ML20044A930
| ML20044A930 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/28/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| NUDOCS 9007170006 | |
| Download: ML20044A930 (89) | |
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l UNITED STATES NUCLEAR REGULATORY COhDESSION l
i OFFICE OF NUCLEAR REACTOR REGUIATION c............==========....
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t In the Matter oft
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MANAGEMENT LEVEL MEETING BETWEEN
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l THE NUCLEAR REGULATORY COMMISSION
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AND LONG ISLAND LIGHTING COMPANY
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Pages: 1 through 87 Place: Rockville, Maryland Date:
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NUCLEAR REGULATORY COMMISSION 2
In the Matter of:
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MANAGEMENT LEVEL MEETING BETWEEN
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THE NUCLEAR REGULATORY COMMISSION
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AND LONG ISLAND LIGHTING COMPANY
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- Friday, July 28, 1989 Nuclear Regulatory Commission 11555 Rockville Pike Room 2F17 Rockville, Maryland The above-entitled matter came on for hearing, pursuant to notice, at 8:12 a.m.
APPEARANCES:
On behalf of the Nuclear Reculatory Commission!
Thomas Murley Stephen varga Frank Miraglia James Partlow James Linville William Russell Joseph Scinto Walter Butler Stuart Brown r
On behalf of Lone Island Lichtino Comoany:
Anthony Early Richard Gutmann Charles Davario Jack Notaro William Steiger John Leonard Heritage Reporting Corporation (202) 628-4888
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PROCEEDINGS
.2 8:12 a.m.
3 HR. MURLEY:
This is a meeting between the NRC 4
and LILCO.
Other attendees are here today.
I would ask 5
thet they hold any comments or que.stions until the end of 6
the meeting, at which time they may address questions or 7
comments to the NRC.
8 To start the meeting I think we probably ought to 9
go around and introduce ourselves, make sure we know who we 10 are.
My name is Tom Murley, I'm the Director of HRR.
11 HR. RUSSELL I'm Bill Russell, the Region 1 12 Administrator.
13 MR. SCINTOt I'm Joe 3cinto, Deputy General 14 Counsel.
15 MR. BUTLERt I'm Walt Butler, Reactor Projects.
16 MR. BROWN:
I'm Stuart Brown, Reactor Projects.
17 18 MA. GUTMANN:
Gutmann, Assistant Department 19 Manager, Nuclear Operations Support Department.
20 MR. DAVARIO:
Chuck Davario.
21 MR. NOTARO:
Jack Notaro, Manager, Nuclear 22 Quality Assurance Department.
23 MR. STEIGER:
Bill Steiger, Assistant Vice-24 President of Nuclear Operations, j
25 MR. LEONARD:
John Leonard, Vice-President of Heritage Reporting Corporation L
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Nuclear Operations.
2 MR. EARLY:
Tony Early, President of LILCO.
3 MR. STAFFIERI Vic Staffieri, General Counsel-4 for LILCO.
5 HR. IRMIN:
Don Irwin, outside Counsel for LILCO.
6 MR. REVELEY:
Joyle Reveley, Outside Counsel.
7 MR. VARGA:
Steve Varga, NRR.
8 MR. LINVILLE:
Jim Linville, Projects Branch 9
Chief Region 1.
10 MR. PARTLOW:
Jim Partlow, Associate Director, 11 NRR.
12 (Audience members identified. )
13 MR. MURLEY:
Thank you.
14 This meeting was called by NRC.
Our purpose is 15 two-fold.
First, to understand LILCO's intentions with 16 regard to the Shoreham plant.
Second, to assure mutual 17 understanding of how those activities at the plant are to be 18 conducted.
19 We are reminded that LILCO holds a valid 20 opethting license.
That allows you to operate Shoreham at 21 full power, provided you meet all the pertinent NRC 22 requirements.
A license carries with it certain 23 obligations, of course.
There are many license conditions 24 that have to be met as long you hold that license.
If you 25 want relaxacion from some of those license canditions, you Heritage Reporting Corporation (202) 628-4888
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1 must obtain NRC approval.
Our regulations specify 2
procedures for making amendments to that license.
3 The NRC has, of course, certain obligations 4
itself.
We have to know the condition of the plant at all 5
times.
We have to make sure that the plant license is 6
respected, that the plant in this case is not allowed to 7
deteriorate under conditions of neglect or any other 8
conditions.
We intend to monitor the activities of the 9
plant to insure compliance with the license conditions and 10 to insure a safe disciplined approach to all license 11 activities at the plant.
12 Stu, did you have any thoughts?
13 MR. BROWN:
No, sir.
14 MR. EARLY:
Dr. Murley, as always it's a pleasure 15 to be here to exchange information with the NRC and have the 16 technical dialogue that we have had over the years in the 17 past.
I think it has always been very productive.
18 I would like to start out and give a little 19 background information on the settlement agreement with the 20 State of New York, which really drives the position that 21 LILCO and the Shoreham plant is in right now, and talk a 22 little bit about the implementation.
My staff here then 23 will go into the technical details of the exact status of 24 the plant and some plans for the future and discuss with you 25 what we think we would like to do with your staff in working Heritage Reporting Corporation (202) 628-4888
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I with them in the future.
2 The background of the situation that we are in 3
now goes back to February of 1989, when LILCO entered into a 4
settlement agreement with the State of New York concerning 5
the Shoreham plant and other matters surrounding Long Island 6
Lighting Company.
A major part of that settlement agreement 7
was a provision that LILCO would transfer to an agency of 8
the State of New York the Shoreham Nuclear Plant, and LILCO 9
would agree that they would not operate the Shoreham plant 10 in the interim.
11 Under the agreement -- I think this is very 12 important -- LILCO will not decommission the plant.
We made 13 that very clear to the State of New York.
We are
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14 transferring the plant to the State of New York.
It then 15 will be up to the State of New York to decide what they want 16 to do with the Shor ham Nuclear Plant.
All of this, 17 obviously, is subject to meeting all NRC requirements and I
18 talking to you and your staff and making sure that you are 19 comfortable with the way we are proceeding, l
20 Several approvals were required for that i
21 settlement agreement, the last of which was the approval of 22 LILCO shareowners.
That shareowner approval for the 23 settlement agreement was obtained on June 28.
Therefore, 24 the settlement agreement is fully effective and legally l
25 binding on all of the parties.
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We are now in the process of implementing that i
2 settlement agreement.
Before I des: ribe the overall 3
approach that LILCO is takin9, I think it's important to i
4 keep in mind a number of key themes that we are operating 5
by.
First of all, LILCO cannot legally operate Shoreham 6
under the settlement agreement.
We intend to abide by the 7
conditions of that agreement.
Therefore, we will not 8
operate the Shoreham Nuclear Plant.
I think that it is i
9 vital to understand that and to look at the plant in that 10 context over the next couple of weeks and months.
j 11 Second, LILCO intends to maintain Shoreham in an 12 absolutely safe condition.
I think that you and your staff 13 and Mr. Russell's staff in the region know the type of 14 first-class quality effort that we can put out at Shoreham.
15 We intend to do exactly that same kind of effort that we 16' demonstrated in the licensing of the Shoreham plant in going 17 through this phase of the Shoreham plant's life.
We are 18 committed to that kind of effort.
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19 20 21 22 23 24 2S Heritage Reporting Corporation (202) 628-4888
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1 MR. EARLY:
During the presentation this 2
morning, you will hear a reference to a condition that we 3
are esiling a minimum posture condition for Shoreham.
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A couple of things that are very important to 5
understand about that minimum posture position.
First of 6
all, by that, we intend to meet all regulations and all i
7 requirements of our license and we agree fully with your 8
comments, Dr. Murley, concerning our obligation to meet all 9
the conditions and our understanding that we have to come to 10 the NRC to have any relief from those conditions, and we I
11 will talk to you a little bit about our plans for coming to 12 you in the future so that we can discuss whether that's 13 appropriate and when it's appropriate.
14 When we talk about the minimum posture 15 requirement, make no mistake.
The Shoreham project is still 16 a major effort for the Long Island Lighting Company.
Under 17 this minimum porcure that we are going to present to you 18 today, we estimate chat our annual budget for 1990, next 19 year, will be in the range of 45 to $55 million.
I suspect 20 that is a larger budget than a number of your older 21 operating plants have.
So, we are talking about a very 22 significant effort to maintain all of the requirements for 23 the Shoreham Nuclear Plant and I've told John Leonard and 24 I've told Bill Steiger that I am committed to provide 25 whatever corporate resources are necessary to make sure that Heritage Reporting Corporation (202) 628-4888
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1 that plant is maintained in a totally safe condition and 2
that we meet all NRC requirements.
And if there is ever any 3
question on the part of your staff or on the part of the 4
Region's staff that we are not meeting any of the 5
requirements of the regulations or our license, we want to 6
know about it, because we want to try and deal with that as 7
soon as we can.
8 What is the process that we are going to follow?
9 Well, we have undertaken a number of detailed 10 analyses that are required by the regulation and we will 11 review those with you today.
The process that we are 12 undertaking has been reviewed by our own nuclear review 13 board and our own nuclear oversight committee and I think 14 the unique aspects of this we are maintaining all of the I
15 processes and procedures that are required for full 16 operation of the plant.
We are going to apply it to this 17 particular stage of the plant's' life, 18 Right now, the defueling of the plant is in i
19 process.
It is a normal routine evolution that every plant 20 carries out during a refueling.
The only difference is that
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21 when we take the fuel out, it will go in the spent fuel l
l 22 pool.
We will not be putting any new fuel in the reactor.
23 We will just move the existing fuel into the spent fuel 24 pool.
25 Once the plant is defueled, then we intend to Heritage Reporting Corporation (202) 628-4888 J
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proceed what we will be calling our minimum posture.
And we 2
will describe that to you in more detail.
3 We believe that everything that we are proposing 4
under our minimum posture scenario are things that are 5
permissible and that we can do under our existing license 6
and that we will meet all of the requirements Qf our license 7
and the regulations.
8 The next step in the process is that we will be 9
applying to you for appropriate license changes and we will 10 review some of those today, but, again, we would like to 11 start a dialogue on those changes so that we make sure 12 everyone is comfortable with the approach that we are going 13 to take.
14 And, finally, at sometime in the future, we will 15 be applying to the NRC for a transfer of our operating 16 license to an entity of the State of New York.
I think it 17 is a little premature to discuss that aspect of it because, 18 to be honest with you, all of the details are not worked l
19 out.
20 One of the major elements is that the State of i
l 21 New York in the form of the Long Island Power Authority will 22 be entering into a contract for technical services with the 23 New York Power Authority.
Those contractual details are now 24 being worked out.
And, obviously, you will have to be 1
25 brought up to date on all of that information once those Heritage Reporting Corporation (202) 628-4888 1
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1 contractual arrangements have been made.
They have not been i
2 made yet, so we don't intend to make any kind of
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3 presentation today on that transfer process.
I believe 4
that's a ways down the road.
5 So, with that, let me turn it over to John 6
Leonard and his people to go to the technical presentation.
7 dm. MURLEY:
Could I make a comment?
There is I 8
guess a thought here that goes beyond mere compliance with 9
our regulations, also.
Because our regulations do allow 1
10 quite a bit of latitude in terms of maintaining systems that 11 are out of operation, for example.
As you know, in Mode 5, 12 it is possible to ceclare systems inoperable and during that 13 mode, certain maintenance need not be done.
14 And we are concerned about comments that we have 15 read in the media from state officials, for example, that 16 this plant will decommission itself.
By that,'we take it to 17 mean that it will be allowed to fall into neglect by taking.
10 advantage of some of our regulations that allow limited 4
19 mainte.tance.
And that is what our concern is and that is 20 what we won't allow to happen, even if we have to interpret 21 our regulations more stringently.
22 MR. EARLY:
We have no intention of allowing the 23 plant to fall into a state of disrepair and i.eglect.
Our 24 people are too proud of the plant to do that.
So, they will 25 not let that happen.
Heritage Reporting Corporation (202) 628-4888 Y
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Second, the plant is too valuable to do that.
2 Whether the plant ultimately would be operated by.the State 3
of New York, which is highly unlikely, but-the'. plant 4
equipment has a lot of value and we recognize that.
And 5
there may be other licensees at come point who would'like to 6
get their hands on pieces of the plant.
But it is not going 7
to fall apart.
And, as I said, our budgets'are 45 to $50 t
million.for 1990.
It is higher than that for the rest of 9
this year b+:ause we have been maintaining our programs, we 10 will contunue to maintain them and just phase down as we 11 think it is appropriate.
Some of the reduction will require 12-your approval.
13 I think the budget that we are proposing while 14 less than what we had originally anticipated under an 15 operating scenario is probably as large as many nuclear 16-plants that are operating;.
So, there is going'to be a lot 4
17 of work going on at that plant.
And I think John's 18 presentation should give you some degree of comfort that it 19 ain't going to fall apart.
- 20 MR. MURLEY:
It is not our intention -- we can't 21 force anyone to operate the plant, obviously.
But as long-22 as there is a valid operating license, we intend to make 23 sure that the equipment and condition is kept appropriate to 24 a plant with an operating license.
