:

Well, wnat you do is, you go to the

.y 12 Federal Register and you find out when it will be published, and x

13 then you calculate 15 days from there, and then in the notice z

l 14 that the secretary sends out you ask for comment by that date.

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15 CHAIRMAN HENDRIE:

I see.

The pcInt of mailing it to x

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16 all the parties in our assorted proceedings is to call their w

i 17 i attention'to it specially and not leave it to their daily az 5

18

. reading of the Federal Register.

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E 19 MR. BICKWIT:

Exactly.

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20 CHAIRMAN HENDRIE:

I dare say that list probab;y can 21 include other people who may not. be parties at the moment, but 22.

who. clearly have some interest in the process, Ehe normal attempt 23,

of the agency to. reach that particular segment of the population 24 that has some inte>est in these affairs.

25 ;

That sounds tight for a comment period, but clearly, L

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7 I

whether it is too tight I an willing to argue about.

It seems to 2

me, you know, that 45 or 60 days would be a rather too leisurely 3

pace to pursue.

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4 How does it strike you?

e 5

COMMISSIONER BRADFORD:

I don't have a good feel, 5j 6,

ubviously, for the schedules of the people who will be R

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ccmmenting.

These are not extensive -- it is not as though we Kl 8

were throwing NUREG 0737 at them and asking for co==ent within d

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9l 15 days.

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10 CHAIRMAN HENDRIE:

Yes, I think that is right.

El 11 COMMISSIONER BRADFORD:

So, they will have a rough r

y 12 sense of what they want to say about it.

I guess I think 15 I

g 13 days is a little tight.

I would go with 20.

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14 CHAIRMAN HENDRIE:

I would be willing to expand it 2

15 five, considering occasionally I find I have to think about w

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g 16 things and do something in periods cf time, and 20 sounds more w

17 like you can get a better set of comments.

I will vote for N

18 the 20.

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COMMISSIONER AHEARNE:

Joe, you have got Oc get three M

i 20 i votes, wherever that will fall.

l 21 CHAIRMAN HENDRIE:

Okay.

t 22 COMMISSIONER GILINSKY:

That sounds reasonable.

j 23,

COMMISSIONER HENDRIE:

Okay.

Twenty days, and let's 24 see how fast you can get it out.

25 ;

MR. BICKWIT:

There is another part of our proposal i

I ALDERSON REPORTING COMPANY. INC.

8 1

that relates to that, and I don't expect it to be accepted, but 2

in view of the it=ediacy of the proble= and in view of the fact 3

that these were proposed rules, we were seeking a delegatien 4

simply to draft them and send them.

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5 COMMISSIONER BRADFORD:

What does that mean?

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6l MR. BICKWIT:

That means that you wouldn't see them.

7 CHAIRMAN HENDRIE:

I can stand that.

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COMMISSIONER 3RADFORD:

I must say, wary though I am dd 9

of establishing a precedent, I assu=e that you can be trusted to 10 do no more than ---

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3 11 COMMISSIONER AHEARNE:

Let's use it as a test case.

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12 COMMISSIONER 3RADFORD:

And after all, we, too, will 5

13 have those 20 days in which to read them and improve on anything 5a l

14 I that seems terribly disturbing.

I 15 COMMISSIONER GILINSKY:

That is fine, yes, so long as u.s j

16 it.is clear that it is out for cettent without necessarily our w

d 17 having taken a position on it, w

a 18 CHAIRMAN HENDRIE:

That clearly has to be the case in

=9 19 terms of 6he rulemaking.

Very good.

So, we have done that.

20 Yesterday we also agreed to publish for con =ent the 21 immediate effectiveness proposition, the alternatives.

There I.

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22 said that the Co=nissioners would like to read that draft, and 23!

there I would like to read it, and I assume if I am going to V

l 24 read it, why, other Co=missioners might not feel it unreasonable i

25 that they read it, too.

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9 1

COMMISSIONER BRADFORD:

Now, that one will be coming 2

around?

3 MR. BICKWIT:

That is right.

4 CHA7RMAN HENDRIE:

Yes.

There, there is a little more o

5 creative effort underway.

U 6

COMMISSIONER BRADFORD:

The only thing I an at all R

7 curious about on the other one, the one we have just agreed to, s]

8 is what you will say in the statement of consideration.

Can you d

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9 give me a sneak preview?

5g 10 MR. BICKWIT:

I think something on the order of what g

11 was said earlier, that there is a need, the Commission considers a

p 12 some need for expedition here, but not at the price of degrading 5

13 the proceedings.

And I actually think that one of the items 14 you want comment on is whether it will degrade the proceedings.

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15 COMMISSIONER BRADFORD:

Exactly.

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16 MR. BICKWIT:

I think we have had the preview.

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17 !

CHAIRMAN HENDRIE:

You have had the colloquy there and

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18 l settled that, good.

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19 I Now, the place that I propose to go new in the course M

20 of this meeting is to talk to Mr. Dircks and his assembled 21 battalions, so that they pernaps don't need to keep coming down 22,

to this series of meetings.

And after we have discussed staff l

23!

resources, problems and what they can do and so on, then we need l

l 24 l to come back to the March 10th memo, the one we have been looking 25 ;

at with chart 3 and the list of rules on page 4, and so on, to i

AI nFQ4nN_QFpnRTIN(: rnMPANY INr

10 I

go on and look at the other items on page 5, and any similar 2

matters that are hanging over us.

3 After that we will look and see whether we have had a 4

look, at least one chance to discuss all of the significant 5

items on everybody's various lists of things we could do.

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I would like in a week or two, as we close toward R

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further hearings with some of our subcommittees on this subj ect, a

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to be able to say the Commission has at least had a preliminary dd 9

discussion on all of those kinds of things.

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10 Okay, Bill, yesterday you came with a pack of view-j 11 graphs.

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12 MR. DIRCKS:

You have a set of the slides before you, E

y 13 ;

and we may have modified them in the meantime, so I will hit the 14 points.

E 15 (Slide.)

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16 Let me introduce the topic and give some precautionary d

17 :

statements.

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18 What we are outlining here is, I think, in response to 5

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19 the assignment you gave us, come back with a set of proposals or n

20 suggestions that would enable us to minimize the delay in the 21 issuance of staff documents in order to allow, basically, the 22 plants to operate with a minimum of holdup.

23 CHAIRMAN HENDRIE:

In particular for that line of 24l licensing cases which are far enough down the line 30 that some 1

25 reasonable planning can affect the timing of staff work and i

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ALDERSON REPORTING COMP

11 1

publication of documents.

2 MR. DIRCKS:

We will not be affecting the near term 3

plants that much.

The major effect will be felt in the '82 '83 i

4 period.

e 5

CHAIRMAN HENDRIE:

Well, you are already taking such An j

6 steps ae you can to help the ones that are close in, but what R

7 we are talking about here necessarily presumes enough time ahead Al 8

of the decision date so you can do reasonable things.

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9 MR. DIRCKS:

We are basing these proposals on the

!g 10 11 month process that you gave us as a target.

The more you deal 3j 11 with that schedule, the less impact will be on the things we 3

g 12 are proposing here.

5 13 Another point I want to caution you on is that we are l

14 looking over a period of two to three years.

The process will C

15 naturally be somewhat: flexible, as you go into this planning y

j 16 phase.

There will be changes made up and down the line.

And the w

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whole thing is interconnected.

18 If by moving the plants into hearing faster, that will 5

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19 in turn impose another workload back on the staff dealing with n

20 interrogatories, new issues that come up during the hearing 21 process.

I mentioned the other day the 175 to 200 interrogatories 22 we got on a seismic problem that will divert the seismic staff 23 l away from doing staff documents to deal with those interrogatories 24l COMMISSIONER AHEARNE:

Unless there are other steps 25,

taken, such as the one that eliminates the staff from discovery.

I i

i ALDERSON REPORTING COMPANY. INC.

12 1

MR. DIRCKS:

That would be, yes.

Because I have 2

another example of another case where surprisingly -- I mean, not 3

a surprise, but unexpectedly the board -- well, we didn't have 4

any notion that this was coming up -- asked five local e

5 psychologists to come in and talk about stress in the control h

j 6

room, which will immediately drag the human factors staff into R

7 dealing with that issue.

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8 COMMISSIONER AHEARNE:

Could you give me a reference to d

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that?

What case is that?

Just as an aside on the status, which Ng 10 case is that?

j 11 MR. DIRCKS:

That is the McGuire case.

g 12 So, the point I am trying to make is, the whole thing i

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13 l 1s interconnected, and any improvements made in one area will

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l 14 help us in this area.

Also, it will come back and impact on 2

15 staff workload.

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16 The major benefits I have listed there.

It will M

d 17 minimize delays on '81 and '82 OL's.

It will prevent delays on U

18 1983 OL's.

It will expedite the review of near term CP's.

And 5

3 19 in '83 it will avoid 92 reactor months of delay using applicant M

20 fuel load dates.

And that is the total, out of a total number 21 of 92 impacted once in '83 22 COMMISSIONER BRADFORD:

How many plants are those 92 23,

months spread over?

i 24 MR. DENTON:

Eleven.

