Text

Transcript of 810430 Meeting in Washington,Dc Re Proposed Rule on OL Applications & Interim Amends on Hydrogen Control.Pp 1-43
	ML20003J223
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Issue date:	04/30/1981
From:	; NRC COMMISSION (OCM)
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References
	REF-10CFR9.7 SECY-81-246, NUDOCS 8105110059
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5 NUCLEAR RZtaLT.ATOR'f CCMMISSION C,

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COMMISSION MEETING, I

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PROPOSED RULF. ON OL APPLICATIONS ~AND f'I/W 0 G 1984 $

"*8 INTERIM AMENDMENTS ON HYDROGEN QONTROL

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April 30, 1981 PAGzr:

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Washington, D. C.

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,YIONS:1p 1l UNITED STATES OF AMERICA 2

NUCLEAR REGULATORY COM! FISSION 3

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PROPOSED RULE ON OL APPLICATIONS AND e

5' INTERIM AMENDMENTS ON HYDROGEN CONTROL j

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Nuclear Regulatory Commission Conference Room 1130

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8 1717 H Street, N.W.

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Washington, D.C.

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I Thursday, April 30, 1981 g

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

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12 l JOSEPH M. HENDRIE, Chairman, presiding.

Ei 13 PRESENT:

E 14 l JOSEPH M. HENDRIE, Chairman t:

VICTOR GILINSKY, Commissioner 15 l PETER A.

BRADFORD, Commissioner 5

l JOHN F. AHEARNE, Commissioner j

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/.LSO PRSSENT:

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SMfUEL CHILK HOWARD SHAPAR E

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WILLIAM J. DIRCKS ED CASE E

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LEONARD BICKNIT Gr.T CUNNINGHAM E

19 DARRELL EISENHUT ROGER MATTSON 5

l ROBERT PURPLE MORTON FLEISHMAN 20 l i

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CHAIRMAN HENDRIE:

Good morning.

The Commission meets 3

this morning to consider a proposed rule on operating license 4i applications.

The paper is SECY-81-246.

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This is a rewrite of the operating license requirements M

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6.l of NUREG-0737 into rule form, done on direction of the e

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8 7l Commission some weeks ago so that the Commission could consider n

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8l whether it wants to see those requirements upgraded from staff d

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9; guidance to regulations.

Some of us thought that was a good i

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10 l idea and some did not the last time around.

z 11 l The schedule also suggests that we will discuss the i

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d 12 proposed interim rule on hydrogen control.

The paper is z

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d 13 81-245.

It is my intention not to talk about hydrogen control s

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14 other than in the sense that the proposed hydrogen control rule zt as it came up a week ago had in it eight or ten or some such

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number of items which also appear in today's rule, 246, and p

17 which in my mind were only peripheral to hydrogen control and

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which I would propose to treat in context of the OL list and I

i 19 e not the hydrogen rule.

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I do not propose that we talk about hydrogen control 21 per se today.

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.i 22j COMMISSIONER GILINSKY:

Could you remind me how we I

23; left the hydrogen rule?

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I COMMISSIONER AHEARNE:

With pu::lenent.

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25l CHAIRMAN HENDRIE:

There were considerabI2 questions i

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'i ALDERSON REPORTING COMPANYe INC.

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and discussions.

Where it stands at the moment is staff is l

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2 l reflecting on it and we had a chat in Bethesda about it a week 3

ago.

There are things which are ongoing in the hydrogen control o

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area.

One of the things which we cannot discuss with the staff 1

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but which is going on and which from their side provides a

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3 6l continuing process of elucidation of problems, promises and e

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7 so on is the McGuire litigation.

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I suggested to the staff that we ought to take another 9l look at it in a few weeks and see what they thought of the i

10l draft language and r,ee if it should come up again or whether 5

5 11 in fact the conclusion is hydrogen control, that the solutions

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are not that well anchored so as to be ready to go into z=

13 regulation form.

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I thought they were after Sequoyah and the N

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15 discussions we had on the CP, construction permit manufacturing 5

f 16 license rule.

I think you felt the same way because we both r

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17 wanted to see a draft rule.

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Af ter last week's discussions, it is not so clear to

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E 19 me that it is ready to be written down in regulation form,. at 5n 20 '

least in a regulation that can simplify things.

.!y impression 21 i was the present draft is not a great help in that regard.

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COMMISSIONER GILINSKY:

Where does this leave

=al aco11 cation or hydrogen control requirements to say DC cook j

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u 24j which is not the subject or a proceeding?

f CHAIRMAN HENDRIE: At the moment, in abeyance. There 25 I

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ALDERSON REPORTING COMPANY, INC.

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1i is no direction to Cook to do one thing or another.

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2' COMMISSIONER AHEARNE: The staff is discussing it.

3 MR. CASi:

Yes, we have asked Cook and are

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4 considering the matter that was taken care of in the Sequoyah l

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case and to propose what they think is appropriate in light of S

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MR. EISENHUT:

They have committed to do that.