25 MR..EARLY:
I think because this is a unique Heritsge Reporting Corporation (202) 628-4888 1
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situation, we welcome weihing with your staff and the 2
technical staff to come up to the plant and review the 3'
detailed plans for the systems to make sure that there is a 4
level of comfort that we are giving the appropriate 5
attention to the appropriate systems.
6 MR. LEONARD:
In implementing what Mr. Early 7
said, we established several objectives and we will mention 8
these throughout our presentation because w's think they are 9
very important.
10
-First, we want to establish the least cost 11 posture consistent with maintaining the operating license.
12 We want to conserve the assets of the company.
And we want 13 to maintain the license and stay within the bounds of that 14 license.
We want to insure that all expenditures are 15 prudent and consistent with the terms of the agreement that.
Je bave that.are legally binding on us.
We intend to meet 16 17 the-requirements of the existent 100 percent license and 18 must be continued given our plant status.
And we intend to 19 keep the NRC thoroughly briefed on our activities.
Now, we 20 have already met with Bill Russell.
We have been arranging 21.
meeting here, Dr.'Murley, with you all.
We' met again with 22 Jim Linville of Region 1, came up to confirm certain things 23 about a week or so ago and Frank Cresenzo our Senior Resident, we welcome him to all of our meetings and any 25 information he wants, we are more than willing to give him.
Heritage Reporting Corporation (202) 628-4888
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14 1-We have tried to work out a two-track method to 2'
achieve'these objectives.
One, I will call a legal and
-3 regulatory track where we have carefully researched the-4 technical specifications, the USAR, other commitments we 5
have made to make sure-that in this minimum posture, we 6
maintain our status within the bounds of those legal 7
constraints.
8 The second track is what I would call the real 9
world track.
I have worked with the NRC long enough to know 10 that'you gentlemen-are sincerely concerned with public 11 health and safety. So, we have performed a very detailed 12 radiological analysis of any problems that could occur at 13 the plant.
It is in final draft form.
You should be seeing 14 it within the next few months officially, and it shows 15 basically that the fuel in the spent fuel pool represents 16 effectively a zero hazard to public health and safety.
17 As an example, there are probably more -- there 18-is probably more energy given off by the lights in this room 19 than there is by that core.
It.has been irradiated for 20 about 2.5 effective full power days.
21 MR. MURLEY:
At one time, we estimated that there 22 was about a 1,000 curies activity in that fuel.
23 MR. LEONARD:
It is more than that, I think' but 24 the heat and the wattage right now is about 550 watts, five 25 good sized light bulbs.
In fact, John Scalice, our plant Heritage Reporting Corporation (202) 628-4888 1
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. manager said to me,-he said, "I'm going to have a really.
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tough' time if we operate these plants, getting the operators 3
to rec 11ize RER means residual heat removal, because.we have 4
to run the system, generate pump heat to keep the head bolts-5 attached.
6 So, you can see 550 watts just natural convection 7
of operation will take care of any problem there.
8 As far as a radiological problem with the spent 9
fuel, we have done some measurements and under water about a 10 foot away, you get about 7R from the modules.
11 It looks to us as if you lost all the water in 12 the fuel pool down to the top of the fuel, you would have 13 about 1R on the. refueling deck.
So, you see the order of
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-14 magnitudes we are talking about is just not even comparable 15 for the fully active operating plant'.
16 My usual procedure, I like my department heads 17 and people that work for me to give detailed presentation 18 because they have their knowledge very ready at hand.
19 And I would like to introduce Bill Steiger. Bill 20
.will be my replacer-sut.
He will be working directly for 21 Tony Early, effective the 1st of August.
I will be moving 22 to another position in the company, but you haven't lost me, 23 yet.
I'm still in Emergency Preparedness and some of the 24 quality assurance and reactor operator training.
That sort' 25 of thing.
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Bill has had many years with the Shoreham plant 2
and for the last effectively seven Years, he has been the.
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-plant manager.
The last couple of years of construction and
-4 since the plant was in an operational mode five years, the 5
immediate last five years, he was the plant manager before 6-he completed up to where he is.
He is very, very qualified 7
to replace me and a very fine manager.
And Bill will 8
discuss the plant at this time.
9 MR. PARTLOW:
Can I ask a question, John, 10 regarding your objectives.
Both you and Tony have spoken to 11 your declaration to abide by all the requirements of the 12 license.
The contract with the NRC in many ways goes beyond 13 the legal requirements of the licensa.
The various 14 commitments that are contained in the safety analysis 15 report, the-various correspondence that might be with the 16 NRC committing to maintaining things a certain way.
Would 17 you speak to your objectives not just in maintaining the 18-legal requirements of the license, but in maintaining such 19 things as the safety analysis report, other commitments to 20 the NRC?
21 MR. LEONARD:
We intend to keep the safety 22 analysis report updated.
In fact, I would expect sometime 23 between now and the end of the year, we will send you a 24 change in the safety analysis report.
I think Mr. Early, I
-25 don't want to put words in his mouth and I would rather have Heritage Reporting Corporation (202) 628-4888
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him. speak for himself, but as far as the site, now, we 2
intend -- we have research commits'ents, we have researched 3
the tech specs, we have researchel the USAR and we feel we 1
4' are living within those bounds.
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MR. EARLY:
It is our.ntent to meet all of those h
6 commitments.
Now, there may be s<me commitments that.just 1
7 don't make sense.
The best examp.e, probably the largest 8
area right now where we are not dsing things, commitments 9
for the first refueling outage, where we say we will do X by-10 the first refueling outage, we're not doing any work on them L
11 right now because it doesn't make sense.
We are -- LILCO 12 will never get to a first refueling outage for Shoreham.
13 But where we have committed to do something that is 14 applicable to the present state,-those commitments will be 15 met or we will discuss with you where we can relax some of 16 those commitments.
17 MR. PARTLOW:
Okay.
18 MR. SCINTO:
Yes, I wanted to interject a 1
19.
thought. At this point, I think my concern is the 20 recognition, our regulations are govern this plant, that-12 1 govern this plant in its present license condition.
22 Regularly, for a operating plant, for a plant that is 23-running at full power, or it intends to run at full power, 24 we have a lot of experience with what you intend to do, how 25 you intend to go about that.
The operating utility, the Heritage Reporting Corporation (202) 628-4888 l
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experience of the industry is directed in that direction.
2 This is a fairly rare event in what LILCO is doing.
We want 3
to make-sure that custom and practice for a full-fledged 4
1perating plant are carefully considered and the regulations 5
and the processes that are called for by the regulations are 6
properly applied to the circumstances of this instance.
7 MR. EARLY:
Joe, we are very sensitive to the 8
process and making sure that the documentation is correct.
9 One thing I would ask of you because I think this is a 10 two-way street is that we be treated like other licensees in
.11 that your focus is the health and safety of the public and 12 the focus of what, how you are reviewing us ought to focus-13 on is there a risk to the public health and safety, in 14 addition to meeting requirements.
And I think it has to be 15 looked at in that context.
And that is very important.
16.
Not, "Well, if the plant were to operate at some time in the 17 future, is this needed?"
18 We have to look at here and now and LILCO's 19 commitment that I reiterate that we cannot and will not 20 operate the Shoreham plant.
21 MR. SCINTO:
I agree.
We recognize it, but the 22 process is y' follow the rules and you follow the
-23 regulations.
In judging the way in which those may be 24 modified to reflect the condition, sure, the safety of the 25 conditions at the plant govern.
But the judgment as to what Heritage Reporting Corporation (202) 628-4888
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e-19 1-processes to-follow to get from the authorization to run the 2-plant at full power, whatever your intentions are, are one.
3 But you presently have authorization to run the plant at l'.
4 full power.
And to get from there to wherever you want to
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5 get, there are procc,ses to follow.
I think I hear you F
6 saying that you in fact will follow them.
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MR. EARLY:
We will follow those processes to the 8
letter.
I think your comment, though, is valid:
Nobody has 9
ever been here before and we need your help and guidance as 10 to what you think the process ought to be, 11 MR. MURLEY:
We accept your assertion, your 12 statement that LILCO does not intend to operate the plant.
13 We can't foresee the future.
We don't know if the plant 14 ever runs or not.
If it doesn't, it has got to be 15 decommissioned at some point.
We don't.want to'see a'de 16 facto decommissioning.
There's got to be plans and 17-procedures that have to be followed.
And we don't know any 18 other way to do it, but to strictly follow the regulations.
19 And that is the point of this discussion.
20 Bill?
21 MR. STEIGER:
What I will briefly run through 22 with you is what we are currently doing at the station for 23 the current point in time.
As John mentioned earlier, what 24 is going through and is the common thing through all of the-25 activities-done by each of the departments within the Office Heritage Reporting Corporation (202) 628-4888
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of Nuclear are the same objectives.
Defining what the 2
posture is, controlling the cost, meeting the requirements 3
of the license and keeping you informed.
Those are the 4
things that sit in front of everyone.
5 The question is what does minimum posture mean 6
for us right now?
Well, at the present time, we are in the 7
' process of'defueling the reactor.
As of this morning, we-B have about 287 bundles out of 560 and they're in the spent 9
fuel pool.
10 What we are doing with our tech specs at the
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11 current time is that we are minimizing those tech specs
'l 12-where everything is maintained operable to the conditions' 13 that the plant is in which happens to be all tech. specs 14 i
associated with fuel movement which is OCS for handling the l
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15 radiation fuel as well as those applicable at all times.
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16 Just.to give you an idea of still how current i
17 everything in the-plant is, we only have 19 active LCOs at
'i 18 this point in time and 8 of them are restraints to startup.
19 That is'to give you a level of how we are maintaining the 20 facility at this point in time.
21 What we are doing internally in the plant is we j
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.are looking at all 124 plant systems and what we are doing l
l 23 is evaluating what we see the long term conditions under the 24 OL where the plant will not run, how we would maintain those
- 25 systems.
Forty would remain operable.
Either the whole l
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system or some portion of that system in terms of meeting 2
the operability definition of the tech specs.
3 Another 41 would remain functional.
It would be 4
where the system io maintained.
It's in good condition, but 5
the surveillances are not current for a tech spec system 6
where it is a supporting load, like an instrument air system 7
is functional, it doesn't have tech specs.which you maintain 8
it, so, we call it functional.
9 Seven will be preserved.
Those are where you 10 wouldn't normally be running it or need it.
An example.of.
11 that is_HPIC or RCIC where it_doesn't meet any conditions
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12 unless they are up in Condition 1 or 2.
So, that would be 13 left in.that condition and 36 others will be secured.
That 14' means they would be de-energized and would be drained and 15 purged and dried out or left in the condition they are.
16 Some of them are oil systams.
17 So, we are currently complying with the existing 18 tech specs.
We don't anticipate any immediate changes.
19 What we would currently do is reviewing everything to 20 determine what changes would be made.
We will reduce 21 surveillance and PMs to be consistent with operable systems
' 22' in maintaining systems functional or in one of those four 23 conditions.
24 We maintain essential support systems.
We will-25 deactivate procedures for systems which will not be Heritage Reporting Corporation (202) 628-4888
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maintained operable.
There are some systems we wouldn't 2
use.
We would run them. They would be de-energized.
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'3 will put those procedures in a hold status, deactivr4ted and 4
just leave them the way they are.
5 All plant improvement modifications that we have 6
made and we have several modifications on the books.
We 7
will not make plant improvements anymore.
We don't intend 8
to run the plant.
9 And we will review tech specs to-a minimization 10 and systems reduction which is what we are doing right now.
11 We understand what systems need to be maintained operable.
12 That's what we are doing.
13 And we are talking to other plants who have been 14 shut down for long terms, like the TVA plants at: Browns 15 Ferry, Peach' Bottom, to get a feel for what conditions they 16 have been-allowed to stay in since this is new ground for 17 us. - We have always maintained the plant full ready to go at 18 all times over the last five years.
So, we are keeping in 19 tune with those people so we are consistent with what has 20 been acceptable in the past.
- r 21 MR. PARTLOW
Question, Bill, a question on that 22 slide.
If I had understood the names on your systems, the 23 bullet that says, " Reduce surveillances and PMs to be 24
-consistent with," I thought that would have said 25
" functional" systems.
Heritage Reporting Corporation (202) 628-4888
.i_
1 23 1
MR. STEIGER:
Most of the systems that are 2
classified as functional don't have surveillance activities.
3
.They are non-tech spec systems.
There may be-a few systems.
l4 in there.that are tech spec systems, okay?
P at the 5
surveillances are only required in conditions 1 or 2.
We 6
are not going to maintain condition 1 or 2 surveillances.
7 It would never go in there.
So, we-would not do those 8
things.
9 If we have surveillances required for a shur -down 10=
condition, those will be maintained.
So, if you have a system th't only operates, the classic one that is easy.for 11 a
12 you.to relate to is raw block monitoring.
Well, that's not l
13 going to be operable because the surveillance isn't going to 14 be done.
That is the type of activity we're talking about.
1 15 MR. MURLEY:
A couple of thoughts on the comments 16' you made.