25 ;

COMMISSIONER BRADFORD:

And what is the average l

ALDERSON REPORTING COMEANLINF

13 1

difference again between the applicant fuel load dates and ours?

f MR. DENTON:

We could subtract the two numbers and 2

diVid* ---

3

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MR. DIRCKS:

Four or five months on the average.

4 COMMISSIONER BRADFORD:

I see.

I hadn't gotten to e

5 U

j 6 l that.

I am a slow reader.

I hadn't gotten to the next line.

1 MR. DIRCKS:

The next one down shows it using the l

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8 staff fuel load dates, and that would avoid, then, 39 months of a

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impact.

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10 COMMISSIONER GILINSKY:

Now, which 11 plants are you 3

5 11 talking about?

d 12 MR. DENTON:

We are talking about the '83 plants here.

E 13 COMMISSIONER GILINSKY:

This is the second group of 5

E 14 plants?

d 15 MR. DENTON:

Yes.

Plants who the applicants expect to 16 be constructed in '83 They are all about the same size, 11 or 3W 12.

They are on my second slide.

In the previous presentation, g

37,

18 I had all the '83 plants listed on a separate sheet, and I had

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all the '81 and '82 plants on one page.

19 P

5

' CHAIRMAN HENDRIE:

Hang on a minute.

What I want to 20 21 make sure is that when I talk about the near term group, and

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22 what I am thinking about there are the 10 or 11 or 12, or whatever

'l 23l it was, plants on a single sheet in one of your handouts within 24 the last couple of weeks, when I talk about the near term group 25 and you talk about the '83 and downstream plants, that we have L

14 i

not left out some plants in late '82, and I want to know that 2

those two terms in sum cover the universe of OL plants.

COMMISSIONER AHEARNE:

But those early plants included 3

4 some slighly into '83 anyway.

CHAIRMAN HENDRIE:

Yes.

5

=

5 MR. DIRCKS :

I don't think we have left out any.

8 6l Eg 7

CHAIRMAN HENDRIE:

Okay.

So that when we talk about ag 8

near term and long term groups, we are talking about, first, the n

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9

'81 '82 licenses, is that right?

And when you say '83, you 10 mean ---

E I

11 MR. DIRCKS:

Calendar year.

d 12 MR. DENTON:

Our ' 81 and ' 82 plants went through 3cd 13 plants to be finished.in very late '82.

This is Fermi, Comanche 5

E 14 Peak, Grand Gulf, Watts Bar, WHP, and so forth, and they were all wb!

15 on one page.

And then any plant where the utility's own

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16 construction date was '83 went over on the next page of plants 3W 6

17 l and we called all of those '83 plants.

Remember, that was one 5

5 18 of the backup slides, and I did give the secretary a complete 5h list of all those slides.

19 9

M 20 CHAIRMAN HENDRIE:

I don't seem to have the backup.

21 Sometime you might slip me sheet 2 o f that.

It gives me a

t.,

22 comforting feeling to be able to run down the list of plants and 23,

made sure somebody hasn't dropped it on the floor and it is l

24 b eing ignored.

25l Okay, fire _away.

15 I

1' MR. DIRCKS :

Okay.

The costs of this proposal would be 2

125 professional staff years of work and 8 secretarial.

These 3

are additions to the current staff.

4 COMMISSIONER GILINSKY:

Which of those reactor month e

5 delay numbers are you using for planning purposes?

9 6

MR. DIRCKS:

The applicant fuel load, the applicant R

7 dates.

And that is a point that I should stress, too.

As those j

8 dates change to actual dates, we can adjust it back again.

d6 9

COMMISSIONER GILINSKY:

If you are going to adjust iog 10 things so you can avoid the 92 months, then you are going to --

E j

11 if the NRC dates are right -- be ready five months before n

f 11 operation for each of those reactors, assuming all our c

13 assumptions are correct and everything else is constant.

l 14 MR. DIRCKS:

As you get closer in, the dates become 5

2 15 firmer, of course.

But I think we were going on the guidance g-g 16 that we received to base our planning on the applican; dates.

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17 i COMMISSIONER GILINSKY:

Well, does that really make w

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5 18 sense, when NRC's projections have themselves proven a bit 5

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19 !

optimistic on the loading dates?

n 20 MR. DENTON:

Well, we have been accused of, when we 21 I use our dates, having a self-fulfilling prophecy, that if the 22 utility realizes we are not going to complete our review or get i

23 '

a license until a year after their plan date, it probably does 24 influence their schedule.

I 25 ;

COMNISSIONER AHEARNE:

Well, what is your judgment?

ALDERSON REFORTING COMPANY. INC.

16 1

COMMISSIONER GILINSKY:

I understand that, and I ;hink 2

we want to avoid doing that.

But at the same time, the applicant 3

schedules are developed not only to be realistic, but also to 4

try and keep control over a process of construction and are just a

5 known to be optimistic and have always been optimistic.

b 6

MR. DENTON:

It is just like our internal scheduling.

R 7

The review will expand to take' the time allowed, you know, if we 4l 8

are not careful.

So, I understand the desire to put a tight date dd 9

and try to hold to it.

If we plan on the basis of the NRC 10 dates, they will be self-fulfilling, because in general once that i

g 11 becomes known that they are not going te 'et a license until some 3

y 12 date, then that becomes the pacing of construction.

r 5

13 COMMISSIONER AHEARNE:

But does it turn around the l

14 other way, that if we plan on their fuel load dates, will they 2

15 meet them?

n j

16 MR. DENTON:

It doesn't guarantee it, no.

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17 COMMISSIONER AHEARNE: -What is your j udgment?

18 MR.

'ON :

It will scatter.

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19 ;

MR. DIh Historically, I guess their dates have 4

20 been more optimistic than our dates.

21 COMMISSIONER GILINSKY:

Historically, our dates have 22 been optimistic, too.

23 MR. DENTON:

But that gets into this, the chicken and 24 the egg.

Is it because of our inability to do the reviews and 25,

so forth.

So, it is hard to separate out.

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17 1

COMMISSIOFER GILINSKY:

I understand.

Nevertheless, 2

because to try to avoid these delays involves some pretty 3

important reallocations of effort and changes in programs, it 4

seems to me we have got to find some reasonable middle here.

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CHAIRMAN HENDRIE:

Why don't we go ahead and hear the

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18 COMMISSIONER AHEARNE:

What you are saying, Joe, is k

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Well, I wouldn't care to be ironclad i

21 about it, but largely.

How about that?

You have got enough t

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23; COMMISSIONER AHEARNE:

Well,-maybe it will be explained 24 as they go through it, and I will j ust wait.

25,

. CHAIRMAN HENDRIE:

All right.

Let's try to let them l

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Let me just add one point.

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Which those offices are taking a=

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Yes.

Which' tasks those offices are pickin6 x

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21 COMMISSIONER BRADFORD:

At the same time, those same 22 offices are all giving up people?

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23 MR. DIRCKS:

They are giving up people, too.

24l COMMISSIONER BRADFORD:

So, the ones in place are going i

25 ;

to work harder?

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MR. DIRCKS:

Well, ones in places like NRR is going into 2

overtime, and if they feel themselves being pinched, they can 3

ease up.

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slip over there and we will get into that.

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a lot fewer manhours to put into it.

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Which is particularly true of an office 22 such as research.

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COMMISSIONER BRADFORD:

Is that reflected in the-item 2 24 i on the preceding slide?

25,

MR. CORNELL:

No, it is not.

Item 2 on the preceding

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slide is only that work which NRR would contract out.

2 MR. DIRCKS:

Let =e stress again, we are mentioning 3

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CHAIRMAN HENDRIE:

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11 MR. DIRCKS:

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19 This is the additional assistance that we need on the

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ALDERSON REPORTING COMPANY, INC

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necessary arrangements.

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that. has been going on for a number of years.

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6 COMMISSIONER ERADFORD:

This is the same program that R

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amendment.

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5 13 COMMISSIONER BRADFORD:

I read their letter to say l

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18 COMMISSIONER AHEARNE:

Actually, what we told Congress 5

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I have no doubt that there are gold 22 watches that have been thrown on the table.

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25; we go into this program.

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ALDERSON REPORTING COMPANY, INC.

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23 1

COMMISSIONER BRADFORD:

When you say additional 2

assistance required, why wouldn't you double that number?

What 3

is the constraint at the upper end there?

Is that the most you

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21 COMMISSIONER BRADFORD:

But is this 26 what was left 22,

when you subtracted everything we could do internally from the

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number 125?

24 l MR. DENTON:

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going to get some relief cn the hiring freeze, the deferral and 2

reshuffling of proj ects, and then this is how much we could get 3

from outside NRR.

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4 MR. CORNELL:

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But this is all based on 11

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this is tne best estimate that we can get at this time.

ALDERSON RFPORTING COMRANY INF

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In the waste management program we are dealing with, 2'

I guess, in that area people with skills in hydrology and earth 3

sciences, and we are talking about moving, and this would.fesult 4

in the delays that are mentioned up there.