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j 8f are coming back to us with a program that I believe is going a

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to be put in the distributing emission system, very similar z;

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E 11 i COMMISSIONER GILINSKY:

You are awaiting their plan?

j 12 l MR. EISENHUT:

I think we may actually have tae

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s 13 plan in.

The proposal may be under review.

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E 14 i CHAIRMAN HENDRIE:

It is not an ordered pre-Lsition.

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t 15 If I was D.C. Cook, I would hustle in with a set of Sequoyah x

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COMMISSIONER AHEARNE:

I think you would also want i

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20j is enough.

5 CHAIRMAN HENDRIE:

I think I would be willing to take 21]

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my chances and say grandfather me, I did the good thing.

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Back to the NUREG-0737 conversion to rule form.

i 24 j We have sone briefing material before us.

There are also some i

25 3 items to ciscuss as we go along.

Do we want to limit it to i

4 ALDERSON REPORTING CO MPANY. INC.

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1; new operating licenses?

There is a basic question and that is j

2i whether we want to pursue making this material into'a rule.

1 3l There was a majority last time I checked.

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4i MR. DIRCKS:

Starting off with the last note, the 5

proposed rule is related only to new operating licenses.

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6 is modeled after the effort we took in the near term 3

7 construction permit rule.

Darrell will go through it.

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j 8l would just like to add my recommendation that we do look at d

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this rule only from the point of view of new operating license 10 j applications and then if you want, we can discuss operating z

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2j 14 COMMISSIONER BRADFORD:

Why is thet?

j 15 MR. DIRCKS:

I think as soon as you get into the E

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16 question of operating reactors, there are a number of i

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17 complications.

You look at schedules, shutdowns, backfits, t

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18 what is done in the past, grandfathering.

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If you take it from a fresh s tandpoint, looking only 20 at new applications, neu OLs, we can at least have the hope of 8,

21) getting a rule out quickly.

I 22 COMMISSIONER BRADFORD:

The new OLs are already built. !

1 23j MR. DIRCKS:

Yes..,but you are not looking at i

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24j shutdowns, when they shut de'wn for power, for refueling and

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1 ALDERSON REPORTING COMPANYo INC.

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We probably are looking a:

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shutdowns.

If the plants are licensed, they will be done, I

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of how conplicated do you want it.

We always face this proble:

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1l flexibility for that and then you have to look at where

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reasonable and what has been committed.

It makes a fairly

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tailored to individual cases, I think it is a whole arena that 7l R

least the first time Bill said he would prefer to avoid.

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around on this rule.

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MR. DIRCKS:

The first time around.

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10 i CHAIRMAN HENDRIE:

We do have to settle the question.

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If you are going to say for new licensees, it is 0737 in order 3

j 12 l to get a license and here is the rule, so do that, we 5

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13 i inevitably have to turn and say, what now for the operating j

14 l reactors.

We h.sve to decide.

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If we are going to alleviate certain requirements j

16 for operating reactors but not others, we are going to have

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Sooner or later we are going to x=

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have to treat the operating reactors side.

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MR. DIRCKS:

We do tend to get tied down in the i

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complexities as we did in the fire protection rule.

I think l

21 if we take it one step at a time, look at this as an OL 22j phase and then come back and take a look at another one i

23 i as an OR phase, we would hopefully get a rule out.

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i 24j COMMISSIONER BRADFORD:

I must say call a spade a l

25 j spade.

It seems to ne a completed plant is a completed plant

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8-1 and the real difference is one set of these plants faces l

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hearings and the rule would help boost them through the 3

hearing process and the other does not face hearings and the 4i rule doesn' t seen as urgent.

5 MR. DIRCKS:

I guess you always face that in any

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All I am trying to do is see if we can R

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accomplish something to s 't a rule out in a fairly reasonable j

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If we go out for comment, you are going to d

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accomplishment, I would like to take a look at this only 5

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13 i in the OL stage and then phase in another one on OR when we ij 14 l come up to bat on that.

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I think the precedent would be set in this rule and 5

g 16 l then we can proceed with a discussion of the OR phase.

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17 COMMISSIONER AHEARNE:

Is anybody prepared to x

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18 address to what extent these provisions have been covered by E

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orders to the operating plants?

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MR. EISENHUT:

I think a lo t cf this will unfold 21 '

as we go through the presentation.

22 CHAIRMAN HENDRIE:

Let's launch the staff on the 23 a p r es ent at ion.

We have several major areas.

One is the content

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24 of the rule itself.

Another one is the question about the ors, 25 the backfitting and how that all works out and then the 3

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question of who will continue to handle it as a staff guidance l

2l proposition.

3 MR. DIRCKS:

Darrell?

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4i MR. EISENHUT:

In the way of background -- may I have l

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5j the first slide?

j 6l (SLIDE.)

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MR. EISENHUT:

We were going to go through some of l

j 8l the pieces and make some of these observations.

d 9i Going to the 737 background item, addressing some of f

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the questions mentioned, 737 was developed about a year ago.

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11j It went out for draft last Summer.