I think at some stage, we need to get an idea of 17 how long you intend to be in this kind of a mode.
I 18 realize, you know, predicting the future is kind of j
19 difficult, but it has got to enter into our thinking as to 20
'what you are telling us here.
21 MR. EARLY:
I think that is going to depend upon 22' how long it takes to transfer the license.
It is my goal to 23 be in a position to make an application to you before the 24 end of the year for the transfer of the license to the State 25 of New York.
And then it is up to the hearing process how Heritage Reporting Corp 6 ration (202) 628-4888
.. u 24 1
long that takes and how long your review of that transfer 2
' takes.
You know, it could be six months.
It could be 18 3-months.
You know,'I'm sure you can't predict and we can't 4
predict.,
5 MR. MURLEY:
Okay, but your thinking and your 6
actions allow for the fact that it may be as long as 12,-16, 7
18 months or even longer.
And this is to sustain them.
8 MR. EARLY:
Yes, as Bill said, we are talking to 9
plants that have had long term shutdowns so that we can get 10 ourselves in the position there is something very similar to 11-things you've seen-already and, hopefully, are comfortable 12' with.
13 MR. MURLEY:
Well, that brings me to my second 14 point.
I am not totally sure if you go to-places like 15 Browns Ferry.that that is a good example of what we would 16 allow today.
I'm just not sure.
To some extent, they got 17 Linto a situation there that was worse than we though". and 18' they had different circumstances.
19 We're going to judge this kind of on its own.
We 20 are not going to hold you to any higher standards.
But I am 21 just'saying that our thoughts today are probably a little 22.
different than what they were five-years ago.
23 MR. STEIGER:
The operations people have been 24 talking to other plants.
I just mentioned that is one of 25 them.
We have been talking with Peach Bottom and Pilgrim, Heritage Reporting Corporation (202) 628-4888
~ - " " - ' ' ~ " "
.1.
f
._.14
, 2 5.
'a305they have been.down for quite a-long time.
And the on wa;did"that is'because wa felt-it was more current.
,no'clOo in Region 1,.Eso, we know what-Bill Russell's.
iognight1 be looking to see down for a period of time.
<3dcro looking_at those facilities.
1 MR. SCINTO:
And this is the' point I wanted to tj0ct?o thought.
The recognition in those other plants Lin'intcntito eventually bring that plant back on line.
.hcro may-very well.be non-tech spec systems that don't ordinary ~surveillances, but from the normal prudent
~
- ty m nagement, knowing that'.they want to bring the
'b0ck'oni ine, they would undertake the customary ---
l
~
uciocr grade -- but standard customary preservation
-entnes activities, i
Youldon't intend to bring this plant.on line.
think the point' Tom was' making before:
We don't' i
t toElet' youblet those: other systems deteriorate by 11gnoring~them,- even though they are.not tech spec cm3.
MR. EARLY:
We understand that'and, as I said, we
' intend to have the plant fallLapart.
We intend to do
'pritts prudent things and that's why we would like to four:peoplet come up and review-the details if there is AnputJonKit.
But, Bill, there are many systems, electronic,
. Heritage Reporting Corporation
/
(202) 628-4888
i-26 1
electricity, where you just don't do anything, they don't 2:
' deteriorate sitting there.
3' MR. STEIGER:
Let me give you a little example to 4
follow up on that..You can do a couple of things relative 5
to preserving a system that would keep you current with your 6
license.
You could run it as if you would run it everyday.
7 You could drain it and put it in nitrogen, you could drain 8
it and purge it with air, dry air.
We are evaluating those 9
three right now.
It is more economical-in many conditions 10 to drain the system, fully purge the system until the system.
11 internals are dry using regular instrument air, which is 12 very dry air, and leave the system in that status.
You 13 reduce the potential for oxidation and corrosion.
l 14 So, we are looking at the different methods of-l 15 doing that and keeping the cost at the same time-to us as t
l 16 low as' we can do it.
Final decisions haven't been made on l
17.
those, but they are all being evaluated right now.
18' Just.to give you a feel of the type of changes l
19 that we are talking about looking at right now, what I am 20
. talking about here, is after all the fuel is out of the core 21
.and everything is into-_the spent fuel pool.
22 MR. MURLEY:
When will that be, Bill 23.
MR. STEIGER:
We figure by August 8th to the 24 10th, sometime in that time frame.
There will be reductions 25 to surveillance activities.
Those are primarily, strictly Heritage Reporting Corporation (202) 628-4888
27.
~1 off the condition, you know, what operating condition you're n:
2 going into, procedures that would be maintained current.
o 3
NWRs that we would project because some systems are at the 4
energized condition.
We're no longer running the pumps and 5
all of the equipment. And the PMs.
6 So, you can still see there is an awful lot of e
E 7
activity that is going on that will be maintained even-N 8
though the plant is shutdown.
')
Now, with respect to the staffing, what we-have 10 done so far to date is we have evaluated the long-term work 11 load -- what we would be continuing in the future -- and we 12 have evaluated the staffing that is needed to support that 13 activity.
And, as a result of that, we still need 269 LILCO 14 people on the property to support that and we will still be 15 having -- we have a maintenance contractor on the property.
16 We will still be having 47 of his people on the property in 17 support.
18 And, as Tony mentioned earlier, a 45 to $55 19 million budget is not chicken feed.
That's quite a bit of
-20 money to maintain a facility.
21 We have reduced consultants.
All of our staff 22 reduction occurs after we have. moved the fuel and it's into 23 the spent fuel pool.
24 We have evaluated positions and'a number of 25 excess personnel.
We have released some of the excess Heritage Reporting Corporation (202) 628-4888 1
l
I 28 1-personnel. That is the' difference between 356 and 269 LILCO 2
people. Those people are LILCO employees.
They are'placed 3
within the Long Island Lighting Company.
That process is 4
going on as to where they will go.
I have had aneurances 5
fron 6
Mr. Early that, looking' ahead, if we have a higher attrition 7
rate than we would expect and I get caught in a bind where 8
it.is difficult to maintain the license and I need people, 9
the two options we have is we will allow the transfer of 10 people back to Shoreham so they can maintain the license 11 correctly or we will go outside and we will bring in the 12-necessary qualified contractor personnel so that we can 13 maintain the license.
14 And we are currently maintaining the organization 15 charts for Chapter 6 of the tech specs.
There is no changes 16-in the plant organization.
17 MR. RUSSELL:
Would you describe the process that 18-you' re using. to determine and effect these reductions?
19 MR. STEIGER:
What we have done is evaluate --
20 MR. RUSSELL:
In the context of the questions Joe 21 asked earlier on the regulatory process.
That is:
How are 22
-you effecting these changes because they are in fact changes 23 from what existed the day we briefed the Commission as to
'24 what your intent was and at that time we were talking about 25-transitioning from contractors to permanent staff and it's Heritage Reporting Corporation (202) 628-4888 1
n-i 29' l
1
- aboutJa 40~ percent total reduction..
What process are you.
.2 using1to make those changes?
o 3-MR. LEONARD:
Bill, let me answer that.
We're J
4 talking about the whole Office of Nuclear Operations here, i
5-not just the staff. In these cases and I think Jim saw what 6
we were doing.
We are reviewing the replacements in terms 1
7 of their qualifications, whether.they meet the ANSI J
1 8
standards, whether they meet the tech spec requirements, 9
whether they meet the USAR requirements.
We are doing that.
10 And I believe in a conversation with the Region, 50-59 was 11 brought up, we really think 50-54 is more applicable, but we 12-
, are doing -these reviews so that we don' t have an unqualified -
13 person-.
14 MR. EARLY:.Also, as you will see from the 15 presentation, we have done a detailed analysis of the
~ 16 requirements that have to be maintained, the physical work l
17
-that has to be done, the. engineering work that has to be 18-done.and then-figuring out what level of staffing is needed l
l 19 to support that and that's how we come up with the numbers.
-20 MR. LEONARD:
A specific example is we have said 21-that some aof the t.ngineers we can release are the shift L
22 technical. advisors, the STAS; since we will not operate che' 23 plant, we could release'the ains.
i.
L 24-
.Now, we are also looking if those STAS would be 25 more properly placed in other positions in the staff that Heritage Reporting Corporation (202) 628-4888
g ll iLJ 30L 1
was permanent out there.
And that decision is being made.
2-MR. RUSSELL:
But you are making that' judgment 3
based upon what the people have to do based upon a shutdown 4
plan.
'S MR. LEONARD:
Correct.
6 MR. RUSSELL:
With the conditions that exist.
7-MR. LEONARD:
And'the tech specs and the USAR.
I 8
mean we have written you a letter.
We had a resignation of 9
our radiological controls manager, Dick DeMasio, who has
-10 left to go to-another utility.
We have replaced him with a 11 gentleman that is imminently qualified:
Dr. Maw Sen Naw, an-12 excellent person in that field.
13 He, however, lacks one aspect-of the 14 qualifications which is two months,-- is that right, Bill?
15 Two_ months at_ the plant above 20 percent power.
16 We have stated in there we have no intention oE
.17 running the plant.
However, should anything change for some 18 reason, we would immediately insure that you got those 19 qualifications before'anything was done.
20 MR. RUSSELL:
So, these changes that-you've made 21 when you reviewed against the FSAR or other commitments as-
. 2:2 Jim asked, that's in some type of a documented review that 23 is available.for review by the Commission?
24 MR. LEONARD:
Well, we-sent you a letter stating 25 we have done the review.
I mean there is no document that I Herithge Reporting Corporation (202) 628-4888 l
1
'4.
31 1
know that shows Bill Steiger meets all the qualifications of 2
Vice President of Nuclear Operations except the fact that 3
-his resume shows that he does.
4 HR. RUSSELL:
I understand. Those are single S
individual changes which occur.
We're used to that process.
6-We see that at operating plants.
I am looking more at the 7
changes to staffing from that which was. proposed'at the time 8
the full power license was issued to the changes you're 9
proposing now based upon your work load analysis and whether 10 that review process would meet the intent of 50-59 as it 11 relates to a change to the conditions, a change in the 12 facility which is potentially a permissible change under
-13 50-59.
Is that process that you followed available for 14 review?
15 MR. LEONARD:
It would be very hard for me to 16
_give you a flat yes on that.
Imeantdkeatechnician, a
17 qualified technician under the ANSI standards.
And we 18 declare that this technician because of the reduction and 19 surveillance requirements is available to return to some 20 other place in the company.
Can you see a specific piece of 21 paper addressing that technician, his qualifications?
The 22 answer.is really not -- no, I can't say that.
23 MR. RUSSELL:
Based upon the last slide you had 24-up, you had a staff reduction from 356 to 269, You must 3
25 have done that on some basis?
Heritage Reporting Corporation (202) 628-4888 I
32 1
MR. LEONARD:
Yes, we.did.
Maybe Bill will 2
answer it as he goes along in his presentation.
We can come 3-back to it again.
4 MR. EARLY:
He will be able to describe the 5-process.
6 MR. DAVERIO:
Sill, we did commit to Jim when he 7.
was up that we were going to write you three letters.
We
'8 have completed the first two which were the individual
'9 letters, individual moves, the Dr.-Maw Sen Naw move, the 10 third letter which we' re still working on is a letter we 11 committed to write on the process we did to get to the 12 numbers.
That is being worked on as we are sitting here 13 back in the home shop.
And then it will go up for John's 14 signature.
I think that letter will be the one that 15 explains the process we went through to get to.these 16 numbers.
And that's what we committed when Jim was. up.
17 MR. RUSSELL:
And the basis for your conclusion-
- 18 that these are appropriate to maintain all your commitments.
19 MR. DAVERIO:
It would be the same type of letter 20 we sent you on individuals, but now for the whole 21 organization.
That was the commitment we made when he was 22 up.
23 MR, STEIGER:
To give you an update on our 24 current activities.
We are currently involved in four off 25
. fuel activities.
Things which we have already done include Heritage Reporting Corporation (202) 628-4888
'I 4
33 1
obtaining the fuel' load changes.
We picked up'some from 2
Boston Edison, somt from TVA.
Those are the ducking 3
chambers.
We have those.
In f act,- they' re instil 3 ed now.
4^
They are just starting to be installed.
5 We have trained a refue1 bridge personnel.
We 6
have gone back and to people that have done it before, we 7
actually moved the dummy in the spent fuel pool until people 8
got familiar again with the operation of the bridge because 9
they hadn't done it in a while.
So, that training was done.
10 We've done an inventory and inspection of all equipment that 11 we need, all the PMs current for the refuel bridge, 12 everything, that's all been done.
_ 13 We did practice lifts and reviewed all the 14 procedures and made sure all that was current before we 15-started to do anything.
16' To date, we have completed a temporary mod.
That 17 is we installed an external vessel level and refuel cavity 18 sensing.
19 We looked at check down leveloinstruments.
We've 20 done all of-the transfer sheets.
That's all been completed.
21-All the maintenance work requested to disassemble.the 22' vessel, the vessel's been disassembled.
All the activities 23 are in place to dd core off-load.
24 To show you where we stand with respect to our 25 schedule of activities, we did all of our support Berltage Reporting Corporation (202) 628-4888
34.