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Now, why is that?

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And they affect the reg guides nW 6

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Yes.

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This particular area happens to be one 5

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And this is dealing with what we hate i

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We could improve on some of this, we don't know.

This is 24 l the best estimate of what we have.

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research program, all research personnel ieing affected here.

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certain items by less than six months, which is, I guess in the

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7 COMMISSIONER AHEARNE:

I am going to honor Joe's 8

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Yg 10 (Slide.)

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Yes.

I guess before we got through with 5

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22 into the international, and he felt if he had to give up one 23 area or the other, that is the first area that would go.

24 i COMMISSIONER GILINSKY:

I must say for myself, you know:

25; if we are not using it, we are not using it, and we are not giving i

At f3E"RSON RFPORTING COMP ANY INC

27 1

up much, and that is something we can let go.

But of that wlgole 2I list, I think that is the one I would look hardest at.

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It raises certain red flags.

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It is my understanding that this would 5

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17 MR. DIRCKS:

Again, we can go down the list.

'de are 18 talking about in the fuel cycle material safety area, the P

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I think we have to look at to what 21 extent they have people left over there, to what extent they are 22 ready to reorganize themselves, and to what extent they are willirE 23 to do more overtime work.

These are, again, office projections.

24 The decommissioning rule, policy statement and generic 25l environmental impact statement, delayed six to nine months.

This i

i ALDERSON REPORTING COMPANY. INC.

28 I

means the rule conceivably could slip from September, '81 until

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rule dates, I am not putting much faith in meeting target dates i.

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COMMISSIONER BRADFORD:

The other question, you are An 8

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list the affects that you can see that it might have, and you try A

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ALDERSON REPERIING-COMP ANYJNC.

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29 1

offices, you know, a total of 12 people, equivalent in project

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job relief, and 26 people actual professionals, actually 3

transferred into the six offices listed, and so on, and now what

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section leaders and the professional say, that is impossible.

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20 I So, there is an awful lot of influence here on the 21 eventual effects by the way in which we go about this proposition, 22 and when we eventually decide where we ought to come down on 23 this, why, I think we all ought to go at it in as cheerful and 24 upbeat a spirit as we can and that will minimize the impact.

25 ;

COMMISSIONER GILINSKY:

Was there only one person in

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ALDERSON REPORTING COMPANY,INC,

30 1

MPA identified?

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2 MR. DIRCKS:

In the skill area, that is the only one 3

that we have identified.

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4 MR. CORNELL:

In many of these cases, the offices s

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3 6l CHAIRMAN HENDRIE:

By george, I am glad to see all of 7

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I might comment on that.

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2 15 (Slide.)

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19 i MR. DENTON:

We probably have the most severe imipacts 5

20 in some sense, in terms of number of things.

There are probably 21 I 50 manyears or so that we have reallocated or reshuffled or 22 deferred.

I am comfortable and the staff is comfortable with 23!

the reallocations that are under consideration here.

24 We did not cut into what we consider the essential 25l safety aspects in any case in order to support the casework, but i

f ALDERSON REPORTING COMP ANY. INC.

31 I

we recognize that going out for technical assistance, for 2

example, does introduce by itself a delay in getting assistance 3

and getting it up to speed.

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TMI action plan in every division.

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Could you j ust give an example w

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5 18 MR. DENTON:

Yes.

Let's go to 7-A.

E" 19 (Slide.)

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We were having trouble maintaining our progress on all s

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of those items.

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24 We might go to 7-B first, to talk about this.

25 ;

(Slide.)

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ALDERSON REPORTING COMPANYn INC, m

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letting slip in the human factors areas.

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developing guidelines for control rooms and for operators.

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Let's start with 7-B, please.

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propdsed for deferring.

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Could you j ust tell me what it 21 is that is being deferred in any of these items?

Let's start

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23,

MR. HANAUER:

All right.

I will start with the top 24 ~

We have already made a substantial change in the operator one.

25 licensing program.

In the meantime, wc have been and plan to i

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i ALDERSON REPO RTWG COREPT3E8Co

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I conduct a number of studies and to make substantial additional

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And for a lack of one person 5

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E 19 MR. HANAUER:

No, sir.

I have to say this viewgraph M

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12 COMMISSIONER AHEARNE:

This one and the previous one, 23 you mean?

24 MR. HANAUER:

The 7-A, 7-A and 73 together would take 25 :

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to redress.

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MR. DIRCKS:

Of course, Steve, having said that, it 3

throws our arithmetic off completely.

4 MR. HANAUER:

Wall, I wouldn't be surprised.

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6 (Slide.)

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the same item 1.A.3.2.

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10 have been the subject of a great deal of discussion with the j

11 Commission, and in fact we are about to go out with a proposed 3

y 12 rule to engrave on tablets this first wave.

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h 14 resources for further improvement would delay a further 2

15 implementation of some of these improvements.

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16 COMMISSIONER GILINSKY:

Could you tell ne what w

d 17 i specifically would ce delayed, say, in the third item?

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18 MR. HANAUER:

In the third item, control room design, 5

19 safety parameter display console, the basic requirements for that i

M 20 are set forth in NUREG 0696, which the Commission approved 21 within the last couple of weeks.

The Commission has not, and 22 specifically did not establish the safety parameter display 23 console as a requirement.

We would expect to request this.

24f We expect this requirement to be laid on, and we 25,

expect the industry to design and install such devices.

However, Al DERSON REPORTING COMP ANY.. INC.

3 5.,

I we would, if this recovery plan is adopted, do a lot less 2

technical review of these and they would g3 in with a lot less of 3

our review than would otherwise be the case.

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7 MR. CENTON:

Now, there are a couple of programs, and Ml 8

this is one of them, in which we were having extreme difficulty d

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meeting the objectives before tho reallocation in the casework, io

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g 11 skills in these human factors areas.

Steve has made progress, 3

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l 14 to seek qualified outside people to help in these areas.

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2 15 were all flashing yellow lights, I think, before this exercise *.

y 16 COMMISSIONER AHEARNE:

I have been trying not to ask A

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questions, but ---

5 18 CHAIRMAN.HENDRIE:

I can't ask you to hold forever.

Go 2

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ahead.

5 20 COMMISSIONER AHEARNE:

Let me ask just one question.

21 I have got a whole host.

But this really does look like the 22 classic historesis case.

It doesn't work the same when you go 23 into the phenomena as when you come out of the phenomena, 24!

Are you saying that if we had six people more that you 25!

don't have yet that all of these things would be done on the i

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t ALDERSON REPORTING COMPANY. INF

I 36 1

schedule we currently laid out for them?

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2 MR. HANAUER:

If I had today six people, which in fact l

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casework law, yes, I could keep these things going, or most of a

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6 reasons.

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COMMISSIONER AHEARNE:

So, these aren't slots, these A

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are ---

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MR. EANAUER:

These are people who will do casework io 10 instead of these things, or give licensing exa.?.s.

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And if you did have those, if 3

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13 j all its days of implementation and its schedules, you currently a

14 expect to be able to meet almost all of those schedules?

2 15 HANAUER:

Tue action plan book youFlocked at a 5

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6 17 j then -- it would be restored to its green and yellow condition, Ecw 18 because that is the program we were pursuing.

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If you give us six shiny new people, there g

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20 is a certain ramp up during which they will be less useful than 21 the people we had on there.

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22 CRAIRMAN HENDRIE:

Steve, one of the characteristics of 23 '

the i. ems on 7-A and 7-B in your area -- I guess these things i

24 :

are all in your area, right?

25 MR. HANAUER:

Yes, sir.

l ALDERSON REPORTING COMP ANY. INC.

37

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CHAIRMAN HENDRIE:

For inctance, item 4 here, l.D.3 I

2 safety system status, what you are talking about are incremental 3

efforts in improvement in that area.

I think this is true of 4

most of these items.

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5 MR. HANAUER:

It is true of most of them, but not that h

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one.

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7 CHAIRMAN HENDRIE:

Let me consider it as a general j

8 area.

The point is that, for instance, by naming one of these d

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proposition as an impacted item, the implication is not that 10 there has been no work in this area and now there will not be any E

j 11 work in this area for some additional time, but rather that there 3

y 12 is an increment of effort that you are contemplating that was 5

13 part of the action plan upgrading and that gets rolled back.

l 14 Right?

2 15 MR. HANAUER:

That is generally true, although there y

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17 i picked up at the time originally foreseen, and that is one of U

5 18 them.

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19 CHAIRMAN HENDRIE:

Okay.

Safety system status is one R

20 of them.

What are the others?

21 COMMISSIGHER GILINSKY:

Could you just explain what 22 that item means?

23!

MR. HANAUER:

That is hardware system.

The designs 24 l I have seen, 'the preliminary designs I have seen are computer

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38 1

is scanned and anomalies are announced to the :ontrol room staff.

2 CHAIRMAN HENDRIE:

It tells you what all your safety 3

related gear is doing that it shouldn't be doing?

4 MP. HANAUER:

Yes.

The most obvious application is g

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immediately of those closed aux feedwater valves.