It was irsued in October a

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12 l of 1980.

The 737 document was meant at the time to be a 3

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13 compilation of all items that had been approved to be

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implemented for both ors and OLs.

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j 16 MR. EISENHUT:

This is simply a comparison or l

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really a breaking down.

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i 18 MR. CASE:

Is the applicability to both ors and OLs?

19 j MR.EIS5NHUT:

Yes, in fact, 737 was conceived n

20 I originally as an OR document.

A large number of utilities

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i 21l were constantly asking me daily, I am getting this letter 22 ;

and that letter, it is hard to keep track of what the 23 requirements are.

I had to be very horest, it was very hard 24 for me to keep track of what the requirements were because 25 we were going out with a different generic letter piecemeal.

ALDERSON REP ORTING COMP ANY. INC.

l 10 1 l We conceived to generate and put together in one i

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f 2i document, in tabular form and with a clarification behind it, 1

3 of each item the staff had decided to approve, to be implemented

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4, on operating reactors.

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5i Pretty closely the same set of requirements were 9

l 6l in effect for OLs.

We made it one document to go out to all R

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7 plants.

There was an Enclosure 1 and 2 which were tables.

j 8 is a table for all operating reactors and d

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It sets forth in the table g

10 what the item is, its subparts, the schedule it had to be Ej 11 l implemented on, the plants it was related to.

It also cross 3

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referenced the generic letter that was previously issued i

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14 clarification to the requirement.

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The classic that keeps coming to mind is way back a

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16 year or so ago, we had told utilities to put the pressuri:er A

Th're are a lot of i

17 heaters on a safety related power supply.

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things you have to back up behind that to say how you want

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them to go about doing that.

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For operating reactors, and I guess equally well for I

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21 3 OLs, it identified whether or not we would require a technical a

22 specification to be written on that item.

It also identified 23 when some rules were due.

24 This is sort of a cookbook.

It identified every item 25 that was approved at the time.

ALDERSON REPORTING COMPANY. INC.

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1 CHAIRMAN HENDRIE:

I must say it is useful to have

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2i the clarification because I remembered 0737 in the context that i

i 3l it was the son of 0694 which was the Commission's approved list r~,

4 of requirements for the near term operating licenses and it e

5, was that which we had heavy interest at the time.

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6 HR. EISENHUT:

It is fair to say that the other 7.

7 piece is because of the emphasis on OLs, there is the revised s

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policy state.nent and I think it was last December, 1980.

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9j is important to remember that 737 not only set forth all the i

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items at the time but it set forth all the items and it i

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j 11l recognized 660, the action plan, would be generating changes 3

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_f 13 It was just those that were approved for implementation.

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be additions and changes as time went on for a various number of l E

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reasons.

It was the staff's best judgment at the time and l

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3 17 over that last year, there has been a considerable number of j

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18 1 reports that have been submitted from utilities reflecting i

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3 19 j on the requirements and the technical substance in 737.

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20 i has been considerable feedback on some of the items.

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21 staff has been reconsidering some of those requirements.

22 You will recall that we had a discussion April 1st 23 on the first wave of orders to be issued to operating reactors, 24 covering the items on this chart which just shows the 25 relationship between those items in here that affect ors and ALDERSON REPORTING COMPANY. INC.

4 12 1:

OLs.

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You will recall a large number of those items as 3

one set in the first six month period of this year, that is,

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4 those items that had implementation dates of requirements i

5; between January 1, 1981 and June 30, 1981, most of th 'se were e

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in the form of a report that had to be supplied to the staff.

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We required a technical evaluation from the industry.

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8' We required it of every operating reactor.

We were requiring e

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10 i I believe it was around 30 technical reports that z

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11 j are due from all plants in this first six month period.

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The staff is reviewing those reports and it leads

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the staff to conclude in some cases that the reports are 1

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conclude in some cases that additional action may be necessary.

E 17 It is really a subset of where there is a follow up to 737 N

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19 (SLIDE.)

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.MR. EISENHUT:

The staff has put together a document

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which took the 737 items, it was meant to take the 737 items 3

22 '

and transform those that relate to OLs into rule form.

That 23 cocument that the Chairman mentioned is in SECY-31-246.

It is a document we sent down a week or so ago.

24 25 There were actually some corrections to the document ALDERSOM REPORTifMG COMPMS% ONC<

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1I we set down, to make it more closely follow 737.

It is our I

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intent that the document before you with there erata are in 3

fact essentially identical to 737 It was meant to be identical 4,

to 737 with these corrections.

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There were some items that were inadvertedly left s

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out.

We refined five items to make them more closely reflect e

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7 the words in 737 i

%j 8j The rule before you for OLs includes the nine items e

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that we discussed last week in connection with the interim 7.

10 l hydrogen rule.

You will recall there were nine items that 3

5 11 i had an 0737 indication next to them.

Those were included when B

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12 we sent the rule down.

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13 The rule follows the short form, as I call it, similar i

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5 14 to what we did in the CP rule, that is, we tried to take the l

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15 essence of the real requirement of the items from 73? and l

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transform them into this rule.