1 activities, disassembled the vessel and we' re about half way 2'
through'the. core off-load.- When.we have finished offloading 3
the core, the nuclear instrumentation and the sources will
'4
' remain-in the vessel.
The vessel will be at normal water
~5 level with the internals, the dryer and the separator 6.
restored, the head sitting in place, but not tension to keep 7
the missile shields back.
So, that will be the final 8
condition which everything will be remaining.
9 Some. of the support activities that we have done 10 at this point in time, we've updated our procedures, like we 11 did the equipment, we did the mods, we trained the people.
12 We got the chambers.
And all that's finished.
13 The vessel has been disassembled, the shield 14
~ plugs, these activities are also all completed.
15 This is what is in progress >right now.. The 16' ' assemblies are out, like I said,.287 are out.
The blade 17 guards are going into the RPV for the control blades.
18 When we are finished, we will drain the cavity.
19 We will reinstall the vessel, put'the shield plugs back in 20 place.
That's the way we will do-the-plant.
21-As I said earlier, with respect to the people, in 22 the plant area, itself -- this is not-the total Office of 23 Nuclear.
This is just-the plant.
It doesn't count 24 engineering.
It doesn't count delay.
It doesn't count the 25 operating support department.
Heritage Reporting Corporation (202) 628-4888
w.
J 35 1
1 There was an authorized complement of 449 people.
21 1At the time you gave us the license, we had approximately 3:
356 people, give or take-a few.
We propose to go to a 4
staffing of 269.
And that 269 is based on our ability to do
~
5 the surveillances and preventive maintenance requirements on 6
a system to maintain the system to allow us to hold the 7
license.
We recognize that 269 would not be the number you' 8
would need to'go to full power operation through power t
9' essential test programming. But it is the number we feel is.
10 appropriate to maintain the plant.in the condition that we 11 intend to leave it.
12 Mr. Early has submitted a letter, I believe it 13 was to you, Dr. Murley, or was it to Mr. Russell?
14 MR. EARLY:
15 MR. STEIGER:
Indicating that before we would 16 ever run the plant, we would come back to the region and the 17 region would evaluate that we had sufficient staffing tolio L,
18 that.
19 MR. EARLY:
And I think that that's a point that u
20 you ought to consider whether you issue a license condition, I
21 a confirmatory action letter or we have some kind of consent l
22 order or consent decree embodying that so you are 23 comfortable.
I mean we hold a full power license.
Many 24 people hold: a full power license and are not operating the 25 plant'and you want to come back for another bite of the Heritage Reporting Corporation (202) 628-4888
36-1 apple-before anyone can do anything.
!2 The purpose of my letter to Bill Russell was to 3
give you that indication but I'm not sure what form we might-4 want-to put that in, but if you are comfortable with it, we 5
certainly would like to talk to you about how we do that,
. hether it is a confirmatory action letter or some other 6
w e
'7-mechanism.
8 MR. LEONARD:
I was mistaken in the area Bill 9
Steiger was going to address on the review of these systems, I
10 so, let me interject something.
When we came down to brief 11 you, we had a black book that we addressed.
John Scalice 12 did.
That was one chapter out of a large number of system 13 chapters and I think Frank has seen those books and the way 14 we went through this is we took a system, we look at that 15 system in detail.
The plant staff did, the system 16-engineers, the operators, and it was reviewed by the Review 17 of Operations-Committee to determine what-had to remain a ~
18 functional in that system to meet the requirements of the 19 tech specs.
20 Once we found that out, we determined what 21 surveillances had to be done, what preventive maintenance 22 had to be done.
That led to looking at the staff, who must 23 remain there, with what1 qualifications.
That has been done.
p
-24 That will be-documented by a final Review of Operations 25 Committee review.
It was presented to our Nuclear Review Heritage Reporting Corporation (202) 628-4888 m
e 4%,
7 s
37 l'-
Board.
2 So, we feel that meets the requirement. And we
'3 have no problems putting in writing that type of procedure d
4 for you.
But what I said is for each person, you would not 5
find a single sheet of auditable paper.
6 MR. MURLEY:
John, at the risk'of sounding 7
tedious here, it is partly what you just said that causes me
-8 at least some concern..
It sounds like you've gone.through L
)
9 and said, "What is the absolute minimum that you neod to l
10-keep a-system in compliance with its tech specs."
And based 1
11 on that absolute minimum, you then determine the absolute l
12 minimum number of staffing.
And what I am concerned about L
13 is that you at some point stand back and look at'the whole 1
14 thing because it could very well be -- we didn't draft these l
't'ech' specs ~and write them on the basis that a plant would be l
15 16'-
in the extended non-operating period for months, if not I
17 years, on:its way to decommissioning.
So, we don't know-L 18 that-there may be certain parts of the. plant that could just i
19 turn into rust buckets under our tech specs. So, we would 20 like you to stand back and look at~the whole thing, too.
211 Now, that is about the third time we've said it, 122.
but what you just said triggered the thought, again, that L'
23 there is-annovera11 consideration that we have that the y
J24 -
plant not turn into --
25 MR. LEONARD:
Let me give you a clear-cut Heritage Reporting Corporation (202) 628-4888 9
l l'
c.
o:
38 1
example.
In our group, I think there is something like 30 2
janitors.
Now, if we were going to let the plant 3
deteriorate and get dirty, rusty, filthy, you wouldn't have i
L 4-30 building attendants to keep the staff, the appearance, S
cleanliness and painting of the plant up.
That's just an 6
example.
7 MR. MURLEY:
Maybe I just need additional
~8 reassurances.
L 9
MR. RUSSELL:
Let me clarify my questioning with l
10 an example, and bear with me.
You used the example of the E
11 STAS.
Let me use the example of the STAS.
12 There are certain commitments in the FSAR as it l
13 relates to STAS.
A licensee can make changes to the FSAR
.I 14 via a process and then four months later with the routine 15 updates or at some other time as to what are those changes-16' to'the application.
That process is 50-59 process.
It is I
17 one that the region routinely inspects.
18 The reason I am asking the questions is because 19 my staff is going to needing to inspect the process that you 20 followed in making some of these changes.
And what you 21 indicated is.that you are going to be making changes to 1
22
. STAS.
You may.let them go, you may move them to some other 23 part of the organization.
I am interested in the process 24 that changed the INSM). to conclude that whatever it is you-25 ~
are going to do is acceptable pursuant'to 50-59.
l.
Heritage Reporting Corporation (202) 628-4888
i 1
c 39 1
And that is why I'm emphasizing vis-a-vis, 2
process.- The mechanism.
Now, you may have done something 3
e>guivalent to, you may be able to put together the details 4
of what~you have done already in staffing and put it into 5
the context of a 50-59 change, reviewed to make sure it 6
doesn't constitute an unreviewed safety question.
It
-7 doesn't impact the tech specs, the standard process 8
requirements far a 50-59 change,.but it does appear that 9
there are changes that you are proposing that could impact 10 sections of the updated FSAR and/or other commitments made 11 to the NRC in the process of doing that.
And because we are 12 going to be inspecting that, we need to understand what that 13 process is and that was the reason for the questions that 14 you proposed to send some letters in to describe what that 15 process is.
We need to be able to understand that and 16-follow.it.
17 MR. STEIGER:
You may get a better feel'if 18 Mr. Daverio goes through with what we're doing in the 19-licensing area.
What we have done in the, plant is look at 20l the tech specs to determine what tech specs need to be l
21 maintained current and what don't.
22 We recognize that that does not encompass all of 23 the requirements or commitments to maintain this facility.
24 There are many other things that are in the USAR and in the 25 FRAR and several other documents with which we remain Heritage Reporting Corporation (202) 628-4888
40 1
committed. Licensing people have gone through those 2
documents.
They have matricized them and they' re going back 3
out to the department managers and they wi!.1 then evaluate 4
what is currently in the USAR or FRAR and any other 5
documents that we have for the condition the plant is going Jgg 6
to be maintained in, the non-operating condition.
7 Where we feel it is inappropriate to do 8
something, we will do the 50-59 analysis and inform you of 9
what we intend to do so that you are at least on board with 10 everything and what our intentions are.
But we recognize 11 that tech specs only has a portion of them.
12 When I'm talking the plant piece, I am talking 13 what the plant is doing right now looking at tech specs.
14 Chuck's group has looked at and said, "Okay, here's a lot of 15 other commitments, let's look at these, too, and how they 16 affect the plant."
17 Some, we will have to continue because it is 1B oppropriate to do so.
Some, probably not be appropriate. to 19 continue.
We will do the analysis and keep you informed.
20 What we have been doing is been keeping the 21 resident informed of what's going on and we asked Frank if 22 he has any questions, please let the region people know.
23 Bring up the people, take a look at what we' re doing.
24 Our intention is to fully comply with our 25 license.
And we recognize we are working on new ground for Heritage Reporting Corporation (202) 628-4888 i
.s 41 1
us, but we are also looking to what you have previously 2
found acceptable for plants that have been down for a couple 3
of years in the region so that we are consistent with what 4
previously has been allowed for a couple of --
5 MR. RUSSELL:
The only issue is the examples you 6
used at Pilgrim and Peach Bottom, I would submit that the 7
staffs substantially grew, the amount of meintenance on 8
balance of plant went up astronomically.
There was an 9
intent at the end to start up and operate the plants.
So, 10 they moved in the other direction from what you're il proposing, so, I am not sure I would completely agree with 12 those examples.
13 From your presentation, I am confused.
Has the 14 reduction in staffir.g begun today?
Are you reducing today?
15 MR. STEIGER:
What we are doing right now is we 16 are evaluating thw placement of people.
Only a few people 17 have left, ve y few.
We intend to hold the people until the 18 core is offloaded and we are in a stable long term condition 19 with the facility.
So, we have all the people there at this 20 point.
21 MR. RUSSELL:
Does that include the contractors?
22 MR. STEIGER:
We are releasing them at this point 23 in time because most of their work was modification work 24 that we're not doing.
25 MR. RUSSELL:
But the contractors that you had Heritage Reporting Corporation (202) 628-4888
1
]
.o-1 42 I
1 that were filling the positions, the transition plan --
2 MR. LEONARD:
They are being released now.
1 3
MR. RUSSELL:
They are being released now.
i l
4 MR. STEIGER:
They have been notification.
Most 5
of them are involved in activities that we are not 6
performing.
7 MR. LEONARD:
Not all, however, but most of them.
i 8
MR. STEIGER:
Mr. Leonard wi?,1 review what is 1
9 going on in the area of our engineering department.
l 10 MR. LEONARD:
Bob Kascack, my manager of Nuclear J
11 Engineering, was not available for this and I will do the l
12 presentation for him.
Again, let me mention that Bob is, 13 has been the manager of Nuclear Engineering for the last 10 i
i 14 months and he will continue to be the manager of Nuclear l
15 Engineering, which will add a significant amount of 16 stability to the whole Office of Nuclear Organization.
17 Again, I'm sure you are tired of seeing these, 18 but we feel it is very important to understand what our i
19 objectives are:
esteblish the cost consistent maintaining i
20 the licensing, and the other thing, and certainly I think 21 you can see we ere keeping you briefed on what we are doing.
22 As far as the minimum posture approach, the 23 Nuclear Engineering, again the responsibilities, work tasks 24 were evaluated for engineering and support organizations.
25 And they include the nuclear engineering department itself, i
Heritage Reporting Corporation (202) 628-4888 l
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the office of engineering which is the other engineering 2
function in LILCO that supports ShorehTm, Stone Webster 3
Engineering Corporation and General Electric.
4 Now, there are continuing service contraces for 5
t ' s latter organizations and they will remain in ef fect.
We r
6 enn call on them to do any engineering that is required.
7 Should any emergency develop out there,
- e. hey can come in 8
very quickly and come in and handle it.
9 After doing this, a minimum organization staff 10 structure was developed.
We have deferred or cancelled long 11 time activities, first refueling outage modifications, that 12 sort of thing.
We are minimizing the use of contractors and 13 we will probably send in a minor revision to the USAR l
14 because we think we can optimize this organization, make it I
15 operate better with a slight reorganization.
16 MR. MURLEY:
John, there is an element -- if I'm l
17 getting ahead of you -- but there is an element I don't see l
18 there.
And that is maintenance of records and maintenance 19 of commitments.
There is a continuing stream of 20 correspondence from NRC, for example, to all licensees.
21 MR. LEONARD:
Chuck Daverio will mention that.
22 1md I will just give you the bottom line.
We intend to 23 maintain a comprehensive set of records.
So, when the plant 24 is transferred, a comprehensive record is transferred with 25 that.
The reason we're doing it is two-fold.
It is to Haritage Reporting Corporation (202) 628-4888 4
i 44 1
protect ourselves because we feel thL it is necessary from i
2 that point of view.
Also, we feel t at your regulations, 3
such as the new decommissioning rule, mandate thatt that a I
4 comprehensive set of records exists for the plant and the i
l 5
NRC review.
So, we are crying to stay out of trouble with j
1 l
6 you.