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5 13 CHAIRMAN HENDRIE:

But it is also fair to note that x

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2 15 existing plant is a big piece of work.

You have got to go f

16 around and put pickup signals from your just great numbers of d

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But you can't 23,

arrive at the question until you do some work on it, and that, 24 in part, was what I think this item covered.

25 '

MR. DENTON:

As Bill said, the exact nature of the ALDERSON REPORTING COMP

39 I

deferral isn't known here, and we will continue to strive to find f.

2 ways to get work done on these things, independent of this 3

reallocation.

4 Why don't I move to 7-C.

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(Slide.)

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We are going to do all the operating reactor items that 3g 7

we think need to be done, followup on the orders, the signficant

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occurrences, the research results.

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backlog of seeming items where someone wants a review done to iOg 10 change the amendment, and some of these we are just going to E

j 11 have to put off and not do.

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12 of them.

This is just examples of the kind that are pending 5

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But I don't want you to think this is the only set, E

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5; 19 l (Slide.)

.:6 20 Now, 7-D is a somewhat different category.

This is 21 deferral of generic issues.

Of course, all the generic issues 22 that are unresolved safety issues will be worked, but there are 23 a class of ones which we are just deferring work on for a while.

24 I They tend to be the category B and C types, and I have listed i

25,

the examples here of ten of the generic issues and their numbers t

I ALDERSON REPORTING COMP ANY, INC

40 1

that would just be deferred, no work would be done on these 2

during this period.

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5 ad hoc review using our best judgment in that area.

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li have been under review for USI's by one group or another, but m

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13 (Slide.)

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14 All together, we have ended up, in effect, abolishing g

15 temporarily two branches that we had set up to go forward in x

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One was the systems interaction branch, which we A

6 17 made a big push on to get moving.

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20 big methodological increase.

21 Another was in the operating experience evaluation 22 branch, which we set up within NRR to follow, to look at LER's 23 !

carefully.

We do it, INE does it, the AEOD does it.

We have 24 agreed to farm out to the other two groups the part that we were 25,

doing there and reassign responsibility within NRR to follow up.

i ALDERSON REPORTING COMPANY. INC,

41 i

But overall, there are some 50'many' ears of activities that are 2

being done differently than we had planned to do them.

3 COMMISSIONER BRADFORD:

Those last two are activities

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4 which have been done, Harold, or which you are proposing as part e

5 of the plan?

The abolition of those two branches.

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6 MR. DENTON:

This would be part of the plan, in order R

7 to free up resources.

One of the key ingredients this plan does, Ml 8

it gets a project manager assigned, a single project manager dd 9

assigned to every plant that is in the '81, '32, '83 list, which i

h 10 we don't feel we can really get the case moving without a E

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3c 13 So, staffing up project managers first, and then l

14 staffing up the technical groups that need to follow those E

15 cases is what this plan accomplishes.

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16 MR. DIRCKS:

I have one more slide to cover.

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17 '

COMMISSIONER BRADFORD:

How many of those cases don't 5

18 have proj ect managers now?

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19 MR. DENTON:

We have cases assigned to more than one R

20 project manager at the time, and I think we ended up with a need 21 for either 12 or 20 project manager,s in order to have a single t

22 project manager at every active case.

23 !

COMMISSIONER BRADFORD:

Every active case over those 24 three years?

I 25,

MR. DENTON:

And the CP's, in order to assure ---

f ALDERSON REPORTING COMPANY. INC.

42 1

COMMISSIONER BRADFORD:

Will some of those project 2

managers also have cases that are further out?

3 MR. DENTON:

Some of the cases that are further out are

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5 there are actions that you have to take on plants like Limerick, 9

6 even though it is not docketed.

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COMMISSIONER BRADFORD:

How many project managers do g

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11 MR. DENTON:

Let me ask Ed the number.

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12 project managers for the operating plants, and then we have B

i 13 project managers for the plants. under construction and review.

l 14 COMMISSIONER BRADFORD:

Just the plants under 2

15 construction and review.

g 16 MR. DENTON:

We have three branches.

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17 i MR. CASE:

I don't have the numbers.

I would rather 18 get them for you.

5" 19 MR. DENTON:

I think it is about 18 or 20 presently, R

20 project managers assigned to all the plants, either in 21 construction or in for an operating license, and that quite 22 often results with the same person having Salem and having a 23,

CP.

i 24 i (Slide.)

l 25 MR. DIRCKS:

The final slide gives you some idea of the

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Il ALDERSON REPORTING COMPANY. INCe I

43 1

funding requirements and the possible sources to meet those 2

requirements.

This is fiscal '81-82.

We need about 12.7 million 3

dollars to carry out this effort, and we have listed the amounts 4

in there.

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This is only money needed by NRR.

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14 the document control contract hanging out there as a possible 2

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d 17 i dealing with the reprogramming in '82 that ne would have to do.

18 This completes everything that I have to say.

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CHAIRMAN HENDRIE:

' Good.

We got you through.

I admire R

20 the restraint of my colleagues.

I thank them for it.

21 Go ahead, John.

22 COMMISSIONER AHEARNE:

If you wouldn't mind, I would 23,

just like to go down through a number of these charts.

24 The proposal of this redistribution, you had on your 25 !

first chart the minimized delays on ' 81 and ' 82 operating I

i ALDERSON REPORTING COMPANL INC.

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44 1

licenses.

To a large extent this is backfilling in behind that, 2

isn't it, in the sense that the '81 and '82 operating license 3

delays are being -- to the extent that NRR or the non-ELD staff, 4

non-licensing board staff is associated with it, it is in order o

5 to get those documents done that you are now working on, and you 5

8 6l are pulling some people in, as I understand it, I

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That is a convenient way to look at it, M

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Is that a correct way?

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16 that may have to be picked up by some of these reassigned people.

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I might mention, too, we are dealing here 5

18 with getting people into the NRh licensing process.

Again, 5

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another thread in this fabric is the impact on ELD if you move 5

l 20 l forward with a process that would get more cases for the hearings.

21 i That is an important part of the problem.

22 CHAIRMAN HENDRIE:

Yes.

We may be able to supply a 23 couple of people from the Commission level.

24f MR. DIRCKS:

But it does impact.

And how you deal with 25,

the problem of the immediate effectiveness rule, I guess, will l

l O.LDERSON REPORTING COMP ANY. INC.

45 1

impact back on OGC and OPE.

2 COMMISSIONER AHEARNE:

In your reallocation within NRR, 3

are you atte.T.pting to -- are you planning on taking people out i

4 of the existing branches and putting them into the casework g

5 branches, or are you trying to take work that can be done and 8

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giving it to the existing branches?

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We are trying to keep the casework within M

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the existing branches to the extent possible, and farm out items d

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So that the casework would be done by 5

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And that led to two branches, then, which in effect would

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Otherwise, it would stay.

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I wasn't asking the split.

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Beyond that, are E

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you taking the work within the division of licensing and trying, a

20 to the extent possible, to parcel extra work out to the other 21 divisions, or are you trying to take people from the other 22 divisions and put them inte the division of licensing?

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So, they will get the project 25,

managers.

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46 I

we will try to let them handle through Franklin Institute with 2

Franklin contract type studies.

But by and large we will just 3

give more money to, say, the division of engineering to get the 4

operating reactor actions done that they would otherwise have o

5 their staff do.

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6 COMMISSIONER AHEARNE:

So, you are trying to keep the e

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7 current organizational structure?

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8 MR. DENTON:

Yes, that is correct.

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9 MR. DIRCKS :

I think in one area that bears on this, 10 I&E will be picking up part of the SAR chapters.

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11 MR. DENTON:

I am trying to maintain the matrix

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You had mentioned this is all 2

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would, at the moment, still prefer to go this route, because this 5

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R 20 MR. DIRCKS:

Well, I don't know how concrete the 11 21 month schedule is.

22 MR. CORNELL:

There is another aspect to this.

There 23l are a_ lot of things which are unknown.

For example, we are 24 banking on offers out.

We don't know what those people are t

25 going to be like when they actually get in-house.

We are banking I

l ALDERSON REPORTING COMPAN% ONC.

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on getting assistance from the labs, so there are a lot of 2

uncertainties.

3 COMMISSIONER AHEARNE:

On the second chart you had 4

4.8 million in '81 and 7.6 in '82.

That is part of the 12.7 that 5

g you list on your last chart, is that correct?

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6 MR. DIRCKS :

I think we didn't catch the extra 0 3 in 7l E

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8 COMMISSIONER AHEARNE:

So that it is 4.8 that you need d

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in ' 81, and most of it is in f 82 that you have to find.

!y 10 The assistance from other offices, you are taking 13 E

j 31 people out of research.

Is that coming primarily fron. one 3

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We are going to do some reorganization and l

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Are these transfers that you are

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21 MR. DIRCKS:

I think we are doing that to start off 22 with a detail, and then we will see how it plays out from there.

23 '

COMMISSIONER AHEARNE:

The detail is planned for?