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17 Concerning the schedules in this proposed rule, 5

18 they are identical to what is in 737 for OLs.

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19 MR. CASE:

Which the Commission previously approved, n

i 20j those approved schedules.

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MR. EISENHUT:

Yes.

There is no change in that.

2 22 -

There are some of those items that we have had l

l 23,

considerable discussion off and on about how close are they 24 going to be.

We came to two conclusions.

First, by and large, 1

25 the OL schedules are being met.

Most of the items are being 1

14 l'

1,i met for OLs, with some exceptions.

You will recall that every

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time we have a briefing on an OL, we identiff those four or five 3;

items that are deviations from 737.

You will recall the license

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4 itself has a lot more 737 items in it than four or five.

That 5,

is because some of the dates are off in the future and we put

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8 6i those in as license conditions.

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R 7i We really do not have a good basis today to change the n

schedules in the proposed OL rule from those in 737.

We can 8

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d 9j all speculate about new schedules as we did a week ago.

There I

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is just not a good basis before us to change those schedules ic

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COMMISSIONER BRADFORD:

Once the thing becomes a rule, z

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13 i if so, what then becomes the mechanism for changing schedules?

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A 14 i Are the schedules not part of the rule?

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15.

MR. EISENHUT:

If it is a rule, they would have to l

a a

l 4

j 16 come bsch in with an exemption request and then I look at i

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it that when we are having a discussion on an OL where we y

17 i

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18 put up a slide and say these are the deviations from "37, T-p 19 -

they would then have to be the deviations from the rule and a

20j we would be given granting relief on those small handfuls of

l 21]

items.

22 (S LIDE. )

23 MR. EIS EN"'JT :

We went back and looked at the 24 :

licenses that have actually been issued post-TMI, The Salems,

25 Sequoyah, McGuire.

These are the only deviations that we had e

i

j 15 1l to put in as license conditions tha*. deviated from the 737 l

2 document.

3 MR. CASE:

And which would deviate from this proposed j

4_

rule.

I 5'

e MR. EISENHUT:

Yes.

These plants have license 8

6 j

conditions.

Farley 2 has a II.F.2 that says thev are going to 8

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f do it before they reach five percent, rather than doing it-i i

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They had provided specific plant by plant

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justification.

10 l l

I would anticipate that justification we went through z

5 11 i to give them this deviation would be the same basis of granting

5 12 I l

them the formal relief under the rule.

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The only point here is there are not that many.

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14 l

[n absence of Mcquire, North Anna and Sequoyah says those utilities I

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2 15 s

committed by license conditiun to meet schedules in 737.

You 16 N

I recall a number of the schedules are in 1982 so the license i;[

17 j y

j condition is a commitment to meet that date.

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18 !

l 2

We did one more thing.

19 '

A j

C0fffISSIONER BRADFORD:

Do you have a rough sense 20!l or how much longer that list will get?

21 'l I

MR. EISENHUT:

The next slide will answer that.

4 22 (SLIDE.)

l 23.

MR. EISENHUT:

The obvious question is what is the 24 real sense in the industry in terms of when a plant wants 25 to ge: an OL, they seem to have this great tendency to be ALDERSON REPORTING COMPANY. INC.

1 16 15 ready to commit to those schedules.

We all know they have i

2, a tendency also to change as time goes on.

3 These are the ones we are aware of today.

It says 4

requests are expected.

We have been talking to these plants 5;

just in the normal follow up to the license and say, remember e

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you have a license condition and if you want to stay in

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7; conformance with the license, you had better be telling us.

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It looks now like all these plants, and when I say a

d 9l "all" it is really tied to these five plants, they all state 2[

E 10 they are going to be coming back in requesting relief on

z i

11 II.D.1, the relief on safety valve test requirements.

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12 The 737 had two parts to it.

Those are approximate z=

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dates that they are telling us they are likely to come back in

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16 North Anna 2 has a problem with II.F.2, the t.

p 17 implementation under inadequate core cooling.

The specific x

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6 18'l subtask, I think it was the reactor water level.

4

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19 j They stated they would like to have the first 20 )

refueling outage after 1/1/ 32 rather than living to the 1/1/32 21 requirement.

Otherwise it would necessitate a shutdown 22.,

which is really the point Commissioner 3radford mentioned 23 earlier.

24,

Some of these requirements

'n result in an extra 25 shutdown.

After the OL, they are pre::y much on some of these

17 1l items like an OR.

There are a few other differences.

I 2l Sequoyah I has come back.on four items where they I

i have stated they are asking for the same thing, that is, the 3

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1 4l first refueling outage after 1/1/82.

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5l This is sort of typical of what we expect en these

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items.

As time goes on, out into the future, the items R

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rolled together for ors and OLs.

As you go past the dates,

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obviously they are the same kinds of dates.

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9l One other aspect in the rule that I will mention is

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10 l we had to split the items into two parts, those items that are E

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11l required before a license that have dates down the road, like u

y 12 1/1/82.