We are doing it out of our enlightened self-interest.
l 7
All of those records will be maintained and 1
i
(
8 transferred when the license is transferred, j
1 l
9 Chuck, you are going to get into that some, 1'
l 10 aren't you?
l l
11 HR. DAVERIO:Yes.
l' 12 These are the activities that.equire continued i
13 engineering support.
Obviously, on site engineering support l
14 for the operable plant systems and structures.
We intend to 15 keep these programs going, chemical control, seismic qual, 16 ALARA station mods.
l l
17 Now, it may seem strange to say " station mods" l
l 18 after I have said we are not going to do any modifications, 19 but we feel there may be mods required, let's say, to rad 20 waste systems if you were circulating fluids in the plant, 1
21 or if you had to do something, if you were going to pull l
l l
22 fuel out, you might have to modify the crank.
So, we are L
23 going to keep that modification program intact, all the 24 procedural compliance there, all the administrative L
25 procedures ready to go should it be needed.
l Heritage Reporting Corporation (202) 628-4888 e
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45 1
And, in fact, we are making a mod or have been j
2 making a mod at the plant to save money.
We have been 1
3 putting in fire detectors so we can reduce the number of 4
fire watches.
And that is a cost effective modification i
5 that actually saves money.
It's in safety-related areas so
~
6 the modification program has to be used.
7 The radiation monitoring program Off-site dose
]
i 8
manual, in-service testing, rad waste storage and shipment, i
9 all those, obviously have to be supported.
We will continue 10 to do that.
We have to support the licensing group with i
11 engineering action, as we mentioned, we have just done a i
12 significant analysis on accidents at the plant in the fuel j
13 and the fuel pool condition.
14 And we have to manage the Stone Webster and GE 15 engineering contracts.
Here are some more that require some 16 work.
And I think that's self-evident.
/
l 17 Again, we feel that many of these activities can 18 be terminated.
Scheduled plant modifications, long term
]
19
' engineering studies, program upgrades, we will continue to 20 have equipment qualification, but we are not going to j
21 upgrade the program that we have.
l 22 The same is true of configuration management.
I 23 believe we had something like a 10-man inspection team about 24 a year and a half ago look at our configuration management.
25 7t wasn't a full configuration management inspection, but l
Heritage Reporting Corporation (202) 628-4888
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46 1
they were very pleased at how we did modifications, how we 2
kept the design basis of the plant.
It is just not a fully 3
computerized system.
4 You know, we say we're not going to go forward 5
with a big computerized system that vs had planned in 1ome 6
or the other areas.
7 MR. MIAAGLIA:
Those activities at the bottom of 8
that chart, John, just as a point of reference.
They were 9
ongoing initiatives where you were looking at had you gone 10 to operation to come up with schedules and things like that?
11 MR. LEONARD:
Correct.
12 MR. MIRAGLIA:
Mo'1 are you terminating those?
13 MR. LEONARD:
We are closing everything out so 14 that a knowledgeable engin0er could take it and move on from 15 there.
That's what we're giving -- we are not taking it and 16 throwin'g it away and putting it in the trash can.
17 MR. MIRAGLIA:
So, you have indicated what its 18 applice.bility is, how it might apply to the facility, how it 19 could ke.; been handled.
20 MR. LEONARD:
Yes.
21 MR. MIRAGLIA:
But this is where it is.
22 MR. LEONARD:
That's correct.
23 MR. MIRAGLIA:
Closing and documenting that.
24 MR. LEONARD:
Documenting the closure, tying a 25 nice ribbon around the package so it will be available for Heritage Reporting Corporation (202) 628-4888 4
F 47 i
1 your inspection and it will be available for the state to i
2 take.
3 MR. MIRAGLIA:
And the same is true with the 1
4 first refueling --
5 MR. LEONARD:
That's corre.ct.
6 MR. MURLEY:
There may well be commitments that
{
7 come in between now and whenever you transfer the license.
P 8
MR. LEONARD:
They would be reviewed in the i
9 normal manner and answered.
You would be given an answer on 10 it.
I mean if something says we have found out that x-11 series of bolting is all subterfuge paper, we would give you'
-12 an answer of what we would intend to do.
I am not saying 13 the answer may be we wouldn't intend to do anything, but we 14 would answer that as we have in the past.
15 MR. MURLEY:
I guess there is a kind of a 16 question, it's a little hypothetical, I suppose, but as you 17 know, we have got a large vendor inspection program that is 18 now, the last year or more, have been finding substandard 19 equipment, j
20 MR. LEONARD:
Yes.
l-21 MR. MURLEY:
And even some falsified equipment.
22 And we have been asking licensees, each licensee in the 23-country to look at his plant and find out what he has.
24 MR. LEONARD:
I think we have been one-of your 25:
leaders, as a matter or fact.
Heritage Reporting Corporation (202) 628-4888
48 1
MR. MURLEY:
Yes, you have.
Now, what would be 2
your intention on something like that?
3 MR. LEONARD:
I would hate to answer myself since 4
I won't be the gentleman in charge at that time, but I think 5
we would look at that and determine whether it would affect 6
the plant and discuss it with you.
And let's say it is a
-j 7
very simple thing to do You have a special piece of 8
equipment, like of our skid-mounted devices and you need
.s 9
information on that.
I have an idea Bill would be 10 cooperative and furnish you that information.
If it means 11 you would have to tear apart every piping system and inspect 12 it, I would assume the answer would bei We-don't feel that 13 is applicable to this plant.
But we won't just ignore it 14 and throw it in the trash basket.
15 The minimum posture status for NED is the 56.
We i
16 are authorieed 114 people, actually I think the most we ever 17 had about a year and a half ago was 100, through attrition 18
-- natural attrition -- we've gone down to 70.
And we 19 replaced that with contractual help and staff positions and 20 we intend to go down after defueling to about 56, 21 The Office of Engineering, a similar situation.
22 Now, these pe#ple are not leaving the company nor are these i
23 engineers leaving the company.
They are with the company, 24 Should any need occur where they are needed, they could be i
25 brought back to a position where they could be used to do Heritage Reporting Corporation (202) 628-4888
v 49 1
whatever work is necessary.
That is particularly true of i
2 the Office of Engineering personnel.
3 A gentleman that might be dedicated to working on 4
Shoreham may now be dedicated to working on the North Port 5
Plant, but is there sitting at a desk and should if it be 6
needed he is available.
But, as you can see, we are still 7
keeping 27 of these people dedicated to supporting that 8
Shoreham staff.
9 MR. EARLY:
I think that is an important thing 10 when you look at the staffing.
I know you are concerned i
L 11 about that.
If we had said, "Look, we're not going to move 12 anybody.
Everyone is going to stay here."
I think we would 13 have lost a lot of people because these are very good 14 engineers.
They are highly motivated.
They would have left 1
l 15 the company and we would have lost them.
16 The strategy that we have taken is to guarantee l
17 them. positions within the company so we have got that talent 18 available (1) so it can be used continuing at Shoreham as 19 necessary, but also because they are good people used in the i
20 company.
I think this strategy that we have taken will u
21 maximize keeping the talent.
22 If we just said, "We're freezing everybody out 23 there."
There would have been a rush to find jobs 24 elsewhere.
l 25 MR. LEONARD:
This is the Nuclear Engineering i:
Heritage Reporting Corporation (202) 628-4888 l
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4
'50
)
1
!epartment and combined Office of Engineering and Contractor 2
Staff.
As you can see, it is going to be reduced from 36 to 3
5.
Now, again, this does not include those people that are 4
on the Stone & Webster contract.
I think there are about 5
22, somewhere between 20 and'30 Stone & Webster people under 6
that technical services agreement that remain in place and l
7 can be called on should an emergency occur at the plant to 8
aupport the plant.
9 The next thing I wanted to address briefly was 10 the spent fuel storage safety analysis because as I 11 mentioned at the beginning, we not only looked at this from 12 a regulatory compliance point of view, but in the real 13 world:
What is the health and safety issues respecting the l
14 public?
15 The plant configuration is for the storage
[
16 handling of spent fuel has not been chengedi The assumption 17 was made we would go into wet storage in the fuel pool.
18 Here is your radioactive inventory.
The only significant i
e 19' hazard is the 1560 curies of krypton 85.
All the iodines L
20 and those things are pretty well decayed off.
1 L
21 The.only way you can get out the other solids 22 really would be if you had a fire that would burn up the 23 core.
The only gaseous stuff you have is about 1500 curies.
24 And as I r:e ationed earlier, the heat generation is 550 25 watts.
The present plant configuration and racioactive Heritage Reporting Corporation (202) 628-4888 i
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51 1
inventory is indeed consistent with these assumptions.
2 We are at about the two-year period on this curve and that's 3
where the 550 watts are.
I think somebody told me that SMUD 4
had something on the order of 20 megawatts decay heat.
It's 5
a different ball game.
6 The safety analysis outiine, we looked at t!.e 7
following regulatory documents for guidance Design Basis 8
ftecident, Rad Waste Fuel Handling Accident, Rad Waste Time 9
Corrupter.
We would mention that our design basis accident 10 is a drop of a single fuel bundle on another fuel bundle and 11 125 of the fuel rod rupture.
- 12 We looked at that.
And you will see the graph of 13 the dosage.
I think it is something like 1.10 to the minus 14 8.
I have the graph.
15 We looked at a much more severe accident, also, 16 where the whole core is ruptured and all the activity that 17 can be released is released, not the solid fission product, 18 but the gases.
19 MR. MURLEY:
Are these off-site doses?
20 MR. LEONARD:
You will see that, yes, when i put 21 up'the slide.
22 MR. MURLEY:
Well, certainly, you can see the 23 problems that would cause doses to your workers.
24 MR. LEONARD:
Not very much even there.
25 MR. MURLEY:
Really?
Heritage Reporting Corporation (202) 628-4888
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1 MR. LEONARD:
Very, very small.
In fact, the 2
accident shows that the reactor building standby ventilation 1
system will not activate.
The operator has to be told he's 4
had an accident and turn it on.
But it is really -- it 5
doesn't matter -- the normal ventilation system, as you will 6
see -- I will just stop talking about it theoretically and 7
put up the slide.
t 8
This is the design basis fuel handling accident.
9 And note that it is a large scale.
You see 1.7 times 10 to 10 the minus 6 full body dose in REM and skin 1.5 10 to the 11 minus 4.
This is the exclusion area boundary results. It is 12 not, you know, really the problem.
13 This is the worst case where the whole core is j
14 ruptured.
Again, notice that it is the normal ventilation 15 system.
I mean I think even the fact that you don't have 16 many particulates, the RBSVS only brings it down to 10.
17-There's not a lot of iodines and things in there for the l
18 charcoal to take out.
It's mostly -
gases.
19 One one-thousandth of a REM whole body, nine i
20 one-hundredths of a REM skin.
21 I don't know whether I mentioned the evaporation 22 rate of the pool, but the assumptions they took in the 23 study, you know, my engineers are super conservative and L
24 they said that the fuel pool would be at 110 degrees.
In l'
25 the winter it is not at 110 degrees at the top of that Heritage Reporting Corporation (202) 628-4888 l
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53 1
building.
It is not even 110 degrees in the summer.
The 2
reactor building ventilation system would always be running i
3 at maximum velocity.
4 The humidity would be zero.
All you have to do 5
is walk out_in Long Island.
It's just like Washington.
The 6
relative humidity is not zero.
If all those things go into 7
effect, 1 think you get seven-tenths of a gallon per minute 8
evaporation.
It takes some';hing like seven months to get 9
down to the top of the active fueling.
10 We figured that a good safety system would be to 11 put a bucket in Mr. Steiger's office and if you wanted a 12 redundant system, I could have a bucket.
But the real world 13 safety I don't think is a problem.
[
14 MR. PARTLOW:
Given this, what do you intend to 15 do with your Emergency Preparedness organization 16 capabilities?
17 MR. LEONARD:
It will stay intact until we talk I
18 to you.
Chuck is going to mention that.
19 MR. DAVERIO:
Good morning.
I'll be presenting 20 the Nuclear Operations Support Department's program under 21 the posture that's just been explained by Mr. Leonard and 22_
Hr. Steiger.
23 We, of course, will show you the same slide and 24 we use the same objectives to get to a least cost, but 25 maintain our conditions in the operating license, make sure Heritage Reporting Corporatio1 (202) 628-4888
m j
e-54 1
we are prudent within the bounds of the settlement 2
agreement, keep you briefed and make sure we are doing i
3 everything we are supposed to meet our commitments.
4 We approached this in NOSD by reviewing the 5
regulations in the commitments to determine if all our i
6 programs and actions are necessary.
7 I will go through these quickly and then I will j
8 go through and catch some of the issues that you have 9
specifically asked us about.
j i
10 We defer necessary items as long as we could, but 11 still within the bounds of the commitments we have made to 12 you, reduced the planned activities if we could, and we have 13 been deferring some procurement activities.
If we have got 1
14 one in a warehouse, I am not necessarily ordering another
]
15 spare part because that comes under me.
l 16 Let me talk about a few issues you asked us 17 about.
You asked about records management.
And our records 18 management program is fully in effect and in compliance with 19 your regulations.