24 MR. DIRCKS:

Six months, I think, to begin with, and 25l then we will look at what permanent restructuring we might want l

ALDERSON REPORTING COMPANY, INC.

48 1

to propose to the Commission.

2 MR. CORNELL:

In gross terms, I think we are looking at 3

this kind of professional experience, professional staff being

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That shouldn't be interpreted to mean that I

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13 MR. CASE:

It may well turn out to be permanent.

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6 17 l COMMISSIONER AHEARNE:

The horizon isn't beyond that 5

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19 MR. DIRCKS:

That is right.

A 20 COMMISSIONER AHEARNE:

You have put the Commission 21 office as six down there just to highlight the fact that there 22 might be six additional, but you weren' t counting that anywhere?

23l MR. CORNELL:

It is not counted.

We have identified 24 l six individuals.

25 ;

MR. DIRCKS:

It would be nice to have.

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- ALDERSOMREPORTING COM P ANY. INC.

49 1

COMMISSIONER GILINSKY:

Which offices are you talking 1

about?

3 MR. DIRCKS:

We have it.

Three, ACRS, OPE and SECY.

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4 COMMISSIONER GILINSKY:

Have you talked to them at all?

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MR. DENTON:

Yes.

In general, they all feel they are M9 3

6l necessary to support the accelerated schedules.

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7l COMMISSIONER AHEARNE:

To an extent,.they cm make a K

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It might also work the other io 10 way.

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19 transferring back to us.

A 20 COMMISSIONER AHEARNE:

I see.

So, really it is a 21 skill question.

22 MR. DENTON:

Yes.

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23 COMMISSIONER AHEARNE:

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50 1

found in research to transfer in?

2 MR. DENTON:

Yes.

And we are maintaining the generic 3

issues branch as it was.

I don't plan to change that.

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I notice that you talked about da 9

doing away with the operating experience evaluation branch, but Y

10 on your chart you had transferring the work out of the division El 11 of licensing, and I wasn't sure which branch you then were talking j

11 about.

You have an operator reactors assessment branch in the 5

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I think that is a misnomer on the chart.

2 15 It is the one that was put into the division of safety 16 technology.

It has always been a small branch that interfaces j

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21 COMMISSIONER AHEARNE:

I can recall back sometime ago 22 when the Commission addressed putting in place the AEOD's office, 23,

and the argument about do you need these kinds of branches in the 24 divisions, and I guess I would encourage the chairman and the EDO 25l to perhaps take a look also at where else that was built into the i

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ALDERSON RE_ PORTING COMPANY, IN_C,

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I structure and there might be some people who could similarly be

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2 transferred into this kind of an operation, and we might face the 3

point that the AEOD's office is really where that ought to be 4

done, and you need not have this other one.

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You then had a chart, summary of dd 9

work undertaken by I&E for NRR, and it wasn't clear whether that Y

10 was counted in your -- when I looked back at your assistance from i

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y 12 MR. DIRCKS:

I think Kevin can take you through this.

=3 13 MR. CORNELL:

There are some mathematical errors.

One, a

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$j 15 look on 3-D, the first item there, NRR over the past has j

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I&E, or being freed up by NRR.

But if you discount that item, M

20 the other difference between 3-C and 3-D has to do with whether 21 you are talking staff here as professional years.

On 3-C wo 12 are talking about the number of professionals freed up in NRR.

23 On 3-D, we are talking about the number of staff years that it 24 would take I&E to pick up that work, which is why the numbers 25 i don't add up.

O i

ALDERSOM REPORTING COM P ANY, INC,

52 1

COMMISSIONER AHEARNE:

I see.

And then one way of 2

interpreting that is ---

3 MR. CORNELL:

It is less efficient to trans fer it over.

4 COMMISSIONER AHEARNE:

Okay.

Now, when you talk about

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I wasn't so much talking about 3

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It is that when you transfer -- usually when you have

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Let me finish what I was going to say.

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18 number of professional work.

m 19 l COMMISSIONER AHEARNE:

Well, my concern is, have you R

20 taken into account the fact it still is going to require NRR 21 people to monitor that fairly closely to get good products?

22 :

MR. DENTON:

Yes.

We did find that in farming work out, I

23 !

the. gain wasn' t as big as j ust transferring-it.

We had to 24 '

continue the surveillance and oversight, and we have accounted 25 for that.

'4 hat we envision in that area, if we pick the first t

ALDERSON REPORTING COMPANY,INC,

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53 1

opticn of laboratory assistance, would be to pick a lab that has 2

enough people in the electrical power systems, instrumentation, 3

thermal transfer areas -- those 1 ing the most severely critical i

skills in the agency -- and gEhe them a substantial number cf the 4

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COMMISSIONER AHEARNE:

But the basic philosophy, our Z

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I have budgeted on the assumption we will 14 have to assign a person there for the technical oversight of the 2

15 activity.

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Actually out to the lab?

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17 MR. DENTON:

Yes.

That would work if we can get a i

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19 l COMMISSIONER AHEARNE:

In your affected program list, n

20 where you talk about less than six months delay, two to three 21 months delay, that is a kind of f1 te tuning ---

22 MR. DIRCKS:

Again, it is just putting sene bounds 23,

around it.

It certainly is not a commitment to do this one way 24 !

or the other, in one month or two months.

f 25,

COMMISSIONER AHEARNE:

Just as an example, so I can ALDERSON REPORTING COMPANY. INC.

54 1

I unde" stand, in the waste management area, as you described the 2

reason for the delay is because they have some hydrology,ceople 3

short in the agency.

You are goin6 to take those people out and

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Yes.

An 8

6 COMMISSIONER AHEARNE:

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11 MR. DIRCKS:

I think you have to look at the initial j

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We are still going to be trying 5

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15 area that John Davis has, for example.

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16 MR. MINOGUE:

Could I add to that, there is also the e

d 17 l assumption that a number of reg guides sirply are not done.

So, 5

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X 20 Further on, if I could comment on something earlier, 21 the six months that occurs so frequently is based on the 22 assumption that we will, in research, in effect delegate some of 23,

the followup programs to either consulting firms or to 24f laboratory staff, and there is about a Jix month transition as 25 ?

some of that occurs.

I ALDERSON REPORT!NGIOMPANL INC.

55 1

COMMISSIONER AHEARNE:

And that you will be able to get 2

the money to do that.

i 3

MR. MONOGUE:

Yes, that is right.

The source of that

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So, the big impact will be 3l 11 relatively short range.

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12 COMMISSIONER AHEARNE:

Now, we get to NRR deferred i

5 13 programs, and you have a whole list of 18 month deferrals.

.Would l

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15 resources that you hope to put on those programs will not be on g

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how this whole process begins to unfold?

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Yes, that is correct.

It goes to the 21 question you had asked earlier about suppose the Commission is 22 successful in cutting the licensing time in half again.

It does 23 seem to me, it makes some sense to get on with a big effort at 24 the beginning, to try to get ahead of the game, and if we find f

25,

that we are actually producing SER's and decisions ahead of need, I

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56 0

i 1 1 then would be the time to scale back and cut back on the 2

deferrals.

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COMMISSIONER AHEARNE:

Now, on your last chart you have 4

three million dollars in FYS1 research as being possible sources.

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here, or reprogram.

Is that the same monies you were talking R

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No.

That money was part of an entirely I

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COMMISSIONER AHEARNE:

I guess three final questions.

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If you look at this, it appears, and I am saying

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21 !

Is that a judgment that it is not as important as previously had 1

22 l been described?

23 MR. DIRCKS:

If you look at the numbers of staff years 4

24 l here, we have one and two; Steve says it is closer to five and 25 six.

I think what he is doing, and I don't know whether he is i

ALDERSON REPORTING COMPANY. INC.

57 1

doing it or not, is multiplying it by two, that number of people

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over two years.

3 I think the list is long, and I think it has a lot of e

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I think the emphasis, there is still a heavy g

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It is still a high priority in NRR.

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7 is a list of items here that may look worse than the number of 3l 8

people we are talking about.

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I guess compared to pre TMI times, we ieg 10 didn't have such a division.

We had only a very few people, we E

j 11 didn't have any psychologists.

Now we have a division of some y

12 60 or more people, and we have a ceiling th'at would permit Steve E

13 ;

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So, we are putting a considerable amount of effort g

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residual items that were in the action plan for further studies, g

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doing the first wave efforte entirely.

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19 as we could reasonably do to gain casework, this is how far we n

i 20 did it, and there were a lot of things that we did not put on the 21 deferral list that are going to get done.

22,

We just didn't make up a list of those, the things that l

23 we are not deferring.

24 COMMISSIONER AHEARNE:

A second question, one of the 25 i results of this will be we will be putting in a substantial I

l l

ALDERSON REPORTING COMP AN f. INC.

58' I

amount of additional resources into the NRR casework process.

l 2 l There has to be a question raised at some point, and so what would 3

the answer be, that in the past part of the problem that we have 4

had is that the resources we have allocated have not been g

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within the NRR organization?

What confidence do we have putting R

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but to have better tracking system or are you handling your d

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resources in a different way?