We had to decide what to put in group one, those that 5

d 13 are necessary prior to an OL and second, those that are

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15 l The cutoff date we put in the proposed rule when we i

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drafted it some months ago was July 15th.

That is just defining w

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one bin or the other.

One could argue the date is obviously i

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l 18 going to have to be reconsidered in connection with the final 5

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19 rule.

5 i

20.

It is strictly an administrative categori:ation.

From,

i 21 4 a practical standpoint, there is only one item that has a due 22 date that falls between July and December of this year for 23 OLs anyway so it really does not make much difference.

The proposed rule is meant to be identical to the 24 :

25 document we reviewed last Fall.

We are proposing it go out

l 18 I

l 1!

for 90 day comment.

The reason for 90 days is the large volume

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2l of issues.

We want people to really have the opportunity to 3l take a hard look at all the issues in hert, to try to get l

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4 the best information back we can.

It is a very complicated i

i 5i task to look at all these schedules.

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Being very candid, I am personally sort of torn between 7li a 60 day and a 90 day.

Sixty is about the shortest comment R

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8l period you can really ever turn anything around on.

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criticism we had before from an CIA Report was we did not zo I

g 10 l give the industry enough time to digest such a very large 5

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11 document with such a large number of requirenents.

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Hence, we opted for the 90 day comment period.

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l 14 about the proposed rule that is addressed in the statement s

2 15 l of considerations.

I have really addressed these somewhat ji i

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16 before.

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17 The statement of consideration points out that E

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18 i while this rule is out for comment, I believe it is on page E

l 19 six and seven of the rule, it states that the staff is going M

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20l, to be conducting a relook at 737.

We are conducting a relook i

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21 ;I at 737 to see whether we really need some of these 22 1 requirements.

23 '

The example I mentioned before was a large number of i

24 ;

these items were previously required to submit reports on 25 these items from the operating reactors and we are digesting

19 l

l 1;

those reports and we may well conclude that you have seen the

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24 same generic analysis nov 75 or 80 times, you do not need to 3

see it another 50 or 60 times.

We will be reaching conclusions

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4 during this period of time on the removal of some of these items.

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5' COMMISSIONER AHEARNE:

That would only be that N

3 6l it was truly a generic analysis.

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MR. EISENHUT:

That is correct.

l l

8 If it was a generic analysis that has gone away, the d

m 9i need for it has gone away.

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10 l There are a couple of other sets of items mentioned z

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These were comments during 3

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he has changed his thinking on overtime limitations, that

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7 3 7 wc rds, j us t as it was before, but during this period of R

20 time we would be reconsidering it.

That is part of the reason 21 why we think the 90 day comment period would be a very useful 22 i period of time.

23,

There is a set of items where one could argue that 24 the item could be swept under an existing regulation already.

25 Late last year, early this year, actually OELD

20 1l completed a study which looked at all these items, which ones 2

could be said to be an extension of a present regulation or 3

really fall under the umbrella of a present regulation.

Their

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5i interpretation really be said to already fall under an existing 3

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6 regulation.

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This was meant just to identify there are some which A

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could be argued to already fall under an existing regulation.

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now to require a little more.

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To put the thing in proper perspective, we are still E

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proposing to go out with this package.as it is in 737 in the l

14 proposed rule.

We wanted to highlight that in this statement E

15 of considerations.

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They have been under review for some time.

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For example, automatic cool pump trips, where we may during this i

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period of time refine our requirement.

A 1

i 20 J CHAIRMAN HENDRIE:

Does that mean turn them on?

1 21 MR. E!SENHUT:

That I will defer to someone else.

22 It depends on if it a three loop or four loop.

23 COFBfISSIONER AHEARNE:

It depends on whether it is 24 a month with an "R."

25 CHAIRMAN HENDRIE:

In the month with an "R" I am

i 21 1!

Chairman.

It is something else for pump 42

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2l MR. EISENHUT:

It appears you clearly understand what 1

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that category means.

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COMMISSIONER 4t!!st33GE:

Is there ever a time when 4

5l you are chairman for only three loop plants?

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CHAIRMAN HENDRIE:

That is a thought' We could have R

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7l chairmen for research and other reactors.

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MR. EISENHUT:

The last category is a group where they l

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addresses PORVs manufactured by a particular vendor, or there E

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may be some that are just too detailed that they should not a

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analysis on the selected 36W plants.

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14 We felt the thing to do at this time is go out with 1

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16 comments from industry.

It was considered at this table and s

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We had regional meetings.

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19 j it as is.

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20q MR. CASE:

This method will provide traceability 21 I of changes in requirements and the final rule will indicate 22 what changes were made and why.

I think it provides a good 23 record basis for changing things.

24

-COMMISSIONER AHEARNE:

If you put cut something for 25 comment and in the interim period of comment you decide something ALDERSON.REPORTIN.G COW 9dm WC,

22 1'

is in there that should not be in there and you pull it out,

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2l I guess that is acceptable unless you were to have some 3

all sweeping statement that would say this covers all aspects 4

of that area.