And, as a matter of fact, just in the 20 last. couple of days, we have been working on a new records 21 management problem that really isn't tied to the ANSI
(
22 standards, I think it is not a record as defined in ANSI.
L 23 It is the in process work.
The in process work really l
24 doesn't become a record until it has got all the right 25 signatures on it, but we are now developing a program to put Heritage Reporting Corporation (202) 628-4888
.. y 55 1
in place to handle in-process work in the records management 2
area so it is handled like a record.
Normally, you wouldn't 3
be doing that, but we are going to do that because that's
'4 the only way we can do it.
5 So, we are actually looking at this as we are 6
going along and adding programs like that.
7 They also, John or Bill, mentioned that we've 8
done a complete USAR review.
We have reviewed our USAR page
{
9 by page, commitment by commitment and developed a matrix 10 that we are now sending out to the other departments for 11 their review to insure compliance.
And in this document is 1
12 which department is responsible for that commitment, is it 13 potentially a 50-59 issue.
Now, it might not be in that 14 they are not doing anything but completely complying with 15 that requirement, but we have made a tentative check.
Maybe 16 this 50-59.
Think about it.
17 We have also looked at it:
Is it administrative?
18 Is it a testing or is it a procedure?
Which are the three 19 issues in 50-59.
And we have also tied the commitment as a 20 commitment to a system condition: operable, functional.
So, 21 we have got a complete matrix.
And if you come up, you can 22 more than look at our documents and we've got the' big black 23 books full of all these papers.
24 The other thing we are doing, we are also i
25 reviewing our SACR list.
That's the Shoreham Action Heritage Reporting Corporation (202) 628-4888
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56 1
Commitment Request list.
And that is a 'ist -- every letter 2
we send to you that has a commitment in
.t, we extract the 3
commitment and put it in a tracking system. We are reviewing 4
overy one of those commitments and we are not sure how we 5
are going to close it out.
We may send you a letter telling 6
you what we have done with that or we may just document it 7
internally and show the resident.
But we are looking at 8
overy commitment we have ever made to you.
9 one of the issues, also, that I would like to 10 raise as a productivity improvement, but one thing we're 11 continuing, is the development if you recall when we made 12 our presentations at readinesa assessment, we were 13 developing a single site trackiny system.
One of the things 14 that we had self-assessed ourselveO was that we didn't have 15 a good way of inter-departmentally tracking.
That function, 16 through Bill and John, is still going on.
We are abtually 17 going to completely implement that system next month and 1
18 that will be the system that will be tracking all the 1
19
. activity.
I 20 So, we have actually improved our tracking system 21-as we committed to you.
And that has continued and that 22 will be in place during -- it's in place now.
But the 23 finalization will be next month.
l 24 I think I've caught all the issues that were 25 brought up.
If there is one I missed that you questioned us Heritage Reporting Corporation (202) 628-4888 m
m.
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57 1
about, just let me know.
2 The rest I will cover I think in the slides I've 3
got, but I didn't have slides for those questions.
4 In the area of emergency planning, under 10 CFR S
50-54, we can't make changes to our plan if we reduce our 6
commitments to you without some kind of amendment to the 7
plan.
We understand that and we are not going to change the 8
plan without asking you.
9 I think we are still ahead of what everyone --
10 most utilities do.
We are still going to do one drill a 11 quarter on site.
We've been doing that forever and we are 12 not reducing that. That's what our program is.
We are going 13 to keep at least two staffs fully trained in all positions, 14 In some positions, we have three.
But our goal is to at t
15 least have two complete staffs.
That is our on site 16 program.
17 In the LERO activities, we are doing our one l
18 drill per quarter as required by the license.
That does not 1
l 19 here a power level tied to that commitment.
We just ran a
(.
l 20 drill and we have one scheduled for September.
So, LERO is 21 completely going on.
As a matter of fact, we are doing R22 requal training this week for the LERO.
23 We are deferring some activities as shown here.
24 And on the Siren test, we have been doing full siren 25 soundings monthly.
Your regulations require quarterly.
We Heritage Reporting Corporation (202) 628-4888
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are going to do quarterly siren soundings.
So, we are 9till 2
in compliance with the regulations and in our program, 3
because we have never had in our program do monthly tests, 4
so, we are just backing that down.
5 The 5 percent power commitments:
There were some 6
commitments we made that we would not exceed 5 percent power 7
until we had complied with those.
All those activities like 8
first refueling activities have been deferred and we're not 9
working on those right now.
10 And that goes to the rest of these issues.
11 So, in the area of emergency planning, we are 12 voing to completely comply unless we do something under 13 59-54 with you or our own review on 50-54.
14 In the area of licensing, we are going to, of 15 course, review the Federal Register daily.
We're not going 16 to do activ'ities like that.
And that is really what the 17 first bullet there is.
18 We are going to look at our procedures to make 19 sure that we can modify our procedures consistent with our 20 programs so that we won't get any procedure violations and 21 we are looking at that right now.
The education center 22 comes under this.
We are going to not be active in the 23 education center.
j 24 We are minimi=ino our activity in the major l
25 indastry groups:
NUMARK and INPO and the BWR Owners Group.
l Heritage Reporting Corporation (202) 628-4888 1
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59 1
And, as to NRC correspondence, all NRC correspondence will 2
be reviewed that comes intg us an it will be logged and 3
documented and tracked.
Those requiring response will be 4
responded to.
i 5
In other words, if you send us a letter that 6
says, "You must responde."
We are going to respond.
7 If you send us a letter that's on a system that's 8
operable, we will respond to those, too, even if it doesn't 9
require it, or we will do what we require internally.
We 10 respond internally to NRC correspondence.
11 So, we intend to do what we have to do with NRC 12 correspondence and respond to y0u as appropriate.
13 MR. MURLEY:
Now, there is one area to me that is 14 not clear.
I understand you intend to turn over at some 15 point a fully valid operating license to some other entity.-
[
16 How, at the time between now and then, there are going to 17 be, probably, new requirements laid out.
Who knows?
But it 18 could very well be things like that come out of our vendor 19 inspection program where we want you to go out and look at 20 certain things.
And you may decide to defer that or i
21 whatever.
But how are you going to keep the record of what l.
22 that requirement is that is part of the license that you 1
i 23 turn over?
Because that becomes a commitment, as far as I l
24 am concerned, under the licensing.
25 MR. DAVERIO:
Well, if it is a document you send Heritage Reporting Corporation (202) 628-4888
r 60 1
us that says we should do this, it would go into our 2
tracking system.
We would respond to you and the response 3
may be "It is not appropriate for us to respond at this i
4 time.
Here is the reason."
And we document that's the 5
response.
So, we've got a letter we know that we didn't 6
give a full response to and it is documented.
I 7
MR. HURLEY:
That could very well mean that you I
8 have got to analysis to know what it means to you.
It may 9
mean a lot of work or it may mean no work.
10 MR. EARLY:
I think we will commit to do whatever 11 is necessary to wrap this up in a clean documentary package.
12 So, if you say, "X-system has to be modified because a i
13 problem has been found."
We may decide since we are not 14 going to operate that system we don't need to, but we will 15 document that that is an open item that has to be addressed t
L 16 if the plant is ever going to operate.
The same way any I
17 other plant would document it if they haven't done the i
18 modification yet, that this is an open item that has a time 19 frame or something.
l 20 We will make sure that the systems do that.
21 HR. RUSSELL:
Would you put the last slide up for i
22 just a minute becacce I want to follow a bit of a different i
23 thread.
24 Licensed operator requalification programs 25 require that you review and discuss industry operating Heritage Reporting Corporation i
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experience, issues from other plants.
There is the 2
accreditation, 3
re-accreditation process that is involved.
We have endorsed 4
that through rulemaking.
Would you describe what you are 5
going to be doing because it appears to me that you are j
6 proposing to eliminate review of operating plant studies, t
7 SOERs, other things that come out that are supposed to be 8
incorporated in training for operators.
9 MR. LEONARD:
Let me address that.
We realize 10 that.
And I have talked to Mr. Early about -- and we also, 11 as you know, are the owner of Nine Mile Point 2.
And we 12 have one billion dollars, if you include the AFC invested in 13 that plant.
And we have a monitoring group that keeps up to 14 de,te with that plant.
r 15 We feel it is absolutely necessary we find out 16 what is going on in the industry.
We will be an associate 17 member of NUMARK and they will send us all necessary f
18 correspondence so we can keep up to date.
And that will be 19 through Nine Mile Point 2.
20 The BWR Owners Group, we are going to be a 21 non-voting participant in the Owners' Group.
Again, we will 22 keep up to date on what is going on in those areas.
With 23 respect to NUMARK, we are dealing with UUMARK now and I have 24 to discuss that with the president on how we want to do 25 that.
But we are aware we have requirements to look at case Heritage Reporting Corporation (202) 628-4888 i
3 62 I
studies that INPO sets out and that sort of thing.
)
2 MR. NOTARO:
Let me add one point to that, Bill.
3 The ISEE Organization which resides within QA is still 4
charged with the responsibility under technical
\\
5 specifications to do that industry experience evaluations.
i 6
We will be doing it in the same form and tone as we have 7
done it in the past.
The disposition of those items may be 8
different, given the condition that we are going to, than it 9
would have been if we were going to re-operate the plant.
10 MR. RUSSELL:
But it is the disposition as it 11 relates to maintaining operator licenses.
In other words, 12 you have -- there are two licenses that we are involved with 13 here.
You have got plant license and you've got operator 14 licenses.
And you have requirements for training, 15 continuing training, what we call requalification training, 16 performance requirements, some flow through the facility 17
' license from the ISEE review of operating experience to the 18 operators to be trained on it, revision to operating l
19 procedures to keep them current.
20 MR. NOTARO:
We would still keep that procea 21 flowing from the ISEE organization to the training 22 organiz'ation to the operators so that there is an evaluation 23 that, for example, something came out of Hatch associated 24 with the HPIC system.
The Shoreham has a HPIC system.
The 25 HPIC system is not going to operate in the future by the L,
Heritage Reporting Corporation (202) 628-4888
i 63 j
1 Long Island Lighting Company.
There was a pressure switch 2
or elbow or material condition that we would not be 3
addressing in the form of a mod or a procedure revision i
4 because we are not going to operate the plant.
]
5 So, the disposition would be that it would not be
)
6 applicable for us, given our condition, to defer a work 7
item, but that information, that intelligence would be made 1
8 available to the operators in the requal program.
j 1
9 Physically, that may result in nothing in the 10 plant. But.from a paper standpoint, that process would still
)
13 be going forward, that information would still be provided 12 to the operators.
I 13 MR. RUSSELL:
Other than the modification portion i
14 which needs to be reflected in a procedure, other procedural 15 changes then that might flow from an operating experience 1
16 review are going to be maintained such as the emergency i
17 operating procedures stay up to date with time and are part 18 of your training program?
19 MR. STEIGER:
I think the proper thing to say 20 right now is we are evaluating how we want to handle that 21 right now, because we know we are not going to run the 22 plant.
We just haven't made a final decision as to how we 23 think is the best way to address and handle that.
24 MR. RUSSELL:
I would just point out that Section 25 6 of your tech specs has certain commitments to procedures Heritage Reporting Corporation
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that you are required to maintain, the EOPs, Operating 2
Procedures, shift relief and turnover.
And to the extent 3
those are not maintained current, you could get into a 4
situation where you are not in compliance with the operating 5
license.
6 MR. STEIGER:
At this point in time,,they are 7
being maintained current.
8 MR. RUSSELL:
- Okay, 9
MR. STEIGER:
What I am talking about is looking 10 at the long term.
As I mentioned earlier, we have done part 11 of the review, we have not completed the review of the USAR 12 and the tech specs and everything.
When we think we are 13 finished with that review, we will be talking with your 14 senior resident and any of the other people in the region 15 that you would like us to so that we come to a mutual i
16' understanding of wh'at that is going to be.
17 So, I think it is premature to give an absolute E
18 answer one way or another right now.
It's still being 19 looked at.
20 MR. RUSSELL:
But right now, they are being 21 maintained?
l 22 MR. STEIGER:
Yes.
Right now, they are.
-23 (Continued on next page.)
24 L.
1 25 i
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MR. DAVERIO:
Okay, additional areas that fall 2
under NOSD's responsibility security.
Again security is a 3
fifty fifty fall program and we are not making any changes 4
to the plan or the program.
We are doing one activity in 5
the security of -- I don't know if you all are familiar with
]
6 the site, but we have two security guard houses that allow 7
access into the site.
8 In our program we can close one and make it a 9
fence line, and we will do that, and that.will allow us to l
10 reduce the staffing within the guard house and the security 11 force, but that's allowed under the plan, but that is the 12 only program -- that's not even a program change, it is just 13 something.that we are doing within our program, but no 14 change to the security program at all at this point.
15 We also have the procurement and the contract, i
16
~and the. administrative sections.
We are not combining -- we 17 are going to reduce buying,-and we will be reducing staff in-18 the course, and that is the remaining section for the same
.19 reason, we are not estimating modifications and doing as 20 much course control work.