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so they 2

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17 COMMISSIONER AHEARNE:

For my final question, I assume s

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that in making this proposal that it is the j udgment then of the 5

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20 impact, unwise, imprudent impact upon the overall safety of what 21 we regulate by doing this?

22.

In other words, another way of saying it is that if we D

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accept this, we aren't then crossing the boundary on the 24 f adequate protection of public health and safety of either l

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operating plants or as we see downstream.

I am making that i

l ALDERSON REPORTING COMPANYe INC, I

59 1

assumption.

If it is wrong, tell me.

But the question is, are

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office directors?

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4 MR. DIRCKS:

I think as you defer programs and move 5

people around, you are taking incremental cuts off of approved a

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Harold might disagree, but what we have tried Rg 7

to do is comply with the instructions as best we could and look 8

where we would not cut into the muscle of the safety program.

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Is your answer that, yes, you b

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I am saying it is meeting the requests, E

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I 21 COMMISSIONER AHEARNE:

Are you saying that it is 22 imprudent?

23 COMMISSIONER BRADFORD:

I think he may be saying that l

24l it is up to us.

25 -

CHAIRMAN HENDRIE:

John, you are asking the wrong I

i 1

ALDERSON REPORTING CCLMPANYJNC.

60 I

question.

2 COMMISSIONER AHEARNE:

I beg to differ, Joe.

I am 3

asking the director of NRR, I am asking, in his judgment, does 4

doing this lead to an impact in the either current or future

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Well, you have now asked it in a way

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And I said, I assume the answer 10 is that ne does not think it is unwise.

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I am satisfied with the level of safety

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And I assume that ED0's pccition d

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I agree with Harold, and I think we have M

20 taken a look across the board in the agency.

21 COMMISSIONER AHEARNE:

And my question -- as I said, D

that was my assumption.

The question was, are there any office 23 directors, major office people, who disagree with that?

24 l MR. DIRCKS:

You have got two of them sitting back i

25 !

there.

ALDERSON REPORTING COMPANYM I

l 61 v

1 MR. SMITH:

I don't disagree.

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2 COMMISSIONER AHEARNE:

I assume that they were here for 3

a purpose.

4 MR. DE YOUNG:

We do not disagree.

However, we cannot a

5 defer work.

We are just not going to do it.

Once you pass by b

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Two inspections in '83 don't make Y

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Absolutely.

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But I see in here, though, that 5

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The impa:t that we read is nine people, 2

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This comes from wcrk which you i

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Yes.

22 COMMISSIONER GILINSKY:

Rather than people moving over s

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24 I MR. DE YOUNG:

We are not moving any people.

l 25,

MR. MINOGUE:

I certainly do not disagree.

I do want to l

ALDERSON REPORTING C OMPANYulNG.

c2 1l make note of one thing.

The impact in research on our ability to i

2! assure the effective efficient use of public funds in these 3

research programs may be impacted.

I think we have worked out

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I hope they work.

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Those are all my questions.

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Peter.

i 10 COMMISSIONRR BRADFORD:

If, in fact, we use the 39 z=

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24 f The way I would like at it is, between now and -- I nave 25 to put in like 138 or 1 0 reactor months of review cn those i,

Al nFRC;ON RE PORTING (~OMP ANY. INC.

63 1

plants in '83 to finish them all 11 months before they are 2

completed, and if you extend them all by four months, I would buy 3

that much more time in the review, so it is maybe a third or a 4

fourth relaxation in the demand for people.

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I would like to raise one word of 5

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After the SSE7 is issued, the staff would have to engage in K]

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If you get that period down to four months, d

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I think we have assumed we will probably E

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I guess what I am getting at is, if you 18 get more time to produce the SSER, you are compacting the amount 5;

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21 CHAIRMAN HENDRIE:

In part, you have got that taken 22 care of ence you go over to single project assignments to 23,

proj ect managers, because if you get a poor proj ect manager that 24 l 1s trying to draft testimony for two projects at the same time, 25,

then you have got a real problem on your hands.

l ALDERSON REPORTING COMPANY. INC.

1

64 1

COMMISSIONER BRADFORD:

For purposes of this reallocatiert 2

what, then, happens as you look out toward 1984 and 19857 Are 3

there another 10 or 12 plants per year in each of those years 4

that would require essentially a continuation of this pattern?

5 Jr do you then go back and pick up the deferred work to a greater 5

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degree?

7 MR. DIRCKS:

As we get out there, the numbers decrease.

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COMMISSIONER BRADFORD:

The number of plants decrease?

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It stays high, I think, for maybe '84, and i

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5 13 COMMISSIONER BRADFORD:

All the plants are essentially 8

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2 15 MRi DENTON:

I have that data but I just don't ecall.

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all those plants are now coming in on us, and I had that in some E

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I just don't have them with me.

It is a few E

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M 20 COMMISSIONER AHEARNE:

There are about 80 that have to 21 b e' picked up.

22 MR. DENTON:

Yes.

23 ;

COMMISSIONER AHEARNE:

That is enough to run you four or

'24 five years.

25 '

CHAIRMAN HENDRIE: _ You had some graphs before that l

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65 1

showed the incoming OL's begin to taper down after what, '85 or 2

something like that, and then you have got the bulk of them, I 3

think, in hand, and then sort of the latecomers are straggling 4

in at scmewhere between two and five a year, and then eventually l

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So, I think the level of effort on casework n

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10 COMMISSIONER BRADFORD:

I don't have any other questions 11 I do j ust want to indicate that I am not comfortable with the l

I 11 full package.

I realize that you made a judgment that it doesn't

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23!

That is the program taken as a whole.

It doesn't mean that 24 there aren't some parts of it that would be acceptable.

25 ;.

CHAIRMAN HENDRIE:

Vic, do you have some questions?

i i

1 ALDERSON REPORTING COMP ANY. INC.

66 1

COMMISSIONER GILINSKY:

For these OL reviews, what sort l

1 2

of manyear figure are you assuming?

And how does that compare 3

with what we used to apply to OL reviews in the pre TMI?

4 MR. DENTON:

We don' t have a specific figure in mind.

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16 COMMISSIONER GILINSKY:

But you havan't added it up in w

d 17 I terms of manyears?

18 MR. DENTON:

No.

5 19 COMMISSIONER GILINSKY:

Do you have any feeling for it?

R 20 Is it a heftier review than we conducted in the past?

21 MR. DENTON:

Oh, yes.

22 MR. CASE:

I would guess about 20 if you did it that 23,

way.

24 COMMISSIONER GILINSKY:

So, roughly double.

25f MR. CASE:

Well, it crept up to maybe 14, I believe.

i Al MFDRON REPORTING CnM P ANY INF

67 1

MR. DENTON:

The review certainly has expanded in a 2

number of areas as a result of TMI and all the TMI action plan 3

items.

So, the SER's are bigger, and areas like fire protection, 4

equipment review, emergency planning have all added to that.

So, e

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More than it used to be?

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Yes.

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10 CHAIRMAN HENDRIE:

Also, the hearings at the OL stage, 5

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14 COMMISSIONER GILINSKY:

If you do develop an estimate, 2

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16 I want to get back to the point that Peter raised and 3

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It seems M

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sending armies out in various directions, to be pretty clear what i

25l problem it is we are dealing with.

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68 1

What I was wondering about is, in particular, who comes

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And also, what does it assume?

3 You were talking about our predictions becoming.self-fulfilling.

4 Is that factored into the 39 months, or is that based on simply e

5 the ability of the utility to complete the plant irrespective h

8 6

of our process?

e R

R 7

MR. DENTON:

Let me tell you how I got the first A

8 8

estimates.

I went to. the blue book that was published in n

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9 December, and assumed that we produced our document as the Yg 10 December blue book schedule called for, thac we met that El 11 completely.

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12 I added onto that a 15 month hearing process.

This was z

t' 5

13 the way -I originally approached the problem.

Then I compared g

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14 those dates that would result from a decision, assuming we met 5

2 15 the blue book, and assuming 15 months, to the applicant's date 5

g 16 and to the NRC's caseload forecasting date, w

y 17 i They are the ones that came out about 130 reactor 5

18 months of delay using the applicants' dates, and about 60 or so A

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19 months using our dates.

M 20 Then when we were asked to assume an 11 month review, 21 I went back and, taking into account some rejuggling of 22 priorities-<ni cases that had occurred since we move some plants 23 up and some back, like: Fermi and Waterford, to adj ust the plants, 1

24 i I went through that again assuming the 11 month hearing process, 25 and then compared the dates to the applicants' dates and our ALDERSON REP _ORTING COMPANY. INC,

69 1

dates, and that is where the numbers came from on the first

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2 slide.

3 COMMISSIONER GILINSKY:

I understand that.

I guess I

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4 shouldn't have asked about the 39 months.

What I really mean is, a

5 how do we come up with the NRC estimate on when the plant will be b

6 completed, and who does that, and what assumptions factor into R

R 7

that?

Xl 8

MR. DIRCKS:

I think we have a caseload forecast panel dd 9

that does this.

They actually visit plants.