Is that correct?

g 5l MR. BICKWIT:

That would be acceptable.

You would j

6, examine the comments together with your own thought processes A:

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j 8l ought to be eliminated.

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9 MR. EISENHUT:

The only thing I believe you cannot do ilj 10

!.s you cannot add new items in.

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11 MR SICKWIT:

You cannot add ones that were not

<m reasonably foreseeable.

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13 COM?fISSIONER GILINSKY:

Presumably it depends

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on how significant the changes are, if people have reasonable E

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notice.

The point of getting comments is to make changes.

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That is why we felt it was i,'

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appropriate to go with the package as it is presently, that l,

5 18 I each utility is working with and develop the rule to be E

1 19 identical to what is in 737

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20 l COM!ISSIONER GILINSKY:

I should add to make changes l

21 i if necessary or sensible.

I 2

22 I CHAIM9J! HENDRIE:

And voted for.

23,

MR. EISENHUT:

I would like to discuss the next 24 -

item briefly, the OR rule item, to answer some questions.

25 We are presently going down the approach of taking l

l 23 six month sets of requirements on ors and issuing orders covering j!

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l 2l those six months of items.

The first six months of items, the l

l 3j rders are presently under development. We are hoping to get

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We had hoped to get 4,j them out before now.

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been developing this rule and 737.

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8; The present rule before you is strictly an OL rule.

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We had proposed sending it out s trictly as an OL rule.

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i 10 l As Bill Dircks mentioned, we could come back with

~z 11 l an OR rule, depending upon which way we would go with it.

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737, the. 737 package for ors.

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need for some of these items requiring shutdowns.

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x are now shutting down for has accumulated, not j ust TMI g

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E 18 requirements but a very large multitude of other items.

E 19 The utilities are coming in now laying out schedules, xb two refuelings in advance, requesting, can I do these five i

i 20 j 21(

NRC items during that outage and these five during that outage.

1 It is getting very complicated.

22 The other thing that is getting very complicated is 23 on utilitias with a number of nuclear plants.

For example, 24 in Illinois, Commonwealth has got a number of nuclear plants.

25

24 i

i If you establish a date to have something in on all

'l 2l their plants, obviously there is a long staggering program I

if it is a shutdown item.

They stagger their plants to be 3

4l shutdown minimum numbers at the same time.

It even affects 5l the multi-units such as the Browns Ferry 1,2,3's or the e

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To a lesser extent, it is the same thing in i

a any dual unit plant.

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5 13 ;

liability question.

When we went to the short tern lessons E

14 learned items that were put in place over a year ago, it 15 turns out if you look at some of these dates, they fall at i'

3 what some people might argue to be the least logical time, 16 3s Our operating reactor dates have hardware items that y

17 E

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18 need to be put in place by July 1st and January 1st of the j

i various years, which happen to be right in the periods of peak l

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1 demand fo r electricity.

Refueling outages tend to go in the 20 '

i 21y Spring and Fall.

One could always argue that the utility could certainly 22 3 23 put the items in three or four months earlier.

Remember also the discussions that on a number of these items it is 24 25 developmental, the reactor water level, for exanple, where the

25 i

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schedules are already very tight.

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It is not as simple a task as it is to work it on OLs i

3 because a larg. number of the items for most - 0Ls are being put 4

in place prior to an OL issuance.

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5l We would anticipate we could turn around and have n

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an OR rule out if desired in about=30 days.

We would p?opose

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7j if we decide to go with an OR rule, that it be done during j

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periods, because typically you get better comments on these i

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to meet commitments but they really have not focused on it to

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In summary, our recommendation today is we approve l

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the OL 737 rule for comment.

We believe we would be ready to l

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16 go by tomorrow.

We have already taken the errata.

They have i

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y 17 been factored into the rule.

The rule for OLs is identical 5

I 18 or is meant to be identical to 737.

=w 19 CHAIRMAN HENDRIE:

With regard to the ors, what would p-B j

20j be different about an OR rule would be the implementation l

i l

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21 schedules?

8 22 :

MR. EISENHUT:

That is right.

There are a few f

23,

differences in items in the actual scope but those are really 24 q trivial.

The second thing is the vast majority is the 25 implementation schedule.

i 26 I

1 CHAIRMAN HENDRIE:

It is kind of a peculiar 2l configuration of the rule to have two rules where the primary 3

difference is some different implementation dates.

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4 COMMISSIONER GILINSKY:

Would you reference this rule s

5 in the other rule, just to indicate the changes?

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The way we would propose to do it R

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package but they would certainly reference one another and J

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There

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Even 737 has different 5

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COMMISSIONER GILINSKY:

Whct would go into the code E

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of Federal regulations?

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MR. EISENHUT:

It would be another comple'.e package.

15,

C0!NISSIONER AHEARNE:

Two separate ru? ss?

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16 MR. EISENHUT:

It could be either way.