21 We were going to do a pro-active vendor manual 22 program this year that will be deferred also.
That 23 translates, and NOSD staffing to reduction.
We presently 24 are at -- the present staffing is 116.
We will be going to 25 87 local employees.
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Just to put it in perspective, there is no change i
2 in emergency planning staff on local staff.
No change in 3
the security staff for LILCO.
We only are only reducing by 4
one licencing person.
5 The bulk of these changes are in the warehouse i
6 personnel, contract development, and core sections.
So it 7
just follows the activities and the plans.
The area of 8
contractor reduction will be going from 31 to 9.
9 The majority of the contractors that will be F
10 remaining are tied to off site emergency planning 11 activities, and the bulk of the contractors leaving are tied 12 to off site emergency planning activities, because there is 13 some reduction there of activities, we can reduce our 14 staffing.
15 In the area of contractors, and by this 16 contractor slide, I am talking the security guard force, and 17 also under NOSD is 40 temporary clerical support people.
We 18 will be reducing about 40 temporary clerical people and 19 about 40 guards by closing the secondary access point, but 20 that will still leave us a staff of approximately 130 guards 21 on site.
22 MR. RUSSELL:
I have one related question that 23 relates to both recent rule making, and part 26 in fitness 24 for duty.
25 MR. DAVERIO:
Yes.
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MR. RUSSELL:
Which went into effect in July for 2
which you have to implement programs by the end of the year, 3
I believe.
4 MR. DAVERIO:
Right.
5 MR. RUSSELL:
It relates to both security and the 6'
kinds of changes that may occur.
7 MR. DAVERIO:
Yes.
8 MR. RUSSELL:
Holding an operating license, you 9
are required to implement programs to meet that, is that t-10 true?
11 MR. DAVERIO:
Yes it is, and we intend to.
We 12 are right now in the process of working with human resources 13 to develop a program that is in full compliance with that, 14 and without some relief for a change in our licence, we know l
15 we have to be in compliance with that.
16 MR. MURLEY:
Okay.
17 HR. DAVERIO:
Let me turn it over to --
h 18 MR. MURLEY:
Yes, I suggest that we take about a 19 ten minute break if that's all right.
20 MR. DAVERIO:
We only have.about 15 minutes left.
i 21 MR. MURLEY:
Nonetheless, let's take a break.
22 There is coffee down there, and the rest rooms are out in 23 the hall.
At ten minute to ten, we'll resume.
iH 24 (Whereupon a brief recess was taken.)
25 MR. MURLEY:
Okay, are you ready?
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HR. NOTARO:
Yes.
I am going to make a 2
presentation as 'itr relates to the Nuclear Quality Assurance 3
Department.
The overall objectives for the Nuclear Quality 4
Assurance Department are the same as what you heard for from 5-the other departments this morning, and that is to establish 6
a least cost posture consistent with our operating licence, 7
and to ensure that all of our expenditures are prudent.
8.
Also it is to make sure that we meet all of the C
9 requirements of our licence, and the keep the continuity and 10 communication with the Nuclear Regulatory Commission open-11 and effective.
12 The Nuclear Quality Assurance Department was 13 evaluated with respect to a minimum posture position, and 14 this was accomplished by considering the updated safety 15 analysis report, technical specifications, and the HQA 16-program, and the pr ne.6ures.
17 The objective was to make sure that we were
-18 maintaining the overall effectiveness of this program.
Now 19 regarding the program effects under a minimum posture, we 20 determined that there would be no QA program changes 21
- required, none at=all.
22 We expect only minimal procedure changes, and we 23 expect that any reduction in resource commitment on the part 24 of the Nuclear Quality Assurance Department would actually 25 be realized as a result of the' fact that there would be a Heritage Reporting Corporation (202) 628-4888
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69 1-decreased activity level throughout the Office of Nuclear.
'2 We are also anticipating that there would be a 3-saving in resource because of this deferral disposition.
We 4
have outstanding items such as audit findings and corrective 5
. action requests, 'and LDR deficiency reports, and these are 6-being reevc'.uated new from the standpoint of does the 7
disposition apply to the condition that we are going _to, and 8
the process that we'll be seeing in the future.
9 If we do not need that disposition in the future, 10 then we will log it very carefully, we will identify it, and 11 it will be resurrectable by some other organization.if that 12 need ever arises in the future.
We will put it in a 13
. complete package, and it will be there for future reference.
14 Each of the organizations.within the department 15 was evaluated.with this thought in mind.
The' Safety 16 Engineering and Reliability Organization, that's the groups 17 that's responsible for coordination of Nuclear Review Board 18 activities, reliability engineering, and the ISEG 19 organization.
20 We will continue activities as appropriate in 21 each of these areas, surveillance, experience review, and-22 Nuclear Review Board.
In the area of ISEG's surveillance, 23 we expect to be conducting one surveillance per month 24' throughout the remainder of 1989.
25 We expect to see a decrease for resource Heritage Reporting Corporation (202) 628-4888 l
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commitment in the experience review area only because of the
~
2 fuel goinglinto the pool, and the process, but not from the-3
-evaluation standpoint.
4 As EMPO issues SCR's -- SOER's, they will be 5
evaluated as I said before, and processed as required by 6
procedures'that are now established.- The Nuclear Review 7
Board'will continue to meet once per quarter as required by 8-
' technical specifications.
9
'We will continue to do audits along the frequency 10 identified within the technical specifications.
I think it 11 is importsnt to emphasize here, as Chairman of the NRB, we 12 had our latest meeting last week.
13
-It was a-joint meeting of the Nuclear Review 14 Board and the Nuclear Oversight Committee, the summer -- the-15 NRC~ people are aware that the Nuclear Oversight Committee'is 16
-made up of our President, and members of our board of 17
~ directors.
'18L We had-this joint meeting last week.
The process 19 that is being laid out for you today, including the details, 20 was presented in full to both of those groups, and their 21 concurrence with the approach and the methodology was 22 unanonymous.
23 Our evaluation has talked to deterral of certain 24 activities which we found are not commitments or regulatory 25 requirements in any sense, either direct or imp: led.
We Heritage Reporting Corporation (202) 628-4818
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=willtbe' deferring reliability system evaluations and 2
reliability maintenance activities.
3 We have completed pilot programs and we are going 4
on in this-line, but now we are going to defer this type of 5-activity.
In the quality systems area, we will continue the 6
audit program both'in scope and content.
-7.
Our audit program right now is a two year cycle i
8 program, and we will continue to do audits based upon the 9
established frequency that now exists within our. program.
10
_ Confirmatory testing and vendor evaluation was questioned
'll before, so I would like to spend a little bit of time on 12 those.
13 We will continue to do confirmatory testing which 14 essentially is independent analysis, third party laboratory 15 assistance, the use of our NDE facility on the property.
We 16 will do that:in.all instances-where the plant requires a
'17 part in either commercial grade or a dedication process, the 18 confirmatory testing program will applied.
19 In the vendor evaluation arer., throughout'1989, 20 we had scheduled 54 individual vendor evaluations.
'We have
~ 21' completed 31, 8 were deferred, and the deferrals are 22 predicated on no longer needing that vendor to supply 23 components to Shoreham, and we had 15 remaining.
24 Of the 15, 12 can be accomplished by virtue of 25
'the case evaluations or the new Nuclear Supply QA Committee.
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We needed three more.to be done for the remainder of 1989 to 2
satisfy our program requirements.
3 On of the three is already completed.
A second 4
one.is' scheduled for next month,.and the third one, which 5
was-a calibration facility, we have determined is no longer
-6' necessary, so we'll have no problem meeting the' vendor 7
. evaluation program requirements.
8 We-do plan to climinate two specific functions.
-9 One'we had planned to be pro-active and conduct our own 10 safety system outage and modification inspection in the last I
4' and given our condition, there is no reason to expend 11-
- quota, 12 that money now.
13-Also for performance base system as you are r
14 aware, there is.a significant commitment to. training, not 15 necessarily QA training or certification, but optional
~16 training'for QA people in.diseAplined areas such as 17 instrumentation and control,. health physics, operations, and 18
.we will no longer be committing that resource.
19 In the quality control area, and this is the f
4 20-organization which most actively interfaces with the plant L
21 staff.on a day to day basis to continue activities and' L
L J22 inspection ~, surveillance review, and the deficiency program.
1 23 We do expect, however, to seu a decrease in'the 24 resource commitment, because as I said before, there will be-25 an associated decrease in the activity within=the plant.
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1 Normally'we.would be conducting 14,000 man hours of 2
inspection-'in the course of a normal-year.
e 3
In the last half of 1989, we_ expect to be'around 4
3,000 to 3,500 man hours.
In the deficiency program review,.
5 with the deferral disposition, we normally would commit 6
5,000 man hours.- We-are expecting that to go down to 7
somewhere on the order.of 1,500 man hours.
8 As the modification process goes to zero within 9-the-plant staff, so to will the commitment for QA to review
'10 the modifications in place.
All of this results in a 11 reduction in the required manpower in the organization.
12 Right.now the department is authorized for 63.
13 personnel.
We are presently at 40, and that is 40 local 14 people, and we expect to be at-29 by October.
This will 15 give us a 15 to 45 day turn around after the expected 16 completion of defueling to make sure that all of the 17 documentation is correct, the final surveillance and audit 18 results are in house, and everything is package' property for 19 future reference.
20-Likewise for contract support, we have been using 21-
' contract support over the last 12 months as we trision down, 22
. presently we'have 25 on board, and we expect to, in the 23 short term, go down to five, and then ultimately down to 24 zero.
Are there-any questions?
25 MR. MIRAGLIA:
All of those reductions were-not Heritage Reporting Corporation (202) 628-4888 1
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because:of the. decrease of program requirements, but of 2
activity?
- 3 MR. NOTARO:
Absolutely correct.
Are there any 4
other' questions?
If not, I would like to turn it back to 5
Mr. Leonard who summarized the morning.
6 MR. LEONARD:
A quick role up of what the 7
departments have said.
We are saying that our approach has 8
been for each department to develop minimum posture 9
activities, looking at the regulatory guidance we have.
10 Departments have developed, based on a minimum 11 posture personnel level, we have review our organizational 12 structure to support this minimum posture.
We have
'13 developed a budget to go along with it.
14 We have discussed our intentions with you, both 15 at,the region level here and out, and in the future, we 16 intend to submit a licence requirements, licence amendments 17
.to you which will reduce some of the operating licence-18 requirements, and I've got a few examples of those, and I 19_
will just mention.
20 They will'be submitted, and we'll discuss with 21
-them in detail.
We will not unilaterally do anything that 22 affects our-area.
Here is what has occurred in the Office 23 aof Nuclear Personnel.
I was authorized a combined staff in 24 the whole office of Nuclear of about 837 people.
25 On top of.that we had catalytic there which will Heritage Reporting Corporation (202) 628-4888
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appear later in a contractor slide.
When we got-our 2
licence, we were down to 593 people and had about 120
'3 contractor staff positions.
-4 We will at the end of this summer be to 452, and
,5 we will stay there until the amendments are discussed with 6
you and received certain changes.- As far as the contractor
- 7 reduction,-the 555 includes temporary clerical, it includes 8
160 security guard force, 250 people in the catalytic 9-maintenance-force, that sort of thing.
That was at the high 10 point of our staffing and contractors.
.11 It also included several stone and Webster groups =
12 that were on site.
We will be at the end of this summer 13' down to approximately 201.
You can see there will still be 14
'six hundred and something people either on site or 15 supportive.
We are to combine 11ocal.and contractors.
.16-Now, what we intend to'do is some time in the not.
~
.17 -
to-distant future to start discussing with you amendments.to 18' the present operating licence.
Phase I is what wefare 19-talking about right now in our non-amendments. -Reduction of 20
.the staff and this sort of thing.
21 To further reduce, let' say the staff, let me
'22-give.you a specific example.
We have the off site emergency.
I 23
-plan called the Long Island Emergency Response Plan.
You i
24 know it is not required below five percent power.
25 We are not going to operate-the plant, and we Heritage. Reporting Corporation (202) 628-4888 i
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~1' will'have a radiological analysis that shows you an off site og
=2 response 1 plan is not required, and we would like to amend a-3 licence of that affect, because we are talking about saving.
4 millions of dollars per year.
5 We think that is very important for us to be 6
' prudent in those areas.
Security plan, we have an agreement 7_
with_Suffolk County that we have a ten man armed response 8'-
team.
I think most utilities are required five, is that 9
correct, and when you multiply that by six shifts, we are 10 talking about 30 people.
That is probably a million 11 dollars.
12 MR. PARTLOW:
Why do you have the extra?-
13 MR. LEONARD:
Because during the hearing, Suffolk
. County demanded that we have a ten -- we have always 14-15 fulfilled out-commitments in Suffolk' County, even though 16 they are vigorously opposed to it.
-17 MR. DAVERIO:
There is an ALC settlement 18, agreement that we are as parties, and the NRC. entered into, 19
_and it is reflected in_the plan.
20 MR. PARTLOW:
Okay.
-21.
MR. LEONARD:
Again, we are not going to decrease.
'22-that, but we get an amendment.