They actually have i

h 10 some sort of a model that they compare the status of construction 3

5 11 against, and they nake an estimate.

They have been fairly L

d 12 active.

I think they visit these plants a year before, two E=

j-13 years, I have forgotten.

It is in Norm Haller's g"oup, and it is

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l 14 headed up by someone who has been doing this for years.

2 15 CHAIRMAN HENDRIE:

I will comment that those dates that g.

1 g

16 we have produced in the past, they used to appear in the gray w

17 book, do we still publish a gray book, or do we?

I have lost

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5 18 track of the colors.

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19 MR. DIRCKS:

We have a brown book now.

l A

20 CHAIRMAN HENDRIE:

Anyway, those dates have always been 21 subjects of discussion and occasionally agony where, from the i

22 utility side, they feel they are having difficulty keeping their 23,

people hard at it when there is an NRC date floating around which

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24 has slipped six months from their project date.

25,

Now, in private conversations, why, their engineers l

l a

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70 I

will tell you that they indeed are going to have slippage in the

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2 schedule that they have got, b ut they feel they have to keep it 3

posted up on the wall and keep driving everybody forward on that i

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4 basis as long as they possibly can, just to prevent a general

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relaxation and much greater slippage.

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6 sort of general problem in scheduling of human endeavors, and R

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But if now we are going to look at some dates for the d

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kind of purpose we have here where the amount of impact on other i

h 10 work in the agency goes up or down, depending on how you choose j

11 those dates, then I think they have to be looked at with some n

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12 care.

5 j

13 At least one of our congressional committees will

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2 15 I guess other committees will want to know how we stand against a

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16 our proj'ected dates.

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17 It seems to me that it might be useful, since we are 18 at a fairly sensitive balance point here, tc review some of these A

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19 dates with the proj ects out there, pointing out to them that it a

20 is not going to be a help to anybody if unrealistic dates 21 persist out there.

But I think we also have to recognize that 22 you can't -- if the nroj ect manager on any kind of project 23 always keeps telling his people every morning his current 24 estimate, personal best estimate is of how the project is going 25,

to come out, he.is never going to get it finished.

And, you kn3w, t

Al flEDGAM 9FDADT lM PAblD A MY INF

71 1 l as a professional in that kind of line over the years, why, you 2

have to keep driving, and you always are aware that, by george, 3

that thing you are driving for may slip a little bit, but if you 4

don't keep driving on it, why, the slippage will be infinite and e

5 you will never get there.

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6i COMMISSIONER GILINSKY:

Well, that is his point of view.

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7 He has responsibilities to build a plant, and that is the way he Ml 8

has got to do it.

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CHAIRMAN HENDRIE:

But I think in conducting an ieg 10 improved analysis of our best dates that we ought to be very 3

E 11 careful that in selecting those we are not, you know, in effect

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12 providing a feedback slippage and an incentive for it.

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y 13 l the purposes of this exercise, why, I think some discussion with

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the projects out there'would be useful.

Among other reasons, it 2

15 hasn't -- we haven't talked to all of the projects, the near g

j 16 term proj ects or the '83 projects recently.

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17 i I know in at least one case some of the informal w

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21 !

says, look, you know, you are j ust killing me with this stuff, l

22 !

it doesn't apply to what I a.n doing now and it doesn't apply to f

23 l the plans I have got before the management and legislatures and 24 !

everything else, and for you to publish things which reflect your i

25,

view as of a year or 18 montns ago is doing me, the project and i

i ALGERMON REPORTING COMP ANY INC

l 72 1

probably yourselves considerable disservice.

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2 So, I think some updating on those things and some 3

discussion is ---

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4 COMMISSIONER AHEARNE:

Some of it had bean done, and a e

5 lot of the model still is based on how much of the construction U

j 6,

is completed.

And when the project manager says it is hurting Rg 7

your people to say that the proj ect is only 80 percent completed, s

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if it is only 80 percent completed, that is a critical element d

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to know.

10 00MMISSIONER GILINSKY:

'dhat bothers me in the way we Ej 11 have gone about this is that we seem to be saying that our k

j 12 estimates are worth nothing.

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13 MR. DENTON:

No.

The reason we went to our estimates E

l 14 was we found that scheduling by their estimates was not a 2

15 reliable indicator of priorities.

And when we were reasonably w

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l 6

17 by our estimates.

It is a key assumption, and it goes both ways.

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18 There is some doubt about our ability to produce SER's and

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19 decisions even though we set this as our goal, that there may be R

20 some slippages here and there for unanticipated problems.

21 So, if you really want to get off the critical path 22 cleanly, so that we are not accused of the delay, it seems best 23 '

to schedule on their construction schedule.

Otherwis e, we have 24 l got situations like St. Lucie where they say they are going to be I

25l finished the end of next year, and they have got the money and the i

ALDERSON REPORTING COMP ANY. INC.

l 73 1

ccats and they have got management support and so forth.

We 2

don't think they are going to make it.

l 3

COMMISSIONER GILINSKY:

You have got the opposite c

l 4

problem, you don't have a realistic schedule on the SER's.

5 MR. DENTON:

But St. Lucie being an example that if we e

Aa I

go to our schedule on St. Lucie, they will be in here talking to 3

6 I e

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you about why we are not scheduling them higher up on the A

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priority list.

So, it eliminates me having to go through a lot n

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9 of' turmoil trying to see exactly when are they going to be z

h 10 finished.

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11 So, if we are within two or three or four or five d

12 months of the applicant's estimate, I am taking that.

3cd 13 COMMISSIONER GILINSKY:

Five months across the board, S

E 14 that is a fairly hefty chunk.

Eu 2

15 COMMISSIONER BRADFORD:

All this could work fairly f

16 well at a time when you didn't have congressional committees i

d 17 using this as a measure of how many billions of dollars we were 5

5 18 damaging the nation by and how many barrels of oil we were 5

E 19 draining from the Middle East.

But if the committees are going 20 to behave that way, and then they are going to use the licensee's 21 schedules as the basis for doing it, then we have got to have 22 more accurate information as to when the plants will really be i

23l finished, because it is no fault of your, obviously, but there is i

24 i no point in just sitting there being gratuitously shillelaghed 25 j about with a lot of numbers that bear no relation to the real i

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74 i

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world.

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MR. DENTON:

And so I fully expect a lot of slippages f

3 in these applicants' dates, and I tried to propose a program that 4

would just get us off the critical path.

I recognize that it may, e

5 in some instances, not have to go this far.

En 8

6 COMMISSIONER AHEARNE:

It is also a hedge that we don't R

R 7

get the improvement in the time of the licensing process, and we s

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ought to always on this side keep in mind that we are facing a dd 9

situation that starts with a plant being reviewed and ends with h

10 a license.

And I think there are varied levels of pain amongst E

5 11 us on which points we prefer to see give, but there is going to g

12 b e pain somewhere, and we are trying to minimize it, I think.

5 I think we started off by saying that y

13 MR. DIRCKS:

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There is uncertainty in our 5

9 15 estimates, in construction estimates, and the estimates that the g

g 16 hearing process is -- how long that is going to take, and what w

17 :

impact tha*, is going to bring back on the staff.

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e the best estimate we could do, and we were also looking to

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fulfill the assignment that you gave us to provide you 21 information to answer the letter that I guess is due this week 22 back to the appropriations committee.

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- 23 CHAIRMAN HENDRIE:

Let me prcpose something in hopes 24 l that we'can get some useful' things at least started, rather than 25; having to return totally to the subj ect.

i

75 I !

We have some concern about whether we ought to be 2

working this program, this staff program, totally against the 3

present set of applicants, finished numbers.

That raises the 4

ante in terms of impacts, in other words.

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On the other hand, if we base it solely on the present E

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set of staff proj ections for completion, that certainly helps the R

7 impact problem a lot, but it may lead us on reevaluation in a few A]

8 months to going back and reporting that once again we are going.

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9 to have to either rejuggle things or we have got impacts that are zo 10 going to appear down the line.

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l 14 projects and some taking into account of what the proj ects 2

15 j currently are able to tell us about their plans, programs,

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d 17 i comfort that we have in either their dates or our dates as a M

I 18 l planning basis.

I think that effort could usefully begin and E

3 19 lj go forward.

5 20 While it goes forward, and starting now, in order that i

21 :

we could be making some motions, I think the following proposition 22 is clear:

Whether we believe that the apparent impact is 90 x

23; reactor months or the apparent impact is 40 reactor months, the 24 long term plants, the ' 83 and beyond plants, thehe is clearly 25 going to be a problem there unless we begin now to take some i

Al nFERAN QFPnDTINt" rnMD A NY INF i

l 76 I

I steps.

2 What I would propose we do from this side of the table 3

is to agree that the staff should begin to move forward along the 4

lines of the proposition here, not carrying it all the way,

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8 half of that, that is the 40 months.

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h 10 propositions that we have in hand.

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11 You based the present proposition on applicants' d

11 construction completion dates and on the 11 month hearing and Z

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We have yet to carry out all the 5

l 14 steps to accomplish -- you know, to put us in a position where 2

15 we think we are reasonably accomplishing in most cases the 11 g

j 16 month hearing and Commission review process.