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y 17 CO>MISSIONER AHEARNE:

I would start out believing 5

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18 r it ought to be restricted to the OL, however, your summary 19 )

point that the only real difference is the scheduling, and 6

i 20) then you say you would want the public comment period to 21 overlap and the better comments will come from the operating 22 reactors.

23 CHAIRMAN HENDRIE: Giving you pause, is it?

1 24 COMMISSIONER AHEARNE:

It seems to imply that you 25 are not really going to address the OL comments until you have ALDERSOM REPORTONG C_OMf9aNV. DNC,

27 1

the OR comments, if they are the better comments.

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2l MR. EISENHUT:

We are prepared to go just with an OL 3

rule.

Im 4l COMMISSIONER AHEARNE:

Your summary point.

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It is just an observation that A

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through comments from the ors than the OLs.

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COMMISSIONER AHEARNE:

I am just pointing out that d

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the logic of those comments makes it seem reasonable if it z

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MR. CASE: What we had in mind was a 90 day comment 7<

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12 ;

on this rule and a 60 day comment on the other rule so the 13 end point would be the same.

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COMMISSIONER AHEARNE:

Then you would say the people t

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The bulk of the comments on the OR i

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rule will be the shutdown, how soon can I shut down, problems T

19 A

with the system, power reliability.

c 20ij COMMISSIONER GILINSKY:

Why can't you put into a statement of considerations the fact

hat you plan to come 22 out with a rule on operating reactor s and owners of operating 23 reactors shou ~d pay attention to this rule?

24 CO:CIISSIONER AHEARNE:

Yes.

25 l

ALDERSON REPORTING COMPANY. INC.

28 1

CHAIRMAN HENDRIE:

It does not look to me as though I

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it would be all that much of a struggle.

You say most of the 2

3, items have identical scope and identical schedules.

L'-)'

4 MR. EISENHUT:

That is right.

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5i CHAIRMAN HENDRIE: There are seven items that would 0

3 6l apply only to ors, and five that apply only to OLs and twelve R

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MR. CASE:

Their current schedules are the same in d

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wind up the same.

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That is why you are going out D

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12 l for comments.

Are they good enough for the proposed rule.

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MR. EISENHUT:

That is the question.

On operating

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Obviously we will get more E

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18 COMMISSIONER AHEARNE: Are you saying the 30 days

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would primarily be spent trying to modify the proposed

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schedules to pick up those comments you have already received?

j 21 '

MR. EISENHUT:

I think some of that period of time

i 22 would be to look at it.

It takes a couple of weeks just to 23 administrative 1y turn it around.

It is the same people 24 doing an OL rule, an OR rule and orders to 70 plants, and a Cp 25 rule.

29 I,

1l It is really the same sets of requirements.

My fear I

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different on the same item.

It is becoming logistica11y a

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4 5

COMMISSIONER GILINSKY: Why wouldn't an operating g

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6i reactor rule simply be a list of twelve dates and seven items?

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7 MR. EISENHUT:

You can say it is a rule that says l

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10 j COMMISSIONER GILINSKY:

Are the twelve modified?

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MR. EISENHUT:

Same scope, modified schedules.

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COMMISSIONER GILINSKY:

It is twelve dates.

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MR. EISENHUT:

Yes.

That would be one variation

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14 k o f doing it.

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15,l COMMISSIONER GILIMSKY:

It seems to me we could do E

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16 one of two things, indicate this will come out very soon or s

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17 incorporate it.

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18,

COMMISSIONER AHEARNE:

Has anfone from Minogue's t

19 )

office been involved?

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4 20]

MR. DIRCKS:

At the Commission meeting where we 21 were told to develop this rule, we were told to develop it 22 on an expedited basis.

The assignment was made at the table 23 that we do it with the person who did the CP rule.

l 24 COMMISSIONER AHEARNE:

Did anyone from Minogue's l

25 office do a qualify control check on rule format or anything?

ALO ER S ON REP ORTING C OM P AN Yo INC.

30 i

1j MR. PURPLE:

We did have a representative from the 3

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2 i Standards Office to work with the team that put this together.

3, COMMISSIONER GILINSKY:

A " body," as they say.

t 4

MR. EISENHU1:

Yes.

5; COMPfISSIONER GILINSKY:

Are the items we dropped e

N 6i from the hydrogen rule all incorporated here?

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MR. EISENHUT:

Yes.

All the items that were tied to n

8 8l 737 are in this docummat, that is, those nine of the fourteen m

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10 I COMMISSIONER AHEARNE:

Those items at least some E

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of the Commissioners wanted to drop from the hydrogen rule 3

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are incorporated?

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d 13 MR. CASE-

Yes, when we drafted them, we did not E

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2 15 MR. EISENHUT:

We took e.xactly what was in the 73 7.

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16 C0!!MISSIONER GILINSKY:

I hope all the parties in l

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17 all the proceedings will be notified.

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MR. EISENHUT:

Yes.

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19 j COMMISSIONER GILINSKY:

What is the effect of the

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rule if approved in final form on ongoing proceedings?

i 21 MR. SHAPAR:

It applies.