The same-is true of the' 23 administrative section of the tech specs.
We have a licence 24
- Lyou all directed us to remove the organization from the 25 tech specs.
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We have letters into you requesting that_they be 2
removed.. This is a generic thing for all utilities, and we 3
would like to see an answer, yes indeed, and when that;is 4
done we can further amend our organization.
I won't dwell-51 on the.others.
I think you get the jest of what I am trying 6
to say.
I think --
7-MR. MURLEY:
One thing that is not here, and 8
maybe I am. talking longer in the future, are you planning to 9
at some point request a possession only lice,nce?
10 MA. LEONARD:
I would defer.that to our 11 President 12 MR. EARLY:
We have been looking at that in how 13 to proceed, and what will be the most expeditious route.
We
]
14 certainly would welcome your views-on that.
I think our 15 current thinking was that we would just ask for a transfer 1
16 of the licence, rather than go through a two' step process of j
-17 a possession only licence proceeding, and then a transfer 18
- proceeding, they would just go to a request for transfer, 19 but-we can talk about whether we ought to have an interim 20 step.
l 21 MR. MURLEY:
Well we're certainly not, going to 22' advise you the best path is.
There are, I think, 23 significant implications.either way.
We need to know at 24 some' point what your plans are.
25 I think we've heard today some assurances that l
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you are going to in the short term, at least, be staying in 2-meeting the licenced conditions, staying in compliance with
'3
' all of the ' t erms' of the full power licence.
4.
There is a long term path that you are on, and 5
this minimum posture position that the company's adopting, 6
although you may be in' literal compliance with our licenced 7
conditions, it's not all clear that in-the long term the 8
condition of the plant, and the readiness of the st'ff,.the 9
capability of the plant staff is not going ta) deteriorate 10 significantly.
11 It'is not clear that that is a viable -- that you 12 are on a viable path to transfer a valid operating licence 13 to any other entity.
I think this meeting, I can regard as 14-a short term assurance that the plant is okay for the near 15 term, but it is not at all satisfied that you got a long 16 term viable plan.
17 MR. EARLY:
Well we clearly need to continue to 18 have further discussions, and ILthink from the presentation, il9 it;is clear that'we will be very helpful if we continue to-20 have the dialogue that your people come up to the plant, 21 review the plant, our programs, procedures, the analysis
-22 that have been done.
23; I think that will help alleviate some of the 24 concerns that.have been raised here, because a lot of work 25.
has gone into that, and we would like to get feedback on the Heritage Reporting Corporation (202) 628-4888
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1 reaction to what we have done.
2' MR. REVELEY:
Tony,-let me say one thing about f
r-3 that.
We~certainly don't expect the NRC to tell LILCO what-4 to do._
That is not your role.
On the other hand.our entire
.5 incognito.
This is a unique situation.
We are all working 6'
our way as best we can.
7 I think LILCO is entitled to hear, and doubt that 8
you all will share with LILCO, your views on the 9-implications of different courses of action, not your 10 indication of what the company should do.
11
'What your understanding of what the implications
- 12 of different paths might be, because I think it is highly 13 desirable to the maximum extent possible, we do all 14=
understand what everyone's position is as we go.along, so we 15 can get through it as effectively as possible.
.16 '
MR. MURLEY:
Well I think just to give one 17
_ example, I have indicated the views that this --'once you 18' are in this mir.imum posture position, I mn not at all sure 19; that that is a - posture that will allow transfer of the 20-licence to another entity.
I think you need to think
= 21.
'through that very_ carefully..
It is one thing to be in that 22
-posture to maintain the plant in some bare minimum 23 maintenance position, but it quite another to think about 24-
' transferring a licence.
25 MR. EARLY:
The transfer of the licence obviously Heritage Reporting Corporation (202) 628-4888
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would.be'with all conditions, limitations, commitments and 2
other thingsfthat we will be developing.
Earlier, we
)
3 committed to this, and I want to make sure it is clear, y
4 As new-requirements come down, we will document e
5 what needs to be'done, so we havo complete documentary 6
package.
You say there-is a preolem with the system and it 7
must be modified before the plar t can go into operation.
8 Well make-sure that is clearly documented.
u 9
We may not make that modification at that time, 10 and in fact, we will not make the modification, but it will
-I 11 be documented so when the licence is transferred, the 12 entity taking it would not be able to anything to operate 13 the plant unless all of those-conditions and everything are 14 met, so it will be all tied up.
15 The other thing that I want to mcke sure is i
16.
clear, we are unequivocally committed to the 50,~
59 process 17.
and will continue that.
I think the difficulty is figuring 18 out what does that mean in this context.
We will continue-19 to keep you people up to date on our views on-it, but we are 20 committed to that process.
j r
21-MR. MURLEY:' In recent years, our relations,.NRC 22 relations with LILCO have been professional in the sense, 23 and.your conduct with the operations of the plant has been 24 good.
We have no question with that.
25 What we have heard today, I would say that the l
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way you are: going about it gives us no near term concern.
2 It is the longer term path that you are-on, that is not at 3-all~ clear.
We are not going to allow the plant to be --
.4 someone said, apparently in the press, to decommission S-itself.
6_
We are not just going to let it sit there and 7
rust.- That is not going to be allowed under the licence.
8 Now how we get from here to wherever the end point'is, 9
whatever that end point is, I think is going.to take a lot 10
'more discussion.
11 MR. EARLY:
Well one of the key elements in our 12 negotiations with the State of New York, is that LILCO would 13 not decommission the plant or do anything to decommission
- 14 the-plant.
We think that is stupid.
15-That was'a decision made. -The decision is going 16
-to be a political and governmental decision made by the=
17 State of New York as to what happens to the plant.
They-18 know, we know, that we are not going to be.in that-position 19 of decommissioning.
We'are trying to maintain our.
t
' 20.
activities consistent with that position.
21 MR. MURLEY:
Let me ask my colleagues if they have any thoughts or questions?
23-MR. SCINTO:
No, I just wanted to -- what Tony 24 said.
Decommissioning is an act, it is a factual act.
You 25 have indicated that LILCO is not planning to decommission, Heritage Reporting Corporation (202) 628-4888 i
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and I think all of our. questions today have gone.to the 2
point that we:want to look to see what you are doing, the 3:
nature of those activities, to assure that that plant 4-remains a' nuclear power plant.
!5 It is presently has an operating licence.. It 6
remains a nuclear power plant of that character,istic.
This 7.
you may not intend to operate the plant, but any other-use-8 of the' plant'other than an operating nuclear _ power plant 9
needs to be authorized by us in advance.
Those are our 10 questions directed-toward that today.
11-MR. MURLEY:
Okay, any other thoughts or 12 comments?
H 13 (Negative response.)
-14
.MR.
EARLY:
Anyone on our side of the table?
115-
~[ Negative response.]
.16 MR. MURLEY:
In my-opening remarks, I indicated:
1',
117 that we'would entertain questionsoto the NRC staff or 18 comments to the NRC staff. :Are there any members of the 19
. general public who are here?
Okay, yes sir?- Would you in 20 state.your name?
l 21 MR. MCGRANERY:
I am James P.
McGranery, Jr.
As 22 the staff and I believe LILCO are aware, I filed a 2.206, a 23 l request on behalf of the Shore Wayne River Central Schoolz o
24 District, and recently on behalf of scientists and engineers 25 for secure energy relating to the course of activities that i
l
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the LILCO people are undertaking with respect to' Shore.
2 I would like to offer three general questions.
I 3
- don't understand how Doctor Early can say that the NRC have 4
received this morning any reassurances of the continuation 5
of Shore as a full power operating licensee.
6 What the NRC sat here and heard was LILCO saying 7
that it was not reducing it's staff at this time,-and then 8
putting up charts showing that they had already made huge 9
-reductions.
You heard LILCO saying that it was going to 10-substantially reduce it's maintenance program and not in 11 accordance with-~these standards that would be necessary for 12 a full power operating licence.
13 You heard LILCO say that it was going to inform 14
-you at some time in the future of a justification for these 15:
actions that it has already,taken'but has not -- but the 16 justifications is not completed.
?
17-You heard a situation described at getting to 18 ttoday, that Mr. Russell, on June 30-said that if he walked 19 on to any other reactor site and found a staff reduction of 20 40 to 50 percent below the commitment, he would be in what 21 he called enforcement stage, but yet Doctor Murley seems 22' reassured.
23 The intent of LILCO is very clear.
They have 24-laid it all out and just asked the NRC to put it's teddiness 25 there -- excuse me.
Now, as to the second group of reports, Heritage Reporting Corporation (202) 628-4888
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LILCO'makes much of it's contractual commitments to the 1
2 states, however, all of those contractual commitments could 3-fall apart.
4 If.you expect those as they stand now, LILCO does
'5.
not speak in very' good faith in'my judgement in saying that 6-it hasn't made up it's mind whether to convert to a 7
profession only licence before transfer or not, t
81
_The asset transfer agreement explicitly states' i
9 the order in which LILCO shall apply for these various 10 applications.
Now,- LILCO also says that its not going to-C 11 have-nothing to do with the decommissioning of this plant.
12-Those agreements clearly state, and you:have I
H 13 copies of them,.that LILCO will in fact be totally 14 financially responsible.
LILCO's activities with respect to 15 decommissioning are a sine.qua non,.so while their name may 16 not.be.on the-licen'ce at that time,_they are going to be 17 intimately involved in the decommissioning.
18 The third point.I would like to address is 1
l 19 something that I have not heard mentioned here, and that is 20 the~ commission's~ responsibilities under the -- is that this.
licensee is trying1to get.you to accept a segmeated group of 21 i--
L 22'-
.different licencing activ'ities.
23 They want you.to look at things part by part.
24 The law is clear that when you have a continuum of actions 1
2 5.-
as Commissioner Bradford has styled this plan, the NRC.is I;
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suppose to stop and take a hard look at the whole continuum-2 while it still has the full range of alternatives open to 3
it.
J 4
Section 10 CFR, section 5101 makes clear the 5
commission's intent to have a licenseo or an applicant stand 6
still and not take any actions that might be adverse before-7
' environmental review of the proposal is completed.
8 You have a situation here which Doctor Murley_has 9
clearly described might. turn into a rust bucket.
In any 10 event, might turn out to be a destroyed operating staff.
I 11 do not consider it significant that LILCO is going to 12 maintain'30 janitors if it is going to get rid of all of its 13 operators.
14 The janitors may have a function in the plant, 15 but they aren't critical to the plants running as the 16;' operators are.
In short, I think that immediately effective 17 orders are appropriate and necessary.
At this time when the 18 licensee has announced its full intent a single plan' leading 19-from June.8th through decommissioning.
20 Decommissioning has a' single term to look at, and is the time to stop and take a.hard look to prevent 2 11 now 22 adverse effects to the environment.
Thank you very much for 23 listening.
24.
MR. MURLEY:
Okay, thank you..Are there any 25' other comments?
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MR. GUTIR:
Doctor Murley, can you give us any
+
2 estimate 1how long the NRC's process is taking in terms of 3
decommissioning of the plant?
4-MR. MURLEY:
No I can't.
I has been noted that'
.5 we are here in new territory, uncharted waters, and we are 6
trying to '-- the purpose' of today's meeting was not to 7
address.that, or even some of the broader: questions that the 8-other person just mentioned, like our responsibilities
-9 underneath it.
10 The goal of today's meeting was to simply assure 11 ourselves that the conditions of the licence are being met 12 today and will in the near future.
I think as I have 13 indicated, we gotRa number of fundamental questions about 14 the longer raised.
They were net addressed in any certain 15 answer.
16 MR. GUTIR:
What is the next step in the process 17 though?-
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MR. MURLEY:
We are going to continue to monitor 2
the plant and continue to, I think, to a large extent, we 3
are going to be looking to LILCO for firming up what their 4
plans are.
Rather than get into a press conference here, 5
let me, if.no further comments from the meeting members, 6
let's thank you for coming in, It has been useful, and we 7
did get the information-that we sought.
Thank.you.
8 (whereupon at 10:26 a.m.,
July 28, 1989, the 9
' hearing. adjourned.)
10 11-12 13 14 15 16 17 18
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'25-Heritage Reporting Corporation (202) 628-4888 i
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i EP.T:F:: ATE 1
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This'is.to certify that the attached proceedings before the
,i 4
United States Nuclear. Regulatory Commission in the' matter J
le.
t lW 5;
of: Management Level Meeting Between the NRC and LILCO' II 6
Name: ' Office of Nuclear Reactor Regulation 7: v.
7 I
1 8
Docket Number:
9 Place:
Rockville, Maryland
.)
10 Date:
July 28, 1989 11 were held as herein appears, and that this is the original l
l-12 transcript thereof for the file'of the United States' Nuclear L
.13 Regulatory _ Commission taken stenographically by me and, 1(
>1 14-thereafter reduced to typewriting by me or under the i
15 direction of the court - reporting company, and that;the I-16 transcript is a true and accurate record of the. foregoing
~17.
proceedings.
f jf,/-
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-(Signature typed) :
20 Official Reporter 21 Heritage Reporting Corporatier.
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