If we did better w

g 17 j there, it is clearly a benefit in terms of your problems.

If we w=

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E 19 problem.

A 20 What I am saying is that not all of the pieces of this 21 overall program have fallen into place, but we are taking some 22,

steps in that area, and I think it would be reasonable to take i

23 !

some steps in the staff reallocation area, and I think I would 24l leave it to you to j udge in which sequence they come.

That is, l

25,

I think there are some things you are going to have to do even if i

--- ALDEEL8EOM 95"PORTlMC COME3 AMY IMF

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77 1,

you decide that the potential downstream impact is, you know, only l

2l a small number, 20 reactor months or something like that.

There 3

are still some things you would want to do to correct that.

I 4

suggest you start taking these steps and sort of begin to work e

5 toward halfway up the line at any rate, and we will continue 3a 6

these discussions and hopefully improve estimates, better R

7 understanding and, in effect, complete the decision process.

M j

8 Would that be acceptable on this side of the table?

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9 COMMISSIONER BRADFORD:

I agree with the general thrust Y

10 of it.

But I would focus their short term efforts, until we E

5 11 really are prepared to approve a package, perhaps on items 2, 5

y 12 and 7 on their page 2 that seem relatively harmless.

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13 l I would specifically not want the other projects to m

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15 we really have decided on what our overall licensing reform, N

g 16 internal staff reallocation, congressional legislation package d

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5 18 CHAIRMAN HENDRIE:

Peter, I think it is useful to 5

19,

identify some of these areas which appear to have clearly less 2

20 impact.

Let's not make an absolute rule about the proj ect 21 deferrals, because I really think there are some areas overall in 22 the assorted things that NRR has cited that are of considerably 23 i less real safety impact than others, and rather than just say 24 no, none of it, why, I think I would be willing to let Harold 25 l move on a few of those items at any rate.

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-.--- ALDERSON IGERORTING COMPANY INF

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COMMISSIONER BRADFORD:

I would want to know which ones 2

they were in advance, though.

It may well be that I would come to 3

agree with you on it, Joe, but I would want to know specifically 4

which ones he was going to defer.

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5 MR. DENTON:

I would guess the main thing we need is to 5

6 get the project managers assigned to some of these plants in '83, R

7 and maybe get a little better feeling for where it all stands.

A l

8 That is one of our present handicaps, just not having that done.

dd 9

CHAIRMAN HENDRIE:

I think you certainly ought to do i

og 10 that.

That puts a responsible staff officer at work worrying i

j 11 about where the proj ect is, where the renew is, where the hearing y

12 process is, and it would help.

5 13 Now, to the extent that to staff your proj ect managers l

14 you begin to implement some of the deferrals you have talked 2

15 about, why, Commissioner Bradford would like to know what you j

16 have got in mind before you get it all cast in concrete, what w

6 17 those particular deferrals seem to mean in the overall context.

5 18 COMMISSIONER GILINSKY:

One thing I would like to know 5{

19 is, to what extent do these changes involve or affect any n

20 specific commitments we have made, as opposed to simply changes 21 in programs-and outlines?

Do you have any feeling for that.

Are 22 there such items involved here?

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23l MR. DENTON:

I guess the action plan comes the closest 24' in terms of commitment, Commissio.. commitment, or publicly stated 25l commitment.

ALDERSON REPORTING COMPANY, INC.

79 1

CHAIRMAN HENDRIE:

I don't think there is anything with 2

specific dates that are now changing.

3 John?

4 COMMISSIONER AHEARNE:

My comments, I guess first I g

5 think what we are seeing is basically a budget review, which had

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6 we all been smarter we would have been doing this last fall, R

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7' because it is essentially, given an envelope of resources where j

8 do you put your efforts.

And I think had we seen this problem d

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last fall, we would have been going through just this process.

@ 10 So, I don't have any basic problem with that.

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11 I think we are probably, as we swung the pendulum one 3

y 12 way, we are now swinging it a little bit the other way.

The 3

y la dates probably aren't going to be as big an impact, and the

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2 15 probably has to be done.

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16 My concerns, which I leave really to the Chairman, to

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17 the EDO and to the director of NRR, are this question of the 18 management control over the shift of resources.

A rapid shift 5

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19 of resources requires an even greater level of management control n

20 than a more slow growth.

21 As far as I am concerned, the only exception I would 22 take to the proposals that you have in here is, I would not go 23 for the deferral of the SEP.

I think that that has too many --

24 that ~ 1t is plugged into too many places and canceling it j ust 25 ;

leads, I think, to a host of problems.

i L

80 1

Then finally, I would urge my colleagues, this

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2 reiterates the need for having a good policy, plann.5

' and 3

programning document that we can put in place.

4 CHAIRMAN HENDRIE:

He manages to hang that thing on e

5 everything we do.

John, I admire you ability to push.

3 N

8 6

MR. DIRCKS:

What I=was trying to do when we got into e

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7 this was put a bound around the whole problem.

We were offering 8

8 up some of these projects as not locked in concrete.

I don't l

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10 proj ect by project deferrals or speed-up or what.

3 5

11 CHAIRMAN HENDRIE:

No.

Peter, as you get to the point d

12 where you are taking this step of pushing things off in NRR, z

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13 particularly the safety related work, why, he would like a chance E

E 14 to hear what it is and so on.

I don't read that as we are going Nz I

15 to have a series of informal Commission meetings and pontificate x=

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p171 proposition.

That is the way I read it, and since Peter isn't ax 5

18 here, why, my reading at least for the moment, I think, has 5

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  • 19 :

precedent.

R 20 A couple of comments.

21 One of the things which we, as Vic has commented to 22 me, one of the assumptions that we always make and I always used 23 to.make when I was doing these exercises was that along comes a 24_

new job and you start out with the assumption that all of the 25!

people you have got-in your shop, whether it is 600 or 3,000, are L'

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working at precisely 100 percent efficiency.

They are fully 2

effective, they have no spare time, they are fully utill ed, 3

every person.

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5 introduced into the shop must have a corresponding impact en that N

other work which was going on.

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8, make it, and I don't propose that you do any different.

But we a

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utilization, and that inevitably a certain amount of the impact

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12 of reallocations of the kind we contemplate here at least have the z=

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through the organization, at the sub chiefs and then the working w

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level, it doesn't create the impression that this is Siberia and 3^

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it is, you know, a work prison, but rather the sense that it is x

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18 an important j ob in One public interest and it is a new

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challenge, and let us see what we can do to get in there and meet x

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i 20 j the challenge.

21 Okay, the second item I would like to comment on.

I am l

22,

not going to give you a chance to rebut to these, by the way.

i 23 i The second item.

With regard to the freeze, my view

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is that the freeze for this agency is now off, and that we go to I

25 '

the CM3 agreed numbers.

The fact that I don't have in my hands I

i AL DERMON RFPt3RTING COMP ANY INC.

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82 i

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the letter, I see no reason to impede going forward and calling l

2 l the people with the offers out and moving ahead.

3 And if the letter hasn't turned up by the end of the 4

week, why, please call our friends at the great OMB and tell them e

5 that is what we are doing, and if they don't like that, why, they An 8

6l can say so.

E 7l The third things is, how quick, out of all of this j

8 array, how quick can we get up an interim hydrogen rule?

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Rather than answering, why don' t you make a note, and when you i

O 10 go back, why, ask the interim hydrogen rule people.

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E 11 MR. CASE:

The existing one final?

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12 CHAIRMAN HENDRIE:

This would be the proposed final z

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13 rule, the proposed final interim hydrogen control rule.

We have E

E 14 got at least one care in which the publication of that would have de 2

15 an inspiring effect.

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16 MR. SMITH:

I believe it is due to the EDO before the 3

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i 17 i end of March.

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18 CHAIRMAN HENDRIE:

No, no.

This is the proposed E

I 19 ;

final rule.

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20 !

MR. DIRCKS:

Before the end of March.

21 COMMISSIONER GILINSKY:

It will be the final?

i 22 !

CHAIRMAN HENDRIE:

When we publish it, it is final.

23,

When they get it up, it is the proposed final.

It can't be 24 l final until it is published.

25 '

COMMISSIONER AHEARNE:

Unless you are willing to ALDERSON REPORTING COMP ANL INC.

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I change your previous vote on delegation of authority.

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CHAIRMAN HENDRIE:

Okhv.

I have kept you overlong.

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3 thank you all.

2 i

4 (Whereupon, at 12: 30 p.

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the meeting was i

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concluded.)

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NUCLEAR REGULATORY CO.*dMISSION This is to certify that the accached proceedings before the Nuclear Regulatory Comission in the matter of:

Discussion of Revised Licensing Procedures Date of ?roceeding:

March 11,1981 Dockee Number:

Place of ?roceeding: Room 1130, 1717 H St.,N.W., Washington, D.C.

were held as herein appesrs, and that this is the Original transcript thereof for the file of the. Ccanission.,

l Marilynn M. Nations Official Reporter (Typed)

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l Official Repcrter (signature) t i

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