22 COMMISSIONER GILINSKY:

If you are in the midst 23 of litigating something which would not be litigable under 24 this rule, it just stops as of the effective date?

25 MR. SHAPAR:

People would make appropriate motions to

l 31 1

implement the new rule to a proceeding.

l I

2 COMMISSIONER GILINSKY:

To what fraction of these 3j items do you think that applies?

I suppose it applies to those

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4 items which went beyond Class 2 or whatever they were.

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MR. BICKtIIT:

Most of 0737 was within existing

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COMMISSIONER GILINSKY:

What remains to be argued 3

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is whether or not the applicant meets the rule?

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9j MR. CASE:

Whether litigation on dates, and there is

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12 l MR. SHAPAR:

There could also be litigation on 5

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whether or not the plant meets the new rule.

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j 14 COMMISSIONER AHEARNE:

It does not foreclose arguing c

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whether or not it is met.

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g 16 l MR. SHAPAR:

Th'ere is one other possible attack on M

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litigation and that is 2.758 of the regulations that says l

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18 l if there are particular circumstances which indicate the c

i 19 rule is not subsurbed in these particular circumstances, then 5

i 20 !l you can attack the rule.

l 21 l COMMISSIONER GILINSKY:

Does that mean if an applicant 4

22 comes in and requests an exemption, that can then be the subject 23 of a hearing?

q 24 MR. SHAPAR:

If the exemption came up in the hearing i

25 process, I would assume the hearing board would determine the 4

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l

32 I

matter.

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2 MR. BICKWIT:

Right, but once the hearing is over, 3

the applicant could come in and request an exemption, even if I

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the Board had decided -- what would normally happen is the 5l intervenor would say the date should be moved up somehow and g

R 6l the board would have said that was an attack on the rula E

7

>fR. SHAP/R:

That is possible. After the board M

3 8l has determined a lot of matters, the license can be amended a

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d 9l at a later date and exceptions can be granted at a later date.

t COMMISSIONER AHEARNE:

You have a statement that 6

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11 some of the items are subjects of other ongoing rulemaking.

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12 Is it possible to take the comments that come in under one z

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rule and automatically transfer those to another rule?

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14 l MR. BICKWIT:

You have to give some sort of notice

.t 15 that you might contend to do that.

You can always tske into j

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l account comments from anywhere.

You might be a litM e hard f

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pressed to tell somebody their opportunity e comment on rule B N

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s 18 was foreclosed because they failed to comment on Rule A, unless i'

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you make it very explicit that you had something like that in l

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mind.

21 3fR. EISENHUT:

Maybe you are saying the paragraph l

22 on page six is not explicit enough, where we state we do not 23 ;

'ntend to issue them and it goes on to say that consolidation 24 or other appropriate action would be taken before final 25 rulemaking.

l 33 1l MR. CASE:

I do not know if that was written

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2' primarily at the time when we had the hydrogen people in both 3

rules.

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4 MR. EISENHUT:

There are emergency preparedness i

g 5i aspects.

There are two or three where we have a number of S

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things going on.

R 7j CHAIRMAN HENDRIE:

Since we contemplate treating some i

j 8 I of those areas in other rules, I had in mind in particular d

9 the operator qualifications, do we really want to exercise E

10 the comments on these points?

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j 11 j MR. EISENHUT:

We would say yes but during that S

y 12 i period of time we would be deciding which rule it goes into.

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,E 13 We assume we are going down the road of continuing to implement

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737 even if and as if there were no other rules.

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15 COMMISSIONER AHEARNE:

There is a real advantage i

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g 16h to having this be a map of 737.

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MR. EISENHUT:

It is very difficult for the industry l

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18 to keep track of all these different pieces of requirements.

_n 3

19 CHAIRMAN HENDRIE:

SUBJECT:

PROPOSED RULE RELATED TO TMI-2 REQUIREMENTS FOR OPERATING LICENSE APPLICATIONS

Purpose:

To obtain Commission approval for publication of proposed amendments in the Federal Register for comment.

Discussion:

A proposed Rule has been developed that incorporates into 10 CFR Part 50 a set of TMI-2 related requirements for operating license applications. These requirements are the same set contained in NUREG-0737.

The approach taken in the proposed rule is similar to that taken for TMI-2 requirements for near-term construction permit applications.

There are two aspects of this proposed Rule that warrant highlighting.

I.

Several of the items applicable to operating license application reviews, as contained in NUREG-0737 and listed below, are being addressed in other decisional processes. All NUREG-0737 items are nevertheless itemized in this proposed Rule for completeness and clarity.

1.

Certain NUREG-0737 items related to Emergency Preparedness are listed only for comoleteness, since they have already been issued as effective regulations.

2.

Several items from NUREG-0737 are being included in the Interim Degraded Core Cooling final Rule and in proposed rule 7

]D 3[d"'B changes regarding operator qualification, Af

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shift manning, and overtime that are under preparation.

Since these rules

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y have not yet been finalized, the enclosed rule includes those same items and, we Ts op 012 l

Contact:

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ML20003J223